(Comments submitted July 15, 2022)

National Farm to School Network (NFSN) represents multi-sectoral national partners, organizations in all 50 states, Washington, D.C., the U.S. Territories, and Native nations, and tens of thousands of farm to school and early care and education (ECE) supporters. NFSN has a vision of a strong and just food system for all, and we seek deep transformation toward this vision through farm to school – the ways kids eat, grow, and learn about food in schools and early care and education settings. Farm to school is a win for kids when they eat nourishing food in meals and snacks, participate in hands-on activities and learn about the importance of where our food comes from; a win for farmers when school market opportunities provide reliable and consistent sales and fair pay; and a win for communities when food is grown, distributed, prepared and consumed for the benefit of every community member.

We appreciate the opportunity to shape the landmark White House Conference on Hunger, Nutrition, and Health this coming fall. NFSN Partner organizations offer a unique perspective on the goals and pillars proposed for the Conference, as they span grassroots community organizations, school districts and school nutrition directors, state agencies supporting child nutrition, food producers, and organizations supporting local food infrastructure and resilience.

NFSN conducted a listening session with our members in July 2022, with a request for feedback on the most important strategies and policies that the WH Conference planners should address to solve pressing crises of hunger, nutrition, and health. Our listening session heard direct accounts from NFSN members across 23 US States and Territories, and members of sovereign Tribal Nations. Nearly half of the organizations participating had BIPOC (Black, Indigenous, People of Color) leadership. Participants brought their experiences as parents, school meal and early care and education (ECE) professionals, nutrition educators, producers, and program administrators.

Feedback from our NFSN Partners is synthesized below, with illustrative quotes and first-hand experiences they shared.

Transformational Actions to Address Hunger, Nutrition, and Health

Allow child nutrition programs to meet their full potential

Child nutrition programs should ensure universal meals for early childhood through high school.

● “There’s a stigma around school meals. Only the "poor kids" eat school meals. We need to elevate school meals across the board, increase participation, AND keep them culturally-relevant.”

The financial model of federal child nutrition programs is inadequate to meet today’s challenges. Realistic reimbursement levels that allow school nutrition directors and CACFP providers to serve nourishing, tasty meals made fairly would be a good first step, but USDA should engage child nutrition providers in a more comprehensive review of the limitations of the current business model and possibilities for redesign.

● “The main barrier is cost on all points of procurement, whether it’s the nutrition director who can barely keep a full staff in the kitchen to prepare local food, or pay the markup so that it’s easier to use, costs make it unattainable for so many.”

● “With the transitional meal pattern and impending new meal pattern, we could see more scratch cooking but we lack infrastructure and pay our workers too little.”

Child nutrition program requirements should be overhauled to fund local procurement, ease administrative burden, and create meals that go beyond meeting nutrition standards to provide holistically nourishing and culturally relevant diets.

● “The transitional meal pattern and impending meal pattern change is great from a nutrition position, but it will still not look the way we would love school food to look.” ● “There is so much pressure on food service providers to feed entire schools with limited resources and recognition. This makes it difficult for them to add the extra effort of a balanced and educational diet to the day to day menu.”

● “Here one big issue in procuring local food is there's no incentive; a lot of food service directors have expressed that going through the whole process is way too burdensome. They don’t feel trusted to make proper decisions or ethically use funds so they’ve asked the state to focus more on distributors. Requiring GAP certification is nuts when a tomato grown in Indiana isn’t leaving Indiana.”

Support producers to grow and sell the nourishing foods that benefit Americans’ health.

Evolve USDA and USDA-funded purchasing to a more decentralized system to buy from small, beginning, “socially disadvantaged” and specialty crop producers.

● “Farmers and food producers in and around the community should be the priority source for schools, senior centers and ECEs to encourage fresh, from scratch foods that support local economies.”

● “We work mostly with what USDA calls socially disadvantaged farmers, Hmong and Latino farmers in the Twin Cities of Minnesota. We need storage, cold storage, logistics, that food hubs like ours provide, that would help schools to be able to work with one vendor and get one invoice, that has helped schools that work with us stay resilient in their food supply. But with that comes the need for infrastructure and technical support for producers who may not all be interested in selling to schools but if they are they have the support.”

● “What would it look like for the federal government to support the pipeline of farmers, public health professionals, etc. in the way they fund all medical residencies in the US?”

Target support for small, beginning, “socially disadvantaged” and specialty crop producers throughout USDA.

● “We must align federal farm policy with federal nutrition policy. As long as they are at odds, we will always be operating in a vicious cycle driven by profit.”

● “Our federal agriculture policies frame commodity farmers as “farmers” and specialty crops as “other,” even though it should be the bulk of our diets!”

● “We have some of the most fertile land in the country in Mississippi and yet there aren’t as many specialty crops that help support child nutrition. Smaller farming operations are often underfunded and the grant writing process is sometimes so arduous and complicated that it excludes smaller operations from being able to apply.”

Economic security and other basic necessities are inextricably linked to the ability to live a healthy life, including diet.

Food, farm, and school nutrition workers are among the most at risk of economic insecurity, and that must change.

● “From the school nutrition side – we have school nutrition staff whose own kids get free lunch. That’s a circular problem. If we don’t address this issue of school nutrition workers being valued professionals who have a secure place in our economy, the same thing for our food producers, we won’t be able to address hunger. We have to get at the root causes by addressing people throughout the food chain.”

Address living wage policies and root causes of hunger.

We’ve been addressing ending hunger actually at a very local level in New Mexico, and to do so we have to focus on poverty, and all the intersections between housing, support programs, and things like that. Here, our local group and city council recommends to provide a true living wage. If you’re going to end hunger, that’s what we have to do.”

● “We have to stop talking about hunger as a problem and start talking about it as a result of a broken, unsupported system.”

● “I find the goal interesting because it discusses ending hunger but not preventing it or addressing food systems issues…There is more to chronic, non-communicable disease than hunger.”

Nutrition programs, research, and meal patterns must be culturally responsive and not replicate oppression.

Ensure nutrition education guidelines are not conflicting and are rooted in a trauma-informed, systems approach.

● “We run into a lot of internal conflicts about what is allowed or not in SNAP Ed. The allowed curricula are solely around the DGAs and are through the lens of white [Eurocentric] healthy food and not being culturally responsive or responsive to communities and what their food systems look like. And when it comes to farm to school programming, those individuals can only work in schools with 50% of students with free or reduced lunch or more because that’s community eligibility for SNAP-Ed. There’s so many things going on in a school environment, it can be really hard to add in farm to school even when it is a SNAP-Ed approved strategy; so there are individuals who are engaging in schools in more of a direct education manner which is perpetuating a lot of cycles of trauma and whiteness.”

Culturally rooted nutrition education should be incorporated into educational goals and provided appropriate funding.

● “We need more nutrition education early in life, and to measure results in terms of influencing behavior.”

● “There’s a lack of capacity for current K-12 educators; on top of not having nutrition education in the curriculums, there’s little to no funding for nutrition educators at the state and federal levels. In many cases, it falls to individual teachers to lead discussions as an extra to base standards.”

Federal nutrition programs for senior centers, school and early childhood should enforce more flexibility in what is provided on the plate including culturally significant foods and locally grown and raised foods.

● “Even though USDA says they will support Tribal foods in meals, some states are great about it and other states are nit picking what is or isn’t an allowed traditional food. This means certain things might have to be donated or not qualify as part of a reimbursable meal.”

Determine and incorporate different measures of personal and community health to get beyond BMI.

● “Our organization’s goal is to get a school food garden into every school in Delaware. I think a good starting point to promoting nutrition and physical activity is addressing how diverse bodies are themselves.”

● “HHS and USDA should jointly examine the role of nutrition in public health outcomes, such as maternal morbidity and mortality.”

Utilize USDA’s existing models of community-led research and advancement within the National Institute of Food and Agriculture (NIFA) to inform ways that nutrition and health research can equitably engage communities.

Policymakers and government officials must create more pathways for state and federal agencies to listen to local needs. The burden to be heard shouldn’t lie solely with the community.

Policymaking spaces must feature lived experiences from program recipients, especially people of color. The effort to engage the public in White House Conference planning is a good first step.

● “Most federal opportunities for input reward people with computer skills and grant writing instead of growers or program participants.”

● “These opportunities need to be created by those looking for this information instead of placing the burden on families to step forward.”

● “We need outreach in the broadest terms in communities and across states and tribal communities to learn from families, immigrant and refugee individuals and families, and sovereign communities, about their specific nutrition needs and priorities.”

● “Culturally responsive perspectives could be considered by convening student and family representatives in social settings where food is served: senior centers, schools, early care centers, and food pantries.”

● “It's been really interesting to see the effort being pushed out to gather feedback for this specific conference. I have never seen that level of soliciting interest for all the policy initiatives that come out on a regular basis. Usually the only thing is a request for public comment, which lots of people don't even hear about or have the capacity to respond to. I know it isn't going to be realistic to do this all the time, but it would be nice to have more opportunities like this to solicit information from people who will actually be impacted.”

Recognize that state and local governments vary widely in their ability to administer programs with limited administrative funding and differing standards or guidelines.

Identify sources for the administrative costs of seeking federal funding.

● “We have seen the infrastructure on school and producer side be a large issue in our state. When programs like Local Food Purchase Assistance come through and don't allow infrastructure or training or Local Food for Schools that doesn't allow human infrastructure, they are not very useful. Our agency wanted to leave LFS on the table because there were no allowable administrative costs and many of our producers didn't understand the point of LFPA because they didn't believe the government was being responsive to their needs.”

Coordinate outreach and guidance on funding sources to make it easier for state and local actors to understand.

● “[Federal programs as they come down to the state agency and local level] are not working together. They compete for time and resources at the state and local level and don't seem aligned around a central theme, question or outcome.”

● “One of our big problems is that we leave a lot of money on the table, especially around some of the feeding programs like the fresh fruits and vegetables program. This is mainly due to poor execution on behalf of the department in getting information out to the schools so that they can participate. We need more all-around support for staffing and people power.”

● Our [state Department of Education] has been open to working with community partners. Community involvement has and will always work. As long as locals can contribute their voice and aspects of their culture it creates necessary and positive change.”

Consider allowing entities other than state agencies to receive funds if the state doesn’t apply.

● “Our state’s Department of Agriculture did not want to participate in Local Food Purchase Assistance. Since it had to be a state agency, there was nothing the nonprofits pushing for our participation could do.”

Leverage school wellness policies to embrace a broader understanding of health, and opportunity to start conversations about student culture.

Address inadequate or inconsistent processes data collection by state agencies.

● “WIC sign up is currently different in all counties of our state, and many are not managing effectively. It has been difficult to impossible to connect families to that resource as a means of supplementing food budgets and supporting local growers.”

● “Missing and incongruent data from state to state has made it difficult to really measure the impact of our Farm to Early Care and Education programs.”

Communities will have more power over their own diet and health when they are empowered with economic equality and equal access to USDA supports to grow their own food and participate in a more decentralized food system.

Federal policies should reflect more support for community-led projects around food sovereignty and more community ownership over food systems.

● “Our state imports 90% of our food, even though we sit on some of the most fertile land in America. There’s no incentive to transition out of grain production into specialty crops; that could be transformational here. Infrastructure for this barely exists in our state.”

Additional Perspectives

“We need infrastructure, more regional food systems, and actually being able to provide local food to schools. I find that is the biggest hurdle here in Lexington, Kentucky; it’s something we saw all during the pandemic, we saw with the Farmers to Families Food Box program that our boxes were coming from Florida and that is something that made absolutely no sense. Our organization had the contacts to be able to receive these food boxes and also work with local farmers to purchase directly from them to supplement what was in the food boxes. And I find that a lot of times, USDA makes it very inaccessible for smaller farmers to be able to participate in selling to the commodity programs and that is a big thing that needs to change.

“We have to invest in individuals and institutions. I started off as just a home-school mom who connected with her community to find out what the need was. As my experience grew, I had more opportunities to be put into leadership positions. Someone trusted me enough to give me these opportunities, and my other organizational co-director and I just kind of hit the ground running. We had already formed relationships with community members and started investing in our communities. Farmers could trust and talk to us, we weren’t just sending mail surveys but showing up on their farms, showing that we are willing to invest in them. It’s crucial to invest in individuals. Invest in the people who can make the change happen, give them the necessary salaries to enable them to do so. Ask, who are the people who could use some economic empowerment?”

“In June 2020, our food hub got funding to buy from farmers who weren’t able to sell at the local farmers markets. We bought at market prices and donated to emergency food organizations; this legislative session they got funding from the state of Minnesota to continue funding that program. This is specifically for emerging farmers in the Twin Cities metro to support underserved and BIPOC farmers, trying to get fresh food into the emergency food pipeline. The program is intentionally a very low barrier of entry for the farmers to participate in – the program provided packaging which is a huge barrier to entry, and provided technical assistance to help growers have healthy harvests.”

Additional Immediate Strategies

Provide flexibility within current reimbursement levels.

“Cash in lieu of commodities as an option for school meals – let’s spend all the money on food instead of trucking from huge manufacturers.”

Enforce transparency to empower purchasers.

“We should require distributors to provide basic provenance information to purchasers to support school districts in navigating local purchases.”

Reduce reporting burden on CACFP providers.

Examine micro-purchase rules in CACFP.

“CACFP Micro-Purchase rules limit consistent purchases from one source, which makes it difficult for small ECE providers to establish long-term purchasing relationships with small farmers in their communities.”

Provide realistic reimbursement levels.

“We need increased reimbursement in areas serving Tribal areas, Hawaii, and Alaska; food is really expensive and infrastructure is poor and it’s impossible for producers to compete with federal commodity distribution.”

Pursue Tribal self-determination in federal programs.

“We’re hoping to see an expansion of Tribal self determination expansion projects to school meals and hoping to expand to all federal nutrition programs.”