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Letter to Congress concerning Child Nutrition Programs

July 18, 2003

The Honorable Thad Cochran, Chair
Senate Agriculture, Nutrition and
Forestry Committee
United States Senate
Washington, DC 20510

Dear Mr. Chairman:

As members of the Senate Agriculture committee you have an opportunity to improve the child nutrition programs when you mark up child nutrition reauthorization legislation this year.  The child nutrition programs have provided access to nutritious foods for millions of children.  These successful programs are particularly important to children in low-income households where parents struggle to provide nutritious food for their children.  The Food Policy Working Group calls upon you to improve the programs by expanding participation, reducing paperwork, and improving the nutrition quality of the food provided.

The Food Policy Working Group is a coalition of mostly religious anti-hunger advocacy organizations concerned with the development of a comprehensive food policy to end hunger in the United States.  We believe that the right to food is a basic human right.  As human beings we have the responsibility to feed ourselves and alleviate the hunger of our neighbors.  However, the federal government also has an obligation to ensure that all people have access to an adequate diet.

Our first priority, and our greatest concern, pertains to proposals that are being developed to address alleged over-certification among children participating in the school lunch program.  We are extremely concerned that this will result in removing significant numbers of eligible low- and moderate-income children from the program.  The fundamental principle for the child nutrition program reauthorization should be to do no harm.  Income verification studies carried out by USDA have found that, when income documentation is required, substantial numbers of eligible children are driven from the program.  Any expansion of the number of children subject to income documentation requirements must be as limited as possible and combined with protections to make sure that eligible children continue to get the meals for which they are qualified.  The most important step that could be taken to improve program integrity without risking harm to eligible children is to expand the use of categorical eligibility and direct certification, so that children whose income has already been verified in another means-tested program can be automatically enrolled for free or reduced-price lunches.  Expanding direct certification would increase certification accuracy and reduce duplicative paperwork without posing risks to eligible low-income children.  Ideally, any changes to the income verification process would be implemented first in a carefully evaluated pilot project.

We support the following investments in child nutrition programs as part of the reauthorization, but would note that these improvements should not be funded by expanding income verification in a manner that would harm eligible children.  Our specific recommendations are:

  • Summer Food Service Program – 1) Expand the “Lugar Summer Food Pilots” to all 50 states and to all sponsors.  Currently the Lugar pilots are operating for only “public sponsors.”  The paper work is simply overwhelming for churches starting the program.  2) Reduce the area eligibility for the program from 50% to 40% of children eligible for free and reduced-price meals.  This is particularly important in rural areas.  3) Fund competitive start up grants.

  • Child and Adult Care Food Program (CACFP) – 1) Reduce the area eligibility for CACFP from 50% to 40%.  2) Extend the age of children in homeless shelters eligible for reimbursement for meals and snacks from the current age of 12 to children up through age 18.  This change would be especially helpful to non profits providing shelter to families. 3) Expand the current supper pilot program.  Because more children in child care have parents who work non-traditional hours, it becomes important for child care providers to be able to serve an evening meal.  4) Increase reimbursement rates so that providers will be able to purchase higher quality foods such as fruits and vegetables.

  • School Breakfast Program – 1) Provide start up grants for the lowest performing states. 2) Establish universal breakfast pilots for secondary schools in low-income areas. 3) Provide additional funds for the purchase of commodities. 4) Expand breakfast in the classroom opportunities in elementary schools in low-income areas. 

  • School Lunch Program – In addition to ensuring that no harm is done through an expansion of income documentation requirements, ensure that all children have access to nutritious meals.  There is evidence that many children in the reduced price category have difficulty affording the 40 cents every day for lunch.  Research has found that reduced price participation declines toward the end of the month.  Therefore, eliminate the reduced-price meal category by bringing the “Free” category up to 185% of poverty. 

  • The Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) – 1) Fully fund WIC so that all women, infants, and children who are eligible for the program are able to participate.  2) Increase the Nutrition Service and Administrative (NSA) funding for nutrition education, and provide additional money to upgrade information systems.  3) Allow states the option to extend certification periods for children and breastfeeding women for up to one year.

Nutrition has a direct effect on the health and well-being of the children we so value.  Providing for their nutritional needs is simply the right thing to do.  Thank you for your consideration.


American Baptist Churches USA

American Friends Service Committee

America’s Second Harvest

Bread for the World

Call to Renewal

Central Conference of American Rabbis

Coalition on Human Needs

Congressional Hunger Center

Episcopal Church USA

Evangelical Lutheran Church in America

Food Research and Action Center

Lutheran Services in America

Mennonite Central Committee U.S. Washington Office

National Council of Churches

National WIC Association

NETWORK, A National Catholic Social Justice Lobby

Presbyterian Church (U.S.A.) Washington Office


The United Methodist Church – General Board of Church and Society

Union of American Hebrew Congregations

United Church of Christ Justice and Witness Ministries

Volunteers of America


For additional information contact Kay Bengston, Assistant Director – Domestic Policy, Lutheran Office For Governmental Affairs, ELCA, Chair of the Food Policy Working Group; 122 C St. NW, #125; Washington, DC 20001; Phone: (202) 626-7942; E-mail:


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