Abstract
Background: The Healthy, Hunger-Free Kids Act was passed in 2010 to update nutrition standards in the National School Lunch and Breakfast Programs to be in accordance with evidence-based guidelines. In 2017 and 2020, the United States Department of Agriculture proposed flexibilities to the nutrition standards for milk, whole grains, and sodium. Objective: This study examines the positions used by stakeholders in support for or opposition to the proposed rules. Methods: We conducted a longitudinal qualitative content analysis of public comments posted to the U.S. Federal Register in response to the USDA's proposed rules in 2017 and 2020. All public comments submitted by individuals and organizations were analyzed (n = 7323, 2017 and n = 2513, 2020). Results: Results indicated three categories of arguments: (1) comments favoring the original law, (2) comments favoring flexibilities, and (3) other. In both comment periods, constituents opposed the implementation of flexibilities, while schools and manufacturers/industry predominately supported them. Academic and advocacy organizations opposed the original proposed change (2017) but relaxed their position in 2020. Conclusions: Any flexibility to the required nutritional standards of school meals has the potential to affect the health trajectory of youth. It is imperative to understand how stakeholders view this issue and inform policy change.