Analysis of Interest Group Influence on Federal School Meals Regulations 1992 to 1996

ABSTRACT

Regulatory changes proposed by the US Department ofAgriculture in 1994 promised to bring progressive changesto school meals. However, lobbying by interest groupsresulted in substantial changes to the final rule.This analysisretrospectively examines the federal school meals policy-making process during 1992 to 1996. Key questions addresswhy the policy changed and what the role of interest groupswas in affecting the shape, pace, and direction of the policy.The study provides suggestions for using the experiences of1992 to 1996 to guide future advocacy efforts and for adapt-ing the approach for application to other food and nutritionpolicies.

KEY WORDS: food and nutrition policy, school meals,interest groups

(J Nutr Educ Behav. 2004;36:90-98.)

BACKGROUND

Concerns about nutritional deficiencies inspired the passageof the National School Lunch Act of 1946.1 Ironically, issuesof nutritional excess drove school meal reform efforts in the1990s. Childhood obesity—in part the result of nutritionalexcess—is a major public health problem.2,3 The importanceof establishing health-supporting eating habits at an earlyage has been underscored by the large and growing body of

scientific evidence linking dietary choices with risk forchronic disease.4-6

Findings from the School Nutrition Dietary AssessmentStudy of 1992 showed that National School Lunch Program(NSLP) participants consume more fat, saturated fat, andsodium than is recommended.7 However, efforts to changethe 50-year-old NSLP have been fraught with difficultiesstemming from the conflicting interests of a myriad of stake-holders, many of whom stand to lose if there is radicalchange in the composition of school meals. Confoundingthe issue is the dual charge of the NSLP: to “safeguard thehealth and well-being of the Nation’s children [while at thesame time] encouraging the consumption of agriculturalcommodities.”8 Agricultural commodities, particularly high-fat dairy products, meats, and processed foods, have beencited as key contributors of excessive amounts of total fat,saturated fat, cholesterol, and sodium in school meals.8-10

Regulatory changes proposed by the US Department ofAgriculture (USDA) in 1994,“The National School Lunchand School Breakfast Program: Nutrition Objectives forSchool Meals,” held the promise of bringing comprehensiveand progressive changes to the NSLP.1 However, intensivelobbying efforts on the part of interest groups within thepolicy development process resulted in changes that sub-stantially reduced the power of the final rule to help schoolsbring meals into compliance with the Dietary Guidelines forAmericans.11,12 Additional changes to the final rule reducedaccountability and repercussions for schools with menus notin compliance with federal nutrition recommendations.12

PURPOSE

Our study focused on the process of federal school mealspolicy making during the 5-year period from 1992 to 1996.The aim was to describe and analyze why the policychanged during the rule-making process, with an emphasison the role of interest groups in affecting the shape, pace, and

90

VIEWPOINT

Analysis of Interest Group Influence on Federal School Meals Regulations1992 to 1996

SUZANNE HAVALA HOBBS, DRPH, MS, RD1; THOMAS C. RICKETTS, PHD, MPH1 , 2 ;JANICE M. DODDS, EDD, RD3; NANCY MILIO, PHD1 , 4

1Department of Health Policy and Administration, School of Public Health,The University of North Carolina atChapel Hill, Chapel Hill, North Carolina; 2Cecil G. Sheps Center for Health Services Research,The University ofNorth Carolina at Chapel Hill, Chapel Hill, North Carolina; 3Department of Nutrition, School of Public Health,

The University of North Carolina at Chapel Hill, Chapel Hill, North Carolina; 4Department of Nursing,School of Nursing,The University of North Carolina at Chapel Hill, Chapel Hill, North Carolina

The authors have no financial conflicts of interest to declare.Address for correspondence: Suzanne Havala Hobbs, DrPH, MS, RD, Department ofHealth Policy and Administration, School of Public Health,The University of NorthCarolina at Chapel Hill, 1121 McGavran-Greenberg, CB #7411, Chapel Hill,NC 27599-7411; Tel: (919) 843-4621; Fax: (919) 966-6961; E-mail: [email protected].©2004 SOCIETY FOR NUTRITION EDUCATION

direction of the policy. No published research to date hasexamined this particular process. In fact, across disciplines,analyses of this type have largely been omitted from policystudies.13-15 The analysis of policy development is critical forthe building of political skills needed to assist those whoseek to promote child nutrition by influencing policy-mak-ing processes.16

CONCEPTUAL FRAMEWORK

The study drew from the general body of literature on pol-icy analysis and interest groups. We applied a conceptualframework to food and nutrition policy based on an eco-logical view of policy making derived from general systemstheory and cybernetic models applied to social situations(Figure 1).

The approach identifies key interest groups within andoutside government with a stake in the policy change.Groups exert influence on the policy in question by affect-ing the shape, pace, or direction of policymaking in an effortto protect and support their interests.These groups includea policy keeper that has the primary role in moving the pol-icy through development and all other stakeholders. The

policy keeper is a strategic management unit with resourcesallocated to implementation of the policy. In the case ofnational school lunch regulatory reforms, the policy keeperwas the Food and Consumer Service (FCS) of the USDA(now the Food and Nutrition Service).

Interest groups react to factors within the policy envi-ronment—the social, political, economic, and organizationalsettings in which the policy evolves—in exerting their influ-ence on the policy-making process. Dimensions that affectthe policy environment include such factors as demograph-ics, epidemiology, technology, the national and world econ-omy, the distribution of resources, political party agendas,and organizational hierarchies.As the actions (or inaction) ofinterest groups evolve within the policy environment, theirinfluence on the policy-making process is further affected bypassage through the filter of the mass media.The print, elec-tronic, and other media may enhance, diminish, or otherwiseredirect issues in such a way as to influence the developmentof the policy and, therefore, its final outcome.

The relative success of stakeholder groups in influencingthe policy process is dependent on such factors as each group’sauthority, influence, status, resources, and skills compared withthose of competing interests. The policy develops throughmutual adaptation as the policy keeper and stakeholders

Journal of Nutrition Education and Behavior Volume 36 Number 2 March • April 2004 91

NongovernmentStakeholders

Policy Keeper Other GovernmentStakeholders

Mass Media

Development ofPolicy Process

Final Rule

Nutrient Composition andNutritional Quality ofSchool Meals

PolicyEnvironment*

SocialEconomicPoliticalOrganizational

Figure 1. Conceptual model for the study. *Policy environment is the backdrop against which the rest occurs. It can influence all other factors.

evolve within the political, social, economic, and organiza-tional conditions surrounding the policy-making process.13

DESCRIPTION OF THE APPROACH

Analysis

We conducted a retrospective analysis of the federal schoolmeals policy-making process occurring during the years1992 to 1996 when a policy window of opportunity openedand related interest group activity intensified. The analysiscombined aspects of an empirical approach developed byMilio,16 the technique of backward mapping with whichElmore is credited,17 and basic steps in policy analysis.Theseapproaches were adapted for use in this case, taking an eco-logical view of policy making similar to the Advocacy Coali-tion Framework.18 The Institutional Review Board of theSchool of Public Health at the University of North Carolinaat Chapel Hill granted approval for the study protocol, andkey informants provided written informed consent.

The analysis focused on one aspect of the proposed rule:the move to a nutrient-based menu planning system(NBMP). Narrowing the focus of complicated cases is crit-ical to achieving a manageable project.13 Furthermore, theauthor (principal investigator) was directly involved in thepolicy-making process that was the subject of the analysisand, as such, was a participant observer.19 Such involvementby the investigator, although a form of bias, is common and,in fact, is often necessary for this type of in-depth research.13

Sampling Methods

A 360° view of the policy-making process was achieved byobserving it from the perspective of the policy keeper—theUSDA—and other stakeholders from within organizations, aswell as from outside domains via data sources such as writtendocuments. A purposeful sample consisting of key partici-pants in the policy process was identified at the outset of thestudy for information-rich interviews. Subsequent snowballsampling was used to identify additional information-richkey informants, for a total of 19.This sample size is typical andappropriate for this form of qualitative research.19 Stakeholdercategories included business and industry, professional, pub-lic interest, and government officials acting as lobbyists. Inter-est groups included in this study are listed in Table 1.

Data Collection Procedures

Policy analysis seeks to “answer applied rather than theoret-ical questions while working under time constraints foreignto most traditional researchers.”20 Observing and analyzingactual cases as they unfold is the best way to gain strategicinformation that can be used to move policies forward.16,21

Research of this nature often relies on qualitative methods ofdata gathering coupled with secondary data, using an inves-tigative approach such as that taken here.

Interview questions were pilot-tested and revised as nec-essary before further interviews were conducted. Interviewswere conducted in a conversational manner, so the order ofthe questions and specific wording varied. All interviewswere conducted by the principal investigator and varied induration. Interviews were taped, and verbatim transcriptswere prepared.

Data included documents and published data sources suchas the Federal Register, proceedings from public hearings, tes-timony presented in response to legislative and regulatoryactions, internal and unpublished reports, memoranda, lettersand other correspondence obtained through internal chan-nels, organizations’ annual reports, policy papers, and news-paper and magazine stories. Use of such documentary datais typical and appropriate for this form of qualitativeresearch.19 Semistructured interview questions were used tocollect interview data. Of particular interest were stakehold-ers’ perceptions of their stake in the policy, their policy posi-tions, their strategies for moving the policy in the directionof their interests, and their views on the short- and long-term feasibility of the policy. Factual statements made byinterviewees were verified via triangulation using docu-mentary data sources or by cross-checking with other inter-viewees while preserving confidentiality.

Data Management and Analysis

The unit of analysis was the interest group, or stakeholder,and its involvement in the policy-making process.The aim

92 Hobbs et al/VIEWPOINT: INTEREST GROUP INFLUENCE ON FEDERAL SCHOOL MEALS REGULATIONS

Table 1. Stakeholders by Interest Group Category

Interest Group Category Stakeholder

Business and Industry National Cattlemen’s Beef Association

National Dairy Council

Produce Marketing Association

Professional American Academy of Pediatrics

American Dietetic Association

American School Food Service Association

Southern California Food Service Association

Public Interest American Cancer Society

American Heart Association

Food Research and Action Center

Vegetarian Resource Group

Government Officials Representative W. M. Goodling (R-PA)

Senator Patrick Leahy (D-VT)

Representative George Miller (D-CA)

US Department of Agriculture (the policy keeper)

A key informant from the Congressional Research Service providedbackground information about the policy-making process but was not astakeholder per se. Note that two key informants each were from theProduce Marketing Association, the American School Food ServiceAssociation, and the US Department of Agriculture for a total of 19 keyinformants.


of the analysis was to document, systematically, the policyprocess by following the actions of interest groups and learn-ing about their goals, resource bases, and strategies for influ-encing the policy in the desired direction.A complementaryfocus of the analysis was the USDA, the policy keeper in thiscase.The FCS of the USDA was the target of interest groupactivities as they attempted to influence the policy design.

Qualitative data were managed and organized using CDCEZ-Text Software for Collection, Management and Analysisof Semi-structured Qualitative Databases, version 3.06(developed by Conwal Incorporated for the Centers for Dis-ease Control and Prevention, Atlanta, Ga). This included amultistep coding procedure and preparation of matrices anddata summaries conducted solely by the principal investig-tor. Data provided by public records, organizations’ annualreports, public documents, and other written documentswere integrated and triangulated as appropriate with inter-view data.

For the purpose of analysis, stakeholders were categorizedby their interests in the policy (antagonistic or supportive)and by the relative weight of their influence. These werederived from documents, supplemented by informationgathered in interviews about the perceptions of key infor-mants, and are displayed in Figure 2.

The direction of a stakeholder’s action was judged onwhether it attempted to strengthen or weaken the proposedpolicy to replace the traditional meal-pattern system withthe NBMP. Stakeholders were identified as being opposed orsupportive of the proposed policy, depending on the direc-tion in which they attempted to influence the policy. Oppo-sition stakeholders were those who opposed the move froma food-based menu-planning system to the NBMP or advo-cated for schools to have the option of using either system.Supportive stakeholders were those who supported themove from a food-based menu-planning system to theNBMP. Further description of stakeholder positions is pro-vided in the legend for Figure 2.

Description of the Evaluation

Detailed findings of the political, social, economic, andorganizational conditions surrounding the policy-makingprocess have been reported.22 Briefly, the school mealspolicy-making process occurred in a highly contentious andpoliticized environment.23-25 The policy action began at thelevel of the undersecretary of agriculture, newly appointedin 1992, when a policy window of opportunity opened foradvocates who desired broad-based reform of the NSLP.24,26-28

Prior to appointment with the Agriculture Department,the undersecretary had established a long history of advo-cating for improved nutrition in school meals via PublicVoice for Food and Health Policy, an advocacy organizationfor which she had served as executive director and thatannually criticized school meals for nutritional excesses.24,29

The political environment changed dramatically with elec-tions in 1994 that gave control of the House and Senate to

the Republican Party.23,25 This change rendered the envi-ronment substantially less favorable to reform efforts previ-ously initiated.30,31

The mass media were generally positive in coverage ofthe proposed changes to school meals early in the policy-making process and were supportive of the undersecretary,but the tone of coverage changed as opponents of theNBMP became more public in their disagreement with thepolicy proposals and the undersecretary’s approach to theprocess.23,30,32-34 The “personality politics” of the case gainedattention in the press. (Note: the undersecretary declined tobe interviewed for this study.)

Economically, multiple stakeholders stood to lose by thechanges to the NSLP proposed by the USDA, particularlyfood producers and foodservice personnel.A comprehensivesummary of the organizational environment, including a listof the policy interests of stakeholder organizations, organi-zational mission, structure and governance, size of budget

Figure 2. Interpretation of stakeholders’ positions on the nutrient-

based menu planning system (NBMP). The Congressional

Research Service and the National Dairy Council are not listed

because their positions are indeterminate. *Problematic stakehold-

ers are those organizations that opposed the move to a nutrient-

based menu-planning system but had a relatively low level of influ-

ence on the process. †Antagonistic stakeholders are those

organizations that opposed the move to an NBMP system (or sup-

ported school choice between continued use of a food-based sys-

tem or a switch to NBMP) and had a high level of influence on the

process. ‡Low-priority stakeholders are those organizations that

supported the move to an NBMP system but had a relatively low

level of influence on the process. §Supportive stakeholders are

those organizations that supported the move to an NBMP system

and had a high level of influence on the process. AAP indicates

American Academy of Pediatrics; ADA, American Dietetic Associ-

ation; ACS, American Cancer Society; AHA, American Heart Asso-

ciation; ASFSA, American School Food Service Association;

FRAC, Food Research and Action Center; NCBA, National Cattle-

men’s Beef Association; PMA, Produce Marketing Association;

SCFSA, Southern California Food Service Association; USDA,

US Department of Agriculture; VRG, Vegetarian Resource Group.

Oppose

Position onNBMP

Support

Least Most

Relative Strength or Weakness in Influencing Policy Process

Problematic∗ Antagonistic†

AAP PMA ASFSAADA NCBA SCFSA Sen. LeahyRep. Goodling FRACRep. Miller

Low priority‡ Supportive§

ACS USDAAHAVRG

and staff, and other organizational findings, is availableelsewhere.22

There was wide variation in the amount of resources thatorganizations devoted to the policy-making process, rangingfrom minimal input (American Cancer Society [ACS], FoodAction and Research Center [FRAC], and the ProduceMarketing Association [PMA]) to a high level of input by theAmerican School Food Service Association (ASFSA), whichemployed an influential lobbyist and included substantialinvolvement of the organization’s top leadership. Organiza-tions favoring a move to a solely nutrient-based menu plan-ning system included the ACS, the American Heart Associ-ation (AHA), USDA, and the Vegetarian Resource Group(VRG).With the exceptions of the National Dairy Council(NDC) and the Congressional Research Service (CRS),which did not take positions, the remaining stakeholdersopposed a move to a solely nutrient-based menu planningsystem.

Figure 2 summarizes stakeholders’ positions on the moveto NBMP and their relative strength or weakness in influ-encing the policy-making process. The ASFSA stood outamong all stakeholders as having had the greatest level ofinfluence on the process among those opposing the move tothe NBMP.The USDA had the greatest level of influence onthe process among those favoring the move to the NBMP,although its level of influence on the process was less thanthat of the ASFSA. All other stakeholders listed had rela-tively low levels of influence on the process. No collabora-tion among groups was reported. A summary of the strate-gic actions taken by interest groups, major points in theprocess at which they were active, and the direction in whichactions affected the policy are summarized in Table 2.

Key informants offered opinions and suggestions aboutwhat advocates of NBMP might have done differently tochange the outcome of the final regulations.They also citedlessons learned from the school meals policy-making processfrom the perspective of their own organizations.

DISCUSSION

Environmental Analysis

Although the timing was right in 1992 to initiate sweepingchanges in the implementation of the federal school mealsprogram, the policy window that permitted advocates to actclosed in 1994 after elections turned control of the Houseand Senate over to Republicans.23,25,30,31

Some of the debate around school meals policy wasplayed out in print by the national news media, whichfocused on acrimonious relationships between the under-secretary and school foodservice professionals, as well as sev-eral members of Congress.23,31 Republicans levied criticismagainst her for alleged partisanship and actions against theContract With America. Furthermore, key informants citedthe failure of the undersecretary to make the necessary tran-

sition from advocate to political appointee and bureaucrat asa major factor in the fray.The proper role of the USDA as aregulatory agency and policy keeper in this case was to con-sider input from stakeholders and facilitate and guide thepolicy process. However, opposition groups perceived theundersecretary as having had a clear preference for theNBMP and as acting more like an advocate than a govern-ment official.

Economically, several industry sectors stood to lose if theNBMP were put into place on a large scale. The biggestpotential losers would have been the meat and dairy indus-tries, although school foodservice professionals alsoexpressed financial concerns over the cost to schools ofimplementing the proposed regulations. Organizationally,groups representing business and industry, professional asso-ciations, public interest, and government had stakes in theproposed regulations,with interests that included, in additionto financial gain or loss, child welfare, administrative flexi-bility, control, and image.Their resource bases, specific mis-sions and objectives, and organizational structures varied andaffected the extent to which they did (or did not) getinvolved or devote resources to the policy process.

Classification of Stakeholders

Of the 3 nonagency organizations allied with the USDA insupporting the NBMP—ACS, AHA, and VRG—2 hadresource bases sizable enough to have potentially been muchmore influential in the policy process. The VRG, althoughsupportive, could probably not have been of more use to theUSDA owing to limited staff and financial capacity. How-ever, the ACS and AHA, each with millions of volunteers andsizable budgets, may have been worthwhile targets of theUSDA for greater involvement.

On the other hand, the analysis in Figure 2 shows theextent to which interest groups opposed the NBMP andsuggests that there was potential for the USDA to do moreto reach out to “problematic” interest groups to bolster sup-port. Groups for which the policy interest was primarilychild welfare (American Academy of Pediatrics [AAP],American Dietetic Association [ADA], FRAC) might havebeen positively influenced more easily than groups that hada financial stake in the outcome. All 3 had extensive net-works inside and outside government and may have beenable to positively influence other problematic stakeholders.In particular, the ADA and FRAC had close ties with theASFSA and might have been an effective intermediary formediating differences between USDA and ASFSA.The PMAand National Cattlemen’s Beef Association (NCBA) eachhad financial interests in the policy that would likely havemade negotiation less productive. Nevertheless, those orga-nizations might have been willing to take a compromiseposition, particularly if other problematic stakeholders hadbeen influenced positively.

Throughout the policy-making process, the ASFSA wasthe USDA’s greatest challenge. The organization had an


extensive network of relationships inside and outside gov-ernment, with a powerful and effective lobbyist and strong,committed grassroots membership. Several policy interestswere at issue for the ASFSA, including image, control, finan-cial concerns, and administrative flexibility, and the organi-zation was committed at all levels—from senior manage-ment to the grass roots—to directing substantial resources tothe policy process. Rather than relying on collaboration orcoalition building per se, the ASFSA informally leveraged

existing relationships within its network to bring aboutcongressional actions that gave it the policy results itneeded. Other than the ASFSA, no other organizationexamined in this study reported employing a lobbyist inthis case.

It is possible that the ASFSA’s strength in this case per-mitted problematic stakeholders to take a less active role inthe process than they might otherwise have taken. Groupsmay have perceived the ASFSA to be an effective enough


Table 2. Stakeholder Summary

Interest Group Points of Direction PolicyCategory Name of Organization Strategic Actions Activity Was Affected*

Business and industry National Cattlemen’s Beef Association Administrative lobbying; a, b –legislative lobbying

Business and industry National Dairy Council Sponsored conference; a, c NAprovided information

Business and industry Produce Marketing Association Administrative lobbying; a, c NAworked with media;provided speakers

Professional American Academy of Pediatrics Administrative lobbying; a, b NAlegislative lobbying

Professional American Dietetic Association Administrative lobbying; a, b, c –legislative lobbying

Professional American School Food Service Administrative lobbying; a, b, c, d –Association legislative lobbying;

worked with media;provided speakers;sponsored conference;provided information

Professional Southern California Food Service Administrative lobbying; a, b –Association legislative lobbying

Public interest American Heart Association Administrative lobbying; a, b, c, d +legislative lobbying;worked with media

Public interest American Cancer Society Administrative lobbying; a, b, c, d NAlegislative lobbying

Public interest Vegetarian Resource Group Administrative lobbying; a, c + worked with media;provided speakers;sponsored conference

Public interest Food Research and Action Center Administrative lobbying; a, c –legislative lobbying;worked with media

Government officials Senator Leahy Legislative lobbying; a, b, d –provided speakers

Government officials Representative Goodling Legislative lobbying; d –worked with media

Government officials Representative Miller Administrative lobbying; a, d –legislative lobbying

Government officials US Department of Agriculture, Legislative lobbying; a, b, c, d –Food and Consumer Services worked with media;

provided speakers;sponsored conference

Government officials Congressional Research Service NA a, b, c, d NA

*+ indicates for; –, against or no apparent effect on the Nutrient Based Menu Planning aspect of the first proposed rule.a indicates June 1994 proposed rule: National School Lunch and School Breakfast Program: Nutrition Objectives for School Meals; b, November

1994: Healthy Meals for Healthy Children Act of 1994 (HR 8; PL 103-448; Sponsor: Senator Leahy); c, January 1995 proposed rule: National SchoolLunch and School Breakfast Program: Compliance with the Dietary Guidelines for Americans and Food-Based Menu Systems; d, May 1996: HealthyMeals for Children Act (HR 2006; Sponsor: Representative Goodling; Cosponsor: Representative Miller).

NA indicates no apparent effect.

advocate for their position so as not to merit the commit-ment of additional resources to the effort.

Analysis of the Policy-Making Process

Little, if any, collaboration was documented as occurringduring the policy process. Coalition activity was primarilylimited to the formation of the Advocates for Better Chil-dren’s Diets (ABCD) coalition, which mainly functioned asa public proclamation of solidarity around some of the issuespertaining to school meals and included groups both in favorof and opposed to the NBMP. Nonagency supporters of theNBMP might have met with greater policy success had theyshared or combined their resource bases for joint efforts.TheACS and AHA, in particular, had substantial financial, staff,and volunteer resources from which to draw, but doing sowould have required that those organizations place theNSLP ahead of other organizational interests. It also wouldhave meant sharing subject matter expertise.The ACS had aninterest in the NSLP from the point of view of child welfare,but they had no one on staff with expertise in nutrition.

The VRG had nutrition expertise that could have beenshared with both the ACS and AHA, whereas the ACS andAHA had the financial base that the VRG did not. Formal orinformal collaboration among the ACS,AHA,and VRG mighthave resulted in a mutually beneficial sharing of resources thatmight have strengthened their policy efforts. All 3 wereengaged in administrative lobbying, and the ACS and AHAengaged in legislative lobbying as well. The AHA and VRGused the mass media.Combining the strengths of these 3 orga-nizations, in cooperation with the USDA, in legislative lobby-ing and working with the mass media, in particular,might havebeen productive in moving their policy interests forward.

It is not clear that interest groups opposed to the NBMPhad much to gain by engaging in the policy process to agreater degree than they did because the ASFSA was so visi-ble and effective by itself. Groups such as the NCBA, PMA,AAP, ADA, Southern California Food Service Association(SCFSA), and FRAC engaged in administrative lobbying, andseveral also engaged in legislative lobbying and other strate-gic actions in support of the ASFSA and opposition to theNBMP. However, just the fact that some of these organiza-tions took a position that was not in support of the NBMPwas significant in itself, notwithstanding the fact that theywere not more active in their opposition than they were.Some advocates of the NBMP might have been surprised tolearn that such organizations as the AAP,ADA, FRAC—eventhe PMA—were not in favor of the NBMP as the sole optionfor meal planning. Closer examination of the data revealedwhy they took the positions they did and identified a failedopportunity for USDA—as well as nonagency advocates ofNBMP—to reach out to these organizations and address theirconcerns to win stronger support for the policy.

Concerns about the cost of implementing the NBMP ledthe AAP and FRAC to fear that access to meals would beadversely affected by the proposed policy. To win the sup-

port of these groups, the USDA would have had to allaythese fears. The ADA, on the other hand, was home to adietetic practice group for dietitians with a professionalinterest in school food service. Membership in this ADApractice group overlapped with ASFSA membership.

ASFSA members held leadership positions within theADA practice group and on the ADA’s Child NutritionAdvisory Committee, which was active on the ADA’s behalfduring the policy-making process. Furthermore, the ASFSA’slobbyist served on the board of directors of the FRAC.

Finally, advocates of the NBMP might have thought thatthe PMA would have been supportive of the proposed rule,under the assumption that the policy would have made iteasier for more fruits and vegetables to be included in schoolmeals. However, the PMA had concerns that schools wouldturn to fortified “super junk foods” and that these wouldreplace whole fruits and vegetables.This concern would haveto have been dispelled for the USDA to have gained the sup-port of the PMA.

None of these strategic moves, however, may have beenpossible or effective without a concomitant change in eitherthe undersecretary’s style of interaction with stakeholders orthe way in which stakeholders perceived these interactions.The print media publicized and greatly increased publicawareness of the personal conflict between the undersecre-tary and the ASFSA and various members of Congress.Whereas initial press coverage emphasized and celebratedthe overdue reform of the NSLP, later coverage in newsreports, editorials, and op-ed columns focused on personalattacks on the undersecretary. Eventually, the White House,which had previously supported the undersecretary’s initia-tive, was forced to step in and support the congressionalactions that superseded the proposed rule.

Ultimately, the comprehensive overhaul of the NSLP ini-tially proposed by the USDA was reduced to an incremen-tal change through congressional actions that forced a com-promise position. The extent to which compromise mighthave been necessary given the environmental conditions ofthe policy process is a matter of speculation, although mostkey informants both in favor of and opposed to the NBMPexpressed the views that political skills and strategic planningwere vital given the complexity of the interrelationshipsamong stakeholders.

Feedback provided by key informants concerning ways inwhich advocates of NBMP could have been more effectiveemphasized the negative perceptions of the undersecretary’smanagement style and personal interactions with stakehold-ers. Such data, although not validated, suggest that theundersecretary’s personal approach may have limited theagency’s ability to advance its policy agenda.The case gen-erated “lessons learned” that may have general application fornutrition advocates.The need for diplomacy skills, strategicplanning, and a willingness to consider all views and engagein negotiation and compromise were highlighted.

However, the case also supports a market-oriented viewof interest group theory, illustrating that political power—


access and political influence—is available for purchase inthe United States.Thus, groups with limited funds must actstrategically to maximize the impact of their policy-makingefforts.Although the FCS/USDA—the policy keeper in thiscase, despite its clear preference for NBMP—was unsuccess-ful in advancing its policy agenda, outside advocates ofNBMP also lost opportunities at the same critical juncturepoints in the policy-making process. Advocates of NBMP,including the ACS, AHA, and VRG, did not recognize thatthe FCS/USDA was out of step with some of its formerallies. Had these organizations had a greater level of aware-ness of the larger political landscape, they might have takensteps to work around the USDA to find areas of commonground with opposition groups. Although it may not havebeen realistic for groups supporting NBMP to expect totalvictory in achieving their policy goals, they may have beenable to participate in a process that sought to compromiseand, in doing so, brought the final policy closer to their pre-ferred position.

CONCLUSIONS AND IMPLICATIONS FORRESEARCH AND PRACTICE

Industry and industry-backed groups often have substantialresource bases and can afford to hire highly paid lobbyistsand engage in a wide range of strategies to influence the pol-icy-making process. In contrast, public interest organizations,including small nonprofit and grassroots organizations, oftenhave comparatively less in terms of staff and financial assets.They and others can use the lessons learned in this case tomake better, more informed decisions about how to directlimited resources for the greatest impact on the policy-mak-ing process. Key in this regard are political awareness and astrategic approach.This case underscored the importance offorming or joining an active, persistent, well-connectedorganization.

Nutritionists and other health professionals and publichealth advocates need a basic understanding of the policyarena in which they fit, as well as the political skills neces-sary to successfully influence policy-making processes. In-depth analyses of food and nutrition policy issues provide ameans of obtaining this knowledge and may be particularlyvaluable for new or unskilled advocates. However, they arerarely conducted.That may be due, in part, to time and costconstraints, although analysis on the level of the presentstudy would likely be feasible for many organizations. Lackof experience and exposure to the tools of policy analysisprobably also contribute to the paucity of this type ofresearch.As this study has shown, analyses of food and nutri-tion policy issues can be designed using a practical approachthat can be tailored to the specific circumstances of the case.The approach used in this case could serve as a blueprint forthe examination of similar food and nutrition and otherpublic health policies.

ACKNOWLEDGMENTS

Data for this paper were derived from the doctoral dissertationof Suzanne M. Havala, Nutrition Policy and Food Policy:The Influence of Interest Groups on Federal School-MealsRegulations, 1992-1996. Chapel Hill, NC:The University ofNorth Carolina; 2001.The authors wish to acknowledge andthank Pam C. Silberman, JD, DrPH, Associate Director forPolicy Analysis, Cecil G. Sheps Center for Health ServicesResearch, The University of North Carolina at Chapel Hill,and Michael F. Jacobson, PhD, Executive Director,The Cen-ter for Science in the Public Interest, for their substantial con-tributions to the study as members of Dr. Havala Hobbs’sDissertation Committee.

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Society for Nutrition Education’s Eight Child Nutrition Education Priorities

These priorities were outlined in a recent letter from Society for Nutrition Education (SNE) to the Institute of Medicine, Committee onPrevention of Obesity in Children and Youth Workshop.

• Enhance and strengthen child nutrition education, promotion and environmental efforts by adding a state-level infrastructure andnetworking component to the United States Department of Agriculture (USDA) Team Nutrition program.

• Increase funding for nutrition education and promotion efforts to a total of $50 million.• Provide expanded authority and funds to USDA in order to fully cover all food and beverage sales and enforce regulations on

school campuses throughout the school day for schools that participate in the National School Lunch or School Breakfastprogram.

• Promote initiatives, such as 5 A Day, that would help increase all types of fruit and vegetable intake among child nutrition programparticipants.

• Require USDA to conduct regular and periodic reviews (at least every 5 years) of the Women, Infants and Children SupplementalNutrition Program (WIC) food package to assure that the food packages are consistent with health and nutrition recommenda-tions as well as nutrition education and promotion efforts.

• Support full funding for the WIC program to reach all nutritionally at-risk eligible women and children with nutrition servicesand supplemental foods.

• Maintain the nutrition and health mission of WIC. Increase the Nutrition Services and Administration funding to assure qualitynutrition education services. Provide adequate funding to accompany additional related administrative and client service require-ments, such as substance abuse, education, immunization, screening, etc.

• Support the WIC Farmer’s Market Nutrition Program reauthorization and secure independent funding stream by decoupling from theWIC caseload funding mechanism.

Documents

Analysis of Interest Group Influence on Federal School Meals Regulations 1992 to 1996