The Strength of a Nudge: New Rules for Wellness Policies

March 07, 2014

HSC’s take on new proposed rules

By Mark Bishop, Vice President of Policy + Communications, Healthy Schools Campaign

Earlier this week, Bettina Siegel at The Lunch Tray posted a thoughtful piece on why she’s not thrilled with the new proposed junk food advertising ban. Essentially, Bettina wrote that since the ban is embedded as a requirement in a school’s wellness policy, it’s weak tea that leaves national policy implementation up to local school boards, superintendents and principals. And as many of us know, many wellness policies are merely dusty documents without real local implementation plans. Take a read; it’s a good piece.

It’s a particularly important conversation right now because the USDA is taking public comment on this proposed policy — and we expect lots of pushback from all sides. For the record, at this moment there have been 10 comments submitted (this will increase by a factor of 10,000 in the coming weeks), and I would classify seven of them as highly critical of school wellness policies and any efforts of the USDA to improve school meals.

However, today Bettina may have stepped back her position a bit in part based on feedback (including feedback from me) and in part because of her very recent experiences on her wellness committee. I’m glad to see a shift in her position, because this rule is more than just a junk food ban. It’s an effort to broadly improve school wellness policies to include more planning and realistic goal setting for schools. I’m fully in agreement when Bettina writes, “…if the rules are adopted in their entirety, wellness policies around the country will be substantially improved.”

But there is another point that hasn’t been mentioned. Wellness policies were not created to be a strong federal mandate. Rather, wellness policies are like a strong federal nudge. They are meant to create space for local schools to engage their communities around issues of health and wellness. One may say this is simply because of the political nature of education today — we are clearly a nation with a strong culture of local control of our schools. However it’s also true that federal policies aren’t as impactful in the day-to-day operations of a school as a team of engaged parents, teachers, students and administrators. And while wellness policies don’t have the strong enforcement mechanisms of, let’s say, speed limits, their softer approach has been effective nevertheless.

Evidence of this effectiveness isn’t fully developed yet, but it’s definitely encouraging. Last year, Robert Wood Johnson Foundation published “Bridging the Gap” which documented the increasing trends in the adoption and quality of those policies. More importantly, a handful of small studies have shown reduced availability of high-fat foodsincreased nutrition education, or higher quality of school meals overall after a local wellness policy is adopted.

To some advocates, federally mandated wellness policies may be perceived as toothless, and they’d want the current proposal to strengthen these policies even more. But although HSC hasn’t developed its official comments on the proposed wellness policy rule yet, I expect that we’ll be strongly supportive. I believe these new changes could go a long way towards reducing junk food marketing, strengthening a school’s wellness goal setting and bringing more community members to the table. In fact it’s possible that if the mandate had more teeth, it would lose one of its key strengths — its ability to engage and empower a local community in discussions around health and wellness.

For school food advocates, the new rules would be welcome additions to one seriously powerful toothless mandate.

HSC commends the USDA for its work, and we look forward to finalizing our comments. Stay tuned!