48 Consolidated and Further Continuing Appropriations Act 42 USC 1758 2012 49 7

48 consolidated and further continuing appropriations

This preview shows page 8 - 10 out of 30 pages.

48 Consolidated and Further Continuing Appropriations Act, 42 U.S.C. § 1758 (2012). 49 7 C.F.R. pts. 210 & 220 (2015). 50 See, e.g. , Healthier School Meals: A Summary of the New USDA Standards for School Breakfast and Lunch , F OOD R ES . & A CTION C TR . (Jan. 2012), nutrition_rule_summary.pdf [] (“The new standards are extraor- dinarily important to the health and learning of America’s school children. Nearly 32 million children eat lunch at school every day; more than 20 million of them are low-income children whose families are struggling to make ends meet and who receive free or reduced-price meals.”). 51 See generally 7 C.F.R. pts. 210 & 220.
Image of page 8
\\jciprod01\productn\H\HLL\53-1\HLL104.txt unknown Seq: 9 20-JAN-16 10:35 2016] For the Health of It 395 in line with the latest scientific nutritional recommendations, and the poten- tial impact on student health could be substantial. Still, critics have attacked the standards from both sides. Some assert that the standards (in their final form) circumvent key nutritional recommendations and fall short on their overall public health goal. 52 Others claim the nutrition standards go too far and impose higher costs on schools to provide food that is both more expen- sive and less liked by students. 53 In light of these criticisms, this section assesses whether the USDA properly quantified the costs and benefits of its proposed standards accord- ing to its legislative and administrative mandates. It concludes that, although the nutrition standards are in fact cost-justified, this justification was not made apparent in the promulgation of the standards themselves. Rather, the cost-benefit analysis of the rule glosses over significant benefits, leaving a direct comparison between costs and benefits unachievable. 54 By delineating the benefits of the nutrition standards here, this section demonstrates that the nutrition standards are cost-justified. A. Changes and Cost-Savings from Proposed Rule to Final Rule With some exceptions, the changes made from the proposed rule in 2011 to the final rule in 2012 were generally intended to reduce the costs rather than increase or maintain the benefits of the proposed nutrition stan- dards. The final rule made significant strides toward reducing costs, as the proposed rule would have increased the cost of the NSLP and SBP by $6.8 billion over five years (a twelve percent increase), 55 whereas the final rule is estimated to cost only an additional $3.2 billion over five years (an eight percent increase). 56 Yet, in reducing the rule’s projected costs by $3.6 billion, the final rule did not adequately assess the corresponding loss in health ben- efits, which were largely unstated or only generally alluded to as a “critical strategy to prevent obesity, and related health risks, among children.” 57 Between the proposed and final rules, the USDA reduced the rule’s costs in three ways. The first category is empirical, and the second two are policy-oriented.
Image of page 9
Image of page 10

You've reached the end of your free preview.

Want to read all 30 pages?

  • Fall '17
  • PAS Physcian assisted suicide
  • The Land

What students are saying

  • Left Quote Icon

    As a current student on this bumpy collegiate pathway, I stumbled upon Course Hero, where I can find study resources for nearly all my courses, get online help from tutors 24/7, and even share my old projects, papers, and lecture notes with other students.

    Student Picture

    Kiran Temple University Fox School of Business ‘17, Course Hero Intern

  • Left Quote Icon

    I cannot even describe how much Course Hero helped me this summer. It’s truly become something I can always rely on and help me. In the end, I was not only able to survive summer classes, but I was able to thrive thanks to Course Hero.

    Student Picture

    Dana University of Pennsylvania ‘17, Course Hero Intern

  • Left Quote Icon

    The ability to access any university’s resources through Course Hero proved invaluable in my case. I was behind on Tulane coursework and actually used UCLA’s materials to help me move forward and get everything together on time.

    Student Picture

    Jill Tulane University ‘16, Course Hero Intern

Stuck? We have tutors online 24/7 who can help you get unstuck.
A+ icon
Ask Expert Tutors You can ask You can ask You can ask (will expire )
Answers in as fast as 15 minutes