2014 Informal Local Wellness Policy Review Findings

Colorado Department of Public Health and Environment

DRAFT

Prepared July 2014

Contents
Introduction ...................................................................................................................................................................3
Districts Reviewed and Process .....................................................................................................................................3
Indicators Reviewed ......................................................................................................................................................5
Key Findings ...................................................................................................................................................................5
Conclusions and Next Steps .........................................................................................................................................10

Introduction
School districts that participate in federal child nutrition programs are required to adopt and implement Local
Wellness Policies (LWP). The requirements for these policies are outlined in federal legislation. Policies were first
required as part of the Child Nutrition and Women, Infants and Childrens (WIC) Reauthorization Act of 2004 and
then reauthorized and expanded in the Healthy, Hunger-Free Kids Act (HHFKA) of 2010. As of 2014, the updated
rules for the updates to LWP are still being finalized.
Additionally, Colorado legislation, policies and rules require schools and districts to address physical education and
activity, school nutrition, health education, etc. For a list of school health related legislation and policies, visit the
Colorado Education Initiative.
This report describes the informal findings from a policy review completed by the Colorado Department of Public
Health and Environment in 2014. The key purpose for this review was to identify baselines for the required
performance measures for the Centers for Disease Control and Prevention efforts with CDE and CDPHE and to
inform trainings and capacity building for Local Wellness Policy development and implementation offered by
CDPHE, CDE and the Colorado Education Initiative (CEI).
Forty-one districts were reviewed for this report. The informal methodology and findings are outlined below.

Districts Reviewed and Process

41 districts reviewed represent over 80%

of the Colorado student population

Total number
of students
Students
Number of
students in
districts
reviewed
0

200,000

400,000

600,000

800,000

1,000,000

The 41 districts were selected based on the following criteria:

Ten school districts supported by the Colorado Department of Education (CDE) and the Colorado
Department of Public Health and Environment (CDPHE) with state appropriated funding and from CDC
enhanced funding, and districts with other grants and funding resources, such as funding from The
Colorado Health Foundation, RMC Health, the Colorado Education Initiative and Kaiser Permanente.
Districts that served a high proportion of students eligible for free and reduced priced lunch.

Additional districts to represent a breadth of regions, size and locations in Colorado, as well as districts
that do not have health and wellness funds.
An aggregate number of districts which serve at least 80% of the student population in Colorado.

CDPHE staff examined school board, district or administrative policies for 41 of the 178 districts in Colorado.
Additionally, any associated regulations, exhibits or rules that were a part of the identified policy were also
reviewed. The policies and/or regulations were accessed on district or school websites. Policies that were
examined included local wellness policy, physical activity, physical education, school nutrition and graduation
requirements. Many additional policies including tobacco prevention, health education, drug policies, bullying
prevention policies, safety policies, etc., are also required and should potentially be included in future reviews. All
online policies were accessed between March 2014-June 2014 and links are provided for LWP on the internal
review document for future reference and to access for training purposes.
A key limitation with this review is that indicators were only identified within the policies found and reviewed.
Districts may have other policies or practices (i.e., human resources policies, codes of conduct, school rules or
principal policies) that support these indicators, but they were not found within the specific policies.

Indicators Reviewed
For this informal review, key indicators were identified based on other formal research studies, as well as
measures from funding and projects related to school health.
Physical Education and Activity Policy Indicators
Daily Physical Education Required
Minutes of Physical Education Required
Minutes of Physical Activity Required or Recommended
Certification Requirements for Physical Education Teachers
Safe Walking or Biking Language
Prohibiting Waivers from Physical Education
Graduation Requirements for Physical Education
Prohibiting Using Physical Activity as Punishment or Taking Time from Physical Education
Recess Before lunch

Nutrition Policy Indicators

Prohibiting Marketing or Advertising Unhealthy Foods
Requiring Lower Pricing of Healthy Foods
Providing Nutrition Education or Nutritional Content Information
Requiring Water Availability or Other Beverage Requirements
Requiring or Promoting Healthy Celebrations and Rewards
Requiring Healthy Fundraising or Concessions
Requiring a Minimum Amount of Time to Eat
School Gardens or Farm to School Efforts
Universal Breakfast or Breakfast In The Classroom

Other Indicators
Monitoring Of The LWP
Date Of Last LWP Update
Graduation Requirement For Health Education

Key Findings
These are informal findings from the review and scan of 41 Colorado school districts. Four districts had no policies
available online, thus percentages are based on the 37 districts with policies available for review.

Requirements for Daily Physical Education or Specific Minutes of Physical Education- Five of districts
( ~13%) that were reviewed included language that required or encouraged specific minutes of physical
education and two districts included some language on daily physical education (or an equivalency) in the
policies reviewed.

Language example:
All students in grades K-12, including students with disabilities, special health-care needs, and in
alternative educational settings, will receive daily physical education (or its equivalent of 600
minutes/month for elementary school and middle and high school students) for the entire school year.

Policy related to CRS 22-32-136.5 (HB11-1069- Physical Activity)- Of the districts reviewed,
approximately 73% had a specific policy for physical activity related to state statute which requires
elementary schools to provide opportunities for at least 600 minutes of physical activity per month. These
districts may have had a standalone physical activity policy (often coded as JLJ in policy materials) or this
policy was incorporated in the LWP. Ten districts had no specific physical activity policy and related
language was not found in other policies reviewed. However, the reference for this policy may have been
included elsewhere in district policies. A number of districts also include a basic Physical Education policy
(often coded as IHAE)- however these policies did not include specific language on minutes, minimum
amount of time or qualifications of instructors, but mostly states the importance of physical education as
well as the following type of language:
Provide adequate funds for facilities, equipment, personnel, and supplies within the District's financial
ability to support the Districts physical education program. The Board also recognizes the need to balance
available funds among all areas of the curriculum. The Superintendent (or designee) shall develop a
coordinated physical education program that is aligned with State and District physical education
standards. Daily physical education and/or physical fitness activities shall be provided for all students,
including those with special medical or physical needs.

Minutes of Physical Activity (including Recess) Required or Recommended- Nearly 60% of the districts
reviewed included language that required or encouraged specific minutes of physical activity in their
policies in addition to their physical activity policy. Many of those districts included some language
around offering for recess.
Language examples:
A minimum of 20 minutes of recess shall be provided in the morning or afternoon, and a minimum of 20
minutes of recess shall be provided prior to lunchtime whenever possible.
A requirement that periods of physical activity be at least 180 minutes per week for elementary students
and at least 225 minutes per week for secondary students.

Physical Education Teacher Qualifications- Seven districts were found to have some language requiring or
encouraging criteria for physical education staff. Two districts indicated that physical education teachers
should meet the criteria for highly qualified teachers (which typically applies to core subjects and
includes holding a degree, being fully licensed and demonstrating subject matter competency). The other
five districts encouraged staff qualifications.
Language example:
Ensure that all physical education and health education teachers meet the criteria for highly qualified as
specified in Colorado statute.

Safe Walking and Biking- Nearly 30% of the districts reviewed had some language about walking or biking
to school. Most language found encouraged walking or biking such as:
"Encourage schools to work with the community to create ways for students to walk, bike, rollerblade
or skateboard safely to and from school."

"The promotion of walking or bicycling to and from school using programs such as Walking School Bus
and Bike Train."

The school district will work with local public works and public safety to assess the need to make
improvements to school routes to make them safe for students to walk or bike to school. Where safe
and feasible, schools should encourage students to walk or bike to school."

Prohibiting Waivers And Exemptions for Physical Education- No districts had specific language that
explicitly prohibited waivers or exemptions for physical education class. When reviewing graduation
requirements, many did not specifically outline the process for waivers, however language on exemptions
was occasionally found: An equivalent (for physical education credit) shall exempt the student from this
requirement. Equivalents shall include: Citywide Marching Band, ROTC, Athletics.

Prohibiting using Physical Activity as Punishment or Taking Physical Education Away as PunishmentTwelve districts or just over 32% were found to have some language around prohibiting using physical
activity or education as a punishment.
Language examples:
Physical activity shall not be imposed nor taken away as a form of punishment for students. For example, a
student shall not be required to run extra laps or do extra push-ups as a result of poor conduct or
academic performance, nor shall recess or Physical Education be taken away from a student as a
punishment.
A requirement that physical activity is not used (e.g., running laps) or withheld (e.g., recess, physical
education) as punishment.

Recess Before Lunch- Approximately 46% of the districts reviewed included some language about offering
recess before lunch. Often this was an encouragement to allow for scheduling needs in schools, however,
some language was more specific.
Language examples:
During the lunch period, when possible, recess will be scheduled prior to lunch, to promote meal
enjoyment, meal participation and consumption, waste reduction, and mental acuity.
A consideration that the school schedule support the implementation of recess before lunch, an evidenced
based practice that studies show results in better student performance and enhanced nutrition.

Competitive Foods- All districts had some language about foods that compete with the school meal
program. However, the language and specificity of this language varied greatly. More work will be done
with schools in 2014-15 to address federal requirements for Smart Snacks in Schools and with Colorado-

specific laws and rules on competitive foods. A number of school also included policy related to the
Healthy Beverage Law, however, further review of the beverage policy could be completed.

Advertising and Marketing of Unhealthy Foods and Pricing of Unhealthy Food- Only two districts
included any language related to restrictions or limitations on marketing of unhealthy foods. No districts
had policy language that required higher pricing for unhealthy foods or lower pricing of healthier items.
One example of policy language indicated: Marketing and advertising of non-nutritious foods and
beverages as outlined in the IOM standards, through signage, vending machine fronts, logos, scoreboards,
school supplies, advertisements in school publications, incentive programs, or other means will be
prohibited where the school directly profits.

Requiring or Encouraging Nutrition Content or Information- About 40% of the districts required or
encouraged that nutrition information for the foods sold or be available. Some language also included a
requirement that students receive nutrition education in school- however, this was typically an
encouragement.

Providing Water on School Grounds- About 40% of the districts had language about ensuring that water
is available on school grounds throughout the day, such as policy language that states make water
available for students throughout the day.

School Parties, Celebrations and Rewards- Language related to foods at school parties, celebrations and
rewards was one of the most frequently identified areas addressed in policy. Nearly 73% of districts had
some language related to this indicator. About a third of these had strong to somewhat strong language in
their policies related to foods at such events.
Language example:
In order to avoid undermining the importance of healthful eating habits, non-food rewards and incentives
shall be used as the first choice to encourage positive behavior. If food is used as a reward, it must meet
the same guidelines as foods sold on the school campus, as defined in the Wellness and Physical Activity
and Nutritional Procedures available from Nutrition Services.- School and classroom celebrations shall
include a variety of foods, with an emphasis on fruits, vegetables, low-fat dairy and whole grains, to
provide students with the opportunity to choose a healthy option. A list of recommended party foods for
parents and staff will be accessible on the District website, and schools may determine if they would like to
develop further guidelines.

School Fundraising- Over 70% of the districts reviewed also included some language around fundraising
and the requirement or encouragement of healthy or non-food options. Although most districts
encouraged healthy fundraisers, such as schools should encourage fundraisers that promote positive
health habits such as the sale of non-food and nutritious food items. With the new requirements for
fundraisers with the Smart Snacks in Schools interim final rules, districts and schools will need to address
fundraisers that meet nutrition standards for foods sold during the school day (with some exemptions
based on the decisions of CDEs Office of School Nutrition).

Requiring a Minimum Amount of Time to Eat- Just under 50% of the districts had some language that
required or supported a minimum of time allocated for students to eat meals. A number of policies
included language such as: provide adequate time for students to eat (national recommendation of at

least 10 minutes for breakfast and 20 minutes for lunch from the time a student receives a meal).

School Gardens, Farm to School- Policies were also reviewed related to efforts to access fresh, local food.
Two districts had language around school gardens. No districts were found to specifically mention farm to
school efforts within their policies.

District Wellness Councils/Teams, Monitoring and Student Engagement- A small number of districts
had a separate policy related to their wellness council or team, however all districts with a local wellness
policy had some language related to the composition of the team; some also outlined the authority of the
team and how the policy is monitored. Many districts used standard model policy language to ensure
compliance with the federal requirements for the LWP such as: The district will establish and maintain a
district-wide Nutrition and Physical Activity Advisory Council. The purposes of the council shall be to
monitor and be proactive in the implementation of this policy, evaluate the districts progress on this
policys goals, serve as a resource to schools (i.e., provide lists of healthy incentives, snacks, etc.) and
recommend revisions to this policy as the council deems necessary and/or appropriate. A small number of
districts specifically mentioned ensuring student engagement in the policy and that was typically found
within the information about the composition of the council. Other specific language related to council
and monitoring include:
o Each principal shall designate a Wellness Monitor.
o Schools shall develop and maintain a school wellness team whose primary purpose is to support
and implement a comprehensive health and wellness environment by creating a yearly School
Health Improvement Plan (SHIP). School wellness teams should operate in accordance with the
Whole School, Whole Community, Whole Child model.
o Each school shall submit and implement up to two wellness goals annually. The District Health
Advisory Council will support development and implementation of these goals.

Physical Education and Health Education Requirements- 31 districts had graduation requirements for
Physical Education outlined in their graduation requirements (often coded as IFK in policy resources).
However, one of those districts is ending this requirement with the class of 2019. Of the 41 districts, two
districts had no requirement for physical education for graduation and the remaining eight districts had
no information available online. There is not a uniform system in the state related to how credits or
hours are earned or a common standard for a credit (thus the number and value range across districts).
The most frequently found credit requirement was 1.0 credit; however, the requirements for that 1.0
credit vary and would need to be reviewed at the district level to determine actual student requirements.
For Health Education, 21 of the 41 districts indicated some level of requirement for graduation, with one
district ending that requirement in future years. Twelve districts had no requirement for health education
and eight had no information available.

Policy Adoption Dates- The adoption dates and revision dates for each LWP were also reviewed. This was
reviewed to determine if the policy is being monitored to some degree. 36 of the 41 districts indicated a
date of last revision and of those districts:
o 19% (7 districts) updated between 2006-2009 (with 6 of the districts not updating since 2006)
o 58% (21 districts) updated between 2010-2012
o 22% (8 districts) updated between 2013-2014

Conclusions and Next Steps

In summary, CDPHE conducted an informal review of 41 district policies to identify baselines for performance
measures, but expanded the review to understand policies that impact at least 80% of Colorados student
population. This review provides significant information to support future Local Wellness Policy trainings and to
provide example language and resources for policy development, implementation and technical assistance to
districts related to creating polices for supportive nutrition environments and implementation of physical
education and activity in schools.
For next steps, regular systematic reviews of policies may be considered in addition to the Administrative Review
(AR) conducted by the Colorado Department of Education- Office of School Nutrition. Also, partners may want to
expand the policy reviews to include other health priorities and topics, including social/emotional wellness, mental
health, bullying prevention, tobacco, marijuana, health education, student involvement, parent involvement, nondiscrimination policies, etc. Colorado will also benefit from the Colorado Healthy Schools Smart Source effort,
which is working to measure policies and practices at the school level. The Smart Source may provide more
information about school-level knowledge and implementation of such policies, since we know that, although the
district may have a policy, it is only effective if it is well implemented and measured.
For more information, please contact Amy Dillon at 303-692-2398 or amy.dillon@state.co.us.

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