Unhealthy eating patterns and sedentary lifestyles have been identified as important drivers of increases in the prevalence of obesity¹ and the increasing rates of diet-related chronic disease among Americans.^2–5 Combining individual interventions with population and policy approaches^1,6 could amplify public and individual-level benefits.

One way to help create healthier food environment is by using food or nutrition standards, such as those defined in the Food Service Guidelines for Federal Facilities (FSG).⁷ FSG are applicable to foods and beverages sold or offered through cafeterias, micro-markets, and vending machines in settings such as worksites, trade schools and universities, public agency or government buildings, and local park and recreation centers. The FSG is a model set of guidelines that can be used or adapted in many settings and with 4 primary goals to: (1) increase the availability of healthier food and beverage options such as improving access to fruits, vegetables, whole grain products, and reducing amounts of added sugars (aligned with the Dietary Guidelines for Americans⁸); (2) promote healthier options through behavioral design strategies such as pricing, placement, and promotion; (3) adhere to food safety protocols that minimize foodborne illness; and (4) foster use of food service practices that promote facility efficiency and support the local food system including farmers and producers. Thus, FSG can provide community worksites and anchor institutions with a comprehensive set of nutrition standards to improve availability of healthier food in public settings through public procurement mechanisms and food service offerings.

Since the release of the initial federal FSG standards in 2011, there has been a noted increase in the use of FSG as a strategy to improve food environments at state^9–12 and local^13–17 levels. At the local level, city councils, composed of elected officials, are the primary governmental entity responsible for promulgating legislation (e.g., ordinance, code, etc.).¹⁸ Research shows that FSG policies are more prevalent in larger municipalities,¹⁹ increasing the opportunity to have far reaching public health impact among municipal residents.²⁰

In a previous FSG municipal-level policy study, authors examined attributes of local-level FSG policies enacted through 2016.¹⁷ Authors identified 6 FSG policies adopted in 5 cities: New York City, NY, Philadelphia, PA, Austin, TX, San Francisco, CA (2 policies), and Seattle, WA. The present study expands on that research, by identifying, describing, and quantifying local FSG policies adopted 2017–2023, and assessing the presence, content, and gaps of FSG policies. Policy attributes across 3 FSG domains were analyzed: (1) nutrition standards; (2) behavioral design; and (3) facility efficiency; as well as the construct of implementation supports included in policy language. Tracking uptake of FSG policies can help researchers better understand the evolution of policy attributes, and the potential population impact over time.

Our search of primary and secondary data sources identified 1934 (839 + 1095) policies with 7 policies meeting inclusion criteria (Figure 1). Exclusions primarily resulted from a policy’s focus on (1) food safety, handling, permitting, and licensing of food vendors; (2) zoning codes for food establishments; and (3) food served or sold to youth in school or childcare.

From 2017 to 2023, 6 cities adopted new FSG policies that met study inclusion criteria, 1) New York City, NY, 2) Chicago, IL, 3) Philadelphia, PA, 4) San Antonio, TX, 5) Columbus, OH, and 6) Denver, CO. Any policies adopted prior to 2017 were not included in the 2017–2023 time period. These cities enacted FSG policies that affected the nutritional quality of foods and beverages procured, sold, or served in various community settings, including government worksites (n = 3) and food retail venues (n = 3). One city adopted a policy that established a Food Equity Task Force to create a local food system that ensures access to healthy and affordable food using the Good Food Purchasing Program,²⁴ which uses FSG as the gold standard. The most common policy vehicle was the EO (n = 3), followed by city code (n = 2); city ordinance (n = 1); and Administrative Directive (n = 1). The FSG Comprehensive Scores for these policies ranged from 6% to 71%, with 2 policies scoring higher than 51% (Table 1). Table 1 presents the 7 enacted FSG policies and describes their policy attributes and percent alignment across the 3 FSG domains: (1) nutrition standards; (2) behavioral design; (3) facility efficiency; and the construct of implementation supports.

This study provides an update of municipal-level FSG policies adopted in the 20 most populous U.S. cities while also quantifying FSG policy attributes. An additional 7 FSG policies were adopted between 2017 and 2023 across 6 cities, 4 of them new since the previous study.¹⁷ Overall nutrition domain and implementation support construct attributes were included more frequently than behavioral design or facility efficiency domain attributes, suggesting there may be common policy attributes to facilitate policy adoption, while other attributes may be more challenging for adoption.

In the previous study, 3 of the policies required healthier offerings in vending machines, 2 set standards for healthy food procurement (food and beverages purchased, prepared, or served by city agencies), and 1 was for an FSG task force.¹⁷ Additionally, 5 of 6 policies in the prior study met a majority of FSG attributes in the classification tool (51% or greater), whereas in the current study, only 2 of 7 policies met a majority. This decrease in the number of policies meeting a majority of criteria is partially explained by 3 policies having identical intent and associated language for limiting selection of beverages as part of children’s meals in food service establishments. Although these policies did not score well across any of the domains, and thus cannot be considered comprehensive, the policies—which attempt to decrease children’s consumption of sugar-sweetened beverages, the primary source of added sugar in children’s diets,²⁵ and a contributor to increased prevalence of obesity²⁶—are far reaching in applying to all food service establishments, including government buildings and restaurant settings. The extensive, population-level reach of these 3 policies is not captured in the FSG Tool.

Two cities, NYC and Philadelphia, enacted multiple FSG policies in the current (2017–2023) and previous (through 2016) surveillance periods. As of 2023, Philadelphia adopted 2 FSG policies, and NYC adopted 3. The Philadelphia FSG policy (EO 4–14 adopted in 2014 and updated in 2022²⁷) affects the nutritional quality of an estimated 20 million meals served each year, while the NYC policy EO 8 affects²⁸ all city agencies that purchase, prepare, and serve or sell meals and snacks. The NYC policy language stipulates that the standards be routinely reviewed to ensure alignment to current nutrition science in the updated DGA (2020–2025). And both FSG policies identify the Public Health Department (PHD) as a source of ongoing technical assistance. The PHD also provides online training modules tailored to meet the needs of city food procurement staff, food service managers, and those who develop menus and serve food. Such policy implementation supports—and regular assessments of the nutrition standards, as included in the FSG tool—may contribute to better implementation outcomes and eventual public health impact. Another factor that may support the acceptability of healthier offerings in certain city buildings is acknowledgement and availability of cultural food offerings. “City departments should be open to participant’s feedback on the food that is served and provide opportunities for choice and cultural and religious food preferences.”.²⁷

It may take an extended time for a jurisdiction not only to adopt a policy, but also to ensure implementation and sustainability of the policy; yet these steps are essential to ensure the policy is fulfilling its intended goals.^29,30 Although this study did not verify an adopted policy’s implementation, implementation supports aimed at facilitating adoption were assessed in the FSG Tool. Five of the 6 policies in the previous study scored 51% or higher in this category, compared with only 1 of the 7 policies in the current study. Despite this, every policy in the current study cited a government body to oversee implementation. Only 1 policy, San Antonio, requires training and/or education for staff and/or vendors. Although no policies included city or local funding for implementation supports (e.g., training, enforcement), it is notable that San Antonio was a previous recipient of funds from CDC’s Division of Nutrition, Physical Activity, and Obesity (DNPAO), which included FSG implementation as a supported strategy.³¹

Our search identified policies related to facility efficiency, though the policies were excluded because they did not include nutrition standards and thus did not meet inclusion criteria. Facility efficiency and food safety standards may be included in separate, non-FSG-related policies^7,17 and it was outside the scope of this FSG-focused study to apply search terms to systematically identify all such policies.

There are some limitations to this study. This analysis was limited to enacted local ordinances, EOs, and administrative policies in the 20 most populous cities in the U.S. Oklahoma City was not included in the previous study as it was not one of the 20 largest cities. Instead, the previous study included El Paso, TX. Municode searches revealed no new policies for El Paso, nor did a search of the El Paso city clerk website (as a verification step). This finding supports consistency in monitoring FSG policies over time. Although FSG policies may fall under other policy types, and municipalities’ policy types may differ, the policy types included are those most commonly codified by a city. Although we (1) used one municipal legal code database, and (2) searched all 20 city clerk websites and secondary sources, some existing FSG policies may have been missed due to source variability in archiving city codes—including current vs historic codes—and due to variability in how cities document their city codes. Additionally, county and/or state governments may apply FSG policies to local jurisdictions, yet we did not search for or identify those policies because this study’s focus was city-level policy adoption. Finally, the FSG tool represents standards within domains that may not include every element needed to determine a policy’s comprehensiveness.

Despite these possible limitations, this analysis of local FSG policies extends previous work examining local and state FSG policies.^9,12,17 Using the previous studies’ FSG tool and methods strengthens the methodology for coding/policy interpretation across multiple coders and maximizes consistent FSG policy monitoring over time. Additionally, this study captured innovations to highlight areas in which policies may not have been formally coded or credited for certain FSG-related policy attributes.

Large cities are continuing to enact FSG policies. However, some policies address FSG components more effectively than others. Additional cities can consider adding more FSG components to policies to more comprehensively align with FSG. Such policies are a population-level strategy to improve food environments and help address diet related health conditions for more Americans. Future studies might explore why some cities have adopted FSG policies while others have not, and what shared characteristics (such as socioeconomic, demographic etc.) distinguish adopters from non-adopters among these largest cities. Other future studies might assess the impact of the FSG policy’s implementation on individual and/or population health outcomes.

Supplemental material for this article is available online.