National School Lunch Program (NSLP) and School Breakfast Program (SBP) Meal Pattern Advisory

To:	Child Nutrition Program Operators
From:	Robert M. Leshin, Director Office for Food and Nutrition Programs (FNP)
Date:	July 20, 2018

On April 25, 2016, the U.S. Department of Agriculture's (USDA) Food and Nutrition Service (FNS) published the final rule "Child and Adult Care Food Program: Meal Pattern Revisions Related to the Healthy, Hunger-Free Kids Act of 2010". This final rule also updated the National School Lunch Program's and School Breakfast Program's meal pattern requirements for infants and preschoolers under 7 CFR 210.10 and 220.8.

While many of the changes to the infant and preschool meal patterns make them more consistent with the requirements for older grade groups (K through 12th grade), some of the meal pattern requirements for infants and preschoolers are different. The Office for Food and Nutrition Programs (FNP) is providing guidance to assist School Food Authorities (SFA) to meet these requirements for FY19 (July 1, 2018):

Effective July 1, 2018, the new CACFP Meal Pattern must be followed for students up to age four
If students are co-mingled with other K-5 age/grade groups, a single menu is allowed when preschoolers and K-5 students are in the same service area at the same time.
The final rule clarifies that when a 5-year-old is in preschool or a 4-year-old is in kindergarten, the school food authority (SFA) may continue to serve the meal pattern appropriate for that grade.

Infant Meal Pattern — USDA Guidance and Regulation

The updated infant meal patterns for lunch and afterschool snack are established under 7 CFR 210.10(q) and (o)(4), respectively. The updated infant meal pattern for breakfast is established under 7 CFR 220.8(p). Please refer to the attached Appendix A. The infant meal pattern requirements in the School Meal Programs are the same as the infant meal pattern requirements in the Child and Adult Care Food Program (CACFP) under 7 CFR 226.20(b). Schools serving meals or afterschool snacks to infants should refer to memorandum CACFP 02-2018, Feeding Infants and Meal Pattern Requirements in the Child and Adult Care Food Program; Questions and Answers* for additional guidance. The memorandum describes the requirements for creditable infant formula, breastfeeding on-site, serving solid foods, parent or guardian provided components, and offers a comprehensive list of questions and answers. All of the requirements outlined in CACFP 02-2018 apply to schools serving meals and snacks to infants.

Pre-K CACFP Meal Pattern — USDA Guidance and Regulation

The following information and charts found in Appendix B, provide general information including the portion size requirements for each food component for pre-K students for NSLP and SBPs.

Less Added Sugar

Yogurt must contain no more than 23 grams of sugar per 6 ounces; and
Breakfast cereals must contain no more than 6 grams of sugar per dry ounce.

Vegetables and Fruits

The combined fruit and vegetable component is now a separate vegetable component and a separate fruit component; and
Juice is limited to once per day.

Whole Grains

At least one serving of grains per day must be whole grain-rich;
Grain-based desserts no longer count towards the grain component; and
Ounce equivalents (oz. eq) are used to determine the amount of creditable grains (starting October 1, 2019).

Protein Options

Meat and meat alternates may be served in place of the entire grains component at breakfast a maximum of three times per week; and
Tofu counts as a meat alternate.

Fluid Milk

Unflavored low fat or fat-free milk must be served to children in preschool; unflavored whole milk must be served to 1 year olds.
Non-dairy milk substitutes that are nutritionally equivalent to milk may be served in place of milk to children or adults with medical or special dietary needs; and

FNS recognizes that when schools are serving preschoolers at the same time as older children (i.e., grades are co- mingled), adhering to two different meal patterns may be operationally challenging. For example, it may be difficult to distinguish preschoolers from slightly older children, resulting in counting and claiming issues. In addition, providing the correct foods and portion sizes on the serving line for two different meal patterns may be logistically difficult.

Schools that serve meals to preschoolers and K-5 students in the same service area at the same time can either follow the grade-appropriate meal patterns for each age group, or serve the K-5 meal pattern under NSLP (7 CFR 210.10 and 220.8) for both grade groups.

FNP's policies for School Food Authorities (SFA) following the Pre-K CACFP Meal Pattern:

USDA defines sweet crackers as graham crackers-all shapes, including animal crackers. Due to the higher, added sugar content, FNP's policy will permit the serving of sweet crackers, at snack service only limited to no more than twice per week.
A combination food is a single serving of a food item that contains more than one food item from different food components that cannot be separated, such as pizza, soup, casseroles, burritos and sandwiches. Some combination foods may be credited for up to three (3) different food components (meat/meat alternate, grains/bread, vegetable or fruit).
- Snack or party mixes and trail mixes are snack food mixtures with a variety of items including nuts, dried fruit seeds and cereal. These cannot be credited unless the menu documents the portions of the creditable ingredients. Please refer to FNP's policy restricting the serving of food items for young children under 4 years of age.
Fruit and nut bars (without grains) can be credited, with documentation based on a) volume of dried fruit meeting the minimum serving size by age group or b) meet the meat alternate serving for peanuts, soy nuts, pine nuts, tree nuts and seeds. Additionally, nuts and seeds may be credited to meet no more than 50% (half) of the meat alternate requirement at a meal (breakfast, lunch or supper). This smaller portion size must be supplemented with another meat or meat alternate to meet at least the minimum portion size required by age and meal pattern requirement. Please refer to FNP's policy restricting the serving of food items for young children under 4 years of age.
The serving size of peanut/nut butters is 3 tablespoons for children ages 3 to 5 to meet the minimum portion size. Due to the choking hazard of nut butters, FNP's policy will permit a serving size that does not exceed 50% (half) of the meat alternate serving size for a preschool child between the ages of 4 years and 5 years of age. This smaller portion size must be supplemented with another meat or meat alternate to meet at least the minimum portion size required by age and meal pattern requirement.

Co-Mingled Preschool Meals — USDA Guidance and Regulation

USDA allows flexibility in the pre-K meal pattern for SFAs that are serving meals to pre-K students in the same service area at the same time as older age/grade groups. With this flexibility, SFAs may serve the pre-K students the same meal pattern as the kindergarten students at the meal service. The flexibility to use comingling is based on the SFAs ability to identify the age/grade groups of the students and the amount of time to serve the meals. However, USDA encourages SFAs to evaluate a variety of serving strategies that will allow them to serve the pre- K meal pattern to pre-K students before utilizing this flexibility.

The presence of pre-K students in the dining area at the same time as older students does not mean that the meal service is comingled. The SFA must still consider the ability to distinguish age/grade groups and if there is reasonable time or opportunity to change the service line. SFAs may also find that there is a comingled serving situation at one meal service and not another.

Before adopting this flexibility, the SFA must consider the following:

Can the pre-K class or group of pre-K students be reasonably distinguished in the service line?
Is there sufficient time to serve the pre-K students the pre-K meal pattern before older students are served?

Serving Options That Are NOT Considered to Be Comingled When:

The pre-K student is easily distinguishable, and there is time and opportunity to serve the appropriate pre-K meal pattern, the pre-K meal pattern must be used.

For Example:

Pre-K students are served and consume breakfast in the classroom. In this situation, pre-K students are served the pre-K meal pattern.
Pre-K students pick up a grab-n-go meal in an area of the building dedicated to pre-K students. In this situation, pre-K students are served the pre-K meal pattern.

Serving Options That May Be Considered to Be Comingled When:

The pre-K student is not easily distinguishable, and there is not time or opportunity to change the service line set up for different age/grade groups, the SFA may use the meal pattern that is used for kindergarten students at that meal service. For breakfast, the age/grade groups are K-5, K-8, or K-12; for lunch, K-5 or K-8.

For Example:

Pre-K students pick up a grab-n-go meal in the cafeteria where students of all age/grade groups pick up a grab-n-go meal. In this situation, pre-K students may be served the kindergarten meal pattern.
Pre-K students go through the cafeteria line and are intermingled with older students or are served in a fashion where pre-K classes alternate with older age/grade group classes. In this situation, pre-K students may be served the kindergarten meal pattern.

Information and guidance is in USDA's memorandum SP 37-2017, Flexibility for Co-Mingled Preschool Meals; Questions and Answers.

If you have any questions or need further assistance, please contact FNP at 781-338-6480 or email: nutrition@doe.mass.edu .

Enclosed:

This institution is an equal opportunity provider.

Last Updated: July 23, 2018