Food and Nutrition Programs

Meal Pattern Variation for Faith-Based/Religious Observance

The Massachusetts Department of Elementary and Secondary Education's Office for Food and Nutrition Programs (FNP), in concert with the United States Department of Agriculture (USDA)'s priority to advance nutrition security in an equitable way that supports resilient, sustainable food systems, annually submits a USDA waiver request to allow for additional flexibilities to federal guidance outlined in "Variations in Meal Requirements for Religious Reasons: Jewish Schools, Institutions and Sponsors". This waiver expands on existing flexibilities available for students requesting menu modifications due to faith-based/religious observance by requesting non-congregate meal service for students who observe fasting during Ramadan. School Food Authorities operating the National School Lunch Program (NSLP) and the School Breakfast Program (SBP); institutions and their facilities participating in the Child and Adult Care Food Program (CACFP); and sponsors and sites in the Summer Food Service Program (SFSP), collectively referred to as "Sponsors," must notify FNP of their intent to serve variations of meal requirements for enrolled program participants requesting kosher meals or observe fasting during Ramadan. All program participants receiving a meal pattern or congregate requirement variation must be enrolled in the Child Nutrition Program and be in attendance at the time of meal service. For review purposes, Sponsors must maintain a record of all approved meal requirements and point-of-service variations, clearly outlining the production of modified meals and alternative point-of-service practices.

Sponsors intending to offer meal pattern variations to accommodate requests for kosher meals or provide non-congregate meal service during Ramadan must disclose their intentions by emailing their DESE consultant to request the web-based form "Meal Pattern Variation Request—Religious Reasons" be added to their compliance packet. After completing and submitting the form, the sponsor is able to use the flexibilities they have elected.

No further action is needed if a Sponsor does not intend to use these flexibilities.

Food Component-Based Dietary Restriction

Sponsors may make approved nutritional or food component-based menu variations to meet the needs of a program participant unable to consume menued meal options due to faith-based or religious observance. Sponsors should implement cross-contamination prevention best practices when accommodating faith-based or religious dietary restrictions to ensure meals prepared with these restrictions maintain their integrity. Food component-based dietary variations include:

Kosher

Kosher, meaning "fit" or "proper" in Hebrew, is typically used to describe a dietary framework for food preparation, processing, and consumption observed by some Jews in observance of Judaism. Kosher diets may require a kosher certification on beef, poultry, fish, fish products, and other animal meats, as well as any product that has been processed and/or packaged to be consumed. Usually, kosher products will not contain meat and dairy ingredients, as kosher guidelines generally forbid pairing meat and dairy. Fish, eggs, and plant-based foods are usually considered neutral (neither meat nor dairy) and may be eaten with either meat or dairy options. Additionally, in most cases, pork and shellfish products are not permitted in a kosher diet.

Please refer to the flexibilities outlined in 783-13 Rev. 3, Variations in Meal Requirements for Religious Reasons; Jewish Schools, Institutions, and Sponsors, as outlined below. Sponsors must notify FNP by submitting a request form if any of the following alternative options are used. Sponsors must also maintain a record of all approved meal requirement variations for review purposes.

• Fluid (Cow's) Milk at meals containing meat or poultry when participants do not have the opportunity to refuse the milk or meat/poultry through Offer vs. Serve:
  Sponsors may choose one of the four options:

  1. Serve an equal amount of non-dairy milk substitute (for medical or special dietary needs) that is nutritionally equivalent to fluid milk as per 7 CFR 210.10 (m). If you have questions about what types of milk will qualify, please reach out to FNP (nutrition@doe.mass.edu ) for assistance.

  2. Serve an equal amount of full-strength juice in place of milk with lunch or supper. When juice is substituted for milk, it may not contribute to the vegetable/fruit requirement. Entities operating five days per week may substitute juice for milk twice per week for lunches and twice for suppers, but no more than once each day. Those operating seven days per week may make three substitutions per week for lunches and three for suppers, but no more than one each day.

  3. Serve milk at an appropriate time before or after the meal service period, in accordance with applicable Jewish Dietary Law.

  4. If planning to serve juice at snack, serve the snack's juice component at breakfast, lunch or supper, and serve the corresponding meal's milk component as part of the snack.

  Milk must be offered or served in other meals according to USDA regulations since Jewish Dietary Laws allow other meat alternatives (e.g., fish, egg, beans and peas, nuts and seeds and their butters) to be consumed with milk at the same meal. Since meal service can look different at each facility, sponsors will be required to indicate the selected option at each site requesting a meal requirement variation.

• Dark Green Vegetables: Sponsors serving the NSLP meal pattern only
  Jewish Dietary law poses challenges to serving the dark green vegetable subgroup as required in the NSLP. Sponsors who are required to or have elected to serve the NSLP meal pattern, facing this challenge, may be exempt from the requirement to serve the dark green vegetable subgroup but must serve the same total amount of vegetables. The vegetables served instead of dark green vegetables must come from the red/orange or beans/peas subgroups.

Halal

Halal, meaning "permissible" or "allowed" in Arabic, is typically used to describe a dietary framework for food preparation, processing, and consumption observed by some Muslims in observance of Islam. Halal diets usually do not permit pork products, alcohol and products that contain alcohol, or products containing ingredients that use non-halal animal-derived products. For example, some cheese products use an ingredient called rennet derived from an animal. Therefore, the cheese may not be acceptable to halal-observant communities.

Variations made to accommodate a halal diet should follow all USDA meal pattern requirements and, as such, do not require sponsors to notify FNP by submitting a request form.

Faith-Based or Religious Day Dietary Restriction

Sponsors may make approved service-based and nutritional or food component-based menu variations to meet the needs of an enrolled participant and accommodate a faith-based or religious observance day or series of days. Specifically:

• Whole Grains During Passover:
  During the observance of Passover, Sponsoring Organizations/SFAs may be exempted from the enrichment and whole grain portions of the child nutrition program grain requirements. Un-enriched matzo may be substituted for the grain requirement during that period of time only. At all other times of the year, matzo served as the grain component must be whole grain rich, whole grain, or enriched in accordance with the specific regulatory meal pattern requirements operated under in the particular program.

• Non-congregate, Adjusted Meal Service Schedule Time During Ramadan:
  During Ramadan, sponsors may serve meals in a non-congregate setting to participants attending school/care and fasting. Ramadan is observed over a 30-day period that can change each year. These dates may differ slightly among communities-defer FNP's current waiver for dates USDA has approved for non-congregate meal service.

If you have questions about the process of expressing intent to offer meal requirement variations for religious reasons or for best practices for providing Kosher or Halah meals, contact nutrition@doe.mass.edu.