School Nutrition Programs Compliance Handbook

School Nutrition Programs Compliance Handbook

Chapter 2 - Meal Planning and Production

DIETARY GUIDELINES FOR AMERICANS

The Healthy, Hunger-Free Kids Act of 2010 requires the National School Lunch and School Breakfast Program to require School Food Authorities (SFA) to provide meals that comply with the Dietary Guidelines for   Americans (DGAs) as required by Sections 4(b0 and 9(a)(4) of the Richard B. Russell National School Lunch Act.  These changes in the law require SFAs to provide healthier meals.  Changes are based on the recommendations of the Institute of Medicine of the National Academies and are expected to enhance the diet and health of school children and help reduce obesity. 

All SFAs must to offer or serve a food-based meal pattern assigned to a grade group.  The requirements assign: minimum serving sizes on grains, meat and meat alternates, milk, fruit, and vegetables; assigns weekly maximum and minimum calories; limits saturated fat and sodium; and eliminates trans-fat.   Additionally, schools are required to increase the availability of fruits and vegetables subgroups, whole grains, and limit the types of milk served to low-fat and fat-free.  Table 1 lists the meal pattern requirements based on grade groups for both breakfast, and lunch and lists the minimum daily serving sizes and maximums weekly serving sizes for each meal component. 

In addition to following to the meal patterns when serving a reimbursable lunch, schools and Residential Child Care Institutions (RCCIs) are also required to provide healthier breakfasts, snacks, and a la carte items, consisting of the required meal components.  Additional foods items may be sold during the school day if they comply with required fat, calorie, and sodium requirements.

         

FINAL RULE FOR CHILD NUTRITION (CN) PROGRAMS: MEAL PATTERNS CONSISTENT WITH THE 2020 – 2025 DIETARY GUIDELINES FOR AMERICANS

On April 25, 2024, the USDA published the final rule for CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans.  This section will cover the changes this final rule made.

Milk

The final rule made the use of low-fat (1%) flavored milk a permanent part of the meal patterns for the National School Lunch Program (NSLP) and the School Breakfast Program (SBP).   

Both NSLP and SBP meal patterns require SFAs to serve two varieties of milk, one of which must be unflavored.  SFAs must select the variety offered from the following:

·       Fat free unflavored milk

·       Fat free flavored milk

·       Low fat (1%) unflavored milk

·       Low fat (1%) flavored milk

The final rule [CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] made no changes for to the process to request fluid milk substitutes for non-disability reasons.  Milk substitutes for non-disability reasons continue to require the following nutrition requirements be met:

 

Final Rule Table 1: Nutrition Requirements for Fluid Milk Substitutes
Nutrient	Per Cup (8 fl. oz.)
Calcium	276 mg.
Protein	8 g
Vitamin A	150 mcg. Retinol Activity Equivalents (RAE)
Vitamin D	2.5 mcg.
Magnesium	24 mg.
Phosphorous	222 mg.
Potassium	349 mg.
Riboflavin	0.44 mg.
Vitamin B-12	1.1 mcg.

Whole Grain-Rich (WGR)

The final rule [CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] maintained at least 80% of the weekly bread/grain servings be Whole Grain-Rich (WGR) for the NSLP and SBP meal patterns.  SFAs must meet the remaining bread/grain servings with enriched bread/grain items. 

For an item to be WGR (using USDA guidelines), the first ingredient must be a whole grain.  Only water may proceed the whole grain on the ingredient list for an item to be WGR.

For more information on WGR products see the USDA Tip Sheet “Crediting Grains in the Child Nutrition Programs,” and check out the USDA “Whole Grain Resource for the National School Lunch and School Breakfast Programs.”  You may request these USDA resources from Oklahoma Human Services (OKHS) School Nutrition Programs (SNP) at AFS.School.Nutrition.Programs@okdhs.org.  

Added Sugar Limits

Beginning July 1, 2025, the final rule [for CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] will gradually place added sugar limits into the meal patterns for NSLP and SBP.

On July 1, 2025, product-based limits will be added to the meal patterns for the NSLP and SBP. The added sugar product-based limits going into effect are listed in final rule table 2.1.  Once these product-based limits become effective, SFAs must procure products compliant with the new added sugar limits.

 

 

Final Rule Table 2.1: Added Sugars Product Based Limits
Product Based Limits
Product	Limit	Implementation Date
Breakfast Cereals	·      No more than 6 grams of added sugars per dry ounce.	July 1, 2025
Yogurt	·       No more than 12 grams of added sugar per 6 ounces	July 1, 2025
Flavored Milk	·      No more than 10 grams of added sugars per 8 fluid ounces.	July 1, 2025

In school year 2027 – 2028, the final rule [for CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] implements additional limits for added sugars. The new added sugar limits are weekly limits for the NSLP and SBP meal patterns are listed in the final rule table 2.2.  Once the new added weekly sugar limits become effective on July 1, 2027, SFAs will need to work to bring their weekly menus into compliance.

 

Final Rule Table 2.2: Added Sugars Weekly Limits

Weekly Limits

·       Weekly limits must be implemented by July 1, 2027 o   Added sugars limited to less than 10% of calories per week in the National School Lunch Program. o   Added sugars limited to less than 10% of calories per week in the School Breakfast Program. *Weekly limits will be in addition to product-based limits

The USDA has a resource tilted “Reducing Added Sugars at School Breakfast” providing useful information for reducing added sugars.

Average Weekly Sodium Levels

The final rule [for CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] kept the average weekly sodium levels in place at the time of the rules published on April 25, 2024, for the NSLP and SBP through school year 2026 - 2027.  The NSLP meal patterns average weekly sodium levels effective through June 30, 2027, are listed in the final rule table 3.1.

 

Final Rule Table 3.1: NSLP Average Weekly Sodium (through June 30, 2027)
Age/Grade Group	Average Weekly Sodium in mg.
K – 5	< 1,110
6 – 8	< 1,225
9 – 12	< 1,280

The SBP meal patterns average weekly sodium levels effective through June 30, 2027, are listed in the final rule table 3.2.

 

Final Rule Table 3.2: SBP Average Weekly Sodium (through June 30, 2027)
Age/Grade Group	Average Weekly Sodium in mg.
K – 5	< 540
6 – 8	< 600
9 – 12	< 640

Beginning July 1, 2027, the average weekly sodium levels for the NSLP listed in table 3.3 will become effective.  Prior to this average weekly sodium level becoming effective, SFAs will need to work to reduce the sodium in their lunch menus.

 

Final Rule Table 3.3: NSLP Average Weekly Sodium Effective July 1, 2027
Age/Grade Group	Average Weekly Sodium in mg.
K – 5	< 935
6 – 8	< 1,035
9 – 12	< 1,080

Beginning July 1, 2027, the average weekly sodium levels for the SBP listed in the final rule table 3.4 will become effective.  Prior to this average weekly sodium level becoming effective, SFAs will need to work to reduce the sodium in their breakfast menus.

Final Rule Table 3.4: SBP Average Weekly Sodium Effective July 1, 2027
Age/Grade Group	Average Weekly Sodium in mg.
K – 5	< 485
6 – 8	< 535
9 – 12	< 570

Beans, Peas, Lentils Vegetable Subgroup

The final rule [for CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] changed the legume vegetables subgroup to the beans, peas, lentils vegetable subgroup (effective July 1, 2024).  There were no changes to the vegetables crediting toward this subgroup due to the final rule.

Beginning July 1, 2024, the final rule [for CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] also provides School Food Authorities (SFA) with the option to:

·       Count beans, peas, lentils offered as a meat/meat alternate at lunch to credit toward the weekly beans, peas, and lentils subgroup

o   Under this option, beans, peas, and lentils would only count toward one overall meal component (meat/meat alternate component or the vegetable component).

School Breakfast Program (SBP) – Grains & Meats/Meat Alternative Component

Effective July 1, 2024, the final rule – CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans:

·       Established a combined grains and meat/alternative meal component for the SBP meal patterns.

·       Removes the requirement of one ounce equivalent of grain be offered each day before meat/meat alternatives credit toward the bread grain serving.

·       School Food Authorities (SFA) may offer meat/alternatives, grains, or a combination of both in meeting the combined component requirement.

SBP – Substituting Vegetables for Fruits

The final rule [for CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] continues to allow SFAs to substitute vegetables for fruit in the SBP and makes the vegetable variety requirement simpler.

·       SFAs who offer vegetables at breakfast once a week can offer vegetables from any vegetable subgroup.  This includes vegetables from the starchy vegetable subgroup.

·       SFAs who offer vegetables more than once a week at breakfast must offer a variety of vegetables from at least two different vegetable subgroups.

Meal Modifications

The final rule [for CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] made changes for meal modifications for a child with a disability.

·       The final rule maintains a medical statement written by a healthcare professional authorized to write prescriptions under state law.

·       Beginning July 1, 2025, the USDA under the final rule authorizes registered dietitians to submit medical statements for disability meal modifications.  The final rule does not require the registered dietitian to have a state license.

Other Changes

Effective July 1, 2024, the final rule removes the dietary prohibition on synthetic trans-fats in the NSLP and SBP.

Beginning July 1, 2024, the final rule adds bean dip to the list of foods exempt from the total fat standard in the Smart Snack regulations.  The exemption applies to products marketed as humas, as well as other Smart Snack requirements.  With this change this provides SFAs with the option to sell bean dip as a Smart Snack

MEAL PLANNING

The Healthy, Hunger-Free Kids Act of 2010 has modified the types of foods and serving sizes that SFAs must offer for a reimbursable meal.  The required meal patterns for reimbursable meals requires schools to offer or serve five required food components for lunch, three required food components for breakfast, a variety fruits and vegetables throughout the week, 80% of all grain products must be whole grain rich products (the remaining serving met with enriched grain items), and low-fat (1%) or fat-free milk.  The weekly requirements must comply with nutrients standards such as low-fat, low-sodium, food items containing no trans-fat, and a weekly average calorie range.  Serving sizes are specified for each grade group.  See Table 1 for specific information on the meal pattern for both breakfast and lunch.   

Keep in mind the meal patterns for the NSLP and SBP are for two separate programs. 

For Example:  A SFA serves 100% fruit juice to meet the daily fruit component serving at breakfast, this serving does not contribute toward the percentage of 100% fruit juice used to meet the weekly lunch fruit component serving.   In this case the 100% fruit juice serving at breakfast would only contribute toward the percentage of the breakfast fruit component serving met using 100% fruit Juice.  Keep in mind, the meal patterns for the NSLP and the meal patterns for the SBP permit up to 50% of the weekly fruit component serving to be met using 100% fruit juice.

For lunch, the meal pattern consists of five specific food components:  1) fruits, 2) vegetables, 3) grains, 4) meat/meat alternates, and 5) fluid milk.  Food components required:  grains must be whole-grain rich (at least 80% of the weekly serving, the remaining up to 20% must be enriched), vegetables must consist of vegetable subgroups, and milk can only be 1% or fat-free.  All items should be low in sodium and saturated fat.  No trans-fat is allowed.  See specific requirements for each food components. 

For breakfast, the meal pattern consists of three different food components:  1) fruits, 2) grains and meats/meat alternates [established under the final rule (published on 04/25/24) for Child Nutrition (CN) programs consistent with 20 – 25 Dietary Guidelines for Americans], and 3) fluid milk.  Vegetables may also be offered in place of fruit.  See breakfast requirements for substituting a vegetable for fruit servings in the section discussing the final rule (for CN programs: Meal Patterns Consistent with the 2020 – 2025 Dietary Guidelines for Americans) at the beginning of this chapter. 

MEAL PATTERNS FOR SEPARATE AGE/GRADE GROUPS

Each school is required to serve the correct portion size, nutrient standards, and calories for each grade group.  For lunch, age/grade groups consist of K-5, 6-8, and 9-12.  The requirements for K-5 and 6-8 overlap slightly.  Therefore, if planned correctly, one menu can be served if the school is compliant with the nutrient standards for each grade group.  Grades 9-12 and cannot be modified to fit the needs of K-8 because larger serving sizes are required.  However, it is possible to plan a menu for K-12 and increase the portion size for high school students. 

Grades 9-12 is distinctive from the other grade groups due to its larger servings and calorie requirements; therefore, its menus must be planned to ensure that all requirements are met.  If a school is a K-12, schools may create a menu with the same menu components and items, but increase the fruit, vegetables, grains, and meats as required, ensuring that requirements are met. 

For breakfast, food portions for all age/grade groups overlap, a menu planner may offer the same food quantities to all children provided that the meal meets the requirements of each grade group.

If an SFA has infants and Pre-K students, contact Oklahoma Human Services SNP for the separate meal patterns.  There is some flexibility that allows Pre-K to be served the same menu as K-5 but serving sizes may be too large.  Infant menus must be created specifically for the age group. 

Table 1:  Meal Pattern Requirements for Breakfast and Lunch*
	Breakfast Meal Pattern			Lunch Meal Pattern
	Grades K-5	Grades 6-8	Grades 9-12	Grades K-5	Grades 6-8	Grades 9-12
Meal Pattern	Amount of Foodb Per Week (Minimum Per Day)
Fruits (cups)	5 (1)	5 (1)	5 (1)	2½ (½)	2½ (½)	5 (1)
Vegetables (cups)	0	0	0	3¾ (¾)	3¾ (¾)	5 (1)
Dark green	0	0	0	½	½	½
Red/Orange	0	0	0	¾	¾	1¼
Beans, Peas, Lentils	0	0	0	½	½	½
Starchy	0	0	0	½	½	½
Other	0	0	0	½	½	¾
Additional Veg to Reach Total	0	0	0	1	1	1½
Grains (oz eq)	7-10 (1)	8-10 (1)	9-10 (1)	8-9 (1)	8-10 (1)	10-12 (2)
Meats/Meat Alternates (oz eq)	Included with grains	Included with grains	Included with grains	8-10 (1)	9-10 (1)	10-12 (2)
Fluid milk (cups) l	5 (1)	5 (1)	5 (1)	5 (1)	5 (1)	5 (1)
Other Specifications: Daily Amount Based on the Average for a 5-Day Week
Min-max calories (kcal)	350-500	400-550	450-600	550-650	600-700	750-850
Saturated fat (% of total calories)	< 10	< 10	< 10	< 10	< 10	< 10
Sodium (mg)	< 540	< 600	< 640	< 1,110	< 1,225	< 1,280
Trans-fat	The final rule for Child Nutrition (CN) programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans published on April 25, 2024, removed the trans-fat prohibition for the NSLP meal patterns and SBP meal patterns beginning on July 1, 2024.

*The final rule for CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans published on April 25, 2024, begin to become effective on July 1, 2024.  See the final rule section at the beginning of this chapter for more information on the meal pattern changed made by the rule.

b: The weekly servings listed in table 1, are for a five-day week. Seven-day meal patterns are available by email at AFS.School.Nutrition.Programs@okdhs.org

1:  Fluid milk: Children are required to be offered at least two varieties of fluid milk from a choice of: fat free unflavored milk, fat free flavored milk, low-fat (1%) unflavored milk, low-fat (1%) flavored milk.  One of the offered varieties is required to be unflavored milk.

Note:  In order to comply with calorie restrictions, SFAs should not exceed the weekly maximums on serving sizes for meat/meat alternate, grains, and milk.  SFAs are not out of compliance for exceeding recommended serving sizes but may be out of compliance for exceeding average calorie, sodium level restrictions, and the weekly saturated fat percentage.

For RCCIs only:  There is one exception to the different grade/age meal patterns:  RCCIs can be allowed to serve one meal pattern to all grade groups if there is a safety concern.  Contact Oklahoma Human Services SNP for more information at AFS.School.Nurition.Programs@Okdhs.org.

FOOD COMPONENTS VERSUS FOOD ITEMS

Food components are the required foods that schools must serve to comply with the meal patterns for the National School Lunch Program and School Breakfast Program.  Food items are the number of food items offered or served. Offering several food items is no indication that the menu planned follows the required meal patterns for the NSLP and the SBP (see table 1 for the meal patterns). 

For lunch, these are the required 5 food components:

• meat/meat alternate
• Whole-grain rich products (up to 20% of the weekly serving may be enriched):  grain, bread, pasta, rice
• milk
• fruit
• vegetables:  consists of 5 subgroups

For breakfast, these are the 3 required food components:

• whole-grain rich products (meat/meat alternate substitute allowed, see requirements)
• fruit (vegetable substitute allowed, see requirements)milk

FOOD COMPONENTS

Fruits

SFAs are required to offer a variety of fruits according to grade groups.  Fruits consist of fresh; frozen without sugar; canned in light syrup, water, or fruit juice; or dried. Pasteurized, full-strength fruit juice may also be offered (it is credited to meet no more than one-half of the fruits component offered over the week).

•       For breakfast, all grades must offer at least 1 cup a day. 

•       For lunch, K-8 grade must be offered at least ½ cup a day.  Grade 9-12 must be offered 1 cup a day. 

•       There are no maximum serving sizes on fruit, only requirements for the daily minimum serving sizes and minimum weekly requirements. 

•       Frozen fruits cannot contain added sugar. 

•       Canned fruits must be light syrup or naturally packed in own juices.  A variety of fresh fruits is recommended. 

•       There are restrictions on fruit/grain desserts (see grain section)

•       Dried fruits count as twice the volume.  ¼ cup of dried fruit counts as ½ cup of fruit.  When   crediting a dried fruit mix, ensure that it is all 100% fruit. Dried fruit with sugar is allowed, however, schools should consider the calorie limits when serving products high in sugar.

•       No more than half of the fruit or vegetable offerings may be in the form of juice for the week.  All juice must be 100% full-strength.  Diluted juice is not creditable. If juice is offered every day in a full serving, fruit must be offered every in the full serving. 

•       Frozen concentrated fruit juice must be reconstituted with water to 100% full-strength before crediting as a fruit.  See food buying guide for crediting information. 

•       Fruit Jell-O made with real fruit juice is not creditable. 

•       No less than 1/8 cup of fruit can be credited toward the minimum amount of fruits.   If the school requires all five food components be served for lunch or all four components to be served for breakfast, the school must serve the minimum required fruits for that day for the required age/grade groups.  This can be served in combinations (1/2 cup of peaches, 1 orange.  If the school is OVS, the student is required to take no less than ½ cup of fruit or vegetable as part of the meal.

•       Refer to the USDA’s Food Buying G uide for Child Nutrition Programs to determine the serving size of whole fresh fruit.  In many cases, a whole fruit only equals ½ cup.  Therefore, an additional item may be required to equal a required serving. 

•       Snack-type fruits such as strips and roll-ups are not creditable towards breakfast or lunch. 

*Keep in mind the meal patterns for the NSLP and the SBP are separate.

Vegetables

School Food Authorities are required to offer a variety of vegetables for lunch in the form of subgroups to reach the weekly requirement per grade group.  Required minimum weekly quantities for each subgroup are established in the lunch meal pattern:  K-5, 6-8, 9-12.  Pasteurized, full-strength vegetable juice is also allowable (it is credited to meet no more than one-half of the vegetables component).  To ensure vegetables are served as required, designate a day of the week for each subgroup.  Vegetables are an option for breakfast.

Each week SFAs are required to offer or serve (depending on approved policy) in proper portions vegetables crediting toward the following vegetable subgroups:

-dark green vegetable                          

-red/orange      

-beans, peas, lentils  

-starchy

-other vegetable (different from the subgroups listed above), and

-additional vegetable from any of the food groups to reach the minimum weekly requirements. 

SFAs must offer weekly no less than 3 ¾ of cup for grades K-8 and no less than 5 cups for high school. The school is not required to offer a vegetable for breakfast.  Review table 1 for minimum serving size for each vegetable subgroup.  There are not maximum limits on vegetables except for vegetable juice.    

·   Dark leafy vegetables in the raw form count as ½ the volume.  This means that 1 cup of a dark leafy green credit (such as spinach) at ½ cup of vegetables.  To credit ½ cup of raw spinach, you must serve 1 cup. 

·   Cooked dark leafy vegetables such as broccoli or spinach are credited by actual volume:  ½ cup of cooked counts as ½ cup of dark leafy vegetable. 

·   Some leafy vegetables are not considered a dark leafy vegetable.  For example, iceberg lettuce is considered creditable to the other vegetable subgroup. 

·   When mixed vegetables or mixed salads cannot be credited to one subgroup because the portion size of that subgroup is unknown, count the vegetable in the “other” subgroup.  If packaging identifies the percentage of each vegetable and it can be credited to that subgroup, if it is more than 1/8 cup.  

·   No less than 1/8 cup of vegetable can be credited toward the minimum amount of vegetables.   If the SFA requires all five food components to be served for lunch, the school must serve the minimum required vegetables.  1/8 cup can be combined with another vegetable to get the full serving.  If a vegetable garnish is served and is less 1/8 cup it is a noncreditable food item.  If the school is OVS, the student is required to take no less than ½ cup of fruit or vegetable as part of the meal.

·   Larger amounts of these vegetables may be served.

·   This category consists of “Other vegetables” as defined in §210.10(c)(2)(iii)(E).  For the purposes of the NSLP, “Other vegetables” requirement may be met with any additional amounts from the dark green, red/orange, and beans/peas (legumes) vegetable subgroups as defined in §210.10(c)(2)(iii).

·   Any vegetable subgroup may be offered to meet the total weekly vegetable requirement.

·   If you have a full strength 100% vegetable juice blend from the same subgroup, you can count it for that subgroup.  If the vegetable juice blend is a combination of vegetables from different subgroups, credit it as a vegetable from the additional subgroup. 

o   No more than half of the vegetable offerings for the week may be in the form of 100% vegetable juice.  Diluted juice is not creditable. 

·   If crediting a vegetable in a product such as vegetable lasagna or pizza, the product must have a CN label or formulation statement that provides the crediting information. 

·   Beans, peas (lentils) may be offered as a vegetable or a meat alternate, but it cannot be creditable toward both.  Ensure both meat and beans are planned sufficiently for the week.

o     If a vegetable is credited as a meat/alternate, it’s serving may credit toward the weekly serving of the beans, peas, lentils vegetable subgroup [as permitted under the final rule for Child Nutrition (CN) programs: meal patterns consistent with the 20 – 25 Dietary Guidelines for Americans published April 25, 2024].

·       For breakfast, vegetables may be substituted for fruits, but:

o   SFAs who offer vegetables at breakfast once a week can offer any vegetable, including vegetables from the starchy vegetable subgroup.

o   SFAs who offer vegetables at breakfast more than once a week at breakfast must offer a variety of vegetables from at least two different subgroups as defined in §210.10(c)(2)(iii).

Vegetable Subgroups

·   For grades K-8, vegetables are broken up into subgroups and a minimum serving size for each subgroup:  dark greens- ½ cup, red/orange- ¾ cups, beans, peas, lentils- ½ cup, starchy vegetables- ½ cup, other vegetables-1/2 cup.  Additional vegetables are to be offered to ensure that schools serve a minimum of 3 ¾ cups a week.  Starchy foods such as potato and corn are not limited, however, should be reduced due to nutrient requirements and other vegetable subgroup requirements. 

·   There are no maximum limits on vegetables, only limits on minimum serving sizes. 

·   Vegetables are not required for breakfast but may be offered if the menu complies with the meal requirements specifically for breakfast. 

·   No less than 1/8 cup of vegetable can be credited toward the required minimum amount of daily and weekly fruit servings.   If the SFA requires all five food components to be served, the school must serve the minimum required fruits for that day for the age/grade group.  This can be served in combinations.  If the SFA is OVS, the student is required to take no less than ½ cup of fruit or vegetable as part of the meal. 

·   Vegetable subgroups can be served in smaller portion sizes if the full serving size for that subgroup complies with the required serving size for the week.  For example, the required serving size for red/orange is ¾ cup for grades 6-8.  Tomatoes can be offered as a ¼ cup serving size on a salad one day, and then carrots can be offered as a ½ cup serving on a different day. 

Table 2: Vegetable Subgroup Familiar Vegetable List
Dark Green (1/2 cup)	Bok Choy, Broccoli, Collard Greens, Dark Green Leafy Lettuce (1 cup = ½ cup serving: see rule), Kale, Mesclun, Mustard Greens, Romaine Lettuce, Spinach, Turnip Greens, Watercress
Red/Orange (3/4 cup)	Acorn Squash, Butternut Squash, Carrots, Hubbard Squash, Pumpkin, Red Peppers, Sweet Potatoes, Tomatoes, Tomato Juice
Beans, peas, lentils (1/2 cup)	Black Beans, Black-Eyed Peas (mature, dry), Garbanzo Beans (Chickpeas) Kidney Beans, Lentils, Navy Beans, Pinto Beans, Soybeans, Split Peas, White Beans
Starchy (1/2 cup)	Cassava, Corn, Fresh Cowpeas, Field Peas, Black-Eyed Peas (not mature/dry), Green Bananas, Green Peas, Green Lima Beans, Plantains, Potatoes, Taro, Water Chestnuts
Other Vegetables (1/2 cup)	Artichokes, Asparagus, Avocado, Bean Sprouts, Beets, Brussels Sprout, Cabbage, Cauliflower, Celery, Cucumbers, Eggplant, Green Beans, Green Peppers, Iceberg Lettuce, Mushrooms, Okra, Onions, Parsnips, Turnips, Wax Beans, Zucchini
Additional Vegetables	As needed to reach the minimum required amount of 3 ¾ for the week.  (Schools and RCCIs that extend above the 5-day week have additional minimum requirements.

Bread/Grain Whole Grain Requirement

The meal patterns for the NSLP and the meal patters for the SBP require at least 80% of the weekly serving for grains, breads and pasta must be Whole Grain-Rich (WGR).  The remainder of the weekly serving, up to 20% must be enriched grain items.  For a product to be considered WGR, at least 51% of the grain ingredients must be form whole grains.  Sometimes this is not easy to determine.

The criterion below determines if a product meets standards: 

·        A serving of the food item must meet portion size requirements for the grains/breads component as defined in FNS guidance, AND

·         Food must meet at least one of the following:

o   The whole grains per serving (based on minimum serving sizes specified for grains/breads in FNS guidance) must be ≥ 8 grams. This may be determined from information provided on the product packaging or by the manufacturer, if available. Also, manufacturers currently may apply for a CN Label for qualifying products to indicate the number of grains/breads servings that are WGR or

o  The product includes the following FDA-approved whole grain health claim on its packaging. “Diets rich in whole grain foods and other plant foods and low in total fat, saturated fat and cholesterol may reduce the risk of heart disease and some cancers.” OR

o  Product ingredient listing lists whole grain first, specifically:

§   Non-mixed dishes (e.g., breads, cereals): Whole grains must be the primary ingredient by weight (a whole grain is the first ingredient in the list)

§   Mixed dishes (e.g., pizza, corn dogs): Whole grains must be the primary grain ingredient by weight (a whole grain is the first grain ingredient in the list).

*Keep in mind the meal patterns for the NSLP and the SBP are separate.

The listing of the products on the packaging is one way to determine if a product is whole grain.  The whole grain should be the first item listed in the ingredient statement.  The item must also list it was a whole grain product.  This means that the words “whole” or “whole grain” appear before the grain ingredient’s name in the ingredient statement. Example is whole wheat, and whole corn.  Rice must be brown rice, since white rice has been processed for manufacturing. 

Some products are misleading.  Many products contain a stamp on the label that state it contains whole grain or it is whole wheat.  Do not assume that this means that the product meets the requirements to be considered WGR.  Look at the label to determine if the first ingredient is a whole grain product, and then look at the serving size to determine if the serving size is sufficient for the meal patterns offered at the school. 

In some products, water is listed as the first ingredient.  If the whole grain is listed as the second ingredient and water is listed as the first, then the product can be considered WGR.  No other ingredient besides water can be listed first. 

Whole grains are defined as, “cereal grains that consist of the intact, ground, cracked or flaked caryopsis [kernel], whose principal anatomical components - the starchy endosperm, germ and bran - are present in the same relative proportions as they exist in the intact caryopsis.”

Items that are considered creditable grain products when it is the first ingredient and complies with proper serving size. 

Table 3: Common Whole Grains
Bromated Whole-Wheat Flour	Stone-Ground Whole-Wheat Flour	Whole-Grain Bulgur
Bulgur	Toasted crushed Whole Wheat	Whole-Grain Wheat
Cracked Wheat or Crushed Wheat	Wheat Berries	Whole-Grain Wheat Flakes
Entire Wheat Flour	Wheat Groats	Whole-Grain Wheat Flour
Flaked Wheat	White Whole-Wheat Flour	Whole-White Wheat
Graham Flour	Whole Bulgur	Whole-Wheat Flakes
Sprouted Wheat	Whole-Durum Flour	Whole-Wheat Flour
Sprouted Wheat Berries	Whole-Durum Wheat Flour	Whole-Wheat Pastry Flour
Sprouted Whole Wheat	Instant oatmeal	Old-Fashion Oats
Whole-Grain Oat Flour	Oat Groats	Quick-Cooking Oats
Whole Oats	Oatmeal or Rolled Oats	Steel Cut Oats
Whole-Oat Flour	Dehulled-Barley	Whole-Barley Flakes
Whole-Grain Barley	Dehulled-Barley Flour	Whole-Barley Flour
Whole-Grain Barley Flour	Whole Barley	Nixtamalized Corn
Whole Cornmeal	Whole-Grain Cornmeal	Popcorn
Whole-Grain Corn	Whole-Grain Grits	Whole Corn
Whole-Grain Corn Flour	Whole-Corn Flour	Brown Rice
Brown-Rice Flour	Sprouted Brown Rice	Wild Rice
Wild Rice Flour	Flaked Rye	Sprouted Whole Rye
Whole-Rye Flakes	Rye Berries	Whole Rye
Whole-Rye Flour	Rye Goats	Amaranth
Sorghum (Milo)	Triticale	Amaranth Flour
Sorghum Flour	Triticale Flour	Buckwheat
Spelt Berries	Whole Einkorn	Buckwheat Flour
Sprouted Buckwheat	Whole-Einkorn Berries	Buckwheat Groats
Sprouted Einkorn	Whole Emmer (Farro)	Millet
Sprouted Spelt	Whole-Grain Einkorn Flour	Millet Flour
Teff	Whole-Grain Spelt Flour	Quinoa
Teff Flour	Whole Kamut (Khorasan Wheat)	Whole Spelt
Note: The following corn ingredients meet the Whole Grain-Rich (WGR) criteria for school meals.
Corn Masa	Hominy Grits	Masa Harina

Granola bars, cereal bars, breakfast bars, fortified cereals, and cereals with fruit can be credited toward the whole-grain rich product is it complies with the whole-grain rich requirements. 

If a school offers a formulated fruit-grain product, the fruit cannot be credited for breakfast or lunch.  It can be counted towards a grain.  If the school chooses to serve the product for lunch, it can only count as a grain-based dessert. 

The NSLP meal patterns limit the grain-base desserts to 2 ounces a week. A school may offer a total of 2 oz. eq or less of grain-based desserts each week. Therefore, a 2-ounce equivalent dessert may be offered once per week, or a 0.5 oz. eq. dessert may be offered four times in a week.

Whole grain cereals need to be fortified.  The only exception is anything under .25 ounce equivalent because it does not contribute the grain requirements. 

If using a processed food item where both meat and grain is credited toward the meal, schools need either a product formulation statement issued by the manufacturer, or a Child Nutrition (CN) label issued by the USDA to identify the grain and meat contribution to the meal.  If a SFA is unable to identify the grain or meat contribution, that product cannot credit toward the meal patterns for the NSLP and, or the meal patterns for the SBP. 

Breading on meat, croutons on salads, and other grain items cannot be credited to the weekly meal pattern unless it is .25 ounces or more.  If it is less than .25 ounce, it is not considered and cannot be combined with other grain products to reach the required serving size.  SFAs must ensure the daily minimum requires are met with some other food item.  If the breaded items are more than .25 ounces, it is considered creditable.  Breaded commercial products are required to have crediting documentation [see the section on Child Nutrition (CN) labels and product formulation statements for more information on crediting documentation].                                                   

There are other bread/grain items that do not contribute fully to the serving size requirement because of other added ingredients.  Some examples are donuts, pastries, granola bars.  See the grain section Exhibit A of the USDA’s Food Buying Guide for Child Nutrition Programs to determine crediting information for items such as donuts and pastries.  SFAs must try to comply with recommended maximum serving sizes for the week to follow the standards for calories, sodium, and saturated fat.  As with the other meal components and dependent on grade group, schools have daily and weekly minimum serving sizes and recommended maximum serving sizes.  Although there is not maximum limit on grain products, exceeding the recommended maximum limits may result in exceeding the limits on calories, saturated fat, and sodium. 

Meat/Meat Alternate

For lunch, SFAs are required to offer daily a meat or meat alternate.  For grades k-5, and 6-8, the daily minimum is 1 ounce with a weekly requirement of 8-10 ounces for k-5 (for five-day week) and 9-10 ounces for grades 6-8 (for a five-day week).  For high school, the daily minimum is 2 ounces, and the weekly requirement is 10- 12 ounces (for a five-day week).  The menu planner has the flexibility to determine when to offer more than daily minimum.  Schools must never go below the daily minimum and should adjust the week to ensure the servings sizes are within the weekly minimum ranges. 

SFAs have the flexibility of serving a meat alternate in place of meat.  Meat alternates consist of cheese, tofu, nuts, yogurt, bean, and legumes.  It is important to note meat/meat alternate products cannot be credited as any other food components (except for some of the vegetables crediting can credit toward the beans, peas, lentils vegetable subgroup and as a meat alternate, but cannot also credit toward the daily and weekly servings for the vegetable component).  Yogurt and cheese are considered a dairy product by many, but they cannot be credited as milk in USDA child nutrition programs (NSLP, SBP, and the Afterschool Snack Program). 

Vegetables from the beans, peas, lentils vegetable subgroup are the exception to how a food item is credited.  When planning a menu, the school must determine if beans and legumes will be credited as a vegetable or a meat alternate.  On the day of service, it cannot be credited as both a vegetable and a meat, even if the serving size exceeds the minimum daily requirements.  Weekly menus must be planned to include the required amounts of vegetables and meat/meat alternates. 

The final rule (CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines) published on April 25, 2024:

·       Permits vegetables from this subgroup crediting toward the meat/meat alternate to be credited toward the weekly vegetable subgroup serving.

o   Note:  Vegetables from the beans, peas, lentils vegetable subgroup crediting toward the meat/meat alternate do not the daily and weekly vegetable component serving.

Milk Requirement

The meal patterns for the NSLP and SBP require School Food Authorities to offer at least two choices of fluid milk from the following [as required by federal regulations 7 CFR Part 210.10 (d) (1) and 7 CFR Part 220.8 (d)]: 

·       Fat-free unflavored milk, low-fat (1%) unflavored milk,

·       Fat-free flavored milk, or low fat (1%) flavored milk.

One of the varieties offered is required to be unflavored milk.

Such products must be pasteurized fluid milk that meets State and local standards.    Whole milk and 2% cannot be offered as part of the reimbursable meal.  Although there are no restrictions on larger portions, schools should limit the serving size to 1 cup a day to minimize the fat and calories.

Milk substitutes must meet the federal guidelines.   The final rule (CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans) published on April 25, 2024, have the following nutrition requirements for milk substitutes:

Table 4: Nutrition Requirements for Fluid Milk Substitutes
Nutrient	Per Cup (8 fl. oz.)
Calcium	276 mg.
Protein	8 g
Vitamin A	150 mcg. Retinol Activity Equivalents (RAE)
Vitamin D	2.5 mcg.
Magnesium	24 mg.
Phosphorous	222 mg.
Potassium	349 mg.
Riboflavin	0.44 mg.
Vitamin B-12	1.1 mcg.

Milk substitutes tend to be for milk allergies or other disabilities.  Contact SNP for guidelines for milk substitutes.  However, milk substitutes are subject to nutrient analysis so calories, sodium, and fat content should be considered. 

NUTRIENT REQUIREMENTS

Calories

The calorie minimum and maximum levels (and related food portions for various components) are based on data pertaining to children’s healthy weight, physical activity level, and opportunities for meals and snacks outside of the school meals programs.  If implemented properly, the meal plans for each appropriate age/grade group allow School Food Authorities to create menus that fall within the calorie minimum and maximum ranges for the week.  The calorie minimum and maximum ranges cannot be calculated daily because there may be some days popular items are offered that may be higher in calories, other days of the week must be planned to offset the higher calorie days to keep the weekly average within range.   The reimbursable meal patterns require schools to offer nutrient dense meals that provide children more fruits, vegetables, and whole grains than specified by the previous meal patterns.   The average calorie level by age/grade level are listed in table 5.

Table 5: Average Weekly Calorie Range for the NSLP and the SBP
Program	Grades K – 5	Grades 6 – 8	Grades 9 -12
NSLP	550 – 650	600 – 700	750 – 850
SBP	350 – 500	400 – 550	450 – 600

Discretionary sources of calories (solid fats and added sugars) may be added to the meal pattern if within the specifications for calories, saturated fat, and sodium.  Foods of minimal nutritional value and fluid milk with fat content greater than 1 percent milk fat are not allowed. 

Sodium

These requirements allow SFAs to reduce sodium incrementally. Listed in table 6, are the average sodium limits and timeline based on program year, type of meal, and grade.  The final rule for Child Nutrition (CN) programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans published on April 25, 2025, established new sodium levels, below is the timelines for the implementation:  

Table 6: Average Sodium Levels and Timelines
Average Sodium Level through June 30, 2027	Average Sodium Level Effective July 1, 2027
Lunch ≤  1,110 mg (grades K-5) ≤  1,225 mg (grades 6-8 ≤  1,280 mg (grades 9-12)   Breakfast ≤  540 mg (grades K-5) ≤  600 mg (grades 6-8 ≤  640 mg (grades 9-12)	Lunch ≤  935 mg (grades K-5) ≤  1,035 mg (grades 6-8 ≤  1,080 mg (grades 9-12)   Breakfast ≤  485 mg (grades K-5) ≤  535 mg (grades 6-8 ≤  570 mg (grades

OFFER VERSUS SERVE

Reducing Plate Waste

If a SFA is following the offer versus serve (OVS) policy for breakfast and/or lunch, they must provide enough for each child to take the full required amount of each component. A child may take smaller portions of the fruits and vegetables components, if desired. Children must select at least ½ cup daily of the fruits or the vegetables components for a meal to be considered reimbursable under OVS in the NSLP and SBP.  If a school practices the serve policy, all components must be served at full serving and a student cannot decline the ½ cup of fruit or vegetable.

Serve or Offer-versus Serve

Sites [facilities where the National School Lunch (NSLP) and the School Breakfast Program (SBP) are operated] are either a “serve” sites or an “offer-versus-serve” (OVS) sites.  To determine which method to use, School Food Authorities must review children’s selection behaviors, convenience, time, and cost of foods.  Schools should always consider ways to reduce plate waste.  The SFA chooses serve or OVS on the form “Meal Counting and Claiming Procedures” listed in the permanent file.  SFAs cannot switch from one method or another without Oklahoma Human Services SNPs’ approval. 

When a site is not offer versus serve, it is required to serve all required food components to each child.  Children are not allowed to decline a required component.  An OVS site is required to offer all required components, but based on policy, children are allowed to decline one or two items.  OVS is a serving method designed to reduce food waste and food costs in the NSLP and the SBP without jeopardizing the nutritional integrity of the meals served.

Once a decision is made to conduct “offer versus serve”, SFAs should have standard procedures for identifying a reimbursable meal and procedures to count only meals that meet the USDA reimbursement requirements.  All staff personnel responsible for serving meals and counting reimbursable meals should be trained to follow proper procedures. 

Offer-Versus-Serve (OVS)

SFAs may elect the OVS method as an option to serving all required items at sites where children grades K through 8^th grade are participating in the NSLP and the SBP.  The OVS method may not be used with children in the pre-K grades (USDA Memo SP 01-2018).  The SFA has the option of determining which sites and grades [except for grades 9 – 12 where OVS is required by federal regulations 7 CFR Part 210.10 (e) and 7 CFR Part 220.8 (e)] to implement OVS and whether the student must choose a minimum of three or four items for lunch.  For breakfast, students may decline one food component.  Note however, that with the meal patterns, a child electing to decline a fruit or a vegetable as one of the two items must take a minimum of ½ serving of fruit of vegetable.  If the ½ serving is selected, the student may only decline one other item. 

Sites with OVS must allow children the option to take all required food components or decline one or two required components, depending on site’s policy. At least three full portions of the five food components offered must be taken for a lunch to be reimbursable.  One exception to the rule is to allow students to take ½ fruit or vegetable as the third selection.  Schools cannot require students to take certain food items unless it declines to use the offer versus serve option. 

Regardless of whether a student chooses three items or takes all five offered food items, the unit price of the meal should be the same price.  Food service programs with high school grades (9^th grade through 12^th) must provide offer-versus-serve to all children [as required by federal regulations 7 CFR Part 210.10 (e) and 7 CFR Part 220.8 (e)].

OVS – Lunch

An “offer versus serve” lunch meal must meet the following requirements:

·          All 5 components of the lunch meal pattern must be offered to all students.

·          For the five required components, the serving size must be consistent with the minimum quantities specified for the meal pattern chart.

·          The student must select full sized portions of at least 3 of the 5 offered components of the meal pattern.

·          Student must take at least ½ cup serving of fruit or vegetable

OVS – Breakfast

An “offer versus serve” breakfast meal must meet the following requirements:

·         Three of the required breakfast food components must be offered

·         Among the three required food items, there must be four food items must be offered to all students.

·         For the four required components, the serving size must be consistent with the minimum quantities specified for the meal pattern chart.

·         The student must select full sized portions of at least 3 of the 4 offered items.

·         Children must take ½ serving of fruit or vegetable substitute and two other food items at full portion.  Example:  If two fruits, milk, and grain are offered and the child decides to take two fruits and a milk, the second fruit serving must be one whole cup.

Under offer versus serve, a SFA can determine the number of servings to offer for each meal component.  SFAs must plan meals in the NSLP and the SBP to meet all meal requirements and provide required amounts of food for all students. Menu planners should consider participation and selection trends to determine what and how much food to offer to children. Careful menu planning will ensure that children have access to all the required food components for the reimbursable meal and minimize food waste.

A menu planner may split a component into multiple items. Under OVS, the child must take at least the daily minimum required by the meal pattern.

·       For example, a K-5 school offers 2-ounce equivalents of grains: spaghetti (1 oz. eq.) with a dinner roll (1 oz. eq.). Since the minimum daily grain serving requirement for grades K-5 is only 1 oz. eq., the student may take either the dinner roll (1 oz. eq.) or the spaghetti (1 oz. eq.) and count as meeting the grains component under OVS. This also applies to the meat/meat alternate component. In grades 9-12, since the daily minimum is 2 oz. eq., children must select at least 2 oz. eq. of grains or meat/meat alternate to count toward these components.  Children are instructed on how much of each component must be selected through meal identification signage.

SFAs with OVS site are required to have signage explaining to children what constitutes a reimbursable meal (breakfast and lunch).  This must include the requirement for the children to take at fruit or vegetables crediting at least ½ cup.

CREDITABLE FOODS

To serve food items as part of the reimbursable meal, schools must ensure the product is a creditable food item.  Creditable food items are listed in the USDA Food Buying Guide for Child Nutrition Programs.  Many vegetables, fruits and meat items are listed in the guide.  When using the Food Buying Guide for menu planning, food service personnel must ensure the product listed in the guide is the same product used in meal production.  If a product is not specifically named in the USDA’s Food Buying Guide for Child Nutrition Programs, schools must obtain a product formulation statement or obtain a Child Nutrition (CN) label for the item.  Product formulation statements and CN labels must state how the item contributes to the meal pattern. 

Crediting Serving Size

Crediting is determined by rounding the food component down to the nearest quarter ounce equivalency for the meat/meat alternate and grain components, and down to the nearest eighth (1/8) cup for the fruit and vegetable components.  This means that a .30 ounce of meat/meat alternate or grain is only credited for .25-ounce eq.  Fruits and vegetables must be at least 1/8 of a cup to count towards a reimbursable meal.  Since these serving sizes do not comply with the meal pattern, it must be combined with the same food component to reach the daily requirements. 

Soups like tomato may contribute toward the Red/Orange vegetable subgroup. To credit, a recipe will be needed to determine the creditable amount of butternut squash, pumpkin, or tomato per serving. If this is a commercial item, a product formulation statement or CN label may be used to determine the creditable amount. School food authorities shall continue to use established guidance regarding tomato paste or purees for crediting found in the USDA’s Food Buying Guide for Child Nutrition Programs.

The fruit or vegetable puree credits based on the actual volume served. For many fruits and vegetables, the pureed form has a smaller volume than whole fruit pieces. Some puree yields for fruit and vegetables are currently in the USDA’s Food Buying Guide (blackberries, plums, raspberries, tomatoes). For other foods, SFAs must rely on manufacturer information, or, for in-house recipes, yields based on volume of fruit/vegetable puree. Please refer to the introduction of Food Buying Guide for Child Nutrition Programs for information about how to obtain in-house yield data.

Leafy greens that are served raw count as half the volume served, while in their cooked form they credit as volume served.  Cilantro and parsley are both classified as dark green vegetables therefore ¼ cup would credit as 1/8 cup of dark green vegetables. Herbs in the Other subgroup, such as chives and garlic, credit as volume as served. SFAs with questions about the subgroup classification of additional herbs not listed above should contact Oklahoma Human Services School Nutrition Programs (SNP) for assistance. Herbs that are used in small amounts (less than 1/8 cup per portion) as a garnish or seasoning would not credit toward the vegetable component.

Creditable dessert items

When using a USDA recipe, review the serving information to determine the serving for the recipe item to credit toward the meal patterns.  Some recipes such as desserts are creditable but limited by the number of ounces that can be served as a grain, if the product contains grains.  Keep in mind the meal patterns for the NSLP have a 2 oz. per week grain-based desert limit. 

Desserts with fruit and grains

The fruit in the dessert can credit toward the fruit component, regardless of whether there is added sugar in the dessert recipe or not. For grain-based desserts, such as pies, cobblers, or crisps, only the grain portion (e.g., crust) counts toward the grain-based dessert limit. A sweetened fruit dessert without grains, such as fruited gelatin or a baked apple, does not count toward the weekly limit on grain-based desserts. However, SFAs should offer sweetened fruit in moderation to stay under the weekly calorie maximum at lunch.

Schools may offer fruit that is fresh, canned in 100 percent juice, light or extra light syrup, or, frozen without sugar.  In addition, this requirement does not apply to frozen grain-based desserts that contain fruit. Therefore, grain-based desserts that contain frozen fruit with added sugar may be credited toward both the grain and fruit components. The grains portion of the dessert remains subject to the weekly limit of 2 oz. eq. for grain-based desserts.

SFAs need to keep in mind the final rule [for Child Nutrition (CN) programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] published on April 25, 2024, establishes weekly added sugar limits beginning on July 1, 2027 (see the final rule section at the beginning of this chapter for more information).

Meat items

When using a USDA Foods’ meats, review the USDA Foods in schools Product Information Sheets to determine how these meat products credit toward the meal patterns.  If crediting information is not available, the school must request company formulation statement for product.  If the meat product is a commercial product with added ingredients, then the product will need either a Child Nutrition (CN) label issued by the USDA, or a product formulation statement issued by the manufacturer.

Child Nutrition Labels

If a food item is not found in the USDA’s Food Buying Guide for Child Nutrition Programs, and a product formulation statement is not obtained (from the manufacturer) to identify its creditability to the meal pattern, then the SFA must obtain a Child Nutrition (CN) label to show how a food item contributes to the meal pattern.  This information is required for all meats, meat alternates and fruit juices that contain other ingredients.  The label clearly identifies; the contribution a product makes toward the meal patterns. Most products with a CN label are products that are not 100% pure but contain other ingredients.  Listed below is a sample CN label that demonstrates the meal pattern contribution.  CN labels are issued by the USDA, during the CN labeling process the USDA certifies the products contributions to the meal patterns.

For more information about CN labeled products, visit:

USDA CN Labeling – https://www.fns.usda.gov/cn/labeling

The USDA posts a CN label verification report to their site.  Click on the Authorized CN Label Manufacturers for a list of companies offering CN labeled products.  Then click on CN label verification report to verify CN numbers and crediting information.  This information is only used to verify CN labeled products.  To offer creditable CN Labeled products, provide the CN information to your distributor.  For a CN labeled product to credit toward meal patterns the packaging with the CN label must be retained by the SFA.  A brochure, a company listing or an invoice indicating how much product is credited as a meat, grain or juice is not sufficient documentation. 

Identifying a CN Label: 

·       It will have a CN logo with a distinct border.

·       It will have a 6-digist production identification number with CN in front of the 6 digits

·       It will have the USDA/FNS authorization statement

·       It will contain the month and year of approval. 

·       It will indicate the food serving sizes and the contribution to the meal patte

Table 7: Child Nutrition (CN) Label Example

Sample CN Label

Product Formulation Statements

If a CN label is not available for meat/meat alternates and juices, a product formulation statement issued by the manufacturer is required.  The manufacturer should be able to provide the product formulation statement.  This statement must clearly make a statement about the contribution the product makes toward the meal pattern requirements.  Unlike the CN label, the product formulation statements will provide detailed information required nutrients, ingredients, and contribution. 

Product Formulation statements should provide detailed information so that the food service staff can identify the item’s contribution to the required meal pattern.  Processed meat entrees, spaghetti sauces, salsas and cheese sauce are examples of food items that must have product information demonstrating how the food item can count toward a vegetable or meat component.  Products that do not demonstrate valid contribution to one of the required food components should be listed as an “other” food item on the daily production sheets.

To determine a product's contribution toward the meal pattern, documentation must state the contribution, be on company letterhead, and an officer of the manufacturer must sign it.  Table 8 contains other information that should be included on the product formulation statement:  

Table 8: Required Elements of a Product Formulation Statement
• product name and product code • serving or portion size • crediting ingredients (Must have a similar description to items in the USDA’s Food Buying Guide for CN Programs). • weight of raw portion • percent of raw meat or poultry • percent fat of raw meat	• certification that the vegetable protein product       used meets USDA-FNS requirements. • percent dry vegetable protein products (VPP) if    product contains VPP • percent protein of the vegetable protein product   (On an as purchased basis)

Procurement and Creditable Food Items

Many manufacturers do not provide product specification information or may provide insufficient information.  School Food Authorities (SFA) cannot use products that do not have a complete statement on file.  During the procurement process, food service staff must communicate the program’s need for sufficient product information from potential vendors.  Remember if the SFA cannot find the product in the USDA’s Food Buying Guide for Child Nutrition Programs and it does not have a CN label, or a product formulation statement, then the product cannot contribute to the meal pattern.  Serving these items may result in breakfast and lunch meals to be non-reimbursable. 

NONCREDITABLE FOODS

Many food items are not creditable toward the meal component because of the ingredients used to produce the product.  The ingredients can diminish the actual portion size of the required food component.  For example, if a school wants to serve ¼ cup of salsa and count it as a vegetable component, the school must have documentation that indicates how much salsa to serve to equal ¼ cup of vegetable. Commercial sauces, such as canned, contain starches and other additives to increase volume not nutrition.  To serve food items not listed in the USDA’s Food Buying Guide for Child Nutrition Programs as part of the meal pattern, documentation that clearly identifies the meal contribution is required.  On the other hand, if a SFA has a recipe identifying how the recipe item contributes toward the meal patterns, then the food item could be creditable.

Schools can serve noncreditable foods as an extra item during the meal but cannot count the item as one of the five required food components.  Most condiments and desserts are examples of noncreditable food items. 

Examples of Noncreditable Food Items

Table 9.1: Examples of Noncreditable Meats and Meat Alternates
• Bacon	• Cream Cheese
• Tofu unless found in the USDA’s Food Buying Guide for Child Nutrition (CN) Programs	• Imitation cheese
• Packaged Macaroni/Cheese/Spaghetti    Products	• Canned Meat Soups (Example:    Chicken Noodle, Chicken Rice)
•Noncommercial and Non-standardized   Yogurt Products	Shelf-stable dried or semi dried meats unless found in Food Buying Guide for CN Programs, or have crediting documentation (CN label or product formulation statemnt)

 

Table 9.2: Examples of Noncreditable Fruits and Vegetables
• Jams, Jelly Preserves	• Plain Gelatin Desserts
• Nectars (Example: Peach, Pear,   Apricot)	• Ades (Lemonade, Limeade,   Orangeade)
• Fruit Drinks (Example: Pineapple/      Grapefruit Drink/HI-C)	• Cranberry Juice, Cranapple Juice     Cocktail, Cranapple Juice
• Coconut	• Tomato Catsup
• Hominy	• Mustard
• Pickle Relish	• Chili Sauce
• Dry Vegetables for Seasoning	• Creamed soups
• Fruit Roll-ups, Fruit Leathers	• Potato chips, Potato Sticks
•       Sherbets	·       Pickles

 

Table 9.3: Examples of Noncreditable Milk
• Ice Cream, Ice Milk or
• Butter                                    • Evaporated Milk ·       Sherbet	• Dry Milk • frozen yogurt

Noncreditable food items and Administrative Review

When a School Food Authority (SFA) serves a noncreditable food item as part of the meal, it is included in the nutrient analysis if triggered during an Administrative Review.  SFAs that routinely serve desserts, condiments, and sauce items may need to modify the menu to offer healthier items.  SFAs using the nutrient standard-based meal pattern are required to analyze meals prior to serving.  All food must meet the guidelines for nutrient standards before serving. 

           OTHER MEAL PATTERN REQUIREMENTS

Availability of Water

The Healthy, Hunger-Free Kids Act of 2010 (the Act), Public Law 111-296, Section 203, establishes a requirement for making potable water available to children at no charge in the School Breakfast Program (SBP), National School Lunch Program (NSLP); this includes the Afterschool Snack Program.

·       Water must be in the place where meals are served during the meal service or adjacent to the meal service area.  Schools can offer water pitchers and cups on lunch tables, a water fountain, or a faucet that allows students to fill their own bottles or cups with drinking water. Whatever solution is selected, the water must be available without restriction in the location where meals are served. 

·       Students must have sufficient time to use the water fountain during their meal period.  It is important to consider the amount of time it takes students to obtain water, children should not have to wait in long lines. 

·       If schools choose to supply cups at the water fountain to reduce long lines, schools cannot charge for cups.  Schools cannot require children to bring their own cups. 

·       For multiple locations, water must be available in each location.  If meals are served in lunchroom, water must be available. 

·       Charges to the food service account for supplying water must be a reasonable cost.  When selecting a method for supply water, it must be efficient and practical.  Water pitchers may be more practical than constructing a water fountain. 

·       If the school is participating in Afterschool Snack Program, water must be available. 

·       Water cannot be flavored.

·      Water cannot be restricted during meal service.  If a child must raise their hand or in any way ask permission to get water, that is restricted access.

Extra Item

Extra items can be offered during breakfast and lunch when it is not contributed as part of the meal pattern.  However, when this choice is made to offer larger portion sizes or extra items that are not contributable towards the meal pattern, consideration must be given to what effect it will have on the dietary specifications.  Calories, saturated fat, sodium, and added sugars (beginning on July 1, 2025, see the final rule section at the beginning of this chapter for more information) are all limited by the meal patterns.  Adding extra items or extra servings can lead to noncompliance and will require SFAs to alter their menu plans. 

Meat is not a required to be served as part of a reimbursable breakfast.  If a SFA would like to add meat as part of the grain & meats/meat alternates component at breakfast, it may do so SFAs may also serve meat as an extra item.  When served as an extra item, SFAs should take steps to ensure that the weekly requirements are on the menu and add meat on any day.  However, when serving extra items, SFAs should be careful not to add additional items that will cause the calorie, saturated fat, and sodium to exceed maximum limits.    

Examples of extra items:

Sour cream

Bacon (including turkey bacon)

Desserts

Meat (when it is not substituted for a grain)

Breakfast substitutions

For breakfast, vegetables may be substituted for fruits.  Beginning July 1, 2024, the final rule [for CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] established the following requirements for substituting vegetables for fruit component servings for reimbursable breakfasts:

·       Vegetables offered once a week at breakfast can have vegetables from any vegetable subgroup, including vegetables from the starchy subgroup.

·       Vegetables offered more than once a week at breakfast must have vegetables from at least two different vegetable subgroups.

However, any vegetable can be offered as an extra food item if it is not credited toward the breakfast meal patterns. 

Salad Bars

Salad bars containing fruits and vegetables and credited towards a reimbursable meal must be stationed before the Point of Service (POS).  This is to ensure that each child’s selections from the salad bar meet the required portions for an entrée or food/menu item.  If a School Food Authority’s (SFA) site is not able to position the salad bar in a location prior to the POS, the SFA is required to get approval from Oklahoma Human Services School Nutrition Programs (SNP) to use an alternate POS to ensure the meal is reimbursable.  If the fruits and vegetables are in an approved location beyond the POS, there must be a system in place to ensure that each reimbursable meal selected by the student includes a fruit or a vegetable, and that the total of any fruit or vegetable item selected under OVS equals at least 1/2 cup.

SFAs are encouraged to use utensils in the proper serving size so that children can take appropriate the food amounts.  Food service staff must ensure that the portions on the student’s tray meet the meal pattern requirements.  Cashiers and other food service staff and staff responsible for POS counts must be able to visually identify the correct portions.  Proportioning in cups or other packages is another way to ensure proper serving sizes. 

An unmonitored salad bar will not count as part of the reimbursable meal, unless there is a system in place to ensure that the required components are taken, and that system is approved by the SA.  Salad bars may be offered as additional food items that do not count as part of the reimbursable meal.  However, if not sold a la carte, those items will be included in the dietary specifications and nutrient analysis during the administrative review. 

To ensure that all the vegetable subgroups are offered, the school can place all five subgroups on the salad bar daily.  On any given day, if a subgroup is not on the salad bar, it must be placed on the serving line.    Remember, if the SFA’s site is not OVS, the SFA must ensure that students receive all five subgroups in a week.  

SFA sites with salad bars need to track all food items on a salad bar production sheet.  Salad bar production records require information such as total weight or volume of each item placed on salad bar, total meals served, and total weight or volume not used.  The leftover amount of each item is subtracted from the total amount placed on the salad bar to determine meals were planned properly and to determine the nutrient standards. 

When offering grains/breads and meat/meat alternates, schools must ensure that students can select the foods in the correct serving sizes to complete with daily and weekly requirements.  SFAs may consider pre-portioning specific items to ensure the correct serving size or provide utensils with the correct portion size.  In many cases, salad bars can be challenging, and school may wish to serve it a la carte and not count it towards a reimbursable me.   

Exceptions to the Meal Pattern and Nutrient Standards

School Food Authorities (SFA) are allowed, on a cases-by-case basis, to offer age-appropriate meals to individual children in unique situations (for example: a 16-year-old teen with developmental issues placed with age/grade group K-5).  Oklahoma Human Services may require the SFA to seek permission prior to deviating from the required meal pattern for the prevalent age/grade group. This is important because the State agency is responsible for promoting proper implementation of the meal requirements.

The nutrition standards for the reimbursable school meal were designed based on age-appropriate nutrition and physical activity habits of the average student. USDA will provide States flexibility and options to both comply with the nutrition standards and meet the needs of these children who may require additional calories and protein. There are no limits on the amount of food children may purchase as a la carte items.

The average daily amount of calories for a week must be within the range (at least the minimum and no more than the maximum values) of each grade group.  Discretionary sources of calories (solid fats and added sugars) may be added to the meal pattern if within the specifications for calories, saturated fat, trans-fat, and sodium. 

One way to ease menu planning for two grade groups within one school is to start with a menu that is appropriate for grades 6-8, then add in a few additional foods to serve to the older grade group. For the older children (grades 9-12), the fruit and vegetable minimums must be met. Therefore, on top of the requirements for the 6-8 group, SFAs must make available to the older children: ½ cup more fruit daily, ¼ cup more vegetables daily and across the week: ½ cup more red/orange vegetables, ¼ cup other, ½ cup additional (any subgroup) vegetables.

An alternative suggestion is to make the full 1 cup fruit and vegetables required for grades 9-12 available to both grade groups (same menu plan for these 2 food components), if such offerings do not exceed the calorie limit for the 6-8 grade group.  One potential method of doing this would be offering a salad bar to all students. 

Weekends

For weekend meals, the RCCI must follow the daily and weekly meal pattern requirements for the National School Lunch Program and School Breakfast Program. Seven day meal patterns are available from Oklahoma Human Services School Nutrition Programs, to request these meal patterns email a request to AFS.School.Nutrition.Programs@okdhs.org.  The seven-day meal patterns adjust the required weekly serving sizes to accommodate the additional two days.

Family Style

Family style will continue to be allowed in RCCIs, but the operator must plan and offer the required food quantities for each child participating in the meal. These offered amounts must meet the food component and dietary specification requires.

Field Trips

Children on a field trip must be offered lunches that meet the daily meal component requirements if the meals are being claimed for reimbursement. However, the menu planner does not have to adjust the planned weekly menu to account for occasional field trips and does not have to pack the same vegetable offering from that day’s “hot” lunch menu for a field trip. The menu planner has the option to offer a different vegetable, or a different vegetable from the same subgroup. However, the meals from field trips would need to be included when planning meals that meet the weekly grain and meat/meat alternate ranges and weekly dietary specifications (calories, saturated fat, and sodium).

Keep in mind potable water is required to be available for all meals being claimed for reimbursement in the NSLP and the SBP.

Long and Short Weeks

SFA sites that regularly serve lunch six or seven days per week must increase the weekly grains quantity by approximately 20 percent (1/5) for each additional day. Seven day meal patterns are available from Oklahoma Human Services School Nutrition Programs, to request these meal patterns email a request to AFS.School.Nutrition.Programs@okdhs.org.

When SFAs regularly operate less than 5 days per week, they must decrease the weekly quantity by approximately 20 percent (1/5) for each day less than five. 

For SFAs with occasional decreases in the length of the week due to holidays, for example, the menus do not have to be adjusted, but menu planners must plan their menus in a way that is consistent with the intent of the meal patterns. Planners should make sure they do not consistently fail to offer certain vegetable subgroups or offer meat/meat alternates and/grains in portions that would exceed the weekly requirements.

Vending Machines

A vending machine that provides a reimbursable school meal is subject to all program regulations and represents an extension of the school food service area. Therefore, school meal vending machines are subject to the same procedures, menu planning requirements, competitive food rules, and offer versus serve requirements that are applicable to meals offered on a service line with a cashier. Also, as a reminder, any use of Program Funds for obtaining and maintaining vending machines to provide reimbursable meals must be in accordance with the procedures set forth in 7 CFR 210.21, as applicable, concerning the procurement of supplies, food, equipment, and services.

It is the SFA’s responsibility for ensuring that a vending machine used to serve reimbursable meals is operated in compliance with program regulations. For example, the SFA must ensure that a machine can properly dispense a reimbursable meal and accurately document when a reimbursable meal has been selected by an eligible student. Moreover, SFAs will need to ensure that the use of the vending machine does not allow an eligible student to receive more than one reimbursable meal per service

period (e.g., one meal through the lunch line and a second meal through the vending machine). It is critical that any identity confirmation procedure does not overtly identify a child as receiving a free or reduced-price meal. Additionally, as a reminder, all reimbursable school meals, including vended meals, must be priced as a unit.

Prior to the use of vending machines to serve reimbursable meals, an SFA must notify their State agency (SA) of their intent to do so. The SA would include the vending machines in any administrative review to ensure that these machines, and their use, follow Program regulations.

Extra Food, Second Servings, Leftovers

There is no limit on the foods that can be offered for sale to children. However, any extra food that is offered to children as part of, not in addition to, a reimbursable meal must be included in the nutrient analysis and count toward the limits on calories, saturated fat, and sodium.

Additional foods offered to children at no charge who have a reimbursable meal count toward the dietary specifications (calories, sodium, saturated fat, and trans-fat). In addition, if the food items are creditable toward a food component in the school meal pattern, they would also be counted and must fit within the weekly requirements for the meal patterns.

A SFA may offer extra beverages at no charge (except Foods of Minimal Nutritional Value) after POS, but these must be considered when analyzing the calorie, saturated fat, and sodium levels associated with the reimbursable meal. The menu planner must be very cautious not to exceed the maximum calorie limit by offering extra beverages after POS, as milk must still be offered with the reimbursable meal. In addition, full-strength juice offered after POS counts toward the weekly juice limit established for the reimbursable meal (no more than half of the total fruit or half of the vegetable offerings over the week may be in the form of juice). Offering juice after the POS would limit the opportunity to include juice as part of the school meal. It could also discourage students’ consumption of fluid milk. Additionally, SFAs are reminded that potable water must be made available during the meal service when meals are claimed for reimbursement at no charge to students in the meal service area.

It is at the discretion of each SFA to charge for second meals or additional servings of meal components. If a SFA charges for second servings, then they are considered a la carte foods and are not included in the nutrient analysis for the reimbursable school meal. SFAs are encouraged to clearly identify the number of servings that children may take as part of the reimbursable meal.

SFAs can easily minimize the impact to the nutrient analysis by modifying the way in which vegetables are offered in the menu. For example, allow children to “choose 0-1” of the food items that would negatively alter the nutrient analysis if chosen as a second or extra, while allowing children to take seconds or extras of those vegetables that do not negatively alter the nutrient analysis if chosen as a second or extra. For example, the school could allow the children to “choose 1 or more” of these vegetables. It is important that each SFA determine how seconds and extras impact their nutrient analysis and plan menus appropriately.

The meal pattern requires a variety of vegetables be offered over the school week and does not put any limits on the amount of vegetables (or fruits) children may take. However, to stay under the required calorie, sodium, and saturated fat limits, a SFA may want to limit some vegetable dishes because they must include second servings and extra foods into the nutrient analysis. Therefore, SFAs should consider the types of foods that students are more likely to select as a second serving and determine how these alter the nutrient analysis.

Desserts such as pudding and ice cream are not considered part of the reimbursable meal. If offered, with the meal it must be included in the dietary specifications of the meal (i.e., calories, saturated fat, trans fat and sodium).

Occasional, small quantities of leftover food served on another day will not be counted toward the meal component requirements, including the vegetable subgroups. The State has discretion to determine whether such leftovers are of a reasonable amount and are not occurring on a regular basis. SFAs may also freeze leftovers and serve them first on the serving line, following standard HACCP protocols, the next time that item reappears in the menu cycle.

However, if leftovers (such as chef salads) are being offered to children on the serving line as part of the reimbursable meal, they must be included in weighted nutrient analyses and are subject to the weekly dietary specifications. If the SFA consistently has leftovers to add to each day’s menus, then the SFA needs to consider participation trends to provide one reimbursable lunch for each child every day.

Multiple Servings and Multiple Serving Lines

If a SFA’s site has multiple serving lines, all required food components, including vegetable subgroups must be planned weekly for each serving line to ensure compliance with weekly meal patterns.  The daily minimum serving requirement applies to fruits, vegetables, grains, meat/meat alternates, and milk (all 5 components) at lunch, and fruits, grains (meats/meat alternates if served), and milk (all 3 components) at breakfast. For menu planning purposes, all offerings must meet the minimum requirement (be equal to or above that amount).

Examples

Example 1:  If a SFA’s site has three serving lines, the meals planned for that line should be planned to ensure that the daily serving size for each food component is offered for that line and that it complies with weekly requirements for that line.  SFAs must also ensure that each vegetable subgroup is planned for that line.  SFAs cannot plan a weekly menu for one line with a missing component or subgroup because a different line offers that food components.  The only exception to this rule is if one serving line is an a la carte line and meals served are not counted as reimbursable. 

Example 2: In grades 9-12 the minimum daily grain requirement is 2 oz. eq. So, if a student is offered a choice between pizza with 2 oz. eq. of grain OR a stir fry with a 1 ounce equivalent of grains, only 1 of those offerings meets the 2 ounce minimum. The student would need to have another ounce equivalent (grain) offered with the stir fry, such as a side item, to meet the daily grains minimu.   

A weekly range requirement applies to both the grain and meat/meat alternate components.

For menu planning purposes, SFAs must offer a weekly menu such that the sum of all daily minimum offerings meets at least the weekly minimum requirement. For grades K-5 and 6-8, the daily grains minimum is only 1 oz. eq., and the weekly grains minimum is 8 oz. eq. The offering of the minimum of only 1 oz. eq. daily would only total 5 oz. eq. across the week. So, on some days, SFAs would have to offer more than 1 oz. eq. of grains as a minimum offering. The same applies to the weekly minimum amount of meat/meat alternate.

Example 3a: If a grade K-5 school offers a 1 oz. eq. grain item (salad) and a 3 oz. eq. grain item (pizza) every day (and instructs the student to select one option only), the minimum weekly offering is 5 oz. eq. grain (1 oz. eq. x 5 days). This menu would not meet the required weekly minimum of 8 oz. eq.

SFAs must also plan their menus so that the sum of the daily maximum offerings for grains and meat/meat alternates is equal to or less than the weekly maximum limit. Therefore, the sum of daily minimums must meet the weekly minimum requirement AND sum of daily maximums must meet the weekly maximum requirement.

Example 3b: If every day a grade 9-12 school offered an item with 3 oz. eq. of grain (even if other items with lower weights were also options), this would add to a total of a possible 15 oz. eq. offered over the week (child could select that 3oz grain item every day). This menu would not meet the required weekly maximum of 12 oz. eq.

As required in Section 210.10(k)(2), each independent line must meet the daily and weekly requirements (including subgroups), to ensure that a child is able to take a reimbursable meal every day in any line they may choose. If serving stations are set up, where a child can go to several different places to select different components of the meal (e.g., first goes to a salad bar, then goes into a pasta station) before passing the point of service, then all the stations as a whole must meet the daily component and weekly vegetable subgroup requirements.

Each of the subgroups must be available to all children in at least the minimum amounts during the week. A child should not have to choose one subgroup over another on a day and lose the opportunity to select the other subgroup that week. If the menu is planned in a way that limits the children’s opportunity to select all vegetable subgroups over the week, the SFA needs to modify the week’s menu to prevent such conflict. For example, if the required dark green vegetable subgroup is offered in one food item/entree and the beans/peas subgroup is offered in a different food item/entrée on the same day, and the student can only pick one, the SFA must provide another opportunity to select either vegetables from the dark green vegetable subgroup or vegetables from the beans, peas, lentil vegetable subgroup  later in the week in order to prevent a subgroup conflict.

                FOOD PRODUCTION RECORDS

A production record is required to be completed for each day’s menu where reimbursable meals are being claimed.  The production record documents the meal prepared then served.  This record indicates whether meals served meet the meal requirements set forth by USDA.  It also serves as a planning tool for the food purchasing and preparation stages of the meal.  Prior to completing a production record, food service staff should plan meals to include all required components and the minimum serving sizes.  With proper planning, schools can complete part of the production record prior to the meal service.  During daily production, the food service staff should record the number of students, number of servings, and the total amount prepared. 

Table 10: Required Elements for Production Records

At a minimum, the production record should contain the following information for each daily menu: ·       The menu and date served ·       Foods used to meet requirements including all condiments ·       Total amount of foods prepared ·       Number of meals prepared ·       Number of meals served ·       Portion size ·       Leftovers ·       Condiments ·       Other items served with the menu

If a school is using the offer-versus-serve method, the staff can forecast the quantity of food needed for preparation by determining which menu items most students will pick.  Example:  if a school offers two entrees, a hamburger or a hot dog, and more students choose a hamburger; the school should plan to serve more hamburgers on the menu.  Forecasting popular food items can reduce food costs.  Schools can offer several choices among the required food components.  Based on the number of choices offered students, the food production record may be very simple or very detailed.  For a prototype production record form contact OKDHS School Nutrition Programs at AFS.School.Nutrition.Programs@okdhs.org.

STANDARDIZED RECIPES

A standardized recipe has been tested and is known to produce the same results and yield every time it is used.  It defines the procedures, the equipment, quantity, and quality of ingredients used in a meal.  When serving reimbursable meals, standardized recipes are necessary to produce enough servings and the correct serving sizes for required food components.  A standardized recipe can also identify required nutrients. 

USDA provides standardized recipes to assist in the production and planning process.  USDA recipes list serving sizes for each required component, number of servings, nutrients, and critical control points necessary to ensure food safety.  All School Food Authorities (SFA) are required to use standardized recipes.

When a SFA chooses not to use USDA recipes, it must create standardized recipes for food items prepared.  Oklahoma Human Services School Nutrition Programs has a standardized recipe form, to request the form email the request to AFS.School.Nutrition.Programs@okdhs.org.  To ensure proper serving sizes, correct yield, and nutrients, schools must follow the recipes as written, including ingredients, brands, and grade of meat and other food items.   

SMART SNACKS REQUIREMENTS

It is important all that food service staff, school administrators, and RCCI administrators (if non-program foods are sold) understand the requirements for the Smart Snack rule because the nutrient standards may affect the way SFAs raise funds for the school food service program and other organizations.  Refer to Chapter 8 for requirements for a la carte items, other food sold on campus, and foods sold for fundraisers.

SUBSTITUTIONS IN CHILD NUTRITION PROGRAMS

Medical or Special Dietary Needs

According to federal regulations, substitutions must be made to the meal pattern for children who have disabilities that restrict their diet. 

Substitutions are not required for children who are not disabled but are unable to consume regular program meals because of medical or other special dietary needs. Refer to USDA-FNS Accommodating Children with Disabilities in the School Meal Programs: Guidance for School Food Professionals (as of 06/01/24, available at https://www.fns.usda.gov/2017-edition-accommodating-children-disabilities-school-meal-programs), for more information.  

Statement for Children with Disabilities

According to the American with Disabilities Act (1990) the term disability means: A physical impairment that substantially limits one or more major life activities of such individual; a record of such impairment; or being regarded as having such impairment (USDA-FNS Accommodating Children with Disabilities in the School Meal Programs: Guidance for School Food Service Professionals, as of 06/01/24, available at https://www.fns.usda.gov/2017-edition-accommodating-children-disabilities-school-meal-programs).  If a student’s disability is episodic, substantially limits a major life activity, the child must be provided reasonable meal modification(s).  Temporary disabilities must be resolved on a case-by-case basis.  USDA regulations 7 CFR Part 15(b) require substitutions or modifications of school meals for children whose disabilities restrict their diets. When possible, the meal modifications for children should be made within the meal patterns.  If a child’s disability requires the meal pattern is changed then a note from a health care professional authorized to write prescriptions in the state of Oklahoma must be obtained.  The final rule [for Child Nutrition (CN) programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] published on April 25, 2024, authorizes registered dietitians to submit medical statement for disability meal modifications beginning on July 1, 2025.  This final rule did not require the registered dietitian to have a state license.  Meal accommodations that do not change the meal pattern can be made without a statement from a medical professional.

The medical professional's (who is authorized to write prescriptions in the state of Oklahoma) statement must identify:

·       the note should identify the child as being disabled, but should not include the specific diagnosis for the child;

·       information about the child’s physical or mental impairment that is sufficient to allow an understanding of how it restricts the child’s diet;

·       An explanation of what must be done to accommodate the child’s disability;

·       The food or foods to be omitted from the child's diet, and the food or choice of foods that must be substituted.

Food Allergies

Generally, children with food allergies or intolerances do not have a disability as defined under either Section 504 of the Rehabilitation Act or Part B of IDEA.  The school food service may, but is not required to, make food substitutions for them. However, when the licensed healthcare professional (who is authorized to write prescriptions in the state of Oklahoma) assessment states in writing food allergies may result in severe and life-threatening (anaphylactic) reactions, the child's condition would meet the definition of "disability," and the substitutions prescribed by the licensed physician must be made.

Beginning July 1, 2025, registered dietitians can also write this medical written statement (this is due to the final rule for CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans published on April 25, 2024, authorizing registered dietitians to submit medical statement for disability meal modifications).

Other Special Dietary Needs

The school food service may make food substitutions, at their discretion, for individual children who do not have a disability, such determinations are only made on a case-by-case basis.  The accommodations must be made within the meal patterns.  School Food Authorities (SFA) may request a medical statement for accommodations made for such children but may not require the statement.  This provision covers those children who have food intolerances or allergies but do not have life-threatening reactions (anaphylactic reactions) when exposed to the food(s) to which they have problems.

SFAs that are pricing programs must charge the same price for substituted foods as the regular price meal.  Although substituted foods may cost the foodservice program more, reimbursement rates for substituted meals will be the same reimbursement for each meal per each student by eligibility category. 

For children with disabilities and special dietary needs, the school and food service personnel should work with family members, other school personnel, and medical personnel responsible for the health, and education of individual students to ensure that reasonable accommodations are made to allow participation in the meal service.

Meal Accommodations and Offer Versus Serve

SFAs participating in Offer Versus Serve (OVS) cannot make meal accommodations by asking a child to exclude the food component/item from their meal selection.  Children in SFAs that participate in OVS must have the option to select all food components/items made available to other children.  For more information see USDA-FNS Accommodating Children with Disabilities in the School Meal Programs: Guidance for School Food Professionals (as of 06/01/24, available at https://www.fns.usda.gov/2017-edition-accommodating-children-disabilities-school-meal-programs) and Offer Versus Serve Guidance for the National School Lunch Program and the School Breakfast Program (as of 06/01/24, available at https://www.fns.usda.gov/updated-offer-vs-serve-guidance-nslp-and-sbp-beginning-sy2015-16)

Religious, Ethnic or Economic Needs

If a school or RCCI wishes to implement a variation in the food components for religious, ethnic, or economic needs, the school must get approval from USDA, Food and Nutrition Service (FNS).  There must be evidence that such variations are nutritionally sound and are necessary to meet religious, ethnic, or economic needs. The sponsor must submit a letter to the SNP unit indicating the substitutions and the reasons for their necessity. The letter is then forwarded to USDA. 

Milk – Substitutions for Non-Medical Reasons

Currently, by regulation, schools must make substitutions for fluid milk for students with a disability when the request is authorized by a licensed healthcare professional (who is authorized to write prescriptions in the state of Oklahoma) and may make substitutions for students with medical or other dietary needs if requested by recognized medical authority.  Beginning on July 1, 2025, the final rule [for CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] published on April 25, 2024, authorizes registered dietitians to submit medical statement for disability meal modifications.  Public Law 108-265 amended the current law to allow schools to substitute non-dairy beverages nutritionally equivalent (as established by the Secretary) to fluid milk for medical or other special dietary needs at the request of a parent/guardian.  The final rule (CN programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans) published on April 25, 2024, have the following nutrition requirements for milk substitutes:

Table 11: Nutrition Requirements for Fluid Milk Substitutes
Nutrient	Per Cup (8 fl. oz.)
Calcium	276 mg.
Protein	8 g
Vitamin A	150 mcg. Retinol Activity Equivalents (RAE)
Vitamin D	2.5 mcg.
Magnesium	24 mg.
Phosphorous	222 mg.
Potassium	349 mg.
Riboflavin	0.44 mg.
Vitamin B-12	1.1 mcg.

SFAs are allowed to accept a written statement from a parent or guardian in lieu of a statement from a recognized medical authority when substituting milk. The supporting statement must identify the student’s medical or other special dietary need that precludes cow’s milk.  It is the SFAs discretion to select the acceptable substitutes that meet the nutritional standards established by USDA requirements (see table 9). 

When a nondairy beverage is offered as a fluid milk substitutes, schools must ensure that it is nutritionally equivalent to fluid milk and provide specific levels of calcium, protein, vitamins A and D, magnesium, phosphorus, potassium, riboflavin, and vitamin B-12.

SFAs will pay for substitution expenses that exceed Federal meal reimbursements.

MEAL CONSUMPTION

Schools must designate specific serving times for lunch, breakfast, and snacks.  All meals should be consumed in the dining area unless another area is designated for meal service.  Meals taken out of the designated food service areas, taken home, or eaten later than the designated lunch times cannot be claimed as a reimbursable meal. 

Meals taken on school field trips may be reimbursed only if the meal meets the meal pattern requirements, this includes the requirement that potable water be available to children during the meal service.  On field trips, milk must be available according to the meal pattern requirements, and therefore, must be stored at the proper temperature to ensure safety.  When serving meals away from the food service area, the school staff must take extra steps to ensure sanitation and food safety. 

Family Style Meals

Family style is an offer-versus-serve meal service option that allows children to serve themselves from common platters of food with assistance from supervising adults. Family style meals are often served in independent living programs and RCCIs.  House parents and school staff can use family style meals as an opportunity to educate students about health, wellness and living skills. 

Additionally, SFAs serving preschool children through NSLP and SBP have the option to use family style meal service.  SFAs should use family styles meals to provide a choice in similar foods and a choice in serving sizes. 

When providing family style meals, the following practices must be conducted:

1. Enough prepared food must be placed on each table to provide the full

 required portion of each of the food components for all children at the table, and to

 accommodate supervising adult(s) if they eat with the children.

2. During the meal, supervising adults must actively encourage each child  

    to accept service of the full required portion for each food component of the meal pattern.

3. The family style meal service allows children to make choices in selecting foods and the size of the initial servings. Children should initially be offered the full required portion of each meal component.

FLEXIBILITY OF MEAL PATTERNS FOR RCCIS

RCCIs are often faced with a challenge of serving different meal patterns to different age/grade groups.  This may be a potential for violence among students at certain types of facilities when they are not served the same portion sized meal.  RCCIs that serve special populations, such as students with severe mental illness or who are at-risk for incarceration, often have legitimate concerns about student unrest at mealtimes

With State agency approval, RCCIs may serve the National School Lunch Program (NSLP) meal pattern in effect for the highest age/grade group served to all residential students if they can demonstrate 1) operational limitations to separating age/grade groups and 2) can show legitimate safety concerns if students are served different portions. 

RCCIs must submit a request to the State agency to utilize this flexibility and clearly articulate the safety concerns to the satisfaction of the State.  State agencies must consider RCCI requests to implement this option on a case-by-case basis and ensure that the above criteria are met.  An

approved exception extends additional meal pattern and dietary specification flexibility to RCCIs for both lunch and breakfast.  For more information regarding policy exceptions for RCCIs contact OKHS School Nutrition Programs at AFS.School.Nutrition.Programs@okdhs.org.

NOTIFICATION OF REIMBURSABLE MEALS AND BREAKFAST PROGRAM

All SFAs must provide student notification of reimbursable meals at the beginning of the meal line [as required by federal regulations 7 CFR Part 210.10 (a) (2) and 7 CFR Part 220.8 (a) (2)].  Using meal identification signage, students are instructed on how much food to select from each component daily to have a reimbursable meal. State agencies and SFAs may establish requirements to fit their menu, facilities, layout, and other considerations. Providing detailed information about the components, such as identifying the vegetable subgroups, is an excellent teaching tool, but is not required.  Federal regulations [7 CFR Part 210.10 (a) (2) and 7 CFR Part 220.8 (a) (2)] requires signage explaining what a reimbursable meal is under Offer versus Serve (OVS) to the children in the meal service area this includes reminding children they must take fruit or a vegetable crediting at least ½ cup toward the meal patterns. Food service programs may use posters, marker boards, or any other resource informs students what constitutes a reimbursable meal. 

Additionally, all SFAs participating in the School Breakfast Program (SBP) must outreach information to all student households to help more children benefit from the School Breakfast Program.  The goal is to increase participation, especially for those students who might otherwise not eat breakfast.  Notifications should:  go out in information packets at the beginning of the year; be listed in bulletins; and be posted on internet sites. 

Although all the foods that are a part of the reimbursable meal do not have to be adjacent to each other, they must be labeled, listed, or otherwise identified near or at the beginning of the serving line, so the students can easily choose all the components for a reimbursable meal. If some of the components of the reimbursable meal (such as the fruits and vegetables) are offered beyond the point of service, the school must ensure that students are aware that every reimbursable meal must include a fruit or a vegetable, and that the total of any fruit or vegetable item selected under OVS must equal at least 1/2 cup.  There must be a system in place to ensure that each reimbursable meal selected by the student under OVS includes a fruit or a vegetable (at least 1/2 cup). 

Record Retention for Meal Planning and Production Records

School Food Authorities (SFA) are required to retain production records not just as documentation used for menu planning, but the production records are   part of the supporting documentation for the monthly reimbursement claim.   Other documentation that is required to be retain include the following:

·       Cycle menus

·       Standardized recipes (retained while being used, and for three years after they are no longer being used)

·       Child Nutrition (CN) labels from the product’s packaging

·       Product formulation statements

·       Notes altering the meal patterns for disabled children from healthcare professionals authorized to write prescriptions in the state of Oklahoma.  This would include medical statements written by registered dietitians altering the meal patterns for children with disabilities.

·       Documentation for milk substitutes meeting the nutrition requirements outlined in the final rule [for Child Nutrition (CN) programs: meal patterns consistent with the 2020 – 2025 Dietary Guidelines for Americans] issued on 04/30/24.

The above documentation and production records are required to be retained for three years after payment for the last reimbursement for the school year has been received.  In the case of cycle menus and standardized recipes     must be retained for the duration of their use and then retained   for three years after payment for the last reimbursement claim has been received for the school year these documents use was ceased.

Chapter Two Resource List

The resources listed in table 11.1 are available upon request to Oklahoma Human Services School Nutrition Programs by email at AFS.School.Nutrition.Programs@okdhs.org.

Table 12.1: Chapter Two Resources
National School Lunch Program (NSLP) Meal Patterns: ·       Five Day Version ·       Seven Day Version	School Breakfast Program (SBP) Meal Patterns: ·       Five Day Version ·       Seven Day Version
Prototype Production Record in Word format	Standardized Recipe Form in Word format
Standardized Recipe Form	USDA FNS Whole Grain Resource for the NSLP and SBP
NSLP Menu Planner in Word format: ·       Five Day Version ·       Seven Day Version	SBP Menu Planner in Word format: ·       Five Day Version ·       Seven Day Version

The resources listed below in table 11.2 are available online.

Table 12.2: Chapter Two Online Resources
The USDA Food Buying Guide for Child Nutrition Programs. Available: ·       Interactive guide at: https://foodbuyingguide.fns.usda.gov/ ·       Mobile app for the guide at: o   The Apple App Store o   The Google Play Store	USDA web page for the National School Lunch Program: ·       https://www.fns.usda.gov/nslp USDA web page for the School Breakfast Program (SBP) ·       https://www.fns.usda.gov/sbp/school-breakfast-program
USDA’s web page for Manufacturer Documentation: Child Nutrition (CN) Labels and Product Formulation Statements: ·       https://www.fns.usda.gov/cn/manufacturer-documentation	USDA CN Labeling webpage: ·       https://www.fns.usda.gov/cn/labeling USDA’s Authorized Labels (CN) and Manufacturers web page ·       https://www.fns.usda.gov/cn/labeling/authorized-labels-manufacturers
USDA Foods in Schools Product Information Sheets: ·       https://www.fns.usda.gov/usda-fis/usda-foods-product-information-sheets	USDA Reducing Added Sugars at School Breakfast: ·       https://www.fns.usda.gov/tn/sbp/reducing-added-sugars