ATTENTION CO-OP DIRECTORS, CHILD NUTRITION DIRECTORS, PRE-K PROGRAM DIRECTORS
This memorandum provides flexibility in the service of
grain-based desserts in the Child and Adult Care Food Program (CACFP). This information applies to all School Food
Authorities (SFAs) who provide meals for Pre-K students under the National
School Lunch Program (NSLP) and School Breakfast Programs (SBP).
The Dietary Guidelines for
Americans recommend limiting the consumption of added sugars and solid fats as
part of a healthy eating pattern, and identify grain-based desserts as sources
of added sugars and saturated fats. As a result, under the updated CACFP meal
patterns, grain-based desserts cannot count towards the grain requirement at
any meal or snack (7 CFR 226.20(a)(4)(iii)), starting October 1, 2017. This
requirement was designed to help reduce the amount of added sugar and saturated
fats that children and adults consume, which, as a percentage of calories, is
particularly high in children.
Establishing limits on sugar, saturated fat,
and other nutrients would require program operators to evaluate each grain item
they serve against the nutrient standards, greatly increasing complexity and
burden on program operators. FNS agreed
and concluded that using categories to define grain-based desserts, instead of
establishing nutrient standards, is the best approach for the CACFP meal
pattern. Initially, FNS adopted the definition requested by numerous commenters
to use the foods denoted with a superscript 3 or 4 in Exhibit A of USDA’s “Food
Buying Guide for Child Nutrition Programs; Questions and Answers” (Exhibit
A). This included sweet crackers as
grain-based desserts which would have eliminated the use of sweet crackers such
as graham crackers (all shapes) and animal crackers in the revised CACFP meal
pattern.
Stakeholder feedback indicates that no longer allowing
sweet crackers as part of a reimbursable meal would be particularly challenging
compared to other grain-based desserts. Stakeholders reported that sweet
crackers are appetizing,
low-cost,
and shelf-stable. They are frequently
served in the program.
FNS has made revisions in the
Exhibit A allowing the use of graham crackers and sweet crackers in the revised
CACFP meal pattern for Pre-K students. As a best practice, FNS
encourages SFAs who serve sweet crackers to do so on a limited basis because of
their higher fat content and added sugar.
This revision does not change the designation of sweet
crackers for the School Meal Programs K-12 meal pattern requirements.
Items with the superscript 5 are allowed and
credit toward the Pre-K reimbursable meals. Items
with the superscript 3 and 4 are considered grain-based desserts and cannot
credit as part of the Pre-K reimbursable meal.
Program operators may on occasion still serve grain-based
desserts in the pre-K program. These
items will not credit as part of the reimbursable meal and should be served
only occasionally.
FNS will continue to monitor any challenges associated with
grain-based desserts to determine if more guidance is needed.
If you have questions concerning the use of grain-based
desserts, email your area specialist or contact them at 501-324-9502.