Arkansas Department of Education Division of Elementary and Secondary Education Child Nutrition Flexibilities for Milk, Whole Grains, and Sodium Requirements beginning July 1, 2019

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Memo Number
Memo Date
Memo Type
Child Nutrition
Regulatory Authority
Response Required
Superintendents; Principals; General Business Managers; Bookkeepers; Child Nutrition Directors/Managers

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Memo Text



The purpose of this memo is to provide information and guidance on the final rule flexibility requirements pertaining specifically to milk, whole grains, and sodium effective SY 2019-2020, which begins July 1, 2019. The final rule is aimed to assist schools in overcoming operational challenges related to the school meals regulations implemented in 2012.


Milk Flexibility

Beginning SY 2019-2020, this final rule will provide National School Lunch Program (NSLP) and School Breakfast Program (SBP) operators with the option to offer flavored, low-fat milk and require that unflavored milk be offered at each meal service. For consistency, the flavored, low-fat milk option will be extended to beverages for sale during the school day, and will also apply in the Special Milk Program (SMP) and Child and Adult Care Food Program (CACFP) for participants ages 6 and older. The Summer Food Service Program (SFSP) currently allows flavored, low-fat milk with summer meals so this rule makes no change to milk service in the SFSP.


NSLP and SBP operators that choose to offer flavored milk must also offer unflavored milk (fat-free or low-fat) at the same meal service. This requirement will ensure that milk variety in the NSLP and SBP is not limited to flavored milk choices. It is expected to help schools that choose to offer flavored milk in their menus stay within the weekly dietary specifications.


By broadening the flavored milk choices in the Child Nutrition Programs, USDA seeks to remove regulatory restrictions that may hinder milk consumption.


Whole Grain-Rich Flexibility
Beginning SY 2019-2020, this final rule will require that at least half of the weekly grains offered in the NSLP and SBP meet the whole grain-rich criteria specified in FNS guidance, and that the remaining grain items offered must be enriched. Requiring that at least half of the weekly grains offered in the NSLP and SBP be whole grain-rich is a minimum standard that schools have already accomplished and is highly achievable, and provides exceptional flexibility for local operators in planning wholesome and appealing school meals. Schools already offering all grains as whole grain-rich do not have to change their menus as a result of this final rule.


By setting a more feasible whole grain-rich requirement in the NSLP and SBP, school districts nationwide are expected to incorporate whole grains easily while still providing menu items that meet local preferences. USDA encourages program operators to incorporate whole grain-rich products in the school menu when possible, especially in popular menu items such as pizza. This change will remove the need for whole grain-rich exemption requests.


Sodium Flexibility
This final rule will provide schools in the NSLP and SBP more time for gradual sodium reduction by:
- Retaining Sodium Target 1 through the end of SY 2023-2024,
- Requiring compliance with Sodium Target 2 in SY 2024-2025 (which begins July 1, 2024; see charts), and
- Eliminating the Final Target that would have gone into effect in SY 2022-2023



For the sake of clarity, it is important to note that the sodium limit applies to the average meal offered during the school week; it does not apply per day or per meal. Menu planners may offer a relatively high sodium meal or high sodium food at some point during the week if meals with lower to moderate sodium content are offered the rest of the week.


Setting a more flexible approach to sodium reduction allows more time for product reformulation, school menu adjustments, food service changes, personnel training, and changes in student preferences. We encourage families and communities to support schools' efforts by taking gradual steps to reduce the sodium content of meals offered to children outside of schools. Wholesome school meals are only a part of children's daily food intake, and children will be more likely to eat them if the foods available to them at home and in the community are also lower in sodium. Helping students adjust their taste preferences requires collaboration between schools, parents, and communities.


Student, parent, and community involvement in menu planning is allowed at 7 CFR 210.12(a). The local school wellness policy at 7 CFR 210.31 also provides an important opportunity to influence the school nutrition environment at large.


This final rule balances nutrition science, practical application of requirements, and the need to ensure that children receive wholesome and appealing meals.


This rule is effective July 1, 2019.


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