Grain-Based Desserts in the Child and Adult Care Food Program

This memorandum provides flexibility in the service of grain-based desserts in the Child and Adult Care Food Program. Memorandum CACFP 02-2017, Grain Requirements in the Child and Adult Care Food Program; Questions and Answers, Oct. 14, 2016, will be revised to reflect this flexibility.

Grain-Based Desserts

The U.S. Department of Agriculture (USDA) was required to update the CACFP meal patterns to align them with the Dietary Guidelines for Americans (Dietary Guidelines). The Dietary Guidelines 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 Oct. 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 percent of calories, is particularly high in children.

In the proposed rulemaking (https://www.fns.usda.gov/cacfp/fr-011515), USDA’s Food and Nutrition Service (FNS) requested that commenters provide suggestions for the best way to define grain-based desserts. When stakeholders commented on grain-based desserts in the meal pattern proposed rule, the majority supported no longer allowing grain-based desserts to be part of a reimbursable meal. Commenters also offered a definition for grain-based desserts. Commenters observed that establishing limits on sugar, saturated fat, and other nutrients would require centers and day care homes to evaluate each grain item they serve against the nutrient standards. This would have greatly increased complexity and burden on CACFP 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. Therefore, 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."

The Exhibit A that was in effect for the CACFP at the time the proposed rule was published, and which commenters recommended for defining grain-based desserts, did not identify sweet crackers (e.g., graham and animal crackers) as grain-based desserts. However, since the publication of the final rule , FNS revised Exhibit A via memorandum CACFP 02-2017, “Grain Requirements in the Child and Adult Care Food Program; Questions and Answers” (https://www.fns.usda.gov/cacfp/grain-requirements-cacfp-qas) to include sweet crackers as a grain-based dessert. This revision was made to be consistent with the National School Lunch Program and School Breakfast Program (school meal programs) which identifies sweet crackers as grain-based desserts. FNS has gathered extensive feedback from stakeholders on the inclusion of sweet crackers as grain-based desserts in order to understand the primary issues with implementation and develop technical assistance resources. Stakeholder feedback shows 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, and are frequently served in at-risk afterschool programs and rural areas because of these attributes.

In light of the above, and because stakeholders did not have an opportunity to comment on the revised Exhibit A, FNS understands some flexibility is needed. Therefore, Exhibit A has been further revised to exclude sweet crackers from being designated as a grain-based dessert in the CACFP (see Attachment 1). This revision does not change the designation of sweet crackers for the school meal programs’ K-12 meal pattern requirements. As a best practice, FNS encourages centers and day care homes to serve sweet crackers on a limited basis because of their higher added sugar content.

FNS recognizes that centers and day care homes may want to occasionally serve grain-based desserts, such as for celebrations or other special occasions. As a reminder, centers and day care homes continue to have the flexibility to serve grain-based desserts as an additional food item that is not contributing to the reimbursable meal. In addition, FNS will continue to monitor any challenges associated with grain-based desserts to determine if more guidance is needed.

State agencies are reminded to distribute this information to program operators immediately. Program operators should direct any questions regarding this memorandum to the appropriate state agency.

State agencies should direct questions to the appropriate FNS regional office.

Angela Kline
Director
Policy and Program Development Division
Child Nutrition Programs

Attachment

• Exhibit A: Grain Requirement for Child Nutrition Programs