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Substituting Vegetables for Grains in American Samoa, Guam, Hawaii, Puerto Rico, the U.S. Virgin Islands, and Tribal Communities

FNS Document #
SP 03-2025, CACFP 03-2025, SFSP 01-2025
Resource type
Policy
Policy Memos
Resource Materials
PDF Icon Policy memo (201.57 KB)
DATE:October 30, 2024
POLICY MEMO:SP 03-2025, CACFP 03-2025, SFSP 01-2025
SUBJECT:Substituting Vegetables for Grains in American Samoa, Guam, Hawaii, Puerto Rico, the U.S. Virgin Islands, and Tribal Communities
TO:Regional Directors
Special Nutrition Programs
All Regions
State Directors
Child Nutrition Programs
All States

On April 25, 2024, the U.S. Department of Agriculture’s (USDA) Food and Nutrition Service (FNS) published the final rule, Child Nutrition Programs: Meal Patterns Consistent With the 2020-2025 Dietary Guidelines for Americans (89 FR 31962). While most provisions in the 2024 final rule focus on the National School Lunch Program (NSLP) and School Breakfast Program (SBP), this rule also includes limited updates to the Child and Adult Care Food Program (CACFP) and the Summer Food Service Program (SFSP) to better align child nutrition programs (CNP) requirements. These updates represent continued progress toward supporting the nutritional quality of meals offered through the CNPs and meeting cultural food preferences of program participants.

This memorandum clarifies longstanding program regulations and provides updated guidance on the use of vegetables as a substitution for grains, including whole grain-rich products, in eligible areas, as described in program regulations. This guidance also provides updates on the expansion of this flexibility to eligible areas following the 2024 final rule. Lastly, this memorandum informs affected state agencies and program operators how to credit vegetables toward the grains component for all CNPs, including the NSLP, SBP, SFSP, and CACFP. This memorandum supersedes SP 29-2013, Crediting Vegetables for Grains in American Samoa, Puerto Rico, and the Virgin Islands, issued on March 21, 2013.

Longstanding Program Regulations

Longstanding program regulations at 7 CFR 210.10(c)(3), 220.8(c)(3), 225.16(f)(3), and 226.20(f) allowed program operators in American Samoa, Puerto Rico, and the U.S. Virgin Islands to substitute vegetables to meet the grains or breads component in the NSLP, SBP, SFSP, and CACFP. Additionally, prior regulations allowed this option in Guam for SFSP and CACFP sponsors, institutions, and facilities.

2024 Final Rule Updates

The 2024 final rule amended existing regulations to allow additional program operators and areas to substitute vegetables to meet the grains or breads component. Expanding this menu planning option responds to extensive partner feedback and is intended to support traditional foodways in CNPs. A full list of eligible areas and entities, including those that were eligible under prior regulations and those that are newly eligible under the 2024 final rule, is below. The 2024 final rule also clarified that any creditable vegetable can be substituted for the grains or bread component with an emphasis on traditional and culturally relevant vegetables.

List of Eligible Entities: Qualifying Criteria

The table below outlines all programs that are eligible to use this menu planning flexibility and the corresponding regulatory citations. Program operators only need to meet one of the qualifying criteria for the relevant program in order to implement the menu planning flexibility.

ProgramExisting Eligible EntitiesNew Eligible EntitiesRegulation
NSLPSchools in American Samoa, Puerto Rico, and the U.S. Virgin Islands.
  • Schools in Guam and Hawaii.
  • SFAs and schools that are Tribally operated, operated by the Bureau of Indian Education or that serve primarily American Indian or Alaska Native children.
7 CFR 210.10(c)(3)
SBPSchools in American Samoa, Puerto Rico, and the U.S. Virgin Islands.
  • Schools in Guam and Hawaii.
  • SFAs and schools that are Tribally operated, operated by the Bureau of Indian Education or that serve primarily American Indian or Alaska Native children.
7 CFR 220.8(c)(3)
SFSPPrograms in American Samoa, Guam, Puerto Rico, and the U.S. Virgin Islands.
  • Programs in Hawaii.
  • Sponsors and sites in any state that serve primarily American Indian or Alaska Native children.

7 CFR 225.16(f)(3)

CACFPPrograms in American Samoa, Guam, Puerto Rico, and the U.S. Virgin Islands.
  • Programs in Hawaii.
  • Institutions or facilities in any State that serve primarily American Indian or Alaska Native participants.
7 CFR 226.20(f)

For the purpose of this menu planning option, “serving primarily American Indian or Alaska Native” applies to programs where American Indian or Alaska Native participants represent the largest demographic group of enrolled participants.

State agencies are reminded to distribute this information to program operators immediately. Program operators should direct any questions concerning this guidance to their state agency. State agencies should direct questions to the appropriate FNS regional office.

Andrea Farmer
Director
School Meals Policy Division
J. Kevin Maskornick
Director
Community Meals Policy Division

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Page updated: November 13, 2024