Updated CACFP Meal Patterns and Updated NSLP and SBP Infant and Preschool Meal Patterns

On April 25, 2016, USDA's Food and Nutrition Service published the final rule “Child and Adult Care Food Program: Meal Pattern Revisions Related to the Healthy, Hunger-Free Kids Act of 2010” (81 FR 24348). These regulations were intended, in part, to update the CACFP meal pattern requirements in 7 CFR 226.20 and the meal pattern requirements for infants and preschoolers in the National School Lunch and School Breakfast Programs under 7 CFR 210.10 and 220.8. Child nutrition program (CNP) operators were required to comply with these updated meal pattern requirements no later than Oct. 1, 2017.

FNS recognized the implementation of the updated meal pattern requirements presented challenges for many CNP operators. As a result, FNS offered technical assistance and a transition period for the first year of implementation, effective Oct. 1, 2017 through Sept. 30, 2018, to allow state agencies and CNP operators to adjust to the updated meal pattern requirements. As this transition period comes to an end, FNS applauds the efforts of CNP operators to achieve and maintain compliance with the updated meal pattern requirements.

During the transition year, FNS continued to develop and issue policy guidance and clarifications as well as educational resources, in response to state agencies’ and CNP operators’ implementation needs. These resources include:

• Policy Memoranda and Q&As
• Team Nutrition CACFP Meal Pattern Training Tools
• CACFP Halftime: Thirty on Thursdays Training Webinars

However, state agencies and CNP operators were not fully equipped with these materials at the outset of the implementation period and ongoing feedback has indicated that some operational challenges continue. In addition, state agencies that were awarded CACFP Meal Service Training Grants in August 2018 to assist with implementation of the updated meal pattern requirements have just begun efforts to effectively utilize the grants.

Given the operational challenges still being experienced by state agencies and CNP operators in implementing CACFP and preschool meal pattern requirements, for fiscal year 2019, FNS strongly encourages state agencies to use the flexibilities available to them under 7 CFR 210.18(l)(2) and 226.14(b). For CACFP, when a state agency finds that an institution, which prepares its own meals, is failing to meet meal requirements under 7 CFR 226.20, fiscal action need not be taken if the state agency determines other action would have a corrective effect (7 CFR 226.14(b)). For state agencies monitoring schools serving preschool meal patterns through the school meal programs, in most cases, state agencies are required to provide training and technical assistance and allow for corrective action before fiscal action is assessed (7 CFR 210.18(l)(2)). However, state agencies, and CACFP sponsoring organizations, must continue to take immediate fiscal action if a meal is completely missing one or more of the required food components (see 7 CFR 210.18(l)(2)(i); 226.2, definition of “meal;” 226.14(a); and 226.20(a)).

As implementation of the updated meal patterns continues, technical assistance resources can be found on the CACFP (https://www.fns.usda.gov/cacfp/meals-and-snacks) and Team Nutrition (TeamNutrition.usda.gov) websites. Resources include the CACFP Halftime: Thirty on Thursdays Training Webinars and the new CACFP Trainer’s Corner Quarterly Webinar Series (https://www.fns.usda.gov/tn/webinars-and-training). Information about the newly awarded 2018 CACFP Meal Service Training Grants is available at https://www.fns.usda.gov/tn/meal-service-training-grants-cacfp.

FNS and the Institute of Child Nutrition (ICN) will continue to offer the CACFP Meal Pattern Requirements Training to state agencies and CACFP sponsoring organizations. The training can be requested through the ICN at https://theicn.org/training/. ICN also offers training materials and additional resources for implementing the updated meal pattern requirements that can be found at https://theicn.org/cacfp.

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