Flexibility for Co-Mingled Preschool Meals: Questions and Answers

This memorandum provides guidance on meals served to preschoolers when they are in the same service area at the same time as grade K-5 students, and it includes Questions and Answers. Additional guidance on the National School Lunch Program’s and School Breakfast Program’s (school meal programs) infant and preschool meal pattern requirements will be issued soon.

Background

On April 25, 2016, the U.S. Department of Agriculture’s Food and Nutrition Service (FNS) 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) to update the school meal programs’ meal pattern requirements for infants and preschoolers under parts 7 CFR 210.10 and 220.8. Schools serving meals to infants and children ages 1- through 4-years old (preschoolers) must comply with these updated meal pattern requirements no later than Oct. 1, 2017.

Co-Mingled Grades

FNS recognizes that some schools serve meals to preschoolers and grade K-5 students in the same service area at the same time. These co-mingled situations may create counting and claiming issues because it may be challenging to determine during a meal service if a child is in preschool or K-5, and the meal pattern requirements for preschoolers and K5 students are slightly different. For example, children may arrive on the same bus and enter the cafeteria for breakfast together. In this situation, it may be difficult for meal service staff to determine which children are in preschool or K-5.

In recognizing these potential integrity issues and the operational challenges, over fifty commenters on the proposed rule requested flexibility to offer a single menu when preschoolers and K-5 students may be co-mingled. In the preamble of the final rule, FNS committed to retaining the flexibility previously afforded to co-mingled meal service situations. Following publication of the final rule, FNS continued to engage in stakeholder feedback regarding the implementation of the updated preschool meal patterns in comingled situations to assess the primary issues. It is clear from stakeholder feedback that it is in the best interest of the child nutrition programs (CNP) to allow a single menu flexibility when preschoolers and K-5 students are in the same service area at the same time. This will help reduce administrative burdens and ensure integrity of the CNPs. Therefore, schools that serve meals to preschoolers and K-5 students in the same service area at the same time may choose to follow the grade-appropriate meals patterns for each grade group, or serve the K-5 meal pattern under parts 7 CFR 210.10 and 220.8 to both grade groups.

Although FNS is providing this flexibility, FNS strongly encourages schools to find ways to serve grade-appropriate meals to preschoolers and K-5 students to best address their nutritional needs. School food authorities should work with their state agency to find solutions to enable them to serve students their grade-appropriate meal pattern prior to using this single menu flexibility. Some best practices to avoid co-mingling situations include serving breakfast in the classroom or staggering the meal service time for preschoolers and K-5 students.

FNS understands implementation of the updated preschool meal patterns will be a significant change for some schools and schools need time to adjust to new processes. Schools are encouraged to use the transition period FNS provided in memorandum SP 30-2017 “Transition Period for the Updated Child and Adult Care Food Program Meal Patterns and the Updated National School Lunch Program and School Breakfast Program Infant and Preschool Meal Patterns” (https://www.fns.usda.gov/transition-period-updated-cacfp-infant-preschool-meal-patterns) to identify strategies to successfully serve the grade-appropriate meals when preschoolers and K-5 students are co-mingled at meal service time. During the transition period (School Year 2017-2018), state agencies must provide technical assistance in lieu of fiscal action when they observe violations related to the updated meal pattern requirements.

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