Comment Requested – Revisions to Meal Patterns Consistent with the 2020 DGAs
March 23, 2023
Based on feedback from our members, NCA has developed the following model comments to help you provide feedback to USDA about the Proposed Rule.
How to Make Your Comments
CHOOSE: Choose one of the following model comments options.
Option 1: Model Comments include top three items.
Option 2: Model Comments include items we support and do not support.
Option 3: Model Comments include items we support and do not support with extended explanation.
MAKE IT YOUR OWN: Customize your comment. It is important for you to personalize your comment based on your opinion and experience.
SUBMIT: Select “Submit Comments” and copy and paste your letter into the comment box.
DEADLINE: Monday, April 10 Deadline Extended - New Deadline is Wednesday, May 10
Tips for Commenting:
- Unique model comments are more likely to draw attention and be weighted heavier by USDA. Therefore, while we are providing model comments, we strongly suggest making these your own and adding personal anecdotes and perspectives to your comments.
- You can comment on any or all of the proposed rules. For example, if you feel very strongly about one particular change only comment on that change and focus on providing your unique perspective and supporting argument.
- Prior to submitting your comments, read our summary of the proposed changes that would impact CACFP and SFSP and/or watch out on-demand webinar with USDA. Also, check out more tips for submitting effective comments.
Submit comments by May 10. Either copy and paste your comments into the comment box or drag and drop or upload a file of your comments. When you’re done, be sure to press the Submit Comment Button at the bottom of the page.
Option 1: Model Comments Top Three Items
Thank you for asking for our feedback on the meal pattern changes proposed in FNS-2022-0043-0001. As an operator of the CACFP and/or SFSP, these will impact my organization and all we serve.
Added Sugars
I support transitioning from a total sugar limit in the CACFP to an added sugar limit to align the CACFP with the Dietary Guidelines for Americans only if providers can continue to use the WIC list to identify breakfast cereals that are creditable in the CACFP.
Terminology Changes
I do not support changing terminology from "meat/meat alternate” to “protein sources,” “food components” to “meal components,” or “grains” to “grain items.” These changes will be costly and require significant retraining. Changing “meat/meat alternate” to “protein source” is unnecessary and will make determining which foods are creditable as protein sources difficult in the CACFP/SFSP.
Milk
I do not support aligning CACFP in any future rulemaking with school meals should Alternative A be finalized with sugar limits and/or restrictions on flavored milk for grades K–8 or K–5 in NSLP and SBP.
Thank you,
[Name, Title]
[Organization Name]
Option 2: Model Comments Simple Letter
As a member of the [CACFP/SFSP] community and a [sponsor/provider] of [CACFP/SFSP], thank you for asking for our feedback. I would like to comment on the meal pattern changes proposed in FNS-2022-0043-0001 that will impact my organization, [org name].
I recognize the importance of aligning with the science-based recommendations of the 2020-2025 Dietary Guidelines for Americans, however the USDA must ensure that proposed changes do not place a significant cost or administrative burden on CACFP and SFSP operators.
I support allowing institutions and facilities, or sponsors, as applicable, that serve primarily American Indian or Alaska Native children to substitute vegetables for grains or breads.
I support explicitly stating in regulations that traditional foods may be served in reimbursable school meals.
I support allowing nuts and seeds to credit for the full meat/meat alternate component.
I support expanding geographic preference options by allowing locally grown, raised, or caught as procurement specifications for unprocessed or minimally processed food items.
I support transitioning to added sugar limits for breakfast cereals and yogurts, but only if the WIC list can be used for cereals credited in the CACFP.
I do not support changing terminology from “meat/meat alternate” to “protein sources.”
I do not support changing terminology from “food components” to “meal components.”
I do not support changing terminology from “grains” to “grain items.”
I do not support aligning CACFP in any future rulemaking with school meals should Alternative A be finalized with sugar limits and/or restrictions on flavored milk for grades K–8 or K–5 in NSLP and SBP.
Thank you for the opportunity to submit comments on the proposed rule Child Nutrition Programs: Revisions to Meal Patterns Consistent With the 2020 Dietary Guidelines for Americans.
[Name, Title]
[Organization Name]
Option 3: Model Comments Extended Letter
As a member of the [CACFP/SFSP] community and a [sponsor/provider] of [CACFP/SFSP], thank you for asking for our feedback. I would like to comment on the meal pattern changes proposed in FNS-2022-0043-0001 that will impact my organization, [org name].
Terminology Changes
I do not support changing terminology from "meat/meat alternate” to “protein sources,” “food components” to “meal components,” or “grains” to “grain items.” These changes may seem insignificant, but they would require all materials with any of these terms to be redone and redistributed which would be incredibly costly and time consuming for operators who do not have the funds or manpower to do so. In addition, the change from “meat/meat alternate” to “protein source” would cause confusion as to which foods are creditable as protein sources and operators would need to be retrained on all terminology changes.
Milk
I do not support aligning CACFP in any future rulemaking with school meals should Alternative A be finalized with sugar limits and/or restrictions on flavored milk for grades K–8 or K–5 in NSLP and SBP.
Added Sugars
I support transitioning from a total sugar limit in the CACFP to an added sugar limit to align the CACFP with the Dietary Guidelines for Americans only if providers can continue to use the WIC list to identify breakfast cereals that are creditable in the CACFP. USDA must also ensure that creditable breakfast cereals and yogurts are widely available at an affordable price in both retail and foodservice. There also needs to be flexibility while operators make this transition, with a reasonable timeline for proper training.
Menu Planning Options for American Indian and Alaskan Native Students
I support the equitable practice of allowing American Indian and Alaskan Native sites to substitute vegetables for grains. However, USDA must ensure that the administrative burden for implementing this change will be minimal.
Traditional Foods
The "traditional foods” definition should be expanded to include traditional foods of other diverse cultures.
I would like to see the following traditional foods included in the Food Buying Guide: [insert traditional foods]
Nuts and Seeds
I support allowing nuts and seeds to credit for the full meat/meat alternate component. CACFP and SFSP already allow nuts and seeds to credit for the full meat/meat alternates component at Snack, so this addition will better align and simplify the meal pattern. While this change may cause concern about choking hazards and nut allergies, providers with young children typically do not serve nuts or seeds anyway.
Geographic Preference Expansion
I support expanding geographic preference options, as they would be beneficial in allowing CACFP child care centers and SFSP Sponsors to procure local foods through the bidding process.
Thank you for the opportunity to submit comments on the proposed rule Child Nutrition Programs: Revisions to Meal Patterns Consistent With the 2020 Dietary Guidelines for Americans.
[Name, Title]
[Organization Name]
You can also mail in your comments to School Meals Policy Division, Food and Nutrition Service, P.O. Box 9233, Reston, Virginia 20195.