USDA Request for Information: Grain-Based Desserts & High-Protein Yogurt

NCA will be developing comments to assist our community in responding to this RFI. NCA members are invited to join us for a Member Policy Briefing on February 7^th to help inform NCA in our comment development. Once model comments are ready, NCA will post a campaign to our action center to make the comment submission process quick and easy.

 

Why It Matters

It is a best practice in Child Nutrition Programs to serve foods that are lower in added sugars and to serve highly-nutritious food items. USDA is continuously looking for ways to ensure that CNPs provide the most nutritious meals. USDA has already taken steps to reduce added sugars in yogurt and cereals and is seeking input on expanding those efforts, without placing an additional burden on program operators or over-complicating program requirements.

 

Current Policies and Potential Alternatives for Grain-Based Desserts

Certain grain products, including cookies, cakes, cereal bars, and toaster pastries, are categorized as grain-based desserts based on their characteristics. FNS' current policy related to grain-based desserts is detailed in The Food Buying Guide for Child Nutrition Programs, Exhibit A. FNS is interested in public input on its current grain-based desserts policies and other approaches that partners recommend for reducing added sugars in the CNPs.

1. What challenges do Program operators face in identifying grain-based desserts, under the current policies?
2. Should FNS adjust its current grain-based desserts policies, such as changing which grain products are categorized as grain-based desserts?

 

Input on Grains High in Added Sugars

In addition to potential changes to its current grain-based desserts policies, FNS is also interested in public input on alternative approaches that partners recommend to reduce added sugars in CNP meals. This includes seeking public input on grain products high in added sugars.

1. Should FNS consider alternative approaches to its current grain-based desserts policies, such as replacing these policies with limits for “grains high in added sugars”?
2. If FNS were to establish limits for “grains high in added sugars,” how should the limits be established?
   1. Should FNS adopt FDA's definition for “high” for nutrient content claims used on food labels to define “grains high in added sugars”? What are the benefits or limitations of this approach?
   2. What opportunities and challenges could arise from having different limits for grains offered to children ages one through three, versus children and adults ages four and older?
   3. What other approaches should FNS consider to define “grains high in added sugars”?

 

Current Policies for Yogurt Crediting

Currently, four ounces (weight) or 1/2 cup (volume) of yogurt credits in the CNPs as one ounce equivalent of meat alternate. High-protein yogurt (which may include Greek and Greek-style yogurt) credits the same as regular yogurt.

1. Are Program operators currently offering Greek or Greek-style yogurt, or other types of yogurt that contain more protein than regular yogurt, as part of reimbursable meals or snacks?
   1. To which age groups and in which meals are these types of yogurt offered?
   2. How frequently are these types of yogurt offered?
   3. Are these types of yogurt popular with participants? Are they more popular than regular yogurt?
2. If Program operators are not offering Greek or Greek-style yogurt, or other types of yogurt that contain more protein than regular yogurt, as frequently as desired, why not? What are the challenges with offering these types of yogurt?

 

Potential Alternatives for High-protein Yogurt Crediting

FNS is interested in public input on potential changes to the current yogurt crediting policies, including what changes would be beneficial to Program operators and participants, and any challenges associated with potential changes.

1. Should FNS create a separate crediting standard for high-protein yogurt that is different than the crediting standard for regular yogurt? Why or why not?
2. If high-protein yogurt contributes differently to the CNP meal patterns than regular yogurt, how should high-protein yogurt be credited? Be as specific as possible, such as the volume or weight needed.
3. If high-protein yogurt were to contribute differently to the CNP meal patterns than regular yogurt, should FNS adopt FDA's definition of “high” for nutrient content claims used on food labels to define high-protein yogurt?
   1. What are the benefits or limitations of this approach?
   2. What opportunities or challenges could arise from having different limits for high-protein yogurt offered to children ages one through three, versus children and adults ages four and older?
4. If high-protein yogurt contributes differently to the CNP meal patterns than regular yogurt, should USDA place any limits on the types of yogurt that can qualify as high-protein yogurt?
   1. Should changes be limited to any specific type of high-protein yogurt?
   2. Should yogurt that is thickened by adding thickening agents ( g., polysaccharides or optional dairy ingredients) credit differently in CNPs? If yes, what implications might that approach have on the requirement for Program operators to plan CNP menus using food-based menu planning?
   3. Should changes include plant-based yogurt alternatives ( g., soy-based yogurt alternatives)?
5. What other approaches should USDA consider for how to define and credit high-protein yogurt?

 

For more information, read the full Request for Information: Grain-Based Desserts and High-Protein Yogurt Crediting in Child Nutrition Programs. To provide feedback to USDA on the RFI, visit regulations.gov. NCA will be sharing model comments in February.