NCA Response – Request for Information on Grain-Based Dessert and High-Protein Yogurt Crediting

Executive Summary NCA’s Response to the RFI

Both sponsoring organizations (sponsors) and program operators recognize the value of the CACFP and the impact it has on the growth and development of children and the quality of child care overall. The CACFP meal pattern ensures that participants receive nutritious meals and snacks and has proven to increase the consumption of milk, vegetables, meat, eggs and whole grains. Operators of the CACFP also recognize the importance of reducing added sugars in the food program.

The CACFP meal patterns were updated in the last child nutrition reauthorization to align with the Dietary Guidelines for Americans in 2010. This resulted in a healthier meal pattern, which NCA strongly supports. However, sponsors and operators have since been met with an increased administrative burden in the CACFP, especially in the area of meal pattern documentation. CACFP regulations require meals and snacks served in the food program to be documented to demonstrate compliance with the meal pattern. While current USDA regulations only require operators to keep records of menus, they do give States the authority to determine and require other types of acceptable record-keeping documents. This has resulted in numerous state-level requirements for meal pattern documentation which has put a significant burden on both sponsors and program operators. Thus, leaving program operators frustrated and expressing the food program is “just not worth it anymore.”

NCA gathered feedback for this RFI through interviews, research, a listening session and a survey of our board members. Overall, NCA urges USDA to avoid creating regulations that further complicate the program and increase the administrative burden on sponsors and program operators, while also considering policies that offer flexibilities to address the needs of every type of CACFP site.

Grain-based dessert responses include:

• NCA opposes the addition of regulations which would require weekly calculations or complicated nutrition analysis for an entire component group.
• NCA recommends FNS explore re-categorizing the cereal bars, breakfast bars, and granola bars category to allow them to be creditable in the CACFP.
• FNS should not establish limits for “grains high in added sugars” for the CACFP.
• FNS should never create any policies that do not align with the current age groups as outlined in the meal patterns (infant, 1–2 year olds, 3-5 year olds, 6-12 year olds, 13-18 year olds and adults).

High-protein yogurt responses include:

• FNS should not create a separate crediting standard for high-protein yogurt that is different from regular yogurt.
• NCA does not support lowering the serving size for high-protein.
• FNS should not adopt the FDA’s definition of “high” for nutrient content claims.
• The addition of another calculation for yogurt (on top of added sugars) would likely prevent operators from serving yogurt products altogether.
• If a high-protein definition were created for yogurt, there should be one definition that is consistent across all age groups.