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Meal Pattern Minute: Medical Statements for Disability Reasons

March 7, 2025

When serving meals in the Child and Adult Care Food Program, a parent/guardian may come to you to discuss meal modifications for their child or older adult due to a disability they have. If a meal modification is requested by the parent/guardian, are you required to request a medical statement to support this claim? 

Watch this Meal Pattern Minute as Isabel Ramos-Lebron, MS, RDN, LD, provides the answer to this important question! 

Want more information? These resources can help. 

  • Child Nutrition Programs: Meal Patterns Consistent With the 2020– 2025 Dietary Guidelines for Americans 
    • This rulemaking finalizes long-term school nutrition requirements based on the goals of the Dietary Guidelines for Americans, 2020–2025, robust stakeholder input, and lessons learned from prior rulemakings. There is a specific section discussing medical statements. Part of this section discusses when medical statements are needed. 
    • “…program operators may accommodate requests related to a disability that are not supported by a medical statement if the requested modification can be accomplished within the program meal patterns and encouraged operators to use this option when possible. At the same time, the updated policy guidance explained that program operators may choose to obtain a written medical statement for all disability meal modifications, even those that fall within the meal patterns...” 
  • Requirement to Accept Medical Statements from Registered Dietitians for Schools and Child and Adult Care Institutions and Facilities (CACFP 07-2025)  
    • When is a medical statement required to support meal modification requests for disability reasons? A medical statement is only required by USDA when the requested modification cannot be accomplished within the Program meal pattern requirements (7 CFR 210.10(m)(1)(i), 220.8(m), and 226.20(g)(1)(i). However, Program operators may choose to require a written medical statement for all disability meal modifications, even those that fall within the Program meal pattern requirements. Program operators should consider the burden of requiring medical statements and must inform parents, guardians, and their children, if age appropriate, of the process for requesting meal modifications (7 CFR 210.10(m)(1)(ii), 220.8(m), and 226.20(g)(1)(i)).
  • Code of Federal Regulations (CFR), 7
    • The CFR reflects the changes made from the Final Rule released on April 24, 2024.  Where there are now only three categories for modifications and variations in reimbursable meals and snacks: modifications for disability reasons, variations for non-disability reasons, and fluid milk substitutes for non-disability reasons.  Below you’ll see the section for modifications for disability reasons. 
      1. Modifications for disability reasons. Institutions and facilities must make meal modifications including substitutions in meals and snacks described in this section for participants with a disability and whose disability restricts their diet. The modification requested must be related to the disability and must be offered at no additional cost to the child or adult participant.
      2. In order to receive Federal reimbursement when a modified meal does not meet the meal pattern requirements specified in this section, the institution or facility must obtain from the household a written medical statement signed by a State licensed healthcare professional. By October 1, 2025, institutions and facilities must also accept a medical statement signed by a registered dietitian. The medical statement must provide sufficient information about the child or adult participant's dietary restrictions, such as foods to be omitted and recommended alternatives, if appropriate. Modified meals that meet the meal pattern requirements in this section are reimbursable with or without a medical statement.

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