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SNA Addresses Meal Pattern Concerns with Development of Implementation Guide

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May 31, 2012 - SNA is taking an active role in addressing meal pattern questions and has appointed an ad hoc working group to develop a practical “How-To Guide” for SNA members. The goal of this guide is to assist in the challenges of implementing the new meal pattern requirements scheduled to go into effect this fall.

The ad hoc group is composed of representatives from USDA, state agencies, foodservice operators and industry. The working group meets regularly via a series of conference calls to develop the “New Meal Pattern Guidelines: A Companion Guide.” The Guide will address the meal pattern requirements for lunch. This training resource will be unveiled at SNA's Annual National Conference (ANC) in Denver in July, as part of four “hot topic” education sessions.

SNA members are strongly encouraged to share their comments and concerns with the ad hoc group regarding the challenges they are facing  in understanding and implementing the final meal pattern requirements. SNA urges you to submit your comments below this web posting and provide your input on areas of greatest concern and challenge as it relates to the final meal pattern.  Further, please feel free to directly contact SNA staff liaisons on this project: Cathy Schuchart, SNA VP, Child Nutrition and Policy and Danny Seymour, SNA Dean of Education at the following email addresses: cschuchart@schoolnutrition.org and dseymour@schoolnutrition.org.

The Ad Hoc group consists of the following state agency directors: Colleen Fillmore (ID), Catherine Digilio Grimes (VA), Lynn Harvey (NC), Katie Millett (MA) and Robin Safley (FL). Individuals representing the food service operator segment include: Wanda Grant (CA), Penny McConnell (VA), Jean Ronnei (MN), and Ken Yant (GA). Pat McCoy of Schwan’s Food Service, Inc., will participate on behalf of the SNA industry segment. George Sneller, former Child Nutrition Director, Office of Superintendent of Public Instruction in Washington will serve as the project consultant. A representative from USDA is also participating in project development.

 

Posted by Admin1 at 5/31/2012 9:44 AM

Greatest concern is meeting caloric minimums based on planned numbers. Our district is only 30% Free/Reduced. The students just don't take enough food to reach the calorie minimums. We are adding higher calorie entrees and extras like ice cream in order to meet minimums. Grain maximums are the second greatest concern. In the past we could add extra whole grain servings to meet calorie requirements, now we are forced to use other calorie sources as mentioned above.
Posted by: Shirley Parker at 5/31/2012 11:08 AM


As a Director I have concerns that an average parent will need simple guidance on what the new propsals mean to them and their children both nutritionally and financially. Help offered to us would be welcomed.
Posted by: Brian Reynolds Director Wilton Public Schools at 5/31/2012 11:12 AM


Meeting the new grain requirement seems almost impossible. Putting a 2 oz meat patty on a 2 ounce equivalent grain will lead to the old saying, "Where is the beef." My bread vendor cannot supply a 2 oz equivalent bun at this time. I am also afraid that many of our students will not accept the new offerings and just not participate in the program. We need more flexibility in doing the right thing!
Posted by: Brenda S Hawkins at 5/31/2012 11:16 AM


I whole-heartedly agree with feeding our children healthy meals and I feel most of us are doing a great job. There are those few that give the rest of our child nutrition programs a bad image and those are the ones that make headlines. But, we need more money to implement the new guidelines so that the programs that are operating in the "black" can continue to do so. We operate the FFVP at our elementary schools and wonder how much fruit & vegetables can I serve to K - 6th grade students and they will consume. Implement mandatory "play first, eat later" for elementaries to help with this concern along with lack of physical activity during the day.
Posted by: Charlene Baker at 5/31/2012 11:17 AM


I understand that we want to get these kids to eat healthy but how are we going to make them eat vegetables or fruit. I have students who refuse to take either so now I have to make them put something on their tray so that they can throw it in the garbage. I can hear parents complain about the waste and why am I forcing their child to take something that they don't want.
Posted by: Joyce Gaulke at 5/31/2012 11:18 AM


we are conserned that some have mentiond that marinated bean salad will not be able to be counted as a serving of beans due to the fact that is has other ingredients other than beans in it. Salsa is not a red vegetable due to the same, other ingredients present. Broccoli normanday will only be able to be counted as an "other" vegetable due to the fact it is not all broccoli, so you can not count any of the dark greeen. Is there any official ruling on this?
Posted by: Cindy Smith at 5/31/2012 11:23 AM


Can you spell out "leafy greens"? I know Romaine lettuce would require 1cup = 1/2 cup veg serving but what about Kale and Spinach?
Posted by: Kris Diller at 5/31/2012 11:24 AM


Our district consists of 53 schools with appox. enrollment of 50,000 students. 9th grade is included in our middle schools. It is of great concern to us that there is no calorie overlap between 8th and 9th grade. I feel it is unreasonable that we need to identify our 9th graders to address the additional mandated 50 calories.
Posted by: Jana Cruz at 5/31/2012 11:25 AM


With the new guidelines set up for K-5, 6-9, and 10-12 divisions, schools are faced with singling out students who have meal times mixed with another group. Example is that we have several 9th graders who eat Sr. High lunch. We would have to single out those students to take less (9th grade) or more (10-12 gr). We also now have to have two different inventories for breads. We currently bake almost all of our bread products. We have to have 2 different sizes for Jr. High and Sr. High., Lower Grade and Higher grade school. What a mess.
Posted by: Donna at 5/31/2012 11:26 AM


Our district has always taken pride in offering our elementary students 5 entree choices per day. With the new bread min/max, this is going to be taken away because we won't be able to meet. USDA has mandated that the daily minimum is 1 G/B. With this, logic tells you that the minimum should be 5 G/B for the week. 1 per day for 5 days is 5?? Not by USDA figures, it is 8 for the minimum. Offering 1 G/B is not feasible, not enough, and offering 2 G/B is too much, ending up with 10. So if we offer yogurt and a 1 oz bread item, we end up with 5 at the end of the week, not enough. If we offer a 1.5 oz B/G product we end up with 7.5, not enough for the minimum. If we offer a 2 oz B/G with it, we end up with 10, too much. We can't offer one B/G one day and another for other days, this would totally confuse the students.

Another concern is for our 7th and 8th grade students. I don't see how you can expect a student of that age to eat a 1 oz meat patty and a 1 or 1.5 oz bun along with the fruits and veggies and not be hungry by the time school gets out. It is almost an embarrassment to put out a portion of protein that small and have to continue to raise lunch prices to stay within the guidelines!!
Posted by: Lori Danella at 5/31/2012 11:31 AM


The maximum grain rule and protien rule are very difficult to deal with from a manufature as well as a operator standpoint.

The maximum grain rule and maximum protien rule is eliminating the variety schools and industry can offer, and it will have significant unintended consequences.

The industry in general is not ready for the required need at operator level.

The Fed is not ready for the flood of new label approvals that this will entail!
Posted by: Brian Hofmeier( Visit ) at 5/31/2012 11:45 AM


While menu planning I am finding it hard to meet the calories for middle and high school, with staying in the range of minimum grains and meat. On elementary menus the challenge has been the minimum/maximum grains. Any menu suggestions would be helpful.
Posted by: Teresa Arnold at 5/31/2012 11:45 AM


I am very concerned that our 5th grade students fall into the same category as kindergarten for nutritional guidelines. By 5th grade our student are developing and having growth spurts that require more calories. If the age categories aren't changed, at least allow 5th graders to slide in with 6-8 students, which seems like more of a natural division. Our Middle School is 5-8 grades as are many others and we are figuring out how to identify them when they are served so they can get smaller portions. I see all kinds of student issues with that.
Posted by: Candy Anderson at 5/31/2012 11:47 AM


Question Regarding Beans / Legumes.

If two servings of Beans / Legumes are served during one meal in the NSLP, can one serving count towards the Vegetable / Legume Requirement and the second count towards the meat / meat alternate requriement?

The USDA comments mention that one serving may not count as both, but make no mention of two servings in the same meal.

Here is the USDA comment from section 32 of Memo SP 10-2012 - REVISED, released on April 27, 2012.

32. How may beans/peas (legumes) be used in school meals?
Dry/mature beans and peas may be offered as a meat alternate or as a vegetable, at the
discretion of the menu planner. However, one serving may not count toward both food
components in the same meal. For example, one serving of refried beans can be offered as a
vegetable in one meal and as a meat/meat alternate on another occasion. The refried beans
offered as a vegetable count toward the weekly beans/peas requirement, but not toward the
meat/meat alternate weekly range. Menu planners must determine in advance how to count
beans/peas in a meal. For additional guidance on beans and peas, see:
http://www.choosemyplate.gov/food-groups/vegetables-beans-peas.html
Posted by: Chris Elliott( Visit ) at 5/31/2012 11:55 AM


I am very happy we are trying to get our children to eat more healthy.But my concern is if we have to give it to them.and they turn around and throw it in the trash.the whole grains have gone over very well,and my kids love fruit ,but to get them to try a new veg,that might be a little tough.But i will give it my all.
Posted by: Caroline Bernal at 5/31/2012 11:58 AM


I am concerned about how the student come to lunch. We are a k-12 school everyone is in one building. K-2 eat first, then 3-4th graders,no problem, then it gets complicated 9-12 eats next then pre k, then the 5-8th grades.do we have to pull the main dishes, fruits, vegetables, salads etc.to figure out how much each age group ate, we have only a few minutes before the next group arrives. Am I making this more difficult than it really is?
Posted by: Rose Meincke at 5/31/2012 11:59 AM


I am having trouble in several areas, but one of my main concerns is the grain amounts. How do you not serve an elementary student an entire sandwich? As it stands now we will only be able to give them one slice of bread on a sandwich day.
We have a large amount of our student body that also likes/relys on the bread and butter and the bread and peanut butter sandwiches we have put out on the line as extra food to help fill the kids up. On grain days we will not be able to do that. What happens to the students that are at school from 7:00 (or before) for activities, tests, practice, ect and that are still there at 6:00 when practice is finished? How will the limited amount of calories provide the energy for them to give their all? How do I justify my meal plan and leave the kids hungry so that as soon as the bell rings they are heading to Burger King, McDonalds, etc to eat another meal? Does not that defeat our purpose for a healthier lifestyle for them? I am not 100 percent sure that I can get the backing for less food from my administration who is always asking for more to fill up the kids and "better" items. Still have to live within a restricted budget but have to pay more for items to be in compliance.
Posted by: Judi Olson at 5/31/2012 12:08 PM


I am concerned, I have been working on new menus, I can get the week to work out on our new form. but then it does not work on nutri-kids system. that is becoming a big problem with all that I have talked to. We have to remember not all get the required time to create menus and anaylize them. YOU need to help up with the nutrition part. I have Hy-Vee helping and are still having to many questions.
Posted by: Judy Lubben at 5/31/2012 12:13 PM


As I read all the comments, I feel that my concerns are very much addressed. I just would like a very simply guidline that I can pass on to my parents, students and district staff. It seem as though they have put the cart before the horse. It seem as they should have had some of the sources in place that will help,FSD, implement the new guidelines, example: Food Buying Guide, USDA Recipes. We have less time to implement the new guidelines than they had to sit back and create. This can be posted or not, it just good to let some of the frustrations out.
Posted by: Geraldine Jette at 5/31/2012 12:21 PM


I don't know how we are going to meet the new meal pattern. We definitely need more training.

I also don't think the analysis should be based on what the manger plans for the students. If they are realistic in planning we will never meet the requirements. I do not agree with all the changes in Child Nutrition.
Posted by: rrobinson at 5/31/2012 12:35 PM


I am very concerned that my High School student will start to leave at lunch time. I offer a large variety of entree choices. I will not be able to offer a variety of entrees that include two grains say nothing about only 1,5 oz protein choice. A senior athlete will not be happy with 1/2 c of pasta/ with a ioz whole grain roll. I have 12% free and reduced rate. The student will go across the street to MacDonald's ,Wendy's or Amartos and get what they want. The max grain and protein requirements are going to lower my particiation. I am even considering pulling the High school out of the National School Lunch program due to the inability of offer many different entrees due to the limits on the amounts of grains and protein we are allowed to offer in a 5 day period.

My next concern is my k-2 schools. We offer 3 vegetable choices and 3 fruit choices each day. Now to tell them that they must take at least 1/2c of a fruit or vegetable means that the waste is going up and my cost is going to go up. K students have a hard enough time eating 2 items on their tray, To force them to take 1/2 c of Fruit or Vegetable is not going to mean that the food is going to be consumed. I don't want to feed the trash can.
Posted by: Judith Campbell at 5/31/2012 12:36 PM


We are having issues in the fruit/vegetable sizes. We offer at least 3-4 fresh fruits and an equivalent number of fresh vegetables daily. It will be confusing to my staff to remember all the variations in portion sizes for the various grade levels. I wish USDA would have said to serve 1 cup of fruits and 1 cup of vegetables for the high school kids across the board and 1/2 cup of each at the elementary level. This bit of 3/4 cup of red orange vegetables is silly.

We offer 5 entree choices at the elementary level and with a one week menu at my high school a student can choose to each something different for 42 days without eating the same entree. We can't begin to figure out our secondary menu and keep it in line with the meat and grain requirements. We thought USDA would be reasonable and use averaging on the meats/grains. As I now understand it, each line will be considered individually and each entree item on the line must fall within the guidelines. We have always offered a yogurt lunch with a 1 grain side at the high school - no more - it's too expensive. I guess my whole frustration is that USDA has taken a very narrow view with the guidelines while I view nutrition as an inexact science. It is more about moderation and choices. This will severely limit choices. I'm in a district with less than 10% free and reduced kids. They are savvy consumers and overall choose very wisely. These changes will force me to drastically cut their options/choices. I'm contemplating taking my high school off the program if the kids revolt - which they will. I'm not going for the additional 6 cents - I plan on letting everyone else figure it out and see how much their participation drops before I make all the changes. Good luck to us all - we need it -retirement is just around the corner and I'm hoping to be out of this mess before my next review.
Posted by: Amy Anderson at 5/31/2012 12:47 PM


1. When a variety of entree choices are offered, I don't know how to determine the minimum/maximum # of grains and proteins.
2. Not enough time has been given to us to implement the new meal pattern when there are still unanswered questions.
3. Am I correct that we are to meet the meal pattern via the "planned menu". If this is true, this bothers me more than anything. I could plan the best menu with refried beans, steamed kale and apricots, but if only 20 students out of 200 students served eat those items, what are we gaining?
Posted by: Louise Easterly at 5/31/2012 12:54 PM


As we have been diligently changing our menus and as I have spent the last 6 months, learning, teaching and implementing the new guidelines, it is not the increase of food costs or the increase of serving more fruits and vegetables that has me concerned, it is the calories and ounce breads and two ounce meat serving for the secondary level that keeps me shaking my head. Those students will be hungry by the end of the day, especilly if they are athletetes or have PE after lunch. I understand the obesity concerns, but what about the 80% of my students who are not obese and very active, where will they get those extra calories. The new guidelines will force my program back into the ala carte sales, (currently all meals are reimbursable meals), as the paid students will not purchase the smaller portions and the F/R students will need more calories.
Posted by: Scott Soiseth at 5/31/2012 12:56 PM


I am very concerned about meeting the very restrictive upper limits on the bread grain requirement at all levels. Quite honestly as much AS I followed the proposed rule and then the final rule I did not see this further reduction coming. If you look at my menus: www.gateschili.org you will see that I offer 5-13 entrees daily depending on the school. A huge part of our winter month menu offerings are our wonderful home made soups. Which now Chicken Rice, Turkey Noodle and any other soup containing bread/grain as an ingredient become problematic to work into the bread/grain upper limits. Soups have worked well to get more of the legumes and other challenging vegetables into our kids too. So how do I still offer the great variety that my students love and make the grains work....... as I understand it from a training session you have to plan that a student could possible select to eat a PBJ sandwich every day, and in Elem that would be over the 9 svgs/wk threshold when standard bread slices are 28gms per slice. I also am wondering why the grains range became more restricted from the proposed rule to the final rule. I felt the proposed rule grain serving guidelines were doable thus I did not offer comment on them. Now I have to work with Breads/Grains that are more restricted and seem very undoable especially when we will need to account for the breading on food items in 2013-2014. WE have been working very hard to get the Whole grains on the menu as frequently as possible, but this upper level restriction is most challenging. The other side of the coin on this is that we all have to work within the parameters of the price equity portion of the legislation and raise our prices year to year. I support that effort and understand the reasoning behind it. But now, It is very hard for me to defend a price increase and then implement the reductions in portion sizes for Breads Grains and Proteins (foods our kids consume) with the increased Fruit Vegetables servings which kids don't typically consume enough of. I agree that children need to consume more fruits, vegetables, and whole grains and I have been working very hard in my district to get them doing just that. But the challenges of this new meal pattern with regard to Bread and Grain upper limits and offering a wide variety of choice in your program just do not seem to mesh. So I am looking for suggestions, tricks on how to make it all come together to offer great meals as we currently do.
Posted by: Debbi Beauvais, RD SNS( Visit ) at 5/31/2012 1:01 PM


meal equity. Although I’m serving more fruits and vegetables, the meat and grain/bread servings are restricted. Since most of our kids only eat the meat and bread, they will be hungry. I keep hearing, if the kids are truly hungry, they would eat all of the fruits and vegetables, but will that really happen?
Because manufacturers are not ready, I have to reduce many of my offerings. Again, students will be paying more for less.
My biggest concern is how to meet the different requirements for age groups. My 8th and 9th graders come to the cafeteria together, in a scramble system. We don’t know which child is in which grade. The regulations came down too late to attempt to have an 8th grade lunch and a 9th grade lunch since class schedules were already set for the new school year. Plus, we have many mixed grade classes at this age, like band and chorus. And, frankly, the Principal doesn’t care about my problems.
I’ve been trying to figure out an overlap for the calories etc, between these two grades, but there really isn’t any way. So, do I not get the extra 6 cents for these meals? I can track what they take, but have to limit the grain breads and meat for the 9th graders to the minimum (and our 10-12 since they also eat in the same kitchen, but at a different time). Restrictive offerings again, higher prices and for my HS kids, and open campus!
The nutrition analysis should be done on what is planned, not what the kid’s select. If we plan healthy meals, but the kids don’t pick it, why is that our fault? At my district, we put out many choices in fruits and vegetables, but the older kids especially just walk past it.
Posted by: Nancy Sitler at 5/31/2012 1:02 PM


Forgot one more concern,
Why, if we have to make sure the kids take at least 1/2 cup of either a fruit or vegetable, are the requirements for elementary kids on vegetables 3/4 cup offered per day. If we offer two vegetables, at 3/8 c each, shouldn't the minimum requirment for them to pick up be 3/8 c. To make the lines go as smoothly as possible, I'm planning all vegetable servings at 1/2 cup, so we don't have to send these kids back for more food.
Posted by: Nancy Sitler at 5/31/2012 1:04 PM


I feel the USDA has taken what could have been a great change for school meals and turned it into something that is going to be near impossible to implement the right way. It is way too prescriptive with daily/weekly grain ranges. Many of us do not have the staff to be able to bake our own, so we're left to purchase most grains. Many manufacturers simply do not have the products that will meet the required ranges, leaving us struggling to find menu items that make sense together and that the students will want to eat. After all, this is all to improve the health of our students, right? If they don't participate, what have we accomplished?

I feel that not enough thought was put into the ranges as far as daily options are concerned. I don't know many schools that just have one option a day. The way we're required to count minimum/maximum ranges is not at all flexible with daily choices. For example, we could no longer have a daily sandwich option for K-5 students. That isn't logical at all.

The way it is currently set up, we're going to have a lot of unhappy students, parents and staff. Instead of bringing more students in to participate in the program, we're going to be pushing them away with rules that are not logical and unreasonable. I am fully on board with the whole grains, more fruits and vegetables, lower sodium, etc. but I am not on board with the way that we're being required to implement things.
Posted by: Crystal Thill( Visit ) at 5/31/2012 1:08 PM


The grain and protien min and max it really difficult to deal with when you offer several choices like we do. How do you keep participation up when you can't offer choices and stay within the guidelines. And how do we tell students to take a fruit or veggie that they do not want just to throw it away! What is the point if they do not eat the fruit or vegggie?
Posted by: stacy coggeshall at 5/31/2012 1:15 PM


I can certainly identify with the difficulties described by Lori regarding grain maximums and minimums. We offer 3 entree choices/day with one of them a consistent daily offering. As a result we have to stay within the range on 3 separate patterns...any maximum, any minimum and the daily choice. While this has been like working a jigsaw without a picture, I have found that I had to develop a minimum and maximum pattern for each day in the week. I have to cluster my days with 1.75 to 2 grains and days with 1 to 1.5 grains. If I bury a "2" within a day with other "2s", then that is my minimum and max that day. I must balance that out with other days that have a low min/max...no more that 1.75 max. So, when I count I will have 6 grains minimum or max for the fist 3 days and a minimum of 2 grains the last 2 days (totaling 8) and a maximum of 8.5 (could possibly go up to 1.75 on one day, depending on the day). I also have to make sure my constant offering- pbj(1.25 + Goldfish @ .75)is offered with Goldfish 3 days/wk (to equal 6 Grains) and without Goldfish 2 days/week (to equal 2 G... 8.5 for the week). Whew! I think a weekly average makes a lot more sense! The protein foods were much easier. Obviously, the more entree options you offer, the more complicated the picture. As the products change it is important to note that we need a variety of products with "1 Grain" and "2 Grains". Hopefully our vendors and manufacturers are aware of our needs.
Posted by: Carolyn Perry-Burst at 5/31/2012 1:21 PM


Requiring the students to take the fruit and or vegetable is not what we should be doing. Encouraging them to take them, yes. Elementary students do not eat all that much at lunch time, there will be alot of waste. Putting a limit on how many m/ma can be served is not good for the older students especially when they are in sports. Many of our MS & HS students complain now that they do not get enough to fill them up and they are not the "OBESE" ones.
WE can't control what they are fed at home and they have alot more time at home for snacking and eating than they do during the school day.
Posted by: Lori at 5/31/2012 1:27 PM


We have numerous concerns. While we are able to meet calories along with G/B and M/MA requirements, we are one of the few districts that still has K-6th, 7th-9th and 10th-12th grade schools. It is very difficult to offer the 9th graders something that the 7th and 8th graders do not receive. Not to mention the fact that at some of our schools, those grade levels are mixed. It feels like we are discriminating against the 7th and 8th graders because of their age. One of our challenges has been leftovers. If we have a dessert that contains enough peanut butter to count as a M/MA, do we have to count it again the 2nd day? Or is it considered a freebie as a leftover? Same goes with the bread, if offer a leftover cookie, is it going to put us over on our G/B for the week?

Another challenge is the salad bar. If we offer the salad bar as another serving line but only offer it 2 days a week, how do we count it?

thanks for your help!
Linda
Posted by: Linda Robertson( Visit ) at 5/31/2012 1:36 PM


I agree that our children need healthier choices at meal time, but that does not mean they will take it, at least in the amounts and restricted varieties we are going to be required to serve. Then add to that the grain bread and the grade level splits (they do not match our campus grade levels)...I just can't see this working out to benefit many of our children. Our district is 74% Free & Reduced, what we provide is the only hot, nutritional and filling meal they have access to all day, we can't screw that up.

I think we are all running around like a bunch of chickens with our heads cut off and there is no clear path to show us what to do or how to implement all the rules and make it work for our kids...they are the most important concern.
Posted by: Janice Miller at 5/31/2012 1:55 PM


Please give us samples of menus/recipes that meet all of the new criteria for a variety of school grade configurations. If someone has already worked out all of these, a visual presentation would be helpful.
the timeline for this change has been totally unrealistic. Our menus and ordering should already be done by May for the start of the school year and we are only now getting trainings offered (beyond the webinars that just told us the new regulations. For those of us that have to switch from Nutrient Menu Planning, this is huge task to accomplish. (Not considering that many actually take vacation during the summer).
Please give us actual samples of menus, production sheets, etc. for those of us who use salad bars, multiple entrees and multiple serving areas. Thanks.
Posted by: Janette Wesch at 5/31/2012 1:56 PM


I find it interesting that these rules were implemented after we have already purchased our commodities for the next school year. Now I am faced with certain proteins that are too large of a serving for our grade schools. I have also experienced the uncertainty of how to follow all of the new rules and produce a menu that students will actually want to eat. How much will this 6 cents help us if no one is eating lunch? I really am hoping that a workshop that I have to drive over 70 miles to get to is going to be really helpful in menu planning! I sincerely wish everyone had all of their ducks in a row before all of these "rules" had to be implemented.
Posted by: Mary Ellen at 5/31/2012 2:21 PM


I think the USDA needs to do their own thinking and get the White House out of their business. It is obvious that this has not been thought through. I realize that we need to teach and guide children to eat right, but as long as the parents don't follow through then it is a losing battle. With this increase of fruits and vegetables the size of the portions is going to put a monumental hardship on the budgets of all schools, with very little extra increase in money, compared to what it will cost to implement these new rules, to what they are supplementing is not balanced. As well as buying more in canned goods to meet the guidelines the availability of decent fresh fruits is limited in the central of the US states. With huge cost increases and very little good variety that is affordable. With the increase in portion size new lunch trays hare having to be purchased, for the food does not fit on the trays, and the waste compared to the increase in cost is going to be extrodinary to say the least, these people making these decisions need to come to the right places to see what havoc they are causing before making across the board decisions that won't work the way they expect them too.
Revisiting their decisions in three or four years after schools have already gone in to debt and reached beyond budget to find out they made a mistake is typical politics and makes no sense.
Posted by: tanya bowin at 5/31/2012 2:29 PM


I was completely blindsided by the new interpretation for counting weekly minimums of Grains/Breads and Meat/Meat Alternates which includes a requirement to count any amount of .25 oz or more.
The justification for the new method of counting was that a child could go through the lunch line and choose the meal/pattern minimum selection daily and then be short 3 G/B for the week if there were a choice of 1 oz G/B options daily at elementary for example. A child could also go through daily and never select milk or a vegetable. This is just a part of the reality of offer vs serve and offering choices. This new interpretation is creating the need for new versions of familiar food items. The hamburger buns cannot be over 2 ounces in order to work in a weekly plan. A flour tortilla that is 1.35 oz will not work either. We are requiring new products from our vendors and are re-working all of the pasta recipes so that the amount of pasta can count for 1 G/B. A .25 or .5 or .75 will not work in the plan. At this time we are opting to simply eliminate our vegetarian lasagna from the menu because it contains .5 G/B and we really do not want to double the amount of pasta for the new requirement puzzle. We are increasing the pasta in the Spaghetti and Meatsauce recipe to increase from a .75 to a 1 G/B and in the Baked Lasagna recipe to increase from .66 to 1 G/B. If the Ravioli does not have exactly 1 G/B then we will no longer be able to use it on any of the menus. It might be able to fit for HS but we don't serve it in the HS. It is mainly an elementary menu item. We also had to change from a very acceptable whole grain roll that weighs 2 ounces but is counted as 1.75 G/B due to the new method of counting weekly minimums. Fractions don't work out very well when the range is 8 to 9 and makes menu planning even more complex for other levels.
I don't mind a maximum level of G/B or M/MA for any level. It would make so much more sense to count the daily maximums and then require that the number be at least the weekly minimum and no more than the weekly maximum. I also suggest that the range for elementary be 8 to 10 (so that we don't have to have days that are only 1 G/B and days that are only 2 G/B for all options), for middle school 8 to 12 and for high school 8 to 14. I also recommend that grains less than 1 G/B not be included in the totals.
The current limitation of 9 G/B maximum for elementary means that one day has to have all 1 G/B selections. We serve rolls and breadsticks offer vs serve style so that the students pick them up instead of placing the breads on the tray. One G/B entree may require a bread and the other may have pasta or rice that counts as the 1 G/B. It is going to be very difficult to ensure that only the students selecting the item that can have the bread are the only ones taking the bread. We have to serve a class every 3 minutes. This is just not practical. In addition, managers will not be allowed to serve out any leftovers that are 2 G/B items on the 1 G/B only day. This can add to food waste and a limit of choices. We also have schools that offer some special vegetarian items daily because of the needs of the student population. Now this will be a very complex exercise in planning which will need to be taught to the school managers. "No, you cannot serve the hummus with homemade pita chips on this day because it only counts as 1 G/B and that would change the weekly minimum if it were offered on a day where all of the other planned items have 2 G/B." This doesn't seem to accomplish anything for child health. Also this means that if a child wanted to select an item with less G/Bs per day that they could not have that option. This is particularly true in High Schools where every single entree has to have 2 G/B with it. What is this accomplishing? Now for the Asian Line we will have to offer 2 servings of rice instead of one and with the Taco Salad we will have to serve 2 ounces of nacho chips instead of 1 ounce.

It took weeks of trying to make out items fit within the new method of counting weekly minimums and the very narrow ceiling for maximums to realize that I could not make it work with current products and recipes. With the 1.75 G/B roll I had one menu cycle week that was either going to be off by .25 for minimums or maximums. Very frustrating to think that the week wasn't meeting standards because of .25 oz. There are numerous other examples of this. I have a master's degree in nutrition and I am very capable of complex reasoning, but this is really crazy. My respect for this program has taken a dive. I hope that there is someone in a position to make decisions that can put us on the right track because right now we're off the track and running in the wrong direction.

I'd also like to challeng the common myth that these changes will influence the childhood obesity problem in any way at all.
There are 365 days out of tee year. If you assume a model of 3 meals per day that is 1095 meals per year. In our district there are 185 student instructional days. If a child attended school daily and ate a school lunch daily that would only be 17% of the total meals for the year. Children are not becoming obese by eating school meals. That "reasoning" is absurd. I do think that the meals are important and should be healthy for children. But we did not cause and will not solve the childhood obesity epidemic. So having school foodservice come within .25 of an ounce of planning weekly grain's breads is unreasonable and without scientific merit.

Also, how are we to control the calorie ranges if we cannot alter the G/B or the M/MA of particular menu items? This also limits control of sodium. It seems that if calories are lower than the range, the only viable option is to add butter and sugar. I don't think that was the intent.

At this time I have not completed the menu plans for secondary levels because I am continually discovering recipes or food items that must be changed to fit exactly into these very narrow parameters. It is so difficult and it is so discouraging as I consider how we are going to train our managers, employees and student customers.
I use a nutritional analysis software program and watch the calories and other nutrients carefully. I'm not asking to be able to plan menus that are not within healthy parameters. I just need to be able to offer items against items that go with the vegetables and to offer a super popular item against a very good item that may not be as popular to give more choices. Now I have to watch which day of the week I can serve items. For elementary we need 3 days with 2 G/B and 2 days with 1 G/B for the 8 and we need 4 days of 2 G/B and one day that has 1 G/B options only. Does it really matter if that pattern is different? Does it really matter if one child out of hundreds of children who eat in the cafeteria daily doesn't get 8 grains/breads at lunch? What about all of the students who only eat in the cafeteria one day per week. Oh horrors if they eat on the day that has 1 G/B options only. What if they don't eat on the days that have the red/orange vegetable selection?

We are also very challenged by some particular school situations that fall outside of the normal parameters. Our district has a special school for students with severe mental and physical disabilities. Meals are prepared in a Middle School and transported. The meals are based on the current Grades 4 - 12 Grouping and we also consider the multiple chewing challenges for these special students. The students range from pre-K to age 22. There is no practical way and it certainly does not even seem to be warranted to try to serve three different levels of menus. Please be practical.

Another challenge is a special school that is a blend of middle school and high school students for girls only. We have asked the principal to please keep the grade levels separate for the lunch schedule next year. It seems that the manager will have to have two sets of production records as well. This is all because of the G/B and M/MA. If this were back to normal then the only thing that would need to be different would be to offer an extra serving of fruit to the HS girls. We are making sure that all of the fruit and vegetable servings are 1/2 cup. Elementary and Middle School students will have the option to take 2 servings of vegetables and 1 serving of fruit. The High School students will be able to take the 2 servings of vegetables and 2 servings of fruit.

I am very excited about the separation of fruits and vegetables and the new standards for the sub-groups of vegetables. I am also thrilled with the additional serving of vegetables. I am completely suppportive of the move to whole grain products.

But the narrow limits for G/B and M/MA and the differences in counting G/B as explained above are not only challenging but counterproductive in attempting to serve a variety of healthy foods for students. Also this seems to be a minor point that could be changed since the Federal Register does not address the weekly counting method. This seems to be a well intended interpretation by someone lacking in practical school feeding experience. Please go back to the more common sense approach for counting for the week and widen the ranges a bit for more menu flexibility.
Thank you for the oppotunity to comment because these details were not clear to me in the proposed regs or I would have commented at that time. I am so very hopeful that good sense will prevail and the idea that all of this has to be changed because one child just might go through the line and not get "enough" grains/bread one week is so ridiculous.
Believe it or not. There is much more that could be added but I desperately need to get back to trying to figure out a 4 week menu cycle for Middle Schools that fit the pieces of the puzzle. Thank you so much for asking for comments.
Posted by: June at 5/31/2012 3:30 PM


It would be extremely helpful if all the vendors would send out a listing of all their products with nutritional info. Over the next few months thousand of food service operators will be requesting all of this info from the vendors. Someone should publish a guide book with all the nutritional info from all the products we use so we are all not recreating the same wheel.
Posted by: Michelle at 5/31/2012 3:34 PM


Thank you for the opportunity to comment on these new guidelines.
As Assitant Director of a large school district 85,000+ enrollment), one of my responsibilities is procurement (food, equipment, supplies, etc). It has been difficult for our menu planner to complete menus for the next school year. I began purchasing food in January, but we received updates to next year's menu requirements as late as April. How can Districts possibly accomplish new menu requirements when food bids require advertising, tabulating, sampling, and School Board approval? This makes me think that the decision makers have no idea the requirements of procurement for School Districts (did they have any experience in School Food Service?).
I am also concerned that these new guidelines will only achieve confusion (on the part of school food service staff and students). It's difficult to explain what students are allowed to take or not take, and then what they MSUT take (another words, offer vs. serve will really no longer be in place). Forcing students to take a fruit or vegetable is an added expense to school districts, and frankly an irresponsible use of tax payer money. Students may be forced to take the fruit/vegetable serving, but they can't be forced to consume the portion. Hence, there will be an increase of very expensive, very healthy trash.
Probably the most disconcerting is the increase food cost associated with these guidelines. The additional $.06 per student may help off-set some of the impact, but only a minimal amount. Districts need to brace for not only significant increases in food costs, but also the decrease in student participation.
I am also concerned about the type of food that we will be serving in the near future! Right now we have strived to provide fresh fruits and vegetables daily, and purchase food items with as much of a "clean label" as possible. I have no doubt that the restrictions on sodium will force industry professionals to develop food products that are jam-packed with other salt substitutes (another words, more chemicals). We will then be forced to abandon our goals of purchasing food that have "clean labels".
I also believe these salt restrictions are more like therapeutic diets. Once again, I lack confidence in the decision makers of these new guidelines. Students will not purchase food that does not taste good. When I was a Clinical Dietitian at a hospital early in my career, there were sodium restricted diets that were less restrictive than some of the goals for 2017-2022. What were these decision makers thinking? As a parent of a young female soccer athlete, I would have to supplement her lunch so she could get enough nutrients and salt to sustain her daily athletic activities. It appears these decision makers have labeled all students as hypertensive, which is not only wrong but irresponsible!
As I mentioned earlier, we are a large district (85,000+ enrollment), and we are surrounded by Districts where Food Service Departments have been out-sourced due to financial incompetencies. These new regulations may only increase our vulnerability of our Department being out-sourced. Increased food costs, decrease participation... it doesn't take a rocket scientist to figure out the bottom line will be severely compromised!
Where the goal may have been to reduce childhood obesity may truly backfire. Older students are quite sophisticated and opinionated. If we don't provide food items they want to eat, they will only go off campus and make purchases elsewhere. The establishments they select for lunch are loaded with fried, salty, high-calorie, nutrient-deprived food items. I don't believe decision-makers want Food Service Departments (that are jam-packed with highly eductaed professionals) to go bankrupt!
I highly recommend these new guidelines are re-evaluated as quickly as possible. keep the guidelines simple, so goals can be easily achieved. I apologize for my negative comments, but my frustration has reached an all time high! I'm very concerned about decreased participation, increased food costs, increased "expensive and healthy" food waste, and increased vulnerability that our Department will be out-sourced.
Thanks for allowing me the opportunity to vent-
Posted by: Yvonne Seiders at 5/31/2012 3:55 PM


-I am also concerned about the 1 oz meat/meat alternate being perceived as too small by our customers, especially when increasing prices.
-When offering 2 portion sizes of fruits and vegetables how is this recorded on production records? We do not want the increased cost of containers. Can we approximate? For example-the server knows that approximately 10% of the students received the larger portion. The servers should be able to guess very closely. Other means of tracking that we have thought of could be expensive & quite time-comsuming.
-Now that many of us have been increasing our whole grains, whole grain maximum's could be easily exceeded. Thank you.
Posted by: Patty Barber at 5/31/2012 4:02 PM


Correction to comments posted by June on May 31 at 3:30 p.m. The Ravioli cannot be over 2 G/B not 1 G/B or we will not be able to fit it into the elementary menus. It seems so silly to have to eliminate a menu choice because of a few grams of flour when it fits nutritionally.
Posted by: June at 5/31/2012 4:05 PM


I do not see how we can be Offer versus serve if we are making the students take a fruit or a vegetable. I agree that students should eat more fruits and veggies, but I can guarantee that more then 50% of the fruits or veggies will go in the trash. And how many of our schools can afford the costs of all this waste?
Posted by: Cathy at 5/31/2012 5:09 PM


My district has junior high schools that house 7-9th grade. Because a lot of districts in my state have this problem our state agency went to bat for us and collected comments and numbers on how many people this would affect. They petitioned our regional office, who supposedly petitioned USDA. And they said… nothing. No changes, no waivers, nothing. Well now I am left planning a menu that contains exactly 10 oz eq of grain/bread for the week and then we have to figure out a way to identify who is in 9th grade and offer them an additional item so that they can meet the increased kcal requirements. This is ridiculous! I flat out told the state agency that I can try and make this look good on paper, but it is NOT going to work out in the lunch room. There is no way that the people that made these rules thought them through and really thought this would work.
I think we could make some sort of grain range work if we gave the industry 3+ years and said we need products that fit this category, but they have had no time to create new products. I am left planning to serve items that I have never tried but have been promised that they will exist in August.
I have a lot of similar concerns as previous comments, but one that has not been mentioned as often is how we are supposed to train our staff, literally overnight, to understand what a reimbursable meal is. School is out for the summer and other than a few summer lunch staff I won’t see everyone again until August. We have 1 day of training planned before school starts. I am nervous about making sure that everyone is well trained and I anticipate spending weeks out in the schools at the beginning of the school year to help train and encourage our staff. We needed more time and I think USDA needed more time to figure out what their rules even mean. I started menu planning months ago, but as more clarification was released I had to start all over. I still feel like at any time a new rule may fall from the sky and mess up what I thought I had done.
I agree that we need useful tools to help train our staff, help educate principals and administrators as well as the public. I also think that it is a great idea to have a place where industry members can post their nutritional information. I am looking forward to Denver to see some new products and hopefully get some good ideas, but that really is too late to change anything for next year. My menus will have to be finalized by July 1 at the latest!
Posted by: Kristine at 5/31/2012 6:12 PM


Most of our children in our parish Love our food... For many... It's their Only good hot cooked meal.... How horrible this will be for most of these children.. Cooking for The Trash is surely what will happen... Oh.. And by the way... Will the government monitor ALL their meals brought from Burger King or McDonald's???? Sicking ...
Posted by: Cindy at 5/31/2012 9:53 PM


Man O man. I agree with all the comments that have been posted so far. Training the cashiers to idenify a reimbursable meal is going to be challenging to say the least. Is there a free interactive web site we can use to help train us?
Just goes to show us how the goverment what's to control lives. I thought we lived in a free country.
Posted by: Gary at 6/1/2012 9:09 AM


I agree with the above comments..especially regarding the grains requirements for schools where the students cross grade groups (example 5-9). The students are mixed as they come through the line, so we are using the common amount (8-9 oz.) for all students. With multiple entrees, it is taking us weeks to put the plan together and we still are having problems. We can't serve a sandwich with one slice of bread. Because we must compare entrees as if a student can take different combinations during the week and not all entrees have the same number of oz. equivalents, it is frustrating. I also agree with above comments in that the implementation timeline is too short...especially with the certification we must have completed during the 2012-13 year. I applaud SNA for putting something together however for most of us...our bids are done and menus (cycle) have to be done before then. Thank you for allowing us to comment!
Posted by: Tammy at 6/1/2012 9:30 AM


The new requirements are a challenge to meet in such a short period of them. There are to many changes to implement at once. I'm for serving more nutritious meals but on the down side I can see A LOT of waste. In the past, when I saw articles of schools implementing fresh fruits and vegetables and how the students were taking them, there were never pictures or information as to how much of that nice fresh fruit and vegetable came back on the tray and thrown away. Let everyone see the WHOLE picture. We can offer and offer and offer (and do what's right), BUT will it be eaten. The vegetable serving size is ridiculous (3/4 cup). I serve grades 1-6. I'm lucky if that even select vegetables and I serve fresh vegetables almost daily. I don't mind the veg. subgroups, legumes are difficult to implement BUT I feel if a school is offer vs serve than all that s/b required to serve for veg. is 1/2cup. Don't make everything so difficult. 1/2 cup fruit or veg, or both. Bread requirement is not enough if we wish to serve sandwich as alternate lunch each day. I don't mind the whole grain breads but serving requirements s/b more. I feel the requirements are for the best interest of the students, which I'm for, but a lot of issues were not taken into consideration such as waste, production records that will take more time, requirements being carried over to parents (parents should have a responsibility in what they are serving their children at home). I could go on and on about this, but many concerns I have have already been address by other food service managers.
Posted by: Darlene Sczygiel at 6/1/2012 9:44 AM


The vegetable requirement for breakfast singles out potatoes as the only vegetable you cannot serve until after 2 cups of the other ones have been served.

It is true that potatoes have many valuable vitamins and minerals. They are a great way for children to enjoy a vegetable. The current rule allows vegetables to be substituted for fruit in breakfast programs.

But the first two cups per week of any substitution must be from dark green, red/orange, beans & peas, or "other vegetables".

This language unfairly singles out potatoes as an unhealthy choice.

The rules should not prevent any vegetables from being served during breakfast. The rule should encourage vegetable consumption across the board, FAIRLY, including potatoes.
Posted by: Joe at 6/1/2012 10:37 AM


I think it would be helpful to see a few sample menus, with pictures and recipes included. As many, I'm struggling with the grain and meat maximums...how will we create a sandwich/burger/etc that looks appetizing (especially for high schoolers who can go off campus), and what will the rest of their plate/tray look like?
Posted by: Sonya at 6/1/2012 10:58 AM


I am a high school district with a free and reduced population of less than 20%. With the new regulations concerning maximum grains and protein, I will not have any kids buying lunch because they will not get enough food!
Two breads and 2oz meat for a 200 pound football player is ridiculous! To expect them to fill up on fruit and vegetable's is just not realistic. I will lose participation and kids will go off campus and purchase "Super Size" burgers and sodas! All of the extreme hard work that I have put into providing "Healthy", "Attractive" choices for the kids are no longer going to meet the new standards. The new regulations are impossible for high schools and will cause loss of participation. The 20 choices that I offer daily will now be 5! Good job USDA!
Posted by: Lila McAllister at 6/1/2012 11:07 AM


It doesn’t take a dietitian to plan these menus; it takes a magician – at least with the resources and products that are currently available. I am communicating with people from all over the country who are meeting in task force groups trying to develop menus, and I have yet to see a cycle menu that is compliant. I have seen a one week menu that probably is, but I cringe at the cost, and I so worry about the participation as there are no alternate choice for the entrée. (And we all know that if participation falls, our costs per meal increases.) The group I am working with locally is frustrated, too. These dedicated, nose-to -the -grindstone professionals are using words like: “absurd, impossible, can’t afford, can’t find, and won’t fit on a tray.” But the best comment came from Teri who said to me, “It should not be this hard to feed a kid lunch.” All I can say to that is “Amen!”
Those of you who know me, know there is no greater supporter of the school meal program. I believe it is the single best thing this country has ever done. That said- I believe one reason it is great is that all students sit at the table together and have equal access to a good meal. If the foods we offer no longer attract our paying customers, it won’t be long until our subsidized meal customers also quit dining with us.
Either the minimum/maximums need to be revised, or the way they are accounted for each day should be changed. Why is it so prescriptive that we are non-compliant if a child eats a sandwich each day? Or, better, we all need a year to see new products, review sample menus, and train our staff.
Posted by: JoAnne Robinett( Visit ) at 6/1/2012 11:12 AM


Thanks for all the comments. Menu planning had always been my favorite task to complete as Food Service Director. Your menu is what can sell or break a business. Now with all the changes being implemented its becoming a big jigsaw puzzle of compiling grains, protein,calories and fat. I am very skeptical on what is going to happen for next year as anticpating loss of food, waste being tripled, loss of revenue and most importantly loss of meal counts. Usually at this time of year I have nexty year's menu completed and sending proofs to our print company. I appreciate the fact and understand the principal of offering more fruits and vegetable that's a great concept and we have been implementing this measure in our school district for years. Thanks for giving us a chance to express our concerns and suggestions.
Posted by: Judy at 6/1/2012 11:31 AM


I am pleased that SNA has asked for the feedback. I know Industry took quite a bite of flack during this process but many could and did foresee the above, unintended consequences. Daily we hear and receive calls asking for help. The grain protein maximums- major problem,no overlap when schools do not align with the 3 age groups- problem, calorie challenges- problem, adding " calorie boosters- non component, non healthy items to meet calories( not more of the extra unlimited use of fruits and vegetables that was believed schools would have to offer), limiting entree options to even try to make this work, impact on participatipon? , opting out of the program.......The prescriptive nature of this rule needs to change in order to allow all stakeholders the ablility to create products and menus that will wind up being consumed by the kids instead of in the trash can--- at an affordable price-- allowing the district to remain solvent and not opt out of the program.
Posted by: Mimi at 6/1/2012 12:06 PM


As an RD and an SNS I think I understand our programs and seek to keep updated with all the new information coming down. I spent over 30 hours myself doing a 3 week cycle for K-8. That was just menu planning-and for 1 menu-not to mention the countless hours in training, reading etc. My staff has also spent about 20 hours so far learning and helping count, recount, etc. One has to be a mathematician to get this straight. Of course getting accurate nutrition info and labels are essential, but very difficult. FoodConnect should be able to go a long way to helping this when it's up and functioning. I notice that every USDA planned menu has 1 choice-makes me wonder if anyone there tried planning a multiple choice menu that most school divisions have today at all levels.
We are a HUSSC division, so we had already worked on f/v recipes to ensure proper amounts of specific subgroups, but with all the requirements and cost I will choose not to offer some of the less popular veggies like brussels sprouts that we offered to give exposure to children. The bread/grain K-8 requirement would have been much simpler if it had stayed within the proposed range of 8-10. I can't put a 2.8 oz sandwich on every day in elementary-ridiculous. I know that 1/2 of grains must be whole this year, but items like couscous that our kids really like will not be allowed next year since it is not a whole grain. The DGAs recommend that 1/2 grains be whole. Not sure why ALL our grains must be whole next year-doesn't jive with the science that we have worked hard to align with the evidence. Not having a clear definition of whole grain is proving difficult. 14.75 or 16? Depends on what label says and the wording on the label!!! So is it 1 or maybe when manufacturers switch we will have to change menus because we could be over or under. We are centralized, I wonder how independent schools are handling this?
For our 6 high school lines-we offer about 22 items a day-all themed and all separate main dish items. We have worked hard to offer school made soups that our kids love-many of those will not be possible next year due to Pro/Grain restrictions. Our deli line is proving to be difficult since there is no 2 bread sub roll available. So we will offer less and charge more due to Section 205 rules. These requirements are very prescriptive, and don't allow much flexibility for local preferences. Training is a whole issue unto itself. USDA is rather cavalier in my opinion, in saying that they realize we need to do it. We have over 30 countries represented in my dept.a great assest, but with technical information there are no materials available to train these folks well. We are all concerned about the 6 cents, and I have been at 2 national meetings where CLong stated that we would be held harmless this year if we were making good faith efforts to get this right. Our state has told us that there is a real possibility that there will be fiscal action if menus don't comply. Looking at MealTalk, there seems to be a fair amount of disconnect between the states on interpretation-are leftovers counted, graham crackers as sweet dessert, etc. Many many questions remain to be sorted out.
Posted by: Becky Domokos-Bays( Visit ) at 6/1/2012 12:45 PM


The mix/max on grains is to prescriptive and is micromanagement.

Any reasonable person would be pleased that the change from white grains to whole grains is enough.

K-5 = 8oz - 9oz range - causes a 1oz overage per week if we offer a nice whole grain sandwich option daily.

9-12 = 10oz - 12oz range - causes a .5oz overage for the week if we offer a 2.5oz whole grain sub roll for the week.

SNA needs to go to the USDA and lobby for a modification to the mix/max rules. To expand them so we can continue to offer a VARIETY of whole grains EVERYDAY! This rule does more harm than good in taking away a valuable nutrient rich variety of foods that we can offer.

An extra .5oz to 1oz of whole grains over the course of a week is not the cause of childhood obesity.
Posted by: Joe at 6/1/2012 2:24 PM


I agree whole-heartedly with all the comments above. I am an RD, former child nutrition director, currently a school nutrition consultant. I have spent my life planning menus (at schools, hospitals and for private clients)but the restrictions created by these meal patterns are absurd. I especially echo the concerns about the g/b and m/ma requirements. To be unable to offer a daily sandwich alternative to elementary students is ridiculous. Also with the weekly minimums,yogurt with a 1 grain side will not be possible. The restrictions at the high school requiring smaller meat and grain portions will definitely reduce participation at schools that are already challenged in attracting customers.

While I completely support the need to offer and encourage a wide variety of fruits and vegetables, you cannot force students to eat them - and students are not going to fill up on these items because the portions of grains and meats have been cut. The food will go in the trash and students will go hungry.

I also have run into the problem of student grade levels overlapping in the 7-9th grade eating at the same time in the same line. The answer I have gotten was that you have to plan different menus and give the older students more calories. How do you accomplish that?
My last concern with this certification process is with schools that do not have an analysis program. Is there going to be a simple guideline for estimating calories and fat? And if so, when? How can you send your menus etc in for validation when the guidelines are so vague and the timeline is so short.
In response to the comment above about consequences for not complying to the process and getting certified - I was told that you still have to be in compliance the following year and you will be targeted for the first round of administrative reviews. How can districts be expected to comply when the guidelines are still incomplete and state administrators don't even have the answers? I'm all for improving nutrition and complying to regs but give us realistic guidelines and timeframes!
Posted by: Judy Stephens at 6/1/2012 2:46 PM


I am a high school manager and we offer at least 7 different entrees everyday. One of our menu items daily is homemade burritos. We live in New Mexico and burritos and enchiladas are a staple here. We are going to the wheat tortilla and I am concerned that students will not eat it. We use corn tortillas for our enchiladas. Is the corn tortilla considered healthy because I haven't found anything in the new meal pattern that says one way or the other. I like a challenge but our ethnic foods will be harder to change than some of our other foods. I want my customers to continue wanting to come in and eat.
Posted by: Nancy Thatcher at 6/2/2012 3:04 PM


Wow. Reading all the listed comments echos all of my concerns. Another thing that worries me is how are we to account for each student's choices in a week's time? Will Susie have a pop up or record of each meal that is taken? Notice, not consumed. Will she be told, yesterday you had a slice of bread and your record shows you may not have one today as it's Friday and your grain account is overconsumed. Ridiculous and obsurd. Are we becoming the food police now instead of child nutrition professionals?
Posted by: carmen johnston( Visit ) at 6/2/2012 8:23 PM


A question SNA should be asking the USDA is:

What comments from the many comments they received on the "Proposed" rule were so pursuasive that they justified the USDA changing their position on the grain requirements to be more restrictive? So restrictive we can't offer a child a sandwich on two slices of bread each day for lunch?

SNA needs to put all available resources to work in making sure these unrealistic time frames are changed for it's membership whom they represent- including industry.

A pilot program should have been pursued as suggested in the comment period by a few State Agency's and State Affiliates. This is going to turn out to be a public relations nightmare for both the USDA and School Meal Programs.

The quote of the day: "You don't need to be an RD to implement this meal pattern you need to be a Magician"
Posted by: Artie Frego at 6/4/2012 7:57 AM


I am wondering if the persons who are responsible for this "strategic" plan would be so kind as to explain to us the logic behind the ridicuous restrictions? Let's say we cut down on sodium, we make available or heck, just force them to take a fruit or a "good" vegetable serving, and we offer half to all whole grains bread options. Would that not be a great accomplishment in these programs? So many of us were already doing this with the HUSSC. Why did we have to come up with another whole set of dietary restrictions?
As I was planning my menus all I was doing was adding up this and adding up that and plugging in this...after I was done I had to step back and look at what I was actually offering. It was not always a "well planned" menu. But the math added up! Now to run the numbers behind the scenes...the calories...and see what other tweaks I have to make.
Good old fashioned menu planning that makes common sense and uses healthy choices is NOT what these changes are creating.
Would someone please speak up and tell us WHY it was thought these minimums and maximums were a good thing?
The idea that a sandwich on whole grain bread everyday at the elementary level AS A CHOICE is bad nutritionally is just bad policy.
Posted by: Jennifer at 6/4/2012 10:23 AM


We are a Menu Planning Committee consisting of Child Nutrition Managers representing PreK through Grade 12, rural and city students. We also have Central Office Child Nutrition Administrators on the committee. We have met 4 times and “finally” have a 3 week cycle menu that we think we can live with. It has been very challenging and we feel like we have had to settle on menus that may reduce student participation just to meet the meal pattern requirements. THERE IS NO FLEXIBILITY. There are not enough products that fit into the new requirements. There is not enough time to implement the new meal pattern in an informative, positive manner.
Limiting Grains to 9 per week for elementary students is ridiculous. That means that we cannot plan a sandwich each day at lunch using the current bread/grain requirements. Many of our elementary students look forward to a PB&J sandwich as a choice each day. Requiring that high school students take 2 grains per day minimum using products in the current market does not always work. For example, a hot dog on a bun (1.3 oz) will no longer work. Putting a hot dog on a 2 B/G will result in too much bread for the meat item. The customers’ perception of what we are doing is not going to be very good. They are going to think we have lost our minds. Training takes time and in the meantime, we will be in a position to defend the menu as planned.
The maximum limits for M/MA and B/G is going to have a major impact on manufacturers and reformulating products that are made specific for Child Nutrition Programs. The B/G change from 14.75 g to 16 g will result in changes to how products contribute to the B/G component and the CN Labels will have to be revised. This will be costly to the manufacturers and we are sure this cost will be passed on to the CNP.
Requirement 1 ¼ cup red/orange vegetable – what is the rationale for ¼ cup? Why not set the requirement to a measure of ½ cup in line with the planned serving sizes.
Why does this have to be so confusing? We want simple instructions to train staff, students, teachers and parents. We want free resources already developed for training. We want sample menus by age group that meet all of the requirements. We should have these resources prior to the implementation date, and we should have the opportunity to train prior to the implantation date. The implementation date is less than a month from now.
Posted by: Nash-Rocky Mount Schools Menu Planning Committee at 6/4/2012 10:29 AM


I am an RD and School Food Service Director of 17 years. I have always loved my job and loved trying new items with the students. This year we have tried kale chips, beet pancakes, and butternut squash. Kids are opinionated and are willing to try free samples but are not willing to pay for meals that they do not like. With all of the restrictions that are being placed on our menus I'm afraid that we will lose our customers to other venues. (Including home packed lunchables and candy- which has been documented in an onsite survey of our 8 cafeterias). Will we be able to "try" new items - I think not! Menus will have to be planned and followed exactly. The grain/bread limitations will limit the homemade soups that we have been serving for years. I do not think students will revolt in a district that has only 13% free and reduced - I think that they will just go off campus more often and pack lunches. Our program that is currently enjoyed and considered a success in our community will be gone forever. We have current waste studies conducted by dietetic students that show that the majority of whole fruits (apples, oranges, bananas) and vegetables are taken in the lunch line and disposed in the trash. Healthier garbage cans is what we all need!
Did the USDA even think of trying these new regulations in a real setting before making us all to implement them? The timeline is ridiculous for September. Where do they think we are going to come up with all of the items that meet the regulations? Our bids have been awarded and our commidity dollars have been spent.
The fun and creativity of school nutrition programs is lost. Maybe they should just give us one menu for the entire country and we should all serve it daily. Then they can really see that we are not the cause of childhood obesity.
Posted by: Beth Krause, RD, CDN at 6/4/2012 10:57 AM


Thank you for asking for our comments! My hope is that you can please be our advocate to USDA and get some of these regulations changed...

First of all, why does it matter how many grain/breads (G/B) we are serving as long as we are meeting the calorie guidelines? It’s not real world and it will be a nightmare for students, parents, and staff to understand. It is extremely difficult to write a menu with multiple entrees on one line and there is just no way to offer something every day (like PBJ or Yogurt) at the elementary school with such a narrow range (8-9 G/B per week). There is no incentive to do scratch cooking because you don’t end up with neat little whole numbers on how many meats (M) or G/B are in the items.

Currently we offer the 2.8 oz PBJ Uncrustable everyday at elementary school. The PBJ Uncrustable is 1 M and 1.25 G/B. So first of all, I will have to package it with a 1 oz cheese stick. Then due to the daily G/B minimums having to add up to at least 8 and the daily G/B maximums not going over 9, I will sometimes have to put a 0.75 G/B chip with it, sometimes a 0.25 G/B (1 pkg of saltines) with it, and sometimes nothing with it. And the one day a month we have a homemade choc chip cookie bar they will get only 1/2 the size of everyone else and on sugar cookie day they won't get the cookie (but they get that 1 pkg of saltines). How is a child going to understand this? It would be much better to not give them the chips and saltines and then they get a homemade cookie the very few times we now can have something like that on the menu. We are having to put these guidelines in place because of childhood obesity and now we are forced to give chips or saltines with our PBJ Uncrustable--something that we don't do now!

I am having the same problem with offering Yogurt daily. Currently I get a 6 oz (1.5 M) yogurt from my LOCAL dairy. However, if my minimum is 1.5 M every day, then I don’t have enough meats for the week (1.5 x 5 = 7.5). So I have to either bid a 4 oz yogurt and put a cheese stick with it or bid an 8 oz yogurt. Either way that means I have to bring a dated product in through our warehouse instead of getting the 6 oz yogurt on my daily dairy deliveries. If you look at any grocery store, a 6 oz yogurt is a standard size yogurt serving, but we are saying a 6 oz yogurt is not an appropriate size.

The G/B with the yogurt is another problem. Currently I serve a pkg of Goldfish Oat & Honey Grahams with my yogurt. It’s a nice whole grain product but it is only 1 G/B and also is now considered a DESSERT. So again I will have to package different G/B items with my yogurt everyday and some of these days it will need to be a 2 G/B item which is a lot of G/B with yogurt. Also, a 2 G/B portion of chips, muffins, crackers—is that really healthier than even a 2 G/B serving of a graham cracker type product?

We are spending way too much time trying to work out a decent elementary menu (with two hot entrees) that meets the guidelines while still keeping PBJ uncrustable and Yogurt as daily choices. It’s actually an impossible task unless the menu becomes so confusing where you are offering different G/B with these items every day. The other crazy thing you are forced to do is put entrée choices together based on how many grains they are--not what is a nice menu. Previously, we looked at how much the students liked the each item, what kitchen equipment was needed for each item, etc. Now we are literally just playing a numbers game, which does not make a kid-friendly menu. We are also forced to increase chips for nachos to 1.5 oz—besides needing the grain we need the extra chips because we are forced to give double the amount of cheese on the chips. Again, this is helping childhood obesity?? Please get rid of the weekly mins/max of meats and grains as long as we are meeting the calorie, fat, sodium, etc levels. Another option is to just to increase the weekly K-5 max of G/B to 10 per week and change the weekly minimum of Meats and G/B to 5 (sum of the daily minimums). I haven't even gotten to doing a nutritional analysis yet (or even our middle school or high school menus) but I am sure we are going to need to add FAT to the vegetables especially to meet calories at the high school—I don’t see how we will be able to meet 750-850 calories with just 2 meats, 2 breads and a bunch of fruits/veges and skim milk.
Posted by: Kim Werning, MS, RD, LD, SNS at 6/4/2012 12:43 PM


No Kid Left Hungry? I disagree and believe we will have many children left hungry!Our intentions may be good but I feel we have forgotten the mind set of a student...
Protein limits are truly affecting me...I serve chili and slaw with hot dogs as condiments with protin limits, no chili. I have been serving commodity cheese to encourage salad consumption...now, protein limits will prevent me from serving the cheese. Has anyone thought about if a serving is less than 1 oz., letting us call it a condiment? Of course I can't even serve a hot dog as I can not offer 2 BR in the bun so let's just take away one of their favorites...(they don't know it is a turkey, reduced sodium hot dog)! And my yogurt trio which is a daily offering...now I must offer 2 G/BR atleast 3 days a week! Explain to the students why some days it is one and some days 2!!! My guess is that they don't need all the g/br servings as they get extra in most cases at home and are actually over eating this food group!!! If I am having trouble with figuring out grain/bread requirements...what is going to happen with the teachers, my staff, students and parents? My menu will no longer be designed with a child in mind, rather USDA...are we not defeating our Mission of feeding the children?
Posted by: Michelle Puckett at 6/5/2012 10:55 AM


I encourage USDA to consider replacing the “full component” as necessary for offer versus serve. If the menu planner plans a chicken rice bowl and allows the student to have ½ cup rice or 1 cup rice, topped with a chicken sauce and many vegetables, only the whole cup can count as the grain, according to the full component rule.
Now if the reimbursable meal was defined as a number of items that meet certain quantities versus the full component it would be easier at the point of service , as well as allow some flexibility for the student. What if there were 6 items: 1 oz. equivalent grain, 1 oz. eq. M/MA , ½ cup fruit, ½ vegetable, 1- 8 fl.oz milk. The extra grain and M/MA are not additional items, but planned to fit within the minimum/maximum weekly. The daily requirement for fruits and vegetables would still have to be offered. The student would still need to choose at least ½ cup fruit/vegetable plus 2 other items. A vegan could choose 1 oz. eq grain, and combine it with the fruits and vegetables, including legumes to come up with an appropriate lunch. A person with higher caloric needs could take all the grains and M/MA offered, but would have to take at least ½ cup fruit and vegetable.
Using the concept of items makes it easy for the cashier to review the tray for reimbursement. For the new rules, a cashier would need to know that a menu of spaghetti and garlic bread required both menu items to be chosen to count as a full grain component. Can you imagine students rushing by and you are looking for the ½ cup of fruit/vegetable and then 2 other full components, remembering what menu items are needed to count as a full component?? This is not realistic. Another sample menu: breaded catfish with red beans and rice would mean that both have to be taken, because anything over 1/8 oz. eq. of grain has to be counted as part of the full component.
We want to encourage menu planners to offer diverse, flavorful, and nutritious food. Allow some more flexibility.
Posted by: Linda Dieleman at 6/5/2012 1:19 PM


I'm still confused as to whether we can serve vegetables that will compete with the categorical requirements. The mandate is minimum serving sizes of specific categories of vegetables. Are we truly supposed to be serving only those categories? Or are we just offering those categories throughout the entire service? And we if serve other vegetables in competition with the categorical vegetables, do we utilize weighted averages to calculate our nutritional values?

It has been very difficult to devise a meal plan that fits in the caloric ranges at all age levels.

I am starting to believe this is all a smoke and mirrors game where the USDA isn't as truly concerned about what students are really eating as much as it appears that students are eating.

There are actually way more comments that I could make. The fruits and vegetables component/s in general, the low caloric ranges, this "one size fits all" mentality, the foods declared starchy versus starchy fodds that aren't declared starchy, the fact that the USDA's "sample" elementary menu old vs new that doesn't meet the guidelines and showing an old way that is in no way relective of old guidelines which we were following, grain requirements - what constitutes a serving, number of servings per week, whole grain requirements, and the relationship to obesity. Does anyone besides me find it strange that the obesity problem is increasing despite all of the healthier options that have been put on the trays in recent years? Maybe, just maybe, it's not the food.
Posted by: Robin Rhodes at 6/5/2012 2:13 PM


I want to be certain I am fully articulating the issue regarding G/B Mins that is causing such an issue. As the end menu planner, I convinced that the policy developers/enforcers/writers have not grasped the problem this has caused.

I fully appreciate use of the “old” G/B chart and the option to count breading! That has certainly provided flexibility. I do believe everyone is on the same page waiting for manufacturers' products to catch up to the guidelines. (However, ultimately that does not help us with a July 1 implementation date.)

Here is our specific issue with the MINIMUM weekly requirement of the G/B:

•The daily G/B minimum has already be defined as 1 G/B – please just leave it at that
oLogic & simple math would have determined a weekly minimum would then equal 5
oUsing the same logic as the vegetable subgroups – the weekly max 9 G/B are OFFERED and students have the choice – why are we forced on G/B to ensure the student meets a minimum? Under OVS they can decline the G/B component anyway!

•If 8 G/B is to be the weekly max – why then isn’t the daily max 8 divided by 5 = 1.6….which would round down to 1.5! 1.5 x 5 = 7.5 which still does not meet the weekly max!! Thereby, proving the determined weekly max is IMPOSSIBLE to meet. THERE IS NO SUCH THING AS A 1.6 G/B…the very regulations tell us to round that down to 1.5. 1.5 x5 = 7.5; 1.75 x 5 = 8.75
•In the design of a multiple entrée option menu, offering a daily option (such as an uncrustable or yogurt & muffin/grahams or salad bar) which equals a 1.25 G/B or 1 G/B, very likely making it our daily min G/B option, means we can’t serve that item in its current manner.
oWe want to continue to serve that item daily – what kido doesn’t like yogurt or pb & j?! Aside from the fact it is an easy production item and already there and prepared/ready by our staff. I just have to believe HHFKA had no intention of eliminating menu choices!
oI understand the simple answer is to add something to it to increase its G/B contribution AND HERE IS WHERE I AM REALLY TRYING TO BE CLEAR….in the real world that item cannot be consistent! When added to an already 1 G/B entrée, if it’s a 1 G/B item – it will put us OVER our MAX on breads (2 G/B x 5 = 10). If it is a .5 G/B item we are under our weekly MIN (1.5 G/B x 5 = 7.5).
oI cannot fathom how we are expected to communicate this to our customers and parents why the size of the same entrée varies throughout the week. Today you get goldfish with your peanut butter and jelly but tomorrow you don't - AND you get to pay the same price!

My ultimate request is to eliminate the requirement of hitting weekly minimum targets in menu planning. I believe the maximum target of 9 per week for elementary students is achievable. However 10 is optimal - which ironically is the EXACT way it was published in the proposed rule!
Posted by: Sarah Chellberg, RD at 6/5/2012 2:40 PM


I agree with all the comments already made about grains, meat/meat alternates, minimums and maximums. We also have developed some great soup recipes that the students have come to like and request when they aren't on the menu. Our Southwest soup with a chicken broth base and lots of black, pinto and kidney beans with other standard soup veggies spicy style has come to be one of the student's favorites.
At this point I feel most concerns have been mentioned and more people need to say ditto to all that has been said.
Posted by: Teal Carpenter( Visit ) at 6/5/2012 3:12 PM


SNA appreciates your comments regarding the challenges many of you are facing implementing the new meal pattern regulations. SNA staff continues to monitor this site and share your input with its Ad Hoc Working Group and with USDA officials. Your input continues to be thoughtful and helpful and has provided personal perspectives and challenges that we need to be alerted to. We look forward to the final product of the Ad Hoc Working Group and also to share this with our members in Denver next month. Cathy Schuchart
Posted by: Cathy Schuchart at 6/5/2012 3:32 PM


I am very concerned about the need to meet the 3 3/4 cups of served vegetables at the elementary level. I have little trouble giving out the fruits but the vegetables are much more challenging to market. How will we evaluate the production records versus the menus? I am also concerned with the portion of the meat and meat alternate. I am anticipating numerous critics about the lack of food on the tray. Thank you for your willingness to allow us to voice our concerns and your work in helping find solutions.
Posted by: Kristin Morello( Visit ) at 6/5/2012 4:02 PM


Ditto to just about everything already said. We are going to spend 100% of our time on planning how to meet the regs, and no time out visiting schools, making sure things are going smoothly. I can't see offering a grain item to those taking a slice of ham but not to those taking breaded nuggets. We have mixed grades in each building and do not always know when the grade changes. Our grade levels are not the same as the USDA grade levels. I can not imagine the building administrators changin class schedules for us. The vegeteable rule is so confusing we need a color coded map to figure out when to serve what. If we offer a choice of vegetables, do we offer 2 orange colored veggies on the same day? I am also concerened about the increase in the amount of veggies that must be served/offered. We have trouble getting kids of all ages to take veggies now, increasing the amount is not going to make it easier. The little ones are already confused. And, does changing the regs REALLY help the obesity problem? I agree with Robin Rhodes: is it just a "feel good" attempt? Maybe it's not the food... maybe it's the life-style that has already been determined by the time children go to school. $0.06 to increase veggies and grains, whole grains? It's not going to make up the cost difference. The "new" USDA menu template that compares old to new menus is not accurate. Kids do not take chef salads over chicken nuggets! We need menus that will sell, that will bring kids in. They are not going to eat school lunch just because we tell them it's good for them. Please... rethink this change!
Posted by: robyn wood at 6/5/2012 4:35 PM


Is there a website or email address that we can direct parent complaints to when we start receiving them next fall?
Posted by: Gayle Smalley-Rader at 6/5/2012 4:43 PM


I am very disappointed to see potatoes "singled out" as the only item you can not serve until others have been met...They are full of vitamins and potassium of which the kids are lacking AND potatoes help to fill their tummies and give them good energy for the day ahead! DO NOT DISCRIMINATE AGAINST POTATOES!
Posted by: janice at 6/5/2012 4:44 PM


Particularly coming from a nutrient based menu planning program, I would like to echo Linda Deilman's recommenditons:
I encourage USDA to consider replacing the “full component” as necessary for offer versus serve. If the menu planner plans a chicken rice bowl and allows the student to have ½ cup rice or 1 cup rice, topped with a chicken sauce and many vegetables, only the whole cup can count as the grain, according to the full component rule.
Now if the reimbursable meal was defined as a number of items that meet certain quantities versus the full component it would be easier at the point of service , as well as allow some flexibility for the student. What if there were 6 items: 1 oz. equivalent grain, 1 oz. eq. M/MA , ½ cup fruit, ½ vegetable, 1- 8 fl.oz milk. The extra grain and M/MA are not additional items, but planned to fit within the minimum/maximum weekly. The daily requirement for fruits and vegetables would still have to be offered. The student would still need to choose at least ½ cup fruit/vegetable plus 2 other items. A vegan could choose 1 oz. eq grain, and combine it with the fruits and vegetables, including legumes to come up with an appropriate lunch. A person with higher caloric needs could take all the grains and M/MA offered, but would have to take at least ½ cup fruit and vegetable.
Using the concept of items makes it easy for the cashier to review the tray for reimbursement. For the new rules, a cashier would need to know that a menu of spaghetti and garlic bread required both menu items to be chosen to count as a full grain component. Can you imagine students rushing by and you are looking for the ½ cup of fruit/vegetable and then 2 other full components, remembering what menu items are needed to count as a full component?? This is not realistic. Another sample menu: breaded catfish with red beans and rice would mean that both have to be taken, because anything over 1/8 oz. eq. of grain has to be counted as part of the full component.
We want to encourage menu planners to offer diverse, flavorful, and nutritious food. Allow some more flexibility.
Posted by: Linda Dieleman at 6/5/2012 1:19 PM
Posted by: Gayle Smalley-Rader at 6/5/2012 4:47 PM


I have found several challenges with the new meal standards.
1. I am not sure how to account for components when there is more than one "entree" choice on the menu. All students go through the same line, but may choose between two or more main item options.
2. We prepare a variety of fresh veggie cups at several of our schools and allow the students to choose the what they like. They are not all the same mix of vegetables. Some may be a combination of carrots and celery, some may be carrot, cauliflower, & broccoli, others may be cucumber and snap peas, etc. I am struggling with how to record the vegetable subgroups for this. While one veggie cup may not equate to a 1/2 cup of any particular sub-group, over a week's time, students will likely consume 1/2 cup or more of several vegetable sub-groups. I really need help trying to figure this out.
3. The very narrow bread/grain range is challenging, to say the least. It leaves little room for some of our student's favorites such as spanish rice made with brown rice. We usually pair this with chicken fajitas or beef & bean burrito, but because of the grain limitation, we will be taking it off our menu this year. It is a shame we are removing some very tasty and nutritious items from our menu due to strict guidelines.
4. My third comment has to do with the late arrival of the new tools that just came out for documenting compliance with the new meal standards. Tomorrow is our last day of school. Not all food service directors work through the summer months and I am anticipating spending a great deal of "extra time" this summer, first figuring out how to make the menus compliant and then how to put it all into a usable document that, from first glance, looks complicated and time consuming.
Posted by: Jodi Hoff at 6/5/2012 5:09 PM


I'm very concerned about the grains at all levels and protein at the high school level. I already have students and parents complaining about them not getting enough to eat....so next year I really will hear them complain. Please see about the potatoes at breakfast. Breakfast is already costing my program a large sum. I could go on and on, but I will let the next person do it. I do agree with serving heathy meals, but so many changes at one time.
Posted by: Betty at 6/5/2012 5:31 PM


Somewhere in this process of "making school meals healthier", we have neglected to consider the child. I have spent countless hours calculating and recalculating bread/grains, proteins, and calories to get them to meet quidelines. I have forfeited menu planning basics (color, flavor, texture),cost and most importantly, student acceptability, to try and acheive the required menu pattern. I have come up with a limited choice menu, that is not even appealing to me. High school students eating 1/2c pasta may ensue rioting in the streets. (I was blogged by 250 students when I offered a whole grain calzone!) I have added back in regular dressings, sweetened the unsweetened fruit, and replaced a whole grain bar with gelatin- all for calories.

All the work that has gone into HUSSC has little use today. I would venture to say that all of those "healthy menus" no longer meet the new criteria. I have little room to experiment with new foods, as I have to use my limited calories on foods the children will actually eat.

I concur with most of the posts, that the bread/grain maximum is the biggest stumbling block. I don't understand that if you have a maximum on calories, why do we need a maximum on breads and meats?

Lastly I would say, that we need to step back from all of the specific "trees" and look, once again, at the total forest-feeding hungry kids healthy meals. How did that get soooo complicated.
Posted by: Peggy Eller at 6/5/2012 5:34 PM


I let my husband read your blog. I have worked in the lunch room for 12 years and he has listen to my comments

He may have a usable idea. You should have a biweekly target and not lock in on the daily lunch calories.
You should fight fire with fire. To require these strict amounts of food areas, one has to assume everybody burns the protein in the same manner, etc A professional in this area of study will probably show that this strict diet for young kids has little impact on their development.
Second: Schools with a good PE program, should be allow wider tolerances in their lunch servings.

There is no solution to meet these guidline, but everyone will try to keep their jobs.
Stand-up for the kids and parents.
Posted by: Carolyn Boose at 6/5/2012 9:36 PM


I agree with all that has been mentioned. Ironically, eliminating nutrient-based menu planning for the more simplified food-based approach has made this such a complicated venture and totally disregards our end-users. If these menu planning requirements are so complicated that those of us in the field are so challenged by them, how in the world are we going to be able to explain such requirements to our students and their parents when they don't understand why they can't just take what they like on their tray? If we're limiting fats and added sugars, working with whole grains and including fruits and vegetables with every meal, we're already providing the basis for a healthy diet. Now we need to micro-manage their diets further by telling them what and how much they can or can't eat from those healthy options? Talk about a recipe for eating disorders!!! Sounds like job security for dietitians and/or those in the psych field!
Posted by: Kari Alvey at 6/5/2012 10:37 PM


I feel these new meal plan regulations are defeating the purpose of serving nutritious meals. If the students won't eat it and it is all thrown away then they certainly are not getting a nurtrious meal - let alone any nutrition at all. We will have less students eating our meals; therefore, leaving more students going hungry.
Posted by: Peggy at 6/6/2012 3:24 AM


I feel if the USDA wants us to know the calorie count and sodium counts they should provide us with programs where we can enter our recipes in and get that information. Most food service programs do not have extra money and time to buy a program and then enter all the data we need . If the government does not do this then maybe the SNA could.
Posted by: Carol Iedema at 6/6/2012 7:17 AM


After reading all the posts, this appears to be a very complicated meal pattern that we must implement. Even the RD's are struggling.
School is out, our orders are placed through the month of Sept. State USDA does not have the answers. ANC is middle of July - we're back in school in less than a month after the meeting. It appears that a pilot school district should have been selected to run this program for a year, work out all the problems before rolling out to the entire country.
It appears that changing the meal pattern is at least 6-9 months behind of what we need to begin our school year.
At the LAC in Washington, not all questions could be answered - at our state conference the questions could not be answered.
I have a school that covers K-12 special needs children and they're all intermingled during the serving. I have yet to hear the solution for this.
Posted by: Elaine at 6/6/2012 9:19 AM


I commented above, but had more to add. Something else that makes absolutely no sense to me is that the suggestion for getting those extra required calories is to add fat and sugar. Really? How are we supposed to add fat and sugar to fresh fruits and vegetables that everyone is pushing us to use more often (and why on earth would we want to)? In the past, our district has added calories by offering another whole grain item. It also bewilders me why we can add fat and sugar to perfectly good foods, but can't use a whole grain graham cracker more than twice a week because it's now dessert.

USDA needs to step back and remember what we're trying to accomplish. Was it the goal to make planning a menu so difficult that even experienced dieticians are having a hard time? Was it the goal to force districts to incur even more expense by forcing students to take a fruit or vegetable that they don't intend to eat?

USDA has taken what started out as a good, solid meal pattern and turned it into a numbers game that may look neat and nice on paper, but does not translate well in the real world.
Posted by: Crystal Thill at 6/6/2012 9:42 AM


Education is a key component to fighting the obesity epidemic, but altering the school nutrition meal pattern in such a restrictive manner seems to be sending a punitive message. If USDA wants to help this obesity problem, then they need to seriously examine the food stamp program. Our tax dollars should be going towards only nutritious food items similar to the WIC program. When students leave our schools, hungry as they will next year, and go to the nearest convenience store in the small town and buy "junk" food with the families food stamps, what have we accomplished? Why can stamps be redeemed at the local restaurants? In the poverty stricken areas of the SE, we see children in very food insecure homes and the school breakfast and lunch are too often the only meals they have all week. Now I am being forced to plan meals, which I have done at all three levels, that force me to restrict the very foods they do not see at home i.e. the meat items. As I am telling my friends and family, I will have my hands slapped and not be allowed to receive a 6 cent reimbursement per plate if I serve 1 slice of bread too much in a week. Where is the common sense? Lastly, I am in agreement with all the other comments regarding pilot programs, too few calories in the elem., then the difficulty of reaching the calories in the high school level without adding "ice cream" as one writer stated. Best wishes to this committee. Our school principals have already realized that they will be making lots more money from the vending machines.
Posted by: Sherrill at 6/6/2012 12:13 PM


No other industry is as highly regulated like schools when it comes to nutrition. You can offer all the fruits and vegetable you want but you cannot make a student eat them. Ultimately, the parents can just say no to school lunch if they think we are the cause of their child's obesity. I am all for healthy options but these new regs are just not sustainable. All of these changes make me think USDA knew it wasn't sustainable but it was a PR success for them and a majority of school foodservice departments will fail financially if changes are not forthcoming. At least give more time for phase in to help us with transition. Next time, check with the people on the frontlines, they can tell you what is workable and what is not.
Posted by: Kevin Oswald at 6/6/2012 1:41 PM


We are now considering dropping our scratch cooking and baking due to the complicated task and recordkeeping of running the recipe analysis, weighted averages, etc. especially when adjusting the number of portions the recipe calls for each time the meal counts increase or decrease.
We are also looking at adding more ala carte entrees just in order to encourage students to eat food from school.

We serve grades 9-12 in affluent areas where students can leave campus to go to the nearest fast food joint and buy the larger entrees to carry them through the rest of the school day (3 p.m. to 5 p.m. depending on the class load).
Imagine offering a seventeen year old boy a hamburger with a 2 oz. bun and a 2 oz. patty!
My fear is more food theft by students because the entrees will be so puny for high schools.
For USDA - Increase the grain maximum and the meat/meat alternate maximum
- Increase the reimbursement rate for the higher grades. We receive the same rate for a 1st grader as we do for a 12th grader.
- Increase the maximum sodium levels. There is a lack of scientific evidence justifying such low maximum levels.
- Allow 100% fruit strips, etc. What's the difference between a smashed fruit in a strip and dried fruit? What's the difference with squeezed/mashed/blended fruit and juice as a beverage and a squeezed/mashed fruit and juice in a fruit strip? (Without the support of Mr. and Mrs. Potato head, this one didn't get legislated as an approved fruit source).
Who will be there when the school district's general fund must support the meal programs and take away funding for classroom materials and resources, maintenance and repairs?
Six cents per meal served is not going to cut it!
- Issue schools six cents based on enrollment figures, not on actual meals served to cover overhead costs, increased food costs, equipment, etc. as a result of implementing the new regulations.
Posted by: Laura at 6/6/2012 3:05 PM


I have been trying to keep up with the compliances for the past couple of years, by adding sweet potatoes, kale, spinach, boccoli, etc. We have created new Bean Recipes and added them to the menu. My main concern is that all children do not have the same taste. Also, education for the children, parents and staff is very important, because when we can no longer put a bagel out because of it's size, I am definitley going to here about it. I worry that the children will still be hungry when they leave the lunchline because of the portion sizes. Especially the grain servings. The K-5 needs to be changed from 8-9 oz to 10 oz's. Where these changes ever piloted to see the results? I did taste testings to get responses, it is not easy to do all at one time!
Posted by: Denise at 6/6/2012 5:12 PM


Healthier items (which contribute a bread/grain serving)such as whole grain snack animal crackers typically selected for occasional dessert offerings at the k-5 level may need to be replaced by lesser nutritional dessert items such as pudding, cake, etc. that do not contribute. Counting Bread/Grains should be exempt for items offered as a dessert/treat item so the upper cap of 9 ounces is possible to achieve while offering the students a treat during the week.
Posted by: Zoe at 6/6/2012 6:13 PM


I am a school nutrition manager in a k-5 setting at this time. I have been in middle 6-8 and high 9-12 as well as prior service in day care setting under food service regulations. I have been evolving with everyone else in the program, training employees, assisting students and working with teachers and administrators along the way. The comments above mirror my own feelings in many ways, the new requirements seem to me to be discriminatory and very difficult to implement for those with boots on the ground. Students on the free and reduced program will be singled out to return to the server for additional items in order to avoid charges and payments and students who are not on the program will just eat elsewhere especially in the upper grades. This will be a nightmare for those food service professionals who are on tight labor budgets as time to explain in simple terms that the rules are immutable to staff who are rushed to "get the kids thru" and to explain to customers during the sale, who are use to "having it their way" time is simply not available to do this. This will add to an already poor image of the child nutrition program. I have pride in my job and it has its rewards, the program has come far in offering many more fresh fruits and vegetables, whole grains and lean meat choices...cutting back on fats and sugars, all these changes are positive, but the new restrictions are so difficult to implement that it looks to me like it will put the brakes on that positivity and drive our paying customers away while forcing our already taxed economy to pay for foods that are forced onto the customer in the free and reduced program who will ultimately discard most of the product.
Posted by: Tracey Lanier at 6/7/2012 8:40 AM


I believe USDA left too much to interpretation in the area of serving sizes. Requiring no specific serving for any age group I believe is a mistake. To have a reimbursable meal a student at any age must have 1/2 cup of fruit or vegetable on their tray. If you offer all fruits and vegetables in 1/2 cup servings it won't be a problem....at least not at the 9-12 grades. Elementary is another issue. If you offer all servings as 1/2 cup you will go be out of your calorie range. Much more that needs to be addressed in this area, but bottom line....younger children need a smaller minimum serving size for the meal to be reimbursable.
Posted by: Libby Cooke at 6/7/2012 8:49 AM


I don't know how you can call it Offer vs. Serve when you are making a student take a fruit or vegetable. You are not giving them the choice to refuse what they want to not take. No matter how many choices of fruits or vegetables we offer each day some days you are going to have something some aren't going to like so by taking away the students option of refusing an item that they may already have decided they do not like I am afraid we are teaching them to be more wasteful because many of them will just throw it away. Especially when it is a half cup serving. That is a lot of vegetable for some of the smaller children.
Posted by: Donna Myrum at 6/7/2012 12:03 PM


We have 3 locations that are K-12, all grades are mixed when getting off of the bus at breakfast time, I know the new reg's for breakfast don't go into affect until next year (2013-2014) but how do we satisfy the needs calorie and menu wise when they all converge at once?
Posted by: Jack Noonan at 6/7/2012 5:12 PM


We are seriously considering dropping out of the NSLP for at least 1 school so we can stay afloat. We have open campus, I can not compete with all the fast food restaurants within 7 miles of our schools. Maybe this is the way to go. The kids will eat what they want, they can go out and get cookies the size of a human head, and enough soda to swim in, and they can bring in whatever they want at any grade level. When I see 1st graders with fritos, cookies, and bologna sandwiches on white bread for their lunch I know the parents are not concerned about what we serve at school. We did not cause the problem by ourselves and we are not going to solve it by ourselves. It takes a village to raise a child, and our village is full of fast food restaurants and the kids play on computers instead of playground equipment. School food service needs to run as a business if we are expected to be a business. No other business has these kinds of restrictions.
Posted by: robyn at 6/8/2012 11:01 AM


As an RD, the nutrition part of school meals has been my passion. I'll add other comments later, but I want to ask about Black-Eyed Peas and Lima Beans. Really? Make these 2 fabulous legumes compete with corn? Are they starchy vegetables? Absolutely! And so is every other legume, sweet potatoes, and many other root vegetables. We're not planning the old diabetic exhange diets; we're planning meals for children. And we WANT them to eat lima beans and black-eyed peas. I dare anyone to show me a kid over-eating these! In Oklahoma, we grow pintos & black-eyes. I've worked very, very hard to get our kids to include them with their meals. Now they do, and we have to choose between corn on the cob and black-eyes? If, for some reason, limas & peas don't have enough protein (like who really cares?), at least move them into the "other" group so they have a chance of survival! Or put a star beside it and say it can't be used as a m/ma. But teaching kids to eat legumes is too important to just shove certain ones out of their lives.
Posted by: Deborah S Taylor at 6/8/2012 11:11 AM


We are a residental treatment center for court committed teenage boys & a 100% free Meals.The boys come with many problems- one of which is poor nutrition. Many have never had 3 meals a day-they were on their own for meals. Many are thin & need the calories, grains & protien so that their bodies can catch up to their age. The new restrictions will keep them hungry & under nourished. Hunger also triggers their very strong survival mode of hoarde food, steal food or fight for food.Hungry angry aggressive boys do act out-decreasing a good out come from treatment.This new plan does not work for this type of population- one size does not fit all. These boys have already been left behid & they will still be left behind,again.
Posted by: Gen at 6/8/2012 12:12 PM


The new requirements have left dedicated, inspired child nitrition workers dismayed at the lack of concern for our students. I have a district that is 66% free and reduced.We have students who only eat at school, these children are hungary and simply cannot make it through the day and then the night with the serving sizes that are now required. We also have small schools that must due to teacher loss send their students "mixed" together. We do not serve our high schools in strict class order, I have asked for help with this situation and so far no one has been able to answer other than speak with the principal and ask for their help. Does anyone actually think that they care considering they are trying to teach children with too few teachers and budgets cut to the bone. If we lose money we will have no district to back us up because they can barely operate themselves.
Posted by: Jennifer Roberts at 6/8/2012 12:16 PM


In planning the Elementary menu for my district I am running into problems with the fruit and vegetable components. (I have not yet addressed the grain issue)
In order to meet the minimums of fruits and vegetables we are required to serve a 1/2 cup portion. Elementary children will have a difficult time consuming that amount of fruit or vegetable. Especially when one considers that most children prefer raw vegetables over cooked. Never mind that the students have 20 minutes TOTAL of lunch time, including time spent standing in line which amounts to only 5 minutes for some to eat! The option would be to decrease serving sizes and offer more options over the course of the week. However, this increases the prep staff time significantly. Six cents won't cover the increased food cost, let alone the increased labor cost of preparing more food items per day.
In addition, how many times per month will kids tolerate carrots? Children are not accustomed to eating the dark green and orange vegetables. Also, why can't the orange fruits count toward the requirement?
I am very discouraged and stressed about meeting these regs. I feel they are very unrealistic.
Posted by: Kris Spellman( Visit ) at 6/8/2012 5:29 PM


Regarding the legume requirement... really? A half cup serving of beans or refried beans? How would a second grade student come close to eating that amount? Also the fruit and vegetable serving sizes are larger than what we have served in the past. If students refuse to eat the new offerings vegetables (a lot of corn, beans, peas and carrots already go into the trash at my district), what will they have to fill up on? A smaller protein and grain portion? An incremental meal pattern change would be much more successful
Posted by: Kris Spellman at 6/8/2012 5:36 PM


I feel like USDA needs a reality check.
Maybe they should come and visit a few districts to see the positive things we are already doing in school lunch.
There are no standardized recipes and no training materials available. Even the sample menu USDA posted didn't meet their own guidelines.
It is all very disappointing. If they can't even interpret their own guidelines, how do they expect us to train employees?
The min/max on proteins and grains limits student choices and makes it extremely difficult to meet the calorie levels.
Implementation will be difficult at best given the timeline.
I think in the long run the new meal pattern is going to do more harm than good.
Students will be upset over the lack of choices. They will also be upset when our employees tell them they will have to take a fruit or vegetable for a reimbursable meal.
This isn't going to be an easy task at the middle and high school level for some of our employees.
I am predicting upset students and even more upset employees.
Posted by: Lisa Wiedner at 6/11/2012 9:05 AM


I too am concerned on all the issues. Would just like to know why it always has to be so complicated!
Posted by: Nykki at 6/11/2012 10:11 AM


I have read most of the comments and have the same thoughts. It is so disappointing that USDA has caved to the political pressure of those you have no idea what is involved in managing a child nutrition program. While the requirements definitely needed updating,the extreme conditions we are now facing will signal the end of the National School Lunch and Breakfast Programs. Districts will not be able to afford to feed the children or be able to survive the loss of customers. The promised six cents now comes with conditions that creates fear if a district doesn't meet all criteria. I have experienced many brainless changes in my 26 years in child nutrition but nothing will top these new regulations. Good luck to all of you and maybe these comments will help in steering USDA back towards reality.
Posted by: eileen staples at 6/11/2012 11:37 AM


The new grain/bread and meat/meat alternate regs are going to be impossible to meet if you offer more than one selection. First “if” you find bread that works at the elementary and Jr. Highs then it is too small for the High School.
2nd If you offer hamburger everyday at the secondary schools you cannot let them have cheese with it or you go over, we have open campus at all secondary schools all this is going to do is drive them away.
I had to eliminate almost all hot rolls at the elementary level if you have one sandwich during the week then it throws you off on the grain/bread .
We have pre-made chef salads and now I have to include a starchy veggie and pea/beans or legumes? So now I am taking what was a very healthy choice and adding in a potato salad and hummus not so they will want it more but just so if “meets” regs. I feel like I am not longer creating a menu that students will want to consume but one that fits in this nice little box that someone who does not have a clue what we have to deal with. Most students have 10 minutes to eat and that’s if they are lucky this is going to create more plate waste higher lunch prices which will lead to a lost in participation. I don’t understand why we are not given more TIME to try and come up with items that will work, most of us have done our bids for next year we can’t sit around until last minute
Posted by: Pam Hart at 6/11/2012 11:59 AM


With regards to the Before and After menus, I would like to ask if there is anyone out there that would serve Pizza sticks with Marinara, a banana, raisins, and WHOLE milk?
We are much more savy and educated than that. What these regulations will do is destroy all of my creativity and use of vegetable blends that I may or may not be able to count in a certain category or it is lumped under "Other". The grains are going to be a problem. And, after these comments the training guide will be unveiled in JULY. Wow, one month to get it done. Of course I have started it, but I am tired of doing, undoing, and redoing work due to an "Interm Rule".
Posted by: Darlene P. at 6/11/2012 12:07 PM


Reading the comments of others, the thread seems to be the impracticality of the new guidelines. The lack of training and time to implement, the acceptability of the students. One of my managers made a wonderful comment. She said that if kids liked kale chips so much, wouldn't you be able to buy big bags of them in the store?
I've had a home garden for over 40 years and can and freeze. I've never gone out to my garden in designer boots and a dress as Mrs. Obama was shown on TV. Put these restrictions in the Congressional cafeteria and see what the reaction is.
Where has common sense gone? We are in the business of feeding children with an emphasis on feeding. As many have said, we will be feeding the trash can, not the children and a trash can does not need good nutrittion. If this is so important, why not start with the food stamp program? Children's tastes are developed in the early years. Require the parents to use their food money wisely--lean meats, fresh fruit, and vegetables--not chips, processed, boxed foods, and other foods low in nutrition and high in calories. I agree with those who have said this is putting the cart before the horse. It may be a nationwide problem, but school lunch is only 17% of a child's meals. I don't believe that is enough to change anyone's eating habits.
Posted by: Linda Miller at 6/11/2012 2:35 PM


So as I sat and listened to my area representatives attempt to explain what we will all have to endure next year,I asked a simple question...who made these decisions. I am told "USDA and The Fed". How easy it must be brush off to a faceless and nameless committee. I would like to see these "Experts" in child nutrition step out from behind the curtain and with a straight face...explain how any of our programs can be successful under these guidelines. I also wonder if they live their own lives eating in this manner that they dictate... I suspect we would find hypocrisy
Posted by: David Bartholomew at 6/12/2012 8:12 AM


Our district is a Healthy US School Challenge district and have been adhering to strict guidelines for 2 years. The process to qualify for HUSSC was daunting and took over two years to modify recipes,find products that meet the requirements, train staff only to now have to meet the challenges of the new meal pattern.The HUSSC requirements made sense and our students were offered a variety of fresh fruits and vegetables,many locally grown, along with beans and lentils. Our challenge begins with the bread/ grain requirments.Do we not know that 9 is not divisible by 5? We have 5 different entrees at the Elementary level. It is going to be very difficult to find the combinations of B/G without making the menu totally monotonous. I have worked in the industry for over 30 years.I have seen the program evolve from a single entree menu choice to one where many choices are offered and are well received by the customers.Many will revert back to offering the same menu items repeatedly in order to formulate menus that meet the new requirements.
Posted by: patty at 6/12/2012 11:01 AM


If I have one more principal ask if we are hiring a chef for their campus, I'm going to scream. STOP with all the "chef stuff" PLEASE. We are a very low (1.5%)F&R....we don't get all the gov't funding that the higher F&R districts do. We don't need a chef to cook what is mandated by the government. I'll put our hard working lunch ladies up against any of their chefs. Our goal is to get the kids to eat...not throw it in the trash. You can offer all the whole grain items you want, but if it's thrown away, what have you accomplished? Why don't they put stipulations on the food products that can be purchased with food stamps? That should be their starting point...not school lunches ! Make them buy healthy foods...not chips, icecream, frozen pizzas,candy, and sodas. And PLEASE quit promoting chefs in the schools. WHO can afford to pay one !
Posted by: Patti Fisher at 6/12/2012 1:14 PM


Good Job USDA! You figured out how to get out of the School Lunch Program. The meal pattern has been designed by someone lacking in school feeding experience. The narrow limits on G/B & M/MA are counter productive to serving a variety of healthy foods fo students. I can't even offer a sanwich a day in grades K-5. The M M/MA should be at least 10 oz over the week. Same with the grains. With this meal pattern, I can't meet minimum calorie requirements.
What KDG. child is going to eat 2 cups of Romaine, much less take it? We are being forced to raise lunch prices by 10 cents for less, more expensive food. You say you are giving us 6 cents. Tell me where I can buy an apple or orange for 6 cents. There will be plenty of expensive, healthy trash.
Participation will go down because there is not enough food served. Students will not purchase food they do no like. Most of the children in my school like our food. Now they will be packing their lunch or parents will be bringing in Pizza Hut, McDonalds & Burger King. Because they want their children to eat what they like to eat.
Posted by: Judy Wecker at 6/12/2012 1:30 PM


I think the comment by Ms. Staples echoes all of our sentiments. Obviously the people who made these rules and regulations have no idea how to feed hungry children. Do not get me wrong; I do believe obesity has to be addressed, but that should come first at home. Our lunch program is not the cause of childhood obesity. Our meals have always been portion controlled. This is not the case in many homes across the country. We are being told to fill these children up with fruit and veggies? Who is kidding who! Most children will take the forced fruit and veggies and take them to the trash. Many students will go away hungry, or not even buy at all. The older ones will stop at the local convenience store and fill up on whatever they can get their hands on because they are still hungry! The younger children will head home and do the same. This will completely defeat what they think they are accomplishing by these impossible standards. I would like to see all of the lawmakers responsible for these new "regs" have breakfast and lunch served to them according to "their" rules.
Posted by: Sheila Horner at 6/12/2012 1:42 PM


I am trying to put together a set of five-week cycle menus; we will be offering two well liked entrees besides the chef salad and yogurt meals. One of the problems I have ran into is meeting the grains in a sensible manner. I do not understand why if grades 9-12 in offering 10-12 offerings a week has to have a minimum for the day of 2 oz. This whole setting takes creativity to a whole lot of extra time that is not built into our schedules. It takes the coney bun of 1.5 oz. to a 'pain' level that should not be.
Posted by: Marcia ERdkamp at 6/12/2012 1:43 PM


You can lead a horse to water but.....you cannot make him drink. I feel as though many children will turn their nose up to our meals and just walk on by, open their brown bags with chips and a candy bar! Those who go through the line will pick up the 1/2 cup fruit or vegetable and then promptly place in the trash. We have accomplished nothing but make the vendors rich!
Posted by: Lee Anne Dampier at 6/12/2012 3:41 PM


I will agree that USDA needs to update their school RECIPES. Those are the school kitchen's standard. The understaffed kitchens do not have the time or resources to be creative with producing new recipes. Their position is to create and serve the meal within their given schedule. USDA also needs to update their COMMODITIES/DONATED FOODS department. For example, if corn, peas or chicken nuggets are to be used infrequently, USDA needs to stop sending them to the school systems.
Posted by: Arlene Leonard at 6/13/2012 1:13 PM


The Food Service Directors of America’s Schools can see great wisdom in much of the Healthy Hunger Free Kids Act.


However, the minimum and maximum tolerance is too close to be reasonable. Additionally the method used to calculate the min/max on grains, M/MA is to prescriptive and creates an environment that actually reduces variety and daily choice for a student unnecessarily.

First the min/max with a tolerance range of just 1oz over the course of a week for K-5 is to prescriptive to be reasonable. The USDA should change the rule to make all min max ranges at least 3oz per week, and do not lower the minimum from the current point in the final rule. This range would be more reasonable for planning meals that are nutritious and exciting.

In my opinion even the best chefs such as Jamie Oliver and Rachel Ray would have a difficult time pleasing the students fickle palate, offering variety, and working within the tight boundaries of a 1oz tolerance over the course of a week (.2oz per day). Not to mention staying in budget….

The second suggestion is to evaluate the daily menu items over the course of a week of planned offerings by category. Treating each alternate daily item separately instead of including alternates in the highest offering and the lowest offering daily.

I will illustrate my suggestion using a PB&J sandwich. A PB&J Sandwich made with 1.8oz of bread meets the 9oz maximum for the week so long as nothing else is offered with a greater amount of grain.

If a chef/director/menu planner/registered dietician attempts to offer the student a choice in the planned menu with a few days of 2oz of grain they would go over the maximum grain allotment.

If the menu is planned with a few 1oz days the minimum will not be reached.

Alternate Item Example=
Monday – Friday PB & J = 1.8oz Grain per day – over the course of the week this equals 9oz. (if you round down to 1.75oz per day = 8.75oz)
This menu items is fine when evaluated alone.

Planned Rotating Example Menu =
Monday: Roasted chicken with ½ cup brown rice = 1 Grain
Tuesday: Whole Grain Pizza = 2 Grain
Wednesday: Whole Wheat Pasta 1 cup = 2 Grain (or ½ cup plus a 1oz wheat dinner roll)
Thursday: Whole Wheat Sub made with Turkey and low sodium cheese = 2 Grain
Friday: Asian Stir fried vegetables with chicken breast, served over ½ cup brown rice = 1 Grain

Grain count for the above menu:
Monday = 1 Grain
Tuesday = 2 Grain
Wednesday = 2 Grain
Thursday = 2 Grain
Friday = 1 Grain
Total Grains for the planned menu = 8 Grains
This planned menu is fine when evaluated alone.

We have established that alone, both the planned menu and the alternate menu are within the grain range.

However when you follow the calculation determined by the final interpretation of the rule you run into problems.

This is the calculation method as I have been told via state agency.
1. Take the highest grain for the day on the menu including alternates
2. Take the lowest grain for the day on the menu including alternates
3. Add together all the high grain amounts for the week
4. Add together all the low grain amounts for the week
5. This gives you the low/high for evaluation against the 8/9oz minimum/maximum

Now we will audit the menus for the $.06 approval


Low Grain Audit =
Monday Low = 1 Grain
Tuesday Low = 1.8 Grain
Wednesday Low = 1.8 Grain
Thursday Low = 1.8 Grain
Friday Low = 1 Grain
Total Low Grains for the week = 7.4oz – this fails to meet the minimum

High Grain Audit =
Monday High = 1.8 Grain
Tuesday High = 2 Grain
Wednesday High = 2 Grain
Thursday High = 2 Grain
Friday High = 1.8 Grain
Total High Grains for the week = 9.6 – this fails to meet the maximum (even if you round down the 1.8 Grain offering to 1.75 you are still over)

Through this demonstration you see that a whole grain rich planned menu meet the min/max for grain without an alternate choice. The alternate PB&J on whole grain bread meets the min/max for grain without the planned menu.

However when you use the calculation method given to us by the USDA via state agency both the minimum and maximum for grain fail.

This is flaw in an otherwise well intentioned rule to move the nation towards a diet rich in whole grains. The unintended consequences of a very strict grain minimum/maximum in this regulation has deprived our nations students of the daily variety they have come to enjoy under the current NSLP.

I’m sure virtually all the directors in the country can see great wisdom in the final rule. However, that same group can also see some flaws. Flaws that left un attended will have negative consequences.

If I had to use an analogy I would say the Final Rule for HHFK is a beautiful sheet of music. In fact it’s one that the Food Service Directors of America’s Schools are looking forward to dancing to. All of us are willing to learn new moves and put on the best show of our lives. However, contained within this sheet of music are a few really sour notes. That left un attended are threatening to displease our audience. This will ruin the entire performance.

The Food Service Directors of America are willing to dance. Just give us a smooth harmonious song for the performance.
Posted by: Joe Kilmer at 6/13/2012 5:03 PM


I don't think the rulemakers took into account the overwhelming task that this is for small, rural districts who don't have staff to work on it. Add to that the narrow window of time, the constant rule changes, and the total inability to meet these criteria, and this becomes the first year that I have not loved my job. I am depressed at having to decimate a program that was meeting HUSSC standards and student acceptance and putting in a numbers game with foods that have no hope of being eaten. I see 20 years of effort out the window, and no one seems able to speak up on our behalf. Wondering why SNA is not out in front of these restrictions??
Posted by: Joyce Johansen at 6/15/2012 8:44 AM


I feel the standards that have been placed before districts is going to be extremely hard to meet this next year, due to the timing as well as we do not have all the information. Training has been poor and unclear on many items. I agree we need to focus on nutrition but restricting many of the items/choices will lead to students looking in other areas after school for a quick snack because they are still hungry. Child Nutrition has always controlled portion and offered a wide variety of choices for students but these restrictions are extreme and cause a problem for menu planning, profitablity, ordering due to manufacturers time frame to produce and provide documentation.

My first concern is "student" nutrition and acceptance of products that are to be offered.
Posted by: Debbie Needham at 6/15/2012 11:45 AM


Why as a100% Free Meals residential school, we do not qualify for the Dinner reimbursement but a non- residential does? Are we not part of the Healthy, Hunger -Free Kids Act Of 2010 ?
Posted by: gwhite at 6/18/2012 10:25 AM


In response to Joyce Johansen who commented "I don't think the rulemakers took into account the overwhelming task that this is for small, rural districts who don't have staff to work on it. Add to that the narrow window of time, the constant rule changes, and the total inability to meet these criteria, and this becomes the first year that I have not loved my job. I am depressed at having to decimate a program that was meeting HUSSC standards and student acceptance and putting in a numbers game with foods that have no hope of being eaten. I see 20 years of effort out the window, and no one seems able to speak up on our behalf. Wondering why SNA is not out in front of these restrictions??"
Posted by: Joyce Johansen at 6/15/2012 8:44 AM

I have been asked to lead a committee of state directors, local directors and industry to develop a guide to include resources available on the SNA website that will assist in implementing the new meal pattern requirements. I formerly was state director for USDA Child Nutrition Programs in Washington State and am familiar with the issues of small school food authorities.
We hear you and we are working with the USDA to ensure they too, hear you. We have been working with the USDA and state agency directors on a more expedited guidance process and additional flexibility in the interpretation and deadlines/timelines for implementation. Additionally, SNA has scheduled 6 “Hot Topic” sessions at ANC Denver on the final meal pattern implementation. Accompanying these sessions will be the unveiling of SNA’s implementation guide: Advice and Resources for Meeting the New Meal Pattern. We look forward to sharing this valuable resource tool with all SNA members.
Posted by: George Sneller at 6/18/2012 9:01 PM


It is improbable that a student who takes a 1 Grain item at lunch on Monday will do the same every day the rest of the week. They will take a variety in most cases, so the way we are being asked to count min. and max. grains is very impractical.
Jerolyn Goodman, RD, SNS
Posted by: Jerolyn Goodman at 6/19/2012 6:21 PM


I agree with all of the above comments and love the analogy that it is like doing a jigsaw without a picture. A challenge to say the least.

My comment that has not been addressed is in regards to legumes. It would be helpful to count legumes that are in an entree as a protein and still have it meet the 1/2 cup legume requirement as long as the weekly 3 3/4 cups of vegetables and all subgroups are met. Not allowing this discourages development of vegetarian entrees and forces more "side" bean dishes, which really limits variety. For example, if I serve a vegetarian chili with 1/2 cup beans that meets the MMA, I still have to serve beans again that week. Let's face it, beans on their own are not a fan favorite.

Which leads to my second point- it seems the new regulations should have been preceded by a year or two of mandatory nutrition education and then an ongoing nutrition program. Kids will not learn to eat unfamiliar foods without coaching, encouragement and education.
Posted by: Clare at 6/19/2012 9:49 PM


1. I was told by the CNC facilitator at our implementation workshop that these new regulations were put in place because 30% of the US children are obese...what about the 70% of children who needs more calories, etc than these guidelines provide?
2. If the new guidelines are not optional as per USDA...why do our menus have to be certified to receive the 6 cents? We were never certified before to receive our reimbursement?
Thank you for allowing me to ask!
Posted by: Stefanie @bousd.k12.ca.us at 6/21/2012 6:44 PM


I HAVE JUST RETURNED FROM OUR STATE FOOD CONVENTION.THE CLASSES THAT I TOOK REGARDING OUR NEW MEAL PATTERN WAS VERY CONFUSING.I DON'T THINK WE WILL BE READY TO IMPLEMENT THIS MEAL PATTERN BY THE BEGINNING OF SCHOOL.FIRST OF ALL WE DON'T HAVE THE TIME TO GET INFORMATION OUT TO OUR PARENTS.I THINK WE NEEDED TO EDUCATE MORE BEFORE WE JUST START ADDING MORE FRUIT AND VEGGISE AND LESS PROTEIN AND GRAINS.I HAVE PK THRU 5TH AND WHEN I PUT 2 OR 3 NUGGETS ON THEIR PLATE THEY ARE GOING TO SAY WERE IS THE CHICKEN. I THINK WE OUR RUNNING OURSELVES OUT OF A JOB BECAUSE THE PARENTS ARE NOT GOING TO UNDERSTAND THAT LUNCHES ARE GOING UP AND PROTEIN AND GRAINS ARE GOING DOWN.PORTION CONTROL IS STILL THE ANSWER REGARDLESS OF WHAT YOU ARE SERVING. I THINK ALL CAFETERIA ALL OVER THE U.S. ARE DOING A GREAT JOB. PLUS THEY WANT FRESH FRUITS AND VEGGIES WERE IS THE MONEY GOING TO COME FROM. I HOPE YOU RETIHINK THIS MEAL PLAN AND GIVE IT A LITTLE MORE TIME. THANKS FOR LISTENING . phudson@smss.org 6/24/12 5:43pm
Posted by: PAULA HUDSON at 6/24/2012 6:43 PM


My biggest concern at the moment is getting the bread/grain servings for my Elementary and Middle School menus to meet. In order to meet the minimum I am going over on the max and vice versa. I worked on my menus for 3 days last year, I am going on week 6 right now for this coming years menu. It should not be this hard to create a menu.

My other issue is not being able to serve a sandwich every day in Elementary schools. We have many students that will only eat a sandwich and next year I am having to serve a cheese stick, granola bar and a small smuckers PB&J in order to try and meet the minimum grain requirements.

My third concern is mixed grade schools. We have several schools that are middle/high and elementary/middle. There should be waivers for these facilities.

Lastly, I am concerned about meeting the calorie ranges for the grade levels. I can't even get my menu to work for the bread/grain. If I'm over or under on mt calories, how do I even begin to change my menu to meet all of the ranges of calories, m/ma and grains?
Posted by: Laura Johnson at 6/25/2012 3:53 PM


I believe the most challenging of all is the grain/bread requirement at the K-5 level. As stated before, it is impossible to offer a sandwich daily in the K-5 level with the 9oz g/b maximum requirement. We utilize 45,000 pounds of peanut butter yearly, and that purchase was made before the new regulations were revealed. Now I can't make sandwiches that fit within those guidelines to the diappointment of thousands of children.

Additionally, I feel that our district has done a great job at reducing starchy vegetables and improving the overall health of our meals. At all grade levels, I now have to INCREASE our starchy vegetable intake to meet the minimum requirements. Considering we have beans once a week and now starchy vegetables at least twice per week, I feel like I am back where I started, and my carbohydrate counters at the school are going to be unhappy.

We need a common sense approach to nutrition. It should not take a district 2 months to complete a menu. It has taken that (if not longer) and several meetings with Child Nutrition Managers to get the menu to where it is right now--and it's still not correct. Even if we do get this menu "right," how am I going to explain this new meal pattern to parents, principals, teachers, and students?

I truly believe there were very few districts doing a poor job of providing adequate nutrition for our students. Most of us care a great deal about what is served to our students and want to do what we know is right. I feel like that has been taken away.
Posted by: Rachel at 6/25/2012 4:11 PM


These are two of the questions that I encountered while practicing on the new spread sheets:

How do you categorize salsa? Would it go under red/orange vegetables as tomato, tomato sauce or tomato paste or would it be accounted for at the end in the condiments section? And if it was counted for as a vegetable, how would you account for the other vegetables in the salsa such as onions? What is the conversion from amount to credible amount?

How do you categorize mixed vegetables? For example if the mixed vegetables contained vegetables from different sub groups and none of the vegetables were in an amount greater than 1/8 cup but the total amount of vegetables served was greater than 1/8 cup. If it is a pre-prepared mix how do you find out how much of each vegetable counts for each category? Would you be able to credit the mixed vegetables under the “other vegetables” tab?
Posted by: Alyssa at 6/26/2012 7:46 PM


As menu planners get further into the process (which is usually finished by this point) it's being discovered that for many of us, we're short on calories, leaving us to add junk like baked chips or pudding instead of offering a larger entree or an extra whole grain item. Someone at USDA please tell me how this makes any sense. How are we supposed to explain to parents, staff, wellness committees, etc. why our new, "healthy" menus have these junk items when they didn't before? Not only that, but it's an unnecessary added cost that the $0.06 isn't going to even come close to touching.

Another unintended consequence menu planners are running into is that we're reverting back to more processed foods since it's simple to decipher exactly what the m/ma and g/b are. It's too complicated and time consuming for many districts to go in and completely redo recipes for a lot of homemade items.

We're about a week into July. For many districts in the South, we start school at the end of August. There are still many questions that have not been answered, and much guidance that has still not been provided. It's really unreasonable to expect people to implement these changes when USDA is not equipped to provide the support necessary to do so.
Posted by: Crystal Thill at 7/5/2012 9:43 AM


Thank you all for your comments and concerns regarding the Meal Pattern Guide. It was released to members this morning, July, 11, 2012. Please see www.schoolnutrition.org/mealpattern for the “New Meal Pattern Guidelines: A Companion Guide."
Posted by: Sarah Murphy at 7/11/2012 9:55 AM


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