Special Edition

This is an official communication between ODE CNP and Sponsors of NSLP

Inside This Issue

• Meal Pattern
• Crediting Documentation
• Production Records
• Meal Counting and Claiming
• Civil Rights

About This Issue This special edition of the SNP newsletter is designed to provide resources for school nutrition personnel.  Sponsors have expressed their concerns regarding staff turn-over, and training resources throughout the pandemic. In an effort to provide assistance, the Oregon Department of Education Child Nutrition Programs has created a special edition newsletter filled with resources to help sponsors navigate the aspects of the school nutrition programs.   The content of the newsletter will provide the reader with resources and information regarding topics such as; meal counting and claiming, production records, crediting and the NSLP meal pattern.  We have put together a conglomeration of information, regulations and tips that we hope you find useful and easy to use. A best practice would be to save an electronic copy of this special edition as it contains live links to program specific information.

Meal Pattern 

There are five required meal pattern components in the National School Lunch Program (NSLP), including Meat/Meat Alternate (M/MA), Grain, Milk, Fruit, and Vegetable. There are three required meal pattern components in the School Breakfast Program (SBP), including Grain, Fruit (or Vegetable), and Milk. These must be offered by schools during each lunch meal and each breakfast meal, respectively. Meals must also meet the daily and weekly amounts as per the chart below. 

• Ensure all required meal components are planned and offered to meet daily/weekly age/grade group meal pattern requirements.
• Ensure meal accommodations requirements for children with disabilities are met.
• Ensure meal service option, traditional or offer vs serve is implemented correctly.

• Portion Sizes - Planned and/or offered menu does not meet meal pattern minimum portion requirements daily and/or weekly; recipes are not accurate and/or accurately followed.
• Milk Variety - a minimum of two allowable fluid cow's milk varieties are not offered daily at breakfast and/or lunch.
• Vegetable Sub-groups - requirements to offer the meal pattern minimum required quantity of all subgroups per week are not met.
• Whole Grain-Rich (WGR) - Grains offered do not meet Whole Grain Rich criteria requirement.

Resources

• Lunch At A Glance
• Vegetable Subgroups in the NSLP
• Breakfast At a Glance
• National School Lunch Program & After School Snack Program: 7 CFR 210
• School Breakfast Program: 7 CFR 220
• ODE CNP Resource Page

Crediting Documentation

Crediting is the process designed by FNS to specify (and document) how individual food items contribute to the Child Nutrition Programs' meal patterns. Several factors impact how food products can credit toward reimbursable meals, such as volume, weight, and overall nutrient profile. Sponsors must keep nutrition information documentation to demonstrate how each food item contributes to the meal pattern.

Meal Pattern Waiver Requests for School Year 2021-2022

In addition to the flexibilities offered in the USDA Food and Nutrition Service (FNS) nationwide meal pattern waiver issued April 20, 2021, COVID-19: Child Nutrition Response #90, a meal pattern waiver request may now be made due to, or in anticipation of, a supply-chain disruption. This waiver applies to the National School Lunch Program (NSLP), the School Breakfast Program (SBP), and the NSLP Seamless Summer Option (SSO).

Sponsors may utilize the flexibilities, only as needed during SY 2021-22, by completing the Oregon Meal Pattern Waiver Request Form (July 2021-June 2022), located on our ODE Oregon Child Nutrition Programs COVID-19 Response and Resources webpage, for State Agency review and approval on a case-by-case basis.  If you have already submitted a waiver request and need to make a revision, please submit a new request form. 

FNS expects and strongly encourages program operators to maintain and meet the nutrition standards for each program by meeting the meal pattern requirements to the greatest extent possible.  The NSLP, SBP, and SSO requirements waived in COVID-19: Child Nutrition Response #90 are:

• That menus meet the dietary specification for sodium, at 7 CFR 210.10(b), (c), and (f); and 8(b), (c), and (f); [This waives sodium requirements; target 1 is encouraged.]

• That all grains offered be whole grain-rich, at 7 CFR 210.10(c); and 220.8(c); [This waives whole grain-rich requirements; whole grain-rich is encouraged.]
• That, for pre-schoolers, at least one serving per day, across all eating occasions, must be whole grain-rich, at 7 CFR 210.10(o)(3) and (p); and 220.8(o); [This waives serving preschooler's whole grain-rich; serving whole grain-rich is encouraged.]
• To offer a variety of vegetables from the vegetable subgroups, at 7 CFR 210.10 (c) and 220.8(c); This waives the vegetable subgroups daily/weekly requirements; meeting vegetable subgroups requirements are encouraged.]
• To offer a variety (at least two different options) of fluid milk, at 7 CFR 210.10(d)(1)(i) and 220.8(d); [This waives the requirement to offer milk variety per day per meal; milk variety per day per meal is encouraged.]
• That low-fat milk must be unflavored, at 7 CFR 210.10(c) and (d)(1)(i), and 220.8(c) and (d); [This allows low-fat milk to be flavored; unflavored low-fat milk is encouraged.]; and
• To plan menus and offer food components for specified age/grade groups in the stated combinations, at 7 CFR 210.10(c) and 220.8(c). [This allows sponsors to follow one age/grade group meal pattern for all meals.]

These meal pattern flexibilities are available through June 30, 2022.  All other meal pattern requirements remain in effect.

Please contact your assigned SNP Specialisthttps://www.oregon.gov/ode/students-and-family/childnutrition/SNP/Documents/Sponsor_Support_List 21_22 (rev 1-2022).docx if you have questions regarding the waivers.

Production Records

Production records document that reimbursable meals were planned and served. Production records are documentation of the type and amount of food produced for reimbursable meals. They are also a planning tool. They provide a record that the meals served meet federal Child Nutrition requirements. Sponsors must keep production and menu documentation for the meals they produce. These records must be kept on file for three years plus the current school year.

Meal Counting and Claiming

Federal reimbursement is provided for each meal that meets program requirements and is served to an eligible student. To obtain this reimbursement, school personnel must accurately count, record, and claim the number of meals actually served to students by category, i.e., paid, reduced-price, and free. Additionally, the number of meals served free and reduced-price and claimed for reimbursement must have adequate documentation on file to support the claim. Note: Sponsors operating Seamless Summer Option (SSO) or Special Provision (CEP or Provision 2) all students eat at no charge and are claimed for free reimbursement.

Note: The areas below are key areas, please read the full regulation listed above for a comprehensive understanding of the requirements.

• Eligibility Documentation (not applicable for sponsors operating the SSO for SY 21-22, or CEP/Provision 2) – Sponsors must have eligibility documentation and determination i.e. household applications, direct certification, and or homeless or migrant lists from the appropriate liaison. Eligibility must also include a system to update the eligibility for incoming and outgoing students

• System for meal counting and claiming – Sponsors must have either a manual or electronic system to accurately record meals and perform edit checks

• Training – Sponsors must have personnel trained on Point of Service meal counting, including identifying a reimbursable meal

• Eligibility Documentation (not applicable for sponsors operating the SSO for SY 21-22, or CEP/Provision 2) – Sponsors must have eligibility documentation and determination i.e. household applications, direct certification, and or homeless or migrant lists from the appropriate liaison. Eligibility must also include a system to update the eligibility for incoming and outgoing students

• System for meal counting and claiming – Sponsors must have either a manual or electronic system to accurately record meals and perform edit checks

• Training – Sponsors must have personnel trained on Point of Service meal counting, including identifying a reimbursable meal

Resources

POS Meal counting Reference Sheet

SSO Daily Meal Count Forms

Meal Counting and Claiming (Video MO - 10 Minutes)

Civil Rights All Sponsors participating in the USDA Child Nutrition Programs must comply with Federal civil rights requirements and regulations. These regulations are intended to ensure that the benefits of the Child Nutrition Programs are made available to all eligible people in a nondiscriminatory manner. Key areas that the Sponsor must implement to meet the requirements Note: The areas below are key areas, please read the full regulation for a comprehensive understanding of the requirements. Nondiscrimination Statement Where: Sponsor’s must have the USDA Nondiscrimination statement display on USDA and child nutrition program materials including parent handbooks, menus, flyers, program websites, employee handbooks, newsletter, free and reduce price meal application and letters to the households. The long statement should be used. The short statement can be used when the document is one page or less. “Justice for All” Poster Must be displayed conspicuous area such as the meal service, school lobby, or Main office. It must be visible to all potential and participating program recipients, teachers and office. Racial and Ethnic Data Collect and maintain data annually Civil Rights Training provide annually with procedures on how to handle complaints and understanding individual rights Provide reasonable accommodations for persons with disabilities Provide equal opportunities regardless of race, color, national origin, sex, age disability Maintain complaint documentation, which includes: complaint procedures, complaints log, updated complaint form available at all sites Common Administrative Review Errors for Civil Rights The sponsor did not post the “And Justice for All” poster in a conspicuous location or the poster is outdated Sponsor did not collect and maintain racial and ethnic data The nondiscrimination statement is incorrect, and inaccurately displayed and absent. Sponsor has the short statement displayed on a document when it should have the long statement The Sponsor is using the wrong nondiscrimination statement The sponsor uses an outdated nondiscrimination statement  In the short statement of, “This institution is an equal opportunity provider.” The sponsor inserts their own institution The sponsor didn’t include the nondiscrimination statement on printed materials and website Sponsor does not maintain a complaint log, procedures and forms The procedures are districts procedures, not USDA. The Procedures do not contain the appropriate place to file a claim Sponsor does not have the current complaint form Sponsor does not have a complaint log Sponsor does not know the procedure and does not handle the complaints correctly according to USDA Civil Rights Procedures Sponsor did not train staff on Civil Rights requirements and procedures

Please visit the ODE Administrative Review webpage for a list sponsors that will be reviewed in the 2021-2022 school year. 

School Nutrition Program Contacts

Civil Rights