Arkansas Department of Education Documentation Requirements for Child Nutrition Meal Pattern Contribution

Memo Information

Memo Number
FIN-15-031
Memo Date
9/19/2014
Memo Type
Regulatory
Section
Fiscal & Administrative Services
Regulatory Authority
§7CFR Parts 210 and 220; USDA Memo TA 07-2010 – REVISED January 15, 2013
Response Required
NO
Attention
Co-op Directors; Elementary Principals; Middle School Principals; High School Principals; Superintendents; Child Nutrition Directors, Menu Planners

Contact Information

Memo Text

The United States Department of Agriculture (USDA) revised policy Memo TA 07-2010 to reiterate to State Agencies (SA) and School Food Authorities (SFAs) the REQUIRED documentation needed for processed products used in the Child Nutrition (CN) programs.  SFAs using processed products in the CN program must have appropriate documentation from the manufacturer that indicates how the product contributes to meeting the child nutrition meal pattern. This may be in the form of a CN Label or a Product Formulation Statement (PFS). The purpose of this memorandum is to highlight common issues related to inaccurate or misleading product literature, product labels, and fact sheets; provide guidance about how product literature can be used to make purchasing decisions; and bring to the SFAs attention several sample Product Formulation Statements (PFS) that can be used to document a product’s contribution to meal pattern requirements. Fact sheets and product labels provide a way for food manufacturers to communicate with program operators about how their products may contribute to the meal pattern requirements for meals served under USDA’s Child Nutrition programs.    Schools and other program operators are not required to offer processed products with CN Labels; however, it is important to recognize that CN Labeled products ensure that the food provides the stated contribution toward CN meal pattern requirements.  Check the following link to make sure that each CN label being used is current: (http://www.fns.usda.gov/cnlabeling/authorized-manufacturers-and-labels). Watermarked CN label documents cannot be used to document the product’s contribution towards meal pattern requirements when the CN label from the product box is not available. Child Nutrition program operators must have the actual box labels or a copy or picture of the actual label; otherwise, they will need to obtain a valid product formulation statement.  Policy on Copied Labels: http://www.fns.usda.gov/cnlabeling/frequently-asked-questions-copying-federally-inspected-product-labels-bidding-process When purchasing a processed product without a CN Label, a program operator must have a completed and signed Product Formulation Statement on manufacturers’ letterhead that demonstrates how the processed product contributes to the meal pattern requirements.  All CN Programs must also maintain files on current nutrient information to meet the requirements of program regulations in 7CFR 210 and 220.  If there is not a Nutrition Facts panel on the processed product, nutrient information must be obtained from the manufacturer.  Program operators are ultimately responsible if a menu does not fulfill meal pattern requirements; therefore, they must keep records of supporting documentation provided by the manufacturers.   General Guidance for Reviewing Product Formulation Statements (PFS):   An appropriate PFS will provide specific information about the product and show how the credit is obtained citing CN Program resources and/or regulations.  Specific policies for Alternate Protein Products and PFS templates for documenting the meat/meat alternate (M/MA) and the whole grain rich components can be reviewed by visiting the following link: (http://www.fns.usda.gov/cnd/cnlabeling/foodmanufacturers.htm)   These documents may be used to determine how a product credits toward the component(s) of the meal pattern requirements. The PFS may need to be modified for various types of products available in the market place. For example, cheese pizza could have crediting information for the red/orange vegetable subgroup in addition to the M/MA and grain components.  Review Product Formulation Statements prior to purchasing processed products. A Reviewer’s Checklist for Evaluating a Manufacturer PFS for M/MA Products is available online at (http://www.fns.usda.gov/cnd/cnlabeling/foodmanufacturers.htm ). • Determine that creditable ingredients listed in the product formulation statement match a description in the Food Buying Guide (FBG) for Child Nutrition Programs available at:  (http://www.fns.usda.gov/tn/food-buying-guide-school-meal-programs).  If a PFS for a specific product claims to provide a higher credit than what is listed in the FBG, the statement must clarify all crediting ingredients, and demonstrate how the product provides that credit according to the FNS regulations, guidance, or policy.   • Verify that the credit a product contributes to meal pattern requirements is not greater than the serving size of the product.  For example, a 2.20 oz. beef patty may not credit for more than 2.00 oz/ M/MA.   Assure that the PFS proves how the claimed credit was obtained.  It is never acceptable for a manufacturer to simply state that the product provides a certain amount of credit for the CN meal pattern.    Program operators are encouraged to review product literature carefully since they are responsible if menus they serve do not meet meal pattern requirements. It is important to note that CN Labeled products provide program operators with a warranty against audit claims when the product is used according to the manufacturer’s instruction. A Product Formulation Statement does not provide any warranty against audit claims.    State agency (SA) compliance monitors have the responsibility to determine if the foods served meet the requirements for a reimbursable meal.  During the review process, it must be determined that: serving of meal components meet the minimum serving sizes; all components are available to all students throughout the meal service; ensure all vegetable subgroups and whole grain rich foods are available in the prescribed minimum serving sizes throughout the week and; Offer vs. Serve (OVS) is implemented properly.  In order to accomplish this, SA reviewers examine SFA cashier training policies, meal reports from POS (Point of Sale) systems, production records, menus, purchasing invoices, CN label documentation, and Product Formulation Statements.  Now that CN labels also document vegetable subgroups for School Programs, they are even more important because meals served without the minimum serving sizes of vegetable subgroups is cause for disallowing an entire week’s worth of meals.  Questions on product compliance with meal pattern requirements should be directed to the District’s Area Specialist at 501-324-9502.  

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