Arkansas Department of Education Acceptable/Unacceptable Product Documentation for Child Nutrition Programs

Memo Information

Memo Number
FIN-15-125
Memo Date
6/11/2015
Memo Type
Regulatory
Section
Fiscal & Administrative Services
Regulatory Authority
§USDA Policy Memo SP 11-2015(v2), SP 27-2015, TA 07-2010 REVISED
Response Required
NO
Attention
Elementary Principals; Middle School Principals; High School Principals; Superintendents; Child Nutrition Director, District Food Purchasing Agent, Bookkeepers

Contact Information

Memo Text

The United States Department of Agriculture (USDA) released Policy Memo SP 11-2015(v2) and SP 27-2015 on March 11, 2015. Child Nutrition Directors should read both memos in their entirety to ensure that valid documentation is used for documenting crediting of menu items toward the meal pattern.

Valid Child Nutrition (CN) Labels is:
· The original CN Label from the product carton; OR
· A photocopy of the CN Label shown attached to the original product carton; OR
· A photograph of the CN Label shown attached to the original product carton.
*CN Labels that are photocopied or photographed must be visible and legible.

CN Labels with “watermarks” may be provided during the bidding process. However, since CN Labels with a watermark can be changed, School Food Authority (SFAs) must verify that the item purchased and delivered meets the same criteria as the “watermarked” CN Label. The only documentation acceptable as a CN Label during an administrative review is one of the 3 examples listed above. Watermarked CN Labels alone are not acceptable.

If the original CN Label from the product carton, a valid photograph or photocopy of the original CN Label is not available, program operators may provide a Bill of Lading (invoice) containing the product name AND either:
· A hard copy of the CN Label copied with a watermark displaying the product name and CN number provided by the vendor; OR
· An electronic copy of the CN Label with a watermark displaying the product name and CN number provided by the vendor.

Product Formulation Statements (PFS) are not needed when a valid CN Label or a “watermarked” CN Label with the Bill of Lading is provided according to the guidelines above.

Product Formulation Statements are only necessary for processed products without a valid CN Label or valid “watermarked” CN Label.

Acceptable Product Formulation Statements will include:
· Manufacturers’ letterhead; and
· Signed by company representative; and
· Identify how the processed product contributes to the meal pattern requirements; and
· Include Nutrition Facts panel information if not available on the processed product.

General Guidelines for Reviewing Product Formulation Statements:
· See A Reviewer’s Checklist for Evaluating a Manufacturer Product Formulation Statement for Meat/Meat Alternate Products which is available online at www.fns.usda.gov/cnd/cnlabeling/foodmanufacturers.htm.
· Determine that creditable ingredients listed in the product formulation statement match the description in the most current Food Buying Guide for Child Nutrition Programs (FBG). If a Product Formulation Statement for a specific product claims to provide higher credit than what is listed in the FBG, the statement must clarify all crediting ingredients and demonstrate how the product provide that credit according to FNS regulations, guidance or policy.
· Verify that the credit a product contributes to the meal pattern requirements is not greater than the serving size of the product. For example, a 2.2 oz beef patty may not credit for more than 2.00 oz. Meat/Meat Alternate (M/MA).
· Assure that the PFS proves how the claimed credit was obtained and that creditable components are visible in the finished product. It is never acceptable for a manufacturer to simply state that the product provides a certain amount of credit for the Child Nutrition (CN) meal pattern. For example, fruit filled muffin may not credit toward the meat alternate because it is not obvious how the product contributes to the meat alternate component. In order to credit as M/MA, the product must have a visible M/MA such as egg, cheese, peanut butter, etc., and the method for determining the crediting must be identified.

A Product Formulation Statement does not provide any warranty against audit claims. Any crediting information received from a manufacturer other than a valid CN Label must be checked by the SFA for accuracy prior to the item being included in the reimbursable meal.

Attachment:
Tip Sheet for Accepting Processed Product Documentation
SP 11-2015 v2
SP27-2015
TA07-2010 v3