Preschool Meal Pattern Requirements for Schools

This (MB) supersedes MB SNP-02-2019 Preschool Meal Pattern Requirements in the NSLP and SBP. Guidance to the meal patterns for preschool-aged children is updated to reflect new requirements from the USDA’s final rules titled Child Nutrition Programs: Meal Patterns Consistent with the 2020–2025 Dietary Guidelines for Americans and Expanding Fluid Milk Options in Child Nutrition Programs, as well as state laws restricting certain food additives in meals served in schools.

Background

Since 2017, the NSLP, NSLP Afterschool Program (ASP), and SBP preschool meal pattern requirements have aligned with those for the Child and Adult Care Food Program (CACFP). Federal regulations for the preschool meal pattern for meals served as a part of the NSLP and SBP are contained in 7 CFR, sections 210.10(o)(3) and (p) and 220.8(o). These regulations require local educational agencies participating in the federal school meal programs, that serve lunch and breakfast to preschoolers under the NSLP, NSLP ASP, and SBP, to serve the meal components and quantities required in the respective meal patterns established for the CACFP. The federal updates to the CACFP meal pattern also impact the meal pattern for preschool-aged children participating in the NSLP and SBP.

Preschool Meal Pattern

Meal Pattern Requirements: Differences between Preschool and Older Grade Groups

When planning meals for children of varying ages, it is important to be aware of the differences between the preschool meal pattern and the meal patterns for the other grades, as per 7 CFR sections as highlighted below.

Meal pattern guidance specific to preschool children:

• Offer versus serve or OVS is not allowed.
  
  
• Beverages
  
  
  • Two fluid milk options are not required.
    
    
  • Flavored milk is not allowed.
    
    
  • Only whole, unflavored milk may be offered to children one year of age.
    
    
  • Unflavored fat-free (skim), low-fat (one percent), reduced-fat (two percent), or whole milk may be offered to children ages two through five.
    
    
  • Pasteurized full-strength juice may credit towards the vegetable or fruits requirement at one meal or snack per day.
    
    
• Grains
  • One whole grain-rich serving per day, across all eating occasions, is required if a grain item is served.
    
    
  • Grain-based desserts may not be offered to meet the grains requirement; however, the guidance offers the flexibility to occasionally serve grain-based desserts for celebrations or other special occasions as an additional food item that is not part of a reimbursable meal when purchased using non-Child Nutrition Program funds.
    
    
  • A meats/meat alternate may be substituted for the entire grain component at breakfast up to three times per week.
    
    
• Vegetables
  • A second vegetable may be served in place of the fruits component at lunch, provided both vegetables are different.
    
    
  • There are no vegetable subgroup requirements for preschoolers.
    
    
  • Vegetables and fruits are one combined component at breakfast and two separate components at lunch and afterschool snack.
    

Added Sugar Requirements: Preschool Meal Pattern Alignment with OIder Grade Groups

Product-based Added Sugar Limits

• Breakfast cereal must contain 6 grams (g) or less added sugars per dry ounce (oz).
  
  
• Yogurt must contain 12 g or less added sugars per 6 oz (2 g per oz).

California State Requirements

California law established restrictions for certain food and food additives for foods served in schools, which includes preschool meals served as part of the NSLP and SBP.

For public noncharter schools, charter schools, and County Offices of Education (COE):

• Deep fried, par fried, or flash fried items, or items that contain artificial trans fats are prohibited per California Education Code (EC) Section 49430.7; school food authorities (SFA) must annually certify compliance. (Additional information below).
  
  
• Beginning January 1, 2027, the manufacture, sale, or provision (delivering, distribution, holding, and offering) of food products that contain brominated vegetable oil, potassium bromate, propylparaben, and red dye number 3 is prohibited (Health and Safety Code Section 109025).

Beginning December 31, 2027, the definition of an NSLP or SBP meal eligible for state reimbursement excludes meals that contain certain food dyes–Blue 1, Blue 2, Green 3, Red 40, Yellow 5, and Yellow 6. (EC Section 49501.5) While this requirement does not apply to the preschool meal pattern, SFAs are encouraged to extend this practice to meals and snacks served using the preschool meal pattern.

The meal pattern information posted on the California Department of Education (CDE) NSLP and SBP Meal Patterns web page, Meal Patterns tab at https://www.cde.ca.gov/ls/nu/he/smi.asp reflects both federal and state requirements.

Annual Certification Requirement

SFAs must annually complete the Certification of Compliance with Nutritional Requirements for State Meal Reimbursement form in the Child Nutrition Information and Payment System. This form specifies, in detail, the nutrition standards that must be met as a condition of receiving state meal reimbursement. For existing SFAs, the form is completed during the Annual Renewal Process; new SFAs complete the form during the initial application process. Failure to submit this form results in ineligibility for state meal reimbursement.

Flexibility for Comingled Preschool Meals

It is important to serve age-appropriate meals. The USDA recognizes that, when SFAs are serving preschoolers at the same time and in the same service area as older children (comingled), adhering to two different meal patterns may be operationally challenging. As a result, USDA allows SFAs the flexibility to use one menu when preschoolers and Kindergarten (K) through grade five students are comingled. Per USDA Policy Memo SP 37-2017, SFAs may use the NSLP and SBP K through grade five (K–5) meal pattern to serve all comingled students. This meal pattern is available on the CDE NSLP and SBP Meal Patterns web page at https://www.cde.ca.gov/ls/nu/he/smi.asp. For additional meal planning guidance, SFAs should refer to MB SNP-08-2026 SFSP-02-2026 Updates to School Nutrition Standards on the CDE MB web page at https://www.cde.ca.gov/ls/nu/sn/mb.asp.

When determining if your service model is comingled, note that, in general, the service area refers to the place where students pick up or choose their meal items. SFAs serving preschool children separately from other age groups, must use the preschool meal pattern.

In California, Transitional Kindergarten (TK) programs, as defined in EC Section 48000, are part of the K through 12 public school system and are the first year of a two-year K program. This means an SFA may choose to use the K-5 meal pattern when serving meals to children in TK. Additionally, because of the age of children in TK, SFAs may instead choose to use the preschool meal pattern when serving them.

Refer to USDA Policy Memo SP 37-2017: Flexibility for Comingled Preschool Meals: Questions and Answers at https://www.fna.usda.gov/cn/flexibility-co-mingled-preschool-meals-questions-and-answers. This policy memo provides guidance on meals served to preschoolers when they are in the same service area at the same time as K–5 students.

Offer Versus Serve and Family Style Meal Service

OVS is not allowed when serving meals to preschoolers [7 CFR sections 210.10(p) and 220.8(o)]. Instead, SFAs are encouraged to use family style meal service whenever possible. Family style meal service allows children to serve themselves from common dishes of food with assistance from supervising adults, if needed. When using family style meal service in the school meal programs, preschoolers must take at least ¼ cup of vegetable or fruit. The supervising adult should offer the required minimum serving size of each food component or food item to each student.

Administrative Review

All SFAs that provide meals to preschoolers will be monitored using the Administrative Review process. As part of the on-site assessment, the CDE will observe meal service along with a review of documentation to determine whether meals contain the required components in the required quantities. The reviewer will determine if the school is using one menu and comingling the preschoolers in the meal service area. If preschoolers are not comingled, then reviewers will complete a validation checklist to ensure that the SFA is in compliance with the preschool meal pattern.

Contact Information

If you have any questions regarding this subject, contact the Nutrition Services Division at SNPInfo@cde.ca.gov.