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School Meal Flexibilities for School Year 2018–19

Nutrition Services Division Management Bulletin

Purpose: Policy, Beneficial Information

To: School Nutrition Program Sponsors

Attention: Program Operators

Number: SNP-13-2018

Date: June 2018

Reference: U.S. Department of Agriculture Interim Final Rule: Child Nutrition Program Flexibilities for Milk, Whole Grains, and Sodium Requirements

Supersedes: Management Bulletin SNP-09-2017 School Meal Flexibilities for School Year 2017–18

Subject: School Meal Flexibilities for School Year 2018–19

This management bulletin provides information and instructions for school food authorities (SFA) regarding several menu planning flexibilities that assist schools in serving healthy and appealing school meals.

On November 30, 2017, the U.S. Department of Agriculture (USDA) issued Interim Final Rule: Child Nutrition Program Flexibilities for Milk, Whole Grains, and Sodium Requirements. This interim final rule extends three menu planning flexibilities currently available to School Nutrition Program (SNP) Operators through School Year (SY) 2018–2019. These flexibilities include:

  • Providing operators the option to offer flavored, low-fat (1 percent fat) milk

  • Extending the state agencies' option to allow individual SFAs to include grains that are not whole grain-rich (WGR) in the weekly menu offered under the National School Lunch Program (NSLP) and School Breakfast Program (SBP) through the exemption process

  • Retaining Sodium Target 1 in the NSLP and SBP

The final rule is expected to be published in fall 2018 and implemented in SY 2019–2020. You can view the interim rule on the USDA Interim Final Rule: Child Nutrition Program Flexibilities for Milk, Whole Grains, and Sodium Requirements Web page at


The Healthy, Hunger-Free Kids Act of 2010 brought many improvements to the SNP to improve meal quality and access. New regulations require school meals to provide more whole grains, fruits and vegetables, lean protein, and low-fat milk. The standards were implemented gradually, over multiple years, giving school staff and students time to adjust to the changes.

In 2014, federal regulations required SFAs participating in the NSLP and SBP to offer all grains that were WGR. Products that meet the WGR criteria contain at least 50 percent whole grain meal and/or flour. The remaining 50 percent or less of grains, if any, must be enriched. Schools are not required to offer 100 percent whole grain products.

The USDA updated school meal nutrition standards which established three sodium targets to be phased in over a 10-year period, with specific levels for students in three grade ranges. Schools were expected to comply with the sodium Target 1 levels by SY
2014–15, the Target 2 levels by SY 2017–18, and the final target levels by SY 2022–23.
The USDA recognizes that school nutrition professionals have worked diligently to overcome operational challenges in providing meals that encourage student participation and enhance their educational experience throughout the school day. However, schools and the food industry have expressed the need for additional time and assistance to effectively achieve changes in the school meal patterns, including those related to sodium and whole grains. In addition, the USDA recognizes that schools need flexibility to offer additional milk options to ensure children receive the nutrients provided by milk.

Low-fat (1 percent) Flavored Milk

The interim final rule allows SFAs the option to serve flavored, low-fat milk in SY 2018–19 without requesting approval. Under this rule, program operators that choose to exercise this option are not required to demonstrate a reduction in student milk consumption or an increase in milk waste, but are expected to incorporate this option into the weekly menu in a manner consistent with the dietary specifications. This flexibility is intended to encourage children’s consumption of fluid milk.

Whole Grain-rich Exemption Request, Criteria, and Process

The interim final rule allows state agencies to continue to grant an exemption from the WGR requirements to SFAs that demonstrate hardship(s) in procuring and serving compliant WGR products that are accepted by students. Exemptions are allowed for any type of grain product(s) and for one or more different products for SY 2018–19. SFAs that are granted an exemption must work with the California Department of Education (CDE) to search for acceptable products and comply with the requirement that at least half of the grains offered are WGR products.

An SFA may submit a School Meal Flexibilities Exemption Request Form with supporting documentation to the CDE if the SFA can demonstrate a hardship in procuring, preparing, or serving WGR products that are compliant with the meal requirements and accepted by students. Documentation of hardships that the CDE may consider includes, but is not limited to:

  • Financial hardship: SFA records demonstrate a significant drop in meal counts after offering WGR product(s) and/or the SFA experienced a significant cost increase when procuring the WGR product(s).

  • Limited product availability: The SFA does not have access to a compliant WGR product in the local market and would like to offer enriched grain item(s) temporarily.

  • Unacceptable product quality: The WGR product(s) offered by the SFA did not retain the desired texture or lost palatability during the typical holding time.

  • Poor student acceptability: The WGR product(s) offered by the SFA received significant negative student and/or parent feedback or there was increased plate waste of that menu item when the SFA offered a WGR product(s) multiple times and over a sustained period of time.

SFAs that receive an exemption are considered compliant with the WGR requirement during an administrative review (AR) if their grain offerings are consistent with the exemption granted by the CDE, and at least half of the grains offered weekly are WGR. SFAs must maintain the approved School Meal Flexibilities Exemption Request Form and supporting documentation to provide to their CDE Child Nutrition Consultant (CNC) during an AR.

Documentation that assists the CDE with the approval of both exemptions includes invoices or purchase orders, menu production records and/or meal counts, vendor lists, photos, student/parent feedback surveys or comment sheets, and a written justification.
The School Meal Flexibilities Exemption Request Form for SY 2018–19 is available in the Download Forms section of the SNP module in CNIPS. An SFA must submit this form with an original signature to the CDE for approval prior to being allowed to use non-WGR products. The CDE will evaluate each request and notify the SFA of the exemption determination by e-mail within four weeks of receipt of this form.

Please send your completed and signed School Meal Flexibilities Exemption Request Form to:

Lori Porter, CNC
Southern School Nutrition Programs Unit
Nutrition Services Division
California Department of Education
1430 N Street, Suite 4503
Sacramento, CA 95814

Sodium Limits

The interim final rule retains the Sodium Target I as the regulatory limit through June 30, 2019. Moreover, the USDA anticipates retaining the Sodium Target I as the regulatory limit in the final rule through at least the end of SY 2020–2021 after reevaluating the sodium requirements in the 2020 Dietary Guidelines. The USDA will continue to support SFAs with their sodium reduction efforts by expanding the availability of low-sodium products offered through USDA Foods, developing recipes that assist with sodium reduction, and providing menu planning resources and technical assistance.

Contact Information

If you have any questions regarding this management bulletin, please contact Lori Porter, CNC, by phone at 916-322-1454 or by e-mail at, or Julie BoarerPitchford, Nutrition Education Consultant, by phone at 916-322-1563 or by e-mail at

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Friday, June 8, 2018
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