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School Meal Flexibilities: Providing Quality Meals

Nutrition Services Division Management Bulletin

Purpose: Policy, Beneficial Information

To: School Nutrition Program Sponsors

Attention: Program Operators

Number: SNP-20-2019

Date: August 2019

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

Supersedes: Management Bulletin SNP-13-2018 School Meal Flexibilities for School Year 2018–19

Subject: School Meal Flexibilities: Providing Quality Meals in California

This management bulletin provides updated information for school food authorities regarding several menu planning flexibilities and resources to assist schools in serving healthy and appealing school meals.

On Thursday, December 6, 2018, the U.S. Department of Agriculture (USDA) announced its final rule on three meal flexibilities. The final rule increases flexibility in the Child Nutrition Program (CNP) requirements related to milk, grains, and sodium, effective School Year (SY) 2019–20.

Highlights of the rule:

  • School Nutrition Programs (SNP) (includes the National School Lunch Program [NSLP] and the School Breakfast Program [SBP]): Provides the option to offer flavored, low-fat (1 percent fat) milk. If a program operator provides a flavored, low-fat milk, they must also offer unflavored milk at each meal service.

  • Special Milk Program: Provides the option to offer flavored, low-fat (1 percent fat) milk to participants ages six and older.
  • Child and Adult Care Food Program: Provides the option to offer flavored, low-fat (1 percent fat) milk to participants ages six and older. Note that in California, however, the Healthy Beverages in Child Care Act does not allow licensed child care centers or day care home providers to serve flavored beverages to children of any age.
  • SNPs: Requires that at least half of the grains offered weekly meet the whole grain-rich (WGR) criteria and that the remaining grain items offered be enriched. Therefore, this policy change will remove the need for the WGR exemption request process. Schools already offering all grains as WGR do not have to change their menus as a result of the final rule. The California Department of Education (CDE) highly encourages program operators to continue to offer all or the majority of grains as WGR.
  • SNPs: Provides more time to reduce sodium levels in SNP meals. Specifically, the final rule maintains Target 1 sodium limits for school meals through SY 2023–24, with Target 2 sodium limits taking effect in SY 2024–25. The final sodium Target 3 was eliminated. Schools already meeting Target 2 do not have to change their menus as a result of the final rule.

You can access the final rule on the USDA Food and Nutrition Service website at External link opens in new window or tab. .

Providing Quality Meals in California

Serving quality, healthy, and appealing meals in schools is a priority to the CDE. Since eating patterns are set when we are young, school meals are an opportunity to shape how children will choose to eat in the future. This demonstrates the impact that meal programs have on the lives of students.

Although the federal requirements have shifted to allow schools to offer some grains that are not WGR and delayed the implementation of the Target 2 sodium requirement, the CDE strongly encourages sponsors to continue to serve the best possible nutrition. Key recommendations of the 2015–20 Dietary Guidelines for Americans states that a healthy eating pattern includes:

  • Grains, at least half of which are whole grains
  • Consuming less than 2,300 milligrams (mg) sodium per day

Whole grains are an important source of key nutrients and dietary fiber. Unfortunately, the net effect of reducing the WGR requirement to only half of the grains offered means that students are only getting the benefit of 25 percent whole grains in their diet. Considering the importance of eating whole grains as part of a healthy diet, the CDE strongly encourages schools to consider continuing to offer all grains in their school meals as WGR, especially if they have already successfully incorporated all whole grain items into their menus and the students are eating them. Likewise, schools are strongly encouraged to work towards lowering the sodium content of their meals now in order to be in compliance with the Target 2 requirements for SY 2024–25.

All children need access to meals of the highest quality and nutritional value to help build a healthier generation, establish healthy eating habits for a lifetime, and set our children up to thrive academically.


The following resources offer guidance for serving quality, healthy, and appealing meals in schools:

Contact Information

If you have any questions regarding this management bulletin, please submit your questions by email at


Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Friday, August 30, 2019
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