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Grain Entrees/Fundraisers Related to Smart Snacks


Nutrition Services Division Management Bulletin

Purpose: Policy, Beneficial Information

To: National School Lunch Program Breakfast Sponsors

Attention: Food Service Directors

Number: SNP-25-2014

Date: August 2014

Reference: U.S. Department of Agriculture Policy Memoranda SP 35-2014: Grain Entrées Related to the Smart Snacks in School Standards and SP 36-2014: Smart Snacks Nutrition Standards and Exempt Fundraisers

Subject: Grain Entrées and Exempt Fundraisers Related to the Smart Snacks in School Rule


This Management Bulletin (MB) provides clarification to school food authorities (SFA) participating in the School Nutrition Programs regarding competitive food and beverage regulations from the U.S. Department of Agriculture (USDA) and when stricter California laws override federal regulations.

Grain-only Entrées

USDA Food and Nutrition Service (FNS) Policy Memorandum SP 35-2014: Grain Entrées Related to the Smart Snacks in School (SSIS) Standards clarifies the option of selling grain-only items as an entrée under Section 210.11 of the Healthy, Hunger-Free Kids Act of 2010 (HHFKA), also known as the SSIS rule. To view the USDA Policy Memorandum SP 35-2014, please visit the Grain Entrees Related to the Smart Snacks in School Standards web page at https://www.fns.usda.gov/grain-entrees-related-smart-snacks-school-standards.

Under the SSIS rule, an “entrée item” must meet one of the following criteria:

  1. Combination of a meat/meat alternate (M/MA) and a whole grain-rich food
  2. Combination of an M/MA and a vegetable or fruit
  3. An M/MA alone, with the exception of yogurt; low- or reduced-fat cheese; nuts, seeds and nuts or seed butters; and meat snacks (such as dried beef jerky)

The USDA recognizes that their definition does not include grain-only items as a competitive entrée. In the School Breakfast Program many students are accustomed to grain-only items (such as pancakes, bagels, waffles, etc.), which are often considered the meal’s entrée. These foods are also commonly sold competitively (i.e., sold outside of the meal as individual items) by the SFA.

According to the USDA Policy Memo, if the SFA determines that a grain-only item—such as pancakes—is the entrée for the reimbursable meal, it can also be considered a competitive entrée. The Policy Memo allows such items to be sold competitively in this situation.

Although the USDA provides SFAs leniency to sell grain-only items as a competitive breakfast entrée under these circumstances, Title 5, California Code of Regulations (5 CCR) Section 15575, does not allow a grain-only item to be sold as a competitive entrée.

California regulations are stricter and define a competitive entrée as a food item that meets one of the following criteria:

  • Two or more of the following foods, eaten together: M/MA, grain/bread, vegetable/fruit
  • A meat/meat alternate alone, excluding nuts, nut butters, seeds, cheese, and yogurt.

A grain-only item—such as pancakes—does not meet the California definition of a competitive entrée and, by default, must meet the competitive snack requirements.

Exempt Fundraisers

USDA FNS Policy Memorandum SP 36-2014: Smart Snacks Nutrition Standards and Exempt Fundraisers clarifies state agency (SA) responsibility for establishing a set number of exempted fundraisers in schools under the SSIS rule. To view the USDA Policy Memorandum SP 36-2014, please visit the Smart Snacks Nutrition Standards and Exempt Fundraisers web page at https://www.fns.usda.gov/smart-snacks-nutrition-standards-and-exempt-fundraisers.

The Policy Memo explains that the SA has the authority to set a limited number of fundraisers per year that are exempt from the SSIS rule. An SA may not delegate this authority to the SFA. Additionally, the USDA allows SAs to establish a procedure for SFAs to petition for an exemption from the base fundraiser limit established by the SA.

Section 15575 of 5 CCR does not allow any competitive food and beverage sales (including fundraisers) to be exempt from the standards established by state and federal law. Exempt fundraisers are not allowed during the school day in California.

Please note that state and federal law allows a food fundraiser that meets the competitive food and beverage standards. Although the fundraiser may be in competition with the federal reimbursable meal program, it is allowable. Meeting the standards of “competitive foods” means that the foods or beverages must meet specific criteria to be sold during the school day. Deeming a food or beverage “competitive” does not automatically disallow the sale of the item. Local educational agencies may implement further restrictions through their local school wellness policy.

Information and Questions

For more information about competitive food and beverage standards, please visit the CDE Competitive Foods and Beverages web page at http://www.cde.ca.gov/ls/nu/he/compfoods.asp

If you have any questions regarding this MB, please contact the Competitive Foods and Beverages team by email at COMPETITIVEFOODS@cde.ca.gov.

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Tuesday, January 25, 2022
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