Request for Information: Grain Based Desserts and High Protein Yogurt Crediting in Child Nutrition Programs

Summary

On Feb. 7, 2023, FNS issued a proposed rule to update CNP meal pattern requirements. Grains, especially whole grains, contribute critical nutrients. However, some grains, called grain-based desserts, are higher in added sugars. Under current policy, grain-based desserts include foods such as cakes, cookies, brownies, breakfast bars, and toaster pastries. The rule included a proposal to limit grain-based desserts in the School Breakfast Program (SBP) to no more than two ounce equivalents per week, consistent with the National School Lunch Program (NSLP). However, based on public comments, FNS did not finalize that proposed limit in the final rule. Public comments raised concerns that the proposal would limit options at school breakfast and recommended that FNS re-evaluate use of grain-based desserts at school breakfast. In the final rule, FNS committed to exploring methods for improving and simplifying grain-based dessert requirements by soliciting further partner input, which is one aim for this request for information.

Yogurt is another popular menu item in CNPs and a source of calcium, zinc, potassium, and probiotics.¹ It may be offered in a variety of forms: plain or flavored, unsweetened or sweetened, strained or non-strained, and/or high-protein or regular; as a standalone option or in different menu items, such as yogurt parfaits or smoothies. The variety of yogurt available at retail and in the K-12 market, including high-protein yogurt (e.g., Greek and Greek-style yogurt), has grown and evolved significantly. Therefore, in 2017, FNS requested public input on whether high-protein yogurt (including Greek and Greek-style yogurt) should credit differently than regular yogurt. Those comments were mixed and, as a result, FNS maintained consistent crediting for all yogurt in the CNPs. FNS is now seeking additional public input to determine if any new information warrants a change to yogurt crediting in the CNPs.

Request for Comments

Written comments must be received on or before [90 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER].

USDA invites the submission of the requested information through one of the following methods:

• Federal eRulemaking Portal (preferred method): Go to https://www.regulations.gov. Follow the online instructions for submitting comments.
• Mail: Send written comments to the Child Nutrition Programs, USDA Food and Nutrition Service, Braddock Metro Center II, 1320 Braddock Place, Alexandria, VA 22314.

All comments submitted in response to this Request for Information will be included in the record and will be made available to the public. Please be advised that the substance of the comments and the identity of the individuals or entities submitting the comments will be subject to public disclosure. USDA will make the comments publicly available via
https://www.regulations.gov.

Details on Current Policies and Areas for Public Input

FNS is committed to finding ways to ease menu planning for program operators and ensure that participants have access to a wide array of nutritious food and beverage choices. Staying up to date with the evolving food environment through ongoing conversations with stakeholders helps FNS learn about additional food options that could improve program menus. With these general interests in mind, FNS is seeking information on the questions in the chart below. We encourage partners to access the request for information and read the questions in the context of the full document.

Grain-Based Desserts

FNS is requesting feedback on three areas related to grain-based desserts:

Current Policies and Potential Alternatives for Grain-Based Desserts

Products that are considered grain-based desserts may be offered to meet part of the grains requirement in some CNPs to encourage whole grains consumption and/or provide participants with foods they enjoy while still meeting nutrition standards. Certain grain products, including cookies, cakes, breakfast/cereal bars, and toaster pastries, are categorized as grain-based desserts based on their characteristics. FNS's current policy related to grain-based desserts is detailed in The Food Buying Guide for Child Nutrition Programs, Exhibit A.

Questions for Commenters

1. What challenges do program operators face in identifying grain-based desserts, under the current policies?
2. Is the current NSLP policy that permits up to 2.0-ounce equivalents of grain-based desserts per week effective at reducing added sugars in school lunches?
   1. The weekly added sugars limit for NSLP will be implemented by July 1, 2027. Will the current grain-based dessert limit for NSLP lunch still helpful for menu planning purposes, once the weekly added sugars limit is implemented?
3. Should FNS adjust its current grain-based desserts policies, such as changing which grain products are categorized as grain-based desserts?

Grains High in Added Sugars

In addition to potential changes to its current grain-based desserts policies, FNS is also interested in public input on alternative approaches that partners recommend to reduce added sugars in CNP meals. This includes seeking public input on grain products high in added sugars.

Questions for Commenters

1. Should FNS consider alternative approaches to its current grain-based desserts policies, such as replacing these policies with limits for "grains high in added sugars"?
2. If FNS were to establish limits for "grains high in added sugars," how should the limits be established?
   1. Should FNS adopt the US Food and Drug Administration's (FDA) definition for "high" for nutrient content claims used on food labels to define "grains high in added sugars"? What are the benefits or limitations of this approach?
   2. What opportunities and challenges could arise from having different limits for grains offered to children ages one through three, versus children and adults ages four and older?
   3. What other approaches should FNS consider to define "grains high in added sugars"?

Strategies to Reduce Added Sugars at School Breakfast

FNS recognizes the specific challenges with reducing added sugars in school breakfast. The agency invites public input on effective strategies to reduce added sugars at breakfast, including when using alternative school breakfast models.

Questions for Commenters

1. Are there strategies for reducing added sugars in the SBP that would support menu planners offering a variety of grains in alternative SBP service models (e.g., grab-and-go breakfasts, breakfast in the classroom)?
2. What menu items are schools serving to reduce added sugars at breakfast? Examples may include protein foods (e.g., eggs; meat; tofu; beans, peas, and lentils) or others.
   1. Please share examples of breakfast menu items lower in added sugars that are popular with students.
3. What additional resources from FNS could help program operators reduce added sugars in CNP menus, including breakfast? Resources could include marketing ideas/materials, menu planners, online trainings and courses, and others.

High-Protein Yogurt Crediting

FNS is requesting feedback on two areas related to yogurt crediting:

Current Policies

Yogurt is a popular menu item and may credit toward all or part of the meats/meat alternates component in the CNPs.² Currently, four ounces (weight) or 1/2 cup (volume) of yogurt credits in the CNPs as one ounce equivalent of meat alternate. High-protein yogurt (which may include Greek and Greek-style yogurt) credits the same as regular yogurt. The manufacturing process for high-protein yogurt (including some Greek and Greek-style yogurt) typically involves straining the product to remove liquid whey, resulting in a thicker yogurt with higher protein content.

Questions for Commenters

1. Are program operators currently offering Greek or Greek-style yogurt, or other types of yogurt that contain more protein than regular yogurt, as part of reimbursable meals or snacks?
   1. To which age groups and in which meals are these types of yogurt offered?
   2. How frequently are these types of yogurt offered?
   3. Are these types of yogurt popular with participants? Are they more popular than regular yogurt?
2. If program operators are not offering Greek or Greek-style yogurt, or other types of yogurt that contain more protein than regular yogurt, as frequently as desired, why not? What are the challenges with offering these types of yogurt?
3. Has high-protein yogurt available via USDA Foods in Schools helped school program operators offer high-protein yogurt to participants?
   1. Is high-protein yogurt incorporated into meals, particularly breakfast, in the same manner as traditional yogurt? Please share examples of how high-protein yogurt is used in menus and/or recipes; are traditional and high-protein yogurt used interchangeably or are there novel uses for high-protein yogurt in school meals?

Potential Alternatives

FNS is interested in public input on potential changes to the current yogurt crediting policies, including what changes would be beneficial to program operators and participants, and any challenges associated with potential changes.

Questions for Commenters

1. Should FNS create a separate crediting standard for high-protein yogurt that is different than the crediting standard for regular yogurt? Why or why not?
2. If high-protein yogurt contributes differently to the CNP meal patterns than regular yogurt, how should high-protein yogurt be credited? Be as specific as possible, such as the volume or weight needed.
3. If high-protein yogurt were to contribute differently to the CNP meal patterns than regular yogurt, should FNS adopt FDA's definition of "high" for nutrient content claims used on food labels to define high-protein yogurt?
   1. What are the benefits or limitations of this approach?
   2. What opportunities or challenges could arise from having different limits for high-protein yogurt offered to children ages one through three, versus children and adults ages four and older?
4. If high-protein yogurt contributes differently to the CNP meal patterns than regular yogurt, should USDA place any limits on the types of yogurt that can qualify as high-protein yogurt?
   1. Should changes be limited to any specific type of high-protein yogurt?
   2. Should yogurt that is thickened by adding thickening agents (e.g., polysaccharides or optional dairy ingredients) credit differently in CNPs? If yes, what implications might that approach have on the requirement for program operators to plan CNP menus using food-based menu planning?
   3. Should changes include plant-based yogurt alternatives (e.g., soy-based yogurt alternatives)?
5. What other approaches should USDA consider for how to define and credit high-protein yogurt?

In addition, FNS welcomes additional input on its current yogurt crediting policies, potential alternatives for high-protein yogurt, and other feedback from partners.

¹ U.S. Department of Agriculture, Agricultural Research Service, Beltsville Human Nutrition Research Center. FoodData Central, available at: https://fdc.nal.usda.gov/fdc-app.html#/food-details/2647437/nutrients.
² USDA's School Nutrition and Meal Cost Study found that low-fat or fat-free yogurt was offered in 10 percent of all daily lunch menus and was more frequently offered in daily menus in elementary schools than middle or high school menus. In SBP, yogurt (mostly low-fat or fat-free) was the most frequently offered meat/meat alternate item and was included in one-quarter (25 percent) of all daily breakfast menus. Additional information is available in the study report.

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