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School Nutrition Programs Compliance Handbook

Chapter 2 - Meal Planning and Production

*All Referenced forms are available upon request.   

Dietary Guidelines for Americans

The Healthy, Hunger-Free Kids Act of 2010 requires the National School Lunch and the School Breakfast Program requires SFAs to provide meal that comply with the Dietary Guidelines for Americans (DGAs) as required by Sections 4(b0 and 9(a)(4) of the Richard B. Russell National School Lunch Act.  Many recent changes in the law require SFAs to provide healthier meals.  Changes are based on the recommendations of the Institute of Medicine of the National Academies and are expected to enhance the diet and health of school children, and help reduce obesity. 

Recent changes to the meal pattern requirements have eliminated past meal patterns such as nutrient standards, assisted nutrient standards and the traditional food-based and enhanced meal patterns.  All SFA are required to offer or serve a food-based meal pattern assigned to a grade group.  The new requirements assign: minimum serving sizes on grains, meat and meat alternates, milk, fruit, and vegetables, assigns weekly maximum and minimum calories; limits saturated fat and sodium; and eliminates trans-fat.   Additionally, schools are required to increase the availability of fruits and vegetables subgroups, whole grains, and limit the types of milk served to low-fat and fat- free.  Table 1 lists the meal pattern requirements based on grade groups for both breakfast, and lunch and lists the minimum daily serving sizes and maximums weekly serving sizes for each meal component. 

In addition to following to the new meal patterns when serving a reimbursable lunch, schools and RCCIs are also required to provide healthier  breakfast, snacks, and a la carte items, which consist of the required meal components.  Additional foods items may be sold during the school day as long as they comply with required fat, calorie, and sodium requirements.

Meal Planning

The Healthy, Hunger-Free Kids Act of 2010 has modified the types of foods and serving sizes that SFAs must offer for a reimbursable meal.  The meal pattern requires schools to offer or serve five required food components for lunch, four required food items for breakfast, a variety fruits and vegetables throughout the week, whole grain rich products,  and low-fat or fat-free milk.  The weekly requirements must comply with nutrients standards such as low-fat, low-sodium, food items containing no trans-fat, and a weekly average calorie range.  Serving sizes are specified for each grade group.  See Table 1 for specific information on the meal pattern for both breakfast and lunch.

For lunch, the meal pattern consists of five specific food components:  1) fruits, 2) vegetables, 3) grains, 4) meat/meat alternates, and 5) fluid milk.  Food components required:  grains must be whole-grain rich, vegetables must consist of vegetable subgroups, and milk can only be 1% or fat-free.  All items should be low in sodium and saturated fat.  No trans-fat is allowed.  See specific requirements for each food components. 

For breakfast, the meal pattern consists of four food items consisting of three different food components:  1) fruits, 2) grains/breads, and 3) fluid milk.  Meats may be offered as an other food or in place of a grain after the minimum weekly requirements for grains have been planned and as long as the other nutrients requirements are within range for calories, fat, sodium, and trans-fat.  Vegetables may also be offered in place of fruit.  See breakfast requirements for substituting a meat or vegetable. 

Meal Patterns for Separate Age/Grade Groups

Each school is required to serve the correct portion size, nutrient standards, and calories for each grade group.  For lunch, age/grade groups consist of K-5, 6-8, and 9-12.  The requirements for K-5 and 6-8 overlap slightly.  Therefore, if planned correctly, one menu can be served as long as the school is compliant with the nutrient standards for each grade group.  Grades 9-12 and cannot be modified to fit the needs of K-8 because larger serving sizes are required.  However, it is possible to plan a menu for K-12 and increase the portion size for high school students. 

Grades 9-12 is distinctive from the other grade groups due to its larger servings and calorie requirements, therefore, its menus must be planned to ensure that all requirements are met.  If a school is a K-12, schools may create a menu with the same menu components and items, but increase the fruit, vegetables, grains, and meats as required, ensuring that requirements are met. 

If an SFA has infants and Pre-K students, contact DHS for meal separate meal patterns.  There is some flexibility that allows Pre-K to be served the same menu as K-5, but serving sizes may be too large.  Infant menus must be created specifically for the age groups. 

For breakfast, food portions for all age/grade groups overlap, a menu planner may offer the same food quantities to all children provided that the meal meets the requirements of each grade group.

For RCCIs only:  There is one exception to the different grade/age meal patterns:  RCCIs can be allowed to serve one meal pattern to all grade groups if there is a safety concern.  See Policy Exception Request Form for approval.

Table 1: Meal Pattern Requirements for Breakfast and Lunch

Breakfast Meal Pattern Lunch Meal Pattern
Grades K-5 Grades
Grades K-5 Grades 6-8 Grades 9-12
Meal Pattern Amount of Foodb Per Week (Minimum Per Day) ​ ​ ​ ​ ​
Fruits (cups) 5 (1) 5 (1) 5 (1) 2½ (½) 2½ (½) 5 (1)
Vegetables (cups) 0 0 0 3¾ (¾) 3¾ (¾) 5 (1)
Dark green 0 0 0 ½ ½ ½
Red/Orange 0 0 0 ¾ ¾
0 0 0 ½ ½ ½
Starchy 0 0 0 ½ ½ ½
Other 0 0 0 ½ ½ ¾
Additional Veg to Reach Total 0 0 0 1 1
Grains (oz eq) 7-10 (1) 8-10 (1) 9-10 (1) 8-9 (1) 8-10 (1) 10-12 (2)
Meats/Meat Alternates (oz eq) 0 0 0 8-10 (1) 9-10 (1) 10-12 (2)
Fluid milk (cups) l 5 (1) 5 (1) 5 (1) 5 (1) 5 (1) 5 (1)
Other Specifications: Daily Amount Based on the Average for a 5-Day Week ​ ​ ​ ​ ​
Min-max calories (kcal) 350-500 400-550 450-600 550-650 600-700 750-850
Saturated fat
(% of total calories)
< 10 < 10 < 10 < 10 < 10 < 10
Sodium (mg) < 430 < 470 < 500 < 640 < 710 < 740
Trans-fat Nutrition label or manufacturer specifications must indicate zero grams of trans fat per serving. ​ ​ ​ ​ ​

NOTE:In order to comply with calorie restrictions, SFAs should not exceed the weekly maximums on serving sizes for meat/meat alternate, grains, and milk.  SFAs are not out of compliance for exceeding recommended serving sizes, but may be out of compliance for exceeding calories restrictions.

Food components versus Food items

Food components are the required foods that schools must serve in order to comply with the meal pattern.  Food items are the number of food offered or served. Offering several food items is no indication that the menu planned is in compliance with the required meal patterns. 

For lunch, the required food components are the following five components:

  • meat/meat alternate
  • whole-grain rich products:  grain, bread, pasta, rice
  • milk
  • fruit
  • vegetables:  consists of 5 subgroups

For breakfast, the required food components are the following three components:

  • whole-grain rich products (meat/meat alternate substitute allowed, see requirements)
  • fruit (vegetable substitute allowed, see requirements)
  • milk



SFAs are required to offer a variety of fruits according to grade groups.  Fruits consist of fresh; frozen without sugar; canned in light syrup, water, or fruit juice; or dried. Pasteurized, full-strength fruit juice may also be offered (it is credited to meet no more than one-half of the fruits component offered over the week).

  • For breakfast, all grades must offer at least 1 cup a day. 
  • For lunch, K-8 grade must be offered at least 2.5 cups a week and no less than ½ cup a day.  Grade 9-12 must be offered 1 cup a day. 
  • There are no maximum serving sizes on fruit, only requirements for the daily minimum serving sizes and minimum weekly requirements. 
  • Frozen fruits cannot contain added sugar. 
  • Canned fruits must be light syrup or naturally packed in own juices.  A variety of fresh fruits is recommended. 
  • There are restrictions on fruit/grain desserts (see grain section)
  • Dried fruits count as twice the volume.  ¼ cup of dried fruit counts as ½ cup of fruit.  When   crediting a dried fruit mix, ensure that it is all 100% fruit. Dried fruit with sugar is allowed, however, schools should consider the calorie limits when serving products high in sugar.
  • No more than half of the fruit or vegetable offerings may be in the form of juice for the week.  All juice must be 100% full-strength.  Diluted juice is not creditable. If juice is offered every day in a full serving, fruit must be offered every in the full serving. 
  • Frozen concentrated fruit juice must be reconstituted with water to 100% full-strength before crediting as a fruit.  See food buying guide for crediting information. 
  • Fruit Jell-O made with real fruit juice is not creditable. 
  • No less than 1/8 cup of fruit can be credited toward the minimum amount of fruits.   If the school requires all five food components to be served for lunch or all four components to be served for breakfast, the school must serve the minimum required fruits for that day for the required age/grade groups.  This can be served in combinations (1/2 cup of peaches, 1 orange.  If the school is OVS, the student is required to take no less than ½ cup of fruit or vegetable as part of the meal.    
  • Refer to the food buying guide to determine the serving size of whole fresh fruit.  In many cases, a whole fruit only equals ½ cup.  Therefore, an additional item may be required to equal a required serving. 
  • Snack-type fruits such as strips and roll-ups are not creditable towards breakfast or lunch.      

Schools are required to offer a variety of vegetables for lunch in the form of subgroups to reach the weekly requirement per grade group.  Required minimum weekly quantities for each subgroup are established in the lunch meal pattern:  2-5, 6-8, 9-12.  Pasteurized, full-strength vegetable juice is also allowable (it is credited to meet no more than one-half of the vegetables component).  To ensure vegetables are served as required, designate a day of the week for each subgroup.  Vegetables are an option for breakfast.

Each week the school is required to offer or serve (depending on approved policy) in proper portions:
 -dark green vegetable                          
  -other vegetable (different from the subgroups listed above), and
 -additional vegetable from any of the food groups to reach the minimum weekly requirements. 

The school must offer weekly no less than 3 ¾ of cup for grades K-8 and no less than 5 cups for high school. The school is not required to offer a vegetable for breakfast.  Review table 1 for minimum serving size for each subgroup.  There are not maximum limits on vegetables except for vegetable juice.    

  •  Dark leafy vegetables in the raw form count as ½ the volume.  This means that 1 cup of a dark leafy greens counts as ½ cup of vegetables.  To credit ½ cup of raw spinach, you must serve 1 cup. 
  •  Cooked dark leafy vegetables such as broccoli or spinach are credited by actual volume:  ½ cup of cooked counts as ½ cup of dark leafy vegetable. 
  •  Some leafy vegetables are not considered a dark leafy vegetable.  For example, iceberg lettuce is considered an other vegetable and not a dark leafy.  It can be served with other dark leafy vegetables but is credited as an other vegetable. 
  •  When mixed vegetables or mixed salads cannot be credited to one subgroup because the portion size of that subgroup is unknown, count the vegetable in the "other" subgroup.  If packaging identifies the percentage of each vegetable and it can be credited to that subgroup, as long as it is more than 1/8 cup.
  •  No more than half of the vegetable offerings may be in the form of juice for the week.  All juice must be 100% full-strength.  Diluted juice is not creditable. 
  •  No less than 1/8 cup of vegetable can be credited toward the minimum amount of vegetables.   If the schools requires all five food components to be served for lunch, the school must serve the minimum required vegetables.  1/8 cup can be combined with another vegetable to get the full serving.  If a vegetable garnish is served and is less 1/8 cup it is a noncreditable food item.  If the school is OVS, the student is required to take no less than ½ cup of fruit or vegetable as part of the meal.

For breakfast, vegetables may be substituted for fruits, but the first two cups per week of any such substitution must be from the dark green, red/orange, beans and peas (legumes) or "Other vegetables"   subgroups as defined in §210.10(c)(2)(iii).

  •  Larger amounts of these vegetables may be served.
  •  This category consists of "Other vegetables" as defined in §210.10(c)(2)(iii)(E).  For the purposes of the NSLP, "Other vegetables" requirement may be met  with any additional amounts from the dark green, red/orange, and beans/peas (legumes) vegetable subgroups as defined in §210.10(c)(2)(iii).
  •  Any vegetable subgroup may be offered to meet the total weekly vegetable requirement.
  •  If you have a full strength 100% vegetable juice blend from the same subgroup, you can count it for that subgroup.  If the vegetable juice blend is a combination of vegetables from different subgroups, credit it as a vegetable from the additional subgroup. 
  •  If crediting a vegetable in a product such as vegetable lasagna or pizza, the product must have a CN label or formulation statement that provides the crediting information. 
  •  Beans, peas (legumes) may be offered as a vegetable or a meat alternate, but it cannot be creditable toward both.  Ensure both meat and beans are planned sufficiently for the week.

Vegetable Subgroups

  •  For grades K-8, vegetables are broken up into subgroups and a minimum serving size for each subgroup:  dark greens- ½ cup, red/orange- ¾ cups, beans and lentils- ½ cup, starchy vegetables- ½ cup, other vegetables-1/2 cup.  Additional vegetables are to be offered to ensure that schools serve a minimum of 3 ¾ cups a week.  Starchy foods such as potato and corn is not limited, however, should be reduced due to nutrient requirements and other vegetable subgroup requirements. 
  •  Grades 9-12 will have to increase fruits and vegetables offered to 1 cup a day.  See Table 1:  Vegetable Groups Required for the School Nutrition Programs Meal Pattern.
  •  There are no maximum limits on vegetables, only limits on minimum serving sizes. 
  •  Vegetables are not required for breakfast, but may be offered if the menu complies with the new meal requirements specifically for breakfast. 
  •  No less than 1/8 cup of vegetable can be credited toward the minimum amount of fruits.   If the schools requires all five food components to be served, the school must serve the minimum required fruits for that day for the age/grade group.  This can be served in combinations.  If the school is OVS, the student is required to take no less than ½ cup of fruit or vegetable as part of the meal. 
  •  Vegetable subgroups can be served in smaller portion sizes as long as the full serving size for that subgroup complies with the required serving size for the week.  For example, the required serving size for red/orange is ¾ cup for grades 6-8.  Tomatoes can be offered as a ¼ cup serving size on a salad one day, and then carrots can be offered as a ½ cup serving on a different day.

List of familiar vegetables 

Dark Green (1/2 cup) Bok Choy, Broccoli, Collard Greens, Dark Green Leafy Lettuce (1 cup = ½ cup serving: see rule), Kale, Mesclun, Mustard Greens, Romaine Lettuce, Spinach, Turnip Greens, Watercress
Red/Orange (3/4 cup) Acorn Squash, Butternut Squash, Carrots, Hubbard Squash, Pumpkin, Red Peppers, Sweet Potatoes, Tomatoes, Tomato Juice
Beans/peas (1/2 cup) Black Beans, Black-Eyed Peas (mature, dry), Garbanzo Beans (Chickpeas) Kidney Beans, Lentils, Navy Beans, Pinto Beans, Soy Beans, Split Peas, White Beans
Starchy (1/2 cup) Cassava, Corn, Fresh Cowpeas, Field Peas, Black-Eyed Peas (not mature/dry), Green Bananas, Green Peas, Green Lima Beans, Plantains, Potatoes, Taro, Water Chestnuts
Other Vegetables (1/2 cup) Artichokes, Asparagus, Avocado, Bean Sprouts, Beets, Brussels Sprout, Cabbage, Cauliflower, Celery, Cucumbers, Eggplant, Green Beans, Green Peppers, Iceberg Lettuce, Mushrooms, Okra, Onions, Parsnips, Turnips, Wax Beans, Zucchini
Additional Vegetables As needed to reach the minimum required amount of 3 ¾ for the week.  (Schools and RCCIs that extend above the 5 day week have additional minimum requirements.

Reducing Plate Waste:  If a school is following the offer versus serve (OVS) policy for breakfast and/or lunch, they must provide enough for each child to take the full required amount of each component. But, a student may take smaller portions of the fruits and vegetables components, if desired. Students must select at least ½ cup daily of the fruits or the vegetables components for a meal to be considered reimbursable under OVS in the NSLP and SBP.  If a school practices the serve policy, all components must be served at full serving and a student cannot decline the ½ cup of fruit or vegetable.

Whole Grain Requirement:  Half of all grains, breads and pasta must be whole-grain rich.  For a product to be considered whole-grain rich, it must contain at least 50% whole grain.  Sometimes this is not easy to determine.

The criterion below determines if a product meets standards: 

  •  A serving of the food item must meet portion size requirements for the grains/breads component as defined in FNS guidance, AND
  •   Food must meet at least one of the following:

    The whole grains per serving (based on minimum serving sizes specified for grains/breads in FNS guidance) must be ≥ 8 grams. This may be determined from information provided on the product packaging or by the manufacturer, if available. Also, manufacturers currently may apply for a CN Label for qualifying products to indicate the number of grains/breads servings that are whole grain-rich.OR

    The product includes the following FDA-approved whole grain health claim on its packaging. "Diets rich in whole grain foods and other plant foods and low in total fat, saturated fat and cholesterol may reduce the risk of heart disease and some cancers." OR

    Product ingredient listing lists whole grain first, specifically:
  •  Non-mixed dishes (e.g., breads, cereals): Whole grains must be the primary ingredient by weight (a whole grain is the first ingredient in the list)
  •  Mixed dishes (e.g., pizza, corn dogs): Whole grains must be the primary grain ingredient by weight (a whole grain is the first grain ingredient in the list).

The listing of the products on the packaging is one way to determine if a product is whole grain.  The whole grain should be the first item listed in the ingredient statement.  The item must also list it was a whole grain product.  This means that the words "whole" or "whole grain" appear before the grain ingredient's name in the ingredient statement. Example is whole wheat, and whole corn.  Rice must be brown rice, since white rice has been processed for manufacturing. 

Some products are misleading.  Many products contain a stamp on the label that state it contains whole grain or it is whole wheat.  Do not assume that this means that the product meets the requirements for the whole-grain rich products.  Look at the label to determine if the first ingredient is a whole grain product, and then look at the serving size to determine if the serving size is sufficient for the meal patterns offered at the school. 

In some products, water is listed as the first ingredient.  If the whole-grain is listed as the second ingredient and water is listed as the first, the product counts as a whole-grain rich product.  No other ingredient besides water can be listed first. 

Whole grains are defined as, "cereal grains that consist of the intact, ground, cracked or flaked caryopsis [kernel], whose principal anatomical components - the starchy endosperm, germ and bran - are present in the same relative proportions as they exist in the intact caryopsis." Examples of common whole grains can be found in Table 7 of the 2005 DGAs document.

Items that are considered creditable grain products when it is the first ingredient and complies with proper serving size. 

Whole wheat Whole oat/oatmeal Whole-grain corn
Popcorn Brown rice Whole rye
Whole-grain barley Wild rice Buckwheat
Triticale Bulgur (cracked wheat) Millet
Quinoa Sorghum  

Example of noncreditable grain ingredients are: white flour, corn, wheat if those ingredients do not have "whole" as the first word, oat fiber, corn fiber, wheat starch, corn starch, bran, germ, and modified food starch (including potato, legume and other vegetable flours).

Granola bars, cereal bars, breakfast bars, fortified cereals, and cereals with fruit can be credited toward the whole-grain rich product is it complies with the whole-grain rich requirements. 

If a school offers a formulated fruit-grain product, the fruit cannot be credited for breakfast or lunch.  It can be counted towards a grain.  If the school chooses to serve the product for lunch, it can only count as a grain-based dessert. 

New rules limit the grain-base desserts to 2 ounces a weeks. A school may offer a total of 2 oz eq or less of grain-based desserts each week. Therefore, a 2 ounce equivalent dessert may be offered once per week, or a 0.5 oz eq dessert may be offered four times in a week.

Whole grain cereals need to be fortified.  The only exception is anything under .25 ounce equivalent because it does not contribute the grain requirements. 

Scratch cooking requires a product to contain 50% whole grain and 50% enriched white to equal a 100% whole-grain rich.   Recipes should be altered to reflect the new requirements.  Breading on meats does not count as whole-grain rich without a formulation statement or a CN label.  

If using a processed food item where both meat and grain is credited toward the meal, schools need either a formulation statement or a CN label to identify the grain and meat contribution to the meal. 

If schools are unable to identify the grain or meat contribution, that product does not count toward the required meal pattern. 

If a school provides lunch choices, such as pizza or a pasta meal, each choice must meet the minimum daily requires. If the minimum requirement for high school is 2 ounces and the pizza contains 2 ounces, but the pasta only contains 1 ounce, the school must provide an additional whole-grain rich serving, such as a roll, to equal the 2 ounces for the pasta meal. 

Breading on meat, croutons on salads, and other grain items cannot be credited to the weekly meal pattern unless it is .25 ounces or more.  If it is less than .25 ounce, it is not considered and cannot be combined with other grain products to reach the required serving size.  Schools must ensure the daily minimum requires are met with some other food item.  If the breaded items are more than .25 ounces it is considered and must contributed to the requirement of whole-grain rich. 

There are other bread/grain items that do not contribute fully to the serving size requirement because of other added ingredients.  Some examples are donuts, pastries, granola bars.  See the grain section Exhibit A of the food buying guide to determine crediting information for items such as donuts and pastries.  When serving products from the Group A-G, noncreditable grains should never exceed 3.99 grams.  Products listed in Group H should never exceed 6.99 grams of non-creditable grain.  

Schools must make an effort to comply with recommended maximum serving sizes for the week in order to be in compliance with the nutrients standards for calories and saturated fat.  As with the other meal components and dependent on grade group, schools have daily and weekly minimum serving sizes and recommended maximum serving sizes.  Although there is not maximum limit on whole-grain rich products for this year, exceeding the recommended maximum limits may result in exceeding the limits on calories, saturated fat, and sodium. 

Meat/Meat Alternate

For lunch, schools are required to offer daily a meat or meat alternate.  For grades k-5, and 6-8, the daily minimum is 1 ounce with a weekly requirement of 8-10 ounces for k-5 and 9-10 ounces for grades 6-8.  For high school, the daily minimum is 2 ounces and the weekly requirement is 10- 12 ounces.  The menu planner has the flexibility to determine when to offer more than daily minimum.

Schools must never go below the daily minimum and should adjust the week to ensure the servings sizes are within the weekly minimum ranges. 

Schools have the flexibility of serving a meat alternate in place of meat.  Meat alternates consist of cheese, tofu, nuts, yogurt, bean and legumes.  It is important to note that these products cannot be credited as any other foods except for the beans and legumes.  Yogurt and cheese are considered a dairy product by many, but they cannot be credited as milk. 

Beans and legumes are the exception to how a food item is credited.  When planning a menu, the school must determine if beans and legumes will be credited as a vegetable or a meat alternate.  On the day of service, it cannot be credited as both a vegetable and a meat, even if the serving size exceeds the minimum daily requirements.  Weekly menus must be planned to include the required amounts of vegetables and meat/meat alternates. 

Milk Requirement:  The Healthy, Hunger-Free Kids Act of 2010, Public Law 111-296, modifies requirements for fluid milk in NLSP and SBP.  School Food Authorities must offer at least two choices form the following:  fat-free milk, low-fat (1%) milk, fat-free or low fat lactose reduced milk, fat-free or low fat lactose-free milk, fat-free or low-fat lactose reduced milk, fat-free or low-fat acidified milk.  Such products must be pasteurized fluid milk that meets State and local standards. Whole milk and 2% cannot be offered as part of the reimbursable meal. Additionally, new restrictions on a la carte items may restrict the sale on 2% and whole milk during school hours Grades K-12 must be offered a minimum of 1 cup a day.  Although there are no restrictions on larger portions, schools should limit the serving size to 1 cup a day in order to minimize the fat and calories. 

Milk substitutes are considered meal exceptions and are not subject to this final rule.  Milk substitutes must meet the federal guidelines.   Milk substitutes tend to be for milk allergies or other disabilities.  Contact SNP for guidelines for milk substitutes.  However, milk substitutes are subject to nutrient analysis so calories and fat content should be considered. 

RCCIs that are juvenile detention centers may meet the milk variety requirement over the week rather than daily if there are potential, legitimate safety concerns regarding the offering different milk to students.  For example, the RCCI may offer all students flavored low-fat or nonfat milk on some days of the week, and unflavored low-fat or nonfat milk on other days.

Nutrient Requirements


The calorie minimum and maximum levels (and related food portions for various components) are based on data pertaining to children's healthy weight, physical activity level, and opportunities for meals and snacks outside of the school meals programs.  If implemented properly, the new meal plans for each appropriate age/grade group allow schools to create menus that fall within the calorie minimum and maximum ranges for the week.  The calorie minimum and maximum ranges cannot be calculated daily because there may be some days popular items are offered that may be higher in calories, other days of the week must be planned to offset the higher calorie days in order to keep the weekly average within range.   The new reimbursable meal patterns require schools to offer nutrient dense meals that provide children more fruits, vegetables, and whole grains than specified by the previous meal patterns.

Discretionary sources of calories (solid fats and added sugars) may be added to the meal pattern if within the specifications for calories, saturated fat, trans fat, and sodium.  Foods of minimal nutritional value and fluid milk with fat content greater than 1 percent milk fat are not allowed. 


These requirements allow SFAs to reduce sodium incrementally.  The 2005 DGAs have set a quantitative upper limit on daily sodium consumption of 2,300 mg (approximately 1 tsp of salt) of sodium per day."  Schools are required to offer a proportionate amount for both lunch and breakfast to reach the daily limit of 2,300 mg.  Listed below is sodium limits and timeline based on program year, type of meal, and grade.  Target III is the final maximum limits beginning year 2022-2023 and thereafter.  

Table 3: Sodium Limits and Timeline

Target I: 2014-15 Target II: 2017-2018
Lunch≤  1230 mg (grades K-5)≤  1360 mg (grades 6-8≤  1420 mg (grades 9-12)Breakfast≤  540 mg (grades K-5)≤  600 mg (grades 6-8≤  640 mg (grades 9-12) Lunch≤  935 mg (grades K-5)≤  1035 mg (grades 6-8≤  1080 mg (grades 9-12)Breakfast≤  485 mg (grades K-5)≤  535 mg (grades 6-8≤  570 mg (grades 9-12)

Trans Fat

SFAs must limit all foods to zero trans-fat.  This requires SFAs to purchase products that list .5 grams or less as zero trans-fat.  The only exception is for foods that contain natural occurring trans-fat.  This is limited to dairy and meat products.  For processed food items containing trans-fat, the CN label or product formulation statement must identify the trans-fat as naturally occurring.  Many manufacturers have begun to eliminate trans-fat.  When ordering, food service staff needs to specify zero trans-fat. 

Naturally occurring trans-fat found in products such as beef, lamb, and dairy products made with whole milk is excluded from this ban. If there is trans-fat listed on the nutrition facts panel of a product containing meat or dairy the SFA should request documentation from the manufacturer that reports the source of the trans-fat.

For commercially prepared products, schools must refer to the nutrition facts panel or manufacturer's specifications to determine that there are zero grams of trans-fat per serving. For mixed dishes that may contain both naturally occurring trans-fat (e.g., beef) and added/synthetic trans-fat (partially hydrogenated oil), the only certain way to determine if the product is in compliance is for schools to request information from suppliers on how much of the trans-fat is naturally occurring versus if any of the ingredients contain added (synthetic) trans-fat.


Serve or Offer-versus Serve

Schools are either a "serve" school or an "offer-versus-serve" (OVS) school.  To determine which method to use, schools must review student selection behaviors, convenience, time and cost of foods.  Schools should always consider ways to reduce plate waste.  School choose serve or OVS on the form "Meal Counting and Claiming Procedures" listed in the permanent file.  Schools cannot switch from one method or another without OKDHS approval. 

When a school is not offer versus serve, it is required to serve all required food components to each student.  Students are not allowed to decline a required component.  An OVS school is required to offer all of required components, but, based on policy, students are allowed to decline one or two items.  OVS is a serving method designed to reduce food waste and food costs in the NSLP without jeopardizing the nutritional integrity of the meals served.

Once a decision is made to conduct "offer versus serve", schools should have standard procedures for identifying a reimbursable meal and procedures to count only meals that meet the USDA requirements for reimbursement.  All staff personnel responsible for serving meals and counting reimbursable meals should be trained to follow proper procedures. 


Schools may elect the method OVS as an option to serving all required items in elementary and middle schools.  The OVS method may not be used with children in the pre-K grades (USDA Memo SP 01-2018).  The SFA has the option of determining which schools and grades to implement OVS and whether the student must choose a minimum of three or four items for lunch.  For breakfast, students may decline one food component.  Note however, that with the new meal patterns, a child electing to decline a fruit or a vegetable as one of the two items must take a minimum of ½ serving of fruit of vegetable.  If the ½ serving is selected, the student may only decline one other item. 

High Schools are required to implement the offer versus serve method, allowing students to decline a maximum of two items.  The vegetable or fruit requirement still applies. 

Schools with OVS must allow students the option to take all required food components or decline one or two required components, depending on school policy. At least three full portions of the five food components offered must be taken for a lunch to be reimbursable.  One exception to the rule is to allow students to take ½ fruit or vegetable as the third selection.  Schools cannot require students to take certain food items unless it declines to use the offer versus serve option. 

Regardless of whether a student chooses three items or takes all five offered food items, the unit price of the meal should be the same price.  Food service programs with high school grades must provide offer-versus-serve to all high school students. 

Example:  Lunch - student when declining two items, a fruit and a vegetable, one half of either a fruit or a vegetable must be taken.  If a student declines a meat and a vegetable, a fruit must be served. 


An "offer versus serve" lunch meal must meet the following requirements:

  •  All 5 components of the lunch meal pattern must be offered to all students.
  •  For the five required components, the serving size must be consistent with the minimum quantities specified for the meal pattern chart.
  •  The student must select full sized portions of at least 3 of the 5 offered components of the meal pattern.
  •  Student must take ½ serving of fruit or vegetable

An "offer versus serve" breakfast meal must meet the following requirements:

  •  Three of the required breakfast food components must be offered
  •  Among the three required food items, there must be four food items must be offered to all students.
  •  For the four required components, the serving size must be consistent with the minimum quantities specified for the meal pattern chart.
  •  The student must select full sized portions of at least 3 of the 4 offered items.
  •  Student must take ½ serving of fruit or vegetable substitute and two other food items at full portion.   Example:  if two fruits are offered, milk and grain and the student decides to take two fruits and a milk, the second fruit serving must be one whole cup.

Under offer versus serve, a school can determine the number of servings to offer for each meal component.  SFAs must plan meals in the NSLP and SBP to meet all meal requirements and provide required amounts of food for all students. Menu planners should take into account participation and selection trends to determine what and how much food to offer students. Careful menu planning will ensure that students have access to all the required food components for the reimbursable meal and minimize food waste.

A menu planner may split a component into multiple items. Under OVS, the student must take at least the daily minimum required by the meal pattern. For example, a K-5 school offers 2 ounce equivalents of grains: spaghetti (1 oz eq) with a dinner roll (1 oz eq). Since the minimum daily grains requirement for grades K-5 is only 1 oz eq, the student may take either the dinner roll (1 oz eq) or the spaghetti (1 oz eq) and count as meeting the grains component under OVS. This also applies to the meat/meat alternate component. In grades 9-12, since the daily minimum is 2 oz eq, students must select at least 2 oz eq of grains or meat/meat alternate to count toward these components. Students are instructed on how much of each component must be selected through meal identification signage.


To serve food items as part of the reimbursable meal, schools must ensure the product is a creditable food item.  Creditable food items are listed in the USDA Team Nutrition Food Buying Guide.  Many vegetables, fruits and meat items are listed in the guide.  When using the Food Buying Guide for menu planning, food service personnel must ensure the product listed in the guide is the same product used in meal production.  If a product is not specifically named in the Food Buying Guide, schools must obtain a product specification statement or obtain a Child Nutrition label for the item.  Product specification statements and CN labels must state how the item contributes to the meal pattern.

Crediting Serving Size

Crediting is determined by rounding the food component down to the nearest quarter ounce equivalency for the meat/meat alternate and grain components, and down to the nearest eighth (1/8) cup for the fruit and vegetable components.  This means that a .30 ounce of meat/meat alternate or grain is only credited for .25 ounce eq.  Fruits and vegetables must be at least 1/8 of a cup to count towards a reimbursable meal.  Since these serving sizes do not comply with the meal pattern, it must be combined with the same food component to reach the daily requirements.      

Soups like tomato may contribute toward the Red/Orange vegetable subgroup. To credit, the recipe will be needed to determine the creditable amount of butternut squash, pumpkin, or tomato per serving. If this is a commercial item, a product formulation statement or CN label may be used to determine the creditable amount. School food authorities shall continue to use established guidance regarding tomato paste or purees for crediting found in the Food Buying Guide for Child Nutrition Programs.

The fruit or vegetable puree credits based on the actual volume served. For many fruits and vegetables, the pureed form has a smaller volume than whole fruit pieces. Some puree yields for fruit and vegetables are currently in the Food Buying Guide (blackberries, plums, raspberries, tomatoes). For other foods, SFAs must rely on manufacturer information or, for in-house recipes, yields based on volume of fruit/vegetable puree. Please refer to the introduction of Food Buying Guide for Child Nutrition Programs for information about how to obtain in-house yield data. 

Leafy greens that are served raw count as half the volume served, while in their cooked form they credit as volume served.  Cilantro and parsley are both classified as dark green vegetables (refer to Q35 of this section) therefore ¼ cup would credit as 1/8 cup of dark green vegetables. Herbs in the Other subgroup, such as chives and garlic, credit as volume as served. SFAs with questions about the subgroup classification of additional herbs not listed above should contact their State agency for assistance. Herbs that are used in small amounts (less than 1/8 cup per portion) as a garnish or seasoning would not credit toward the vegetables component.

Creditable dessert items

When using a USDA recipe, review the serving information to determine if the food item contributes to a food based meal pattern.  Some recipes such as desserts are creditable but limited by the number of ounces that can be served as a grain, if the product contains whole grain rich.      

Meat items

When using a USDA commodity meat, review the commodity fact sheets to determine if meat products are creditable.  If crediting information is not available, the school must request company formulation statement for product.


Many food items are not creditable toward the meal component because of the ingredients used to produce the product.  The ingredients can diminish the actual portion size of the required food component.  For example, if a school wants to serve ¼ cup of salsa and count it as a vegetable component, the school must have documentation that indicates how much salsa to serve to equal ¼ cup of vegetable. Commercial sauces, such as canned, contain starches and other additives to increase volume not nutrition.  In order to serve food items not listed in the Food Buying Guide as part of the meal pattern, documentation that clearly identifies the meal contribution is required.  On the other hand, a homemade salsa may comply with the meal requirements if the school has a standardized recipe to identify the meal contribution.

Schools can serve noncreditable foods as an extra item during the meal, but cannot count the item as one of the five required food components.  Most condiments and desserts are examples of noncreditable food items. 

Examples of Noncreditable Food Items

      Meat and Meat Alternates

• Bacon • Cream Cheese
• Packaged Macaroni/Cheese/Spaghetti    Products • Imitation cheese
•Noncommercial and Nonstandardized   Yogurt Products
• Canned Meat Soups (Example:    Chicken Noodle, Chicken Rice)
Shelf-stable dried or semi dried meats unless found in food buying guide or CN labeled

   Fruits and Vegetables

• Jams, Jelly Preserves • Ades (Lemonade, Limeade,   Orangeade)
• Nectars (Example: Peach, Pear,   Apricot) • Cranberry Juice, Cranapple Juice     Cocktail, Cranapple Juice
• Fruit Drinks (Example: Pineapple/      Grapefruit Drink/HI-C) • Tomato Catsup
• Dry Vegetables for Seasoning
• Mustard
• Fruit Roll-ups, Fruit Leathers • Chili Sauce
• Creamed soups 
• Plain Gelatin Desserts • Potato chips, Potato Sticks


• Ice Cream, Ice Milk or                                                
• Butter                                     • Evaporated Milk
  • Sherbet
• Dry Milk • frozen yogurt                        

Noncreditable food items and School Meal Initiative

When a school serves a noncreditable food item as part of the meal, it is included in the nutrient analysis if triggered during an Administrative Review.  Schools that routinely serve desserts, condiments, and sauce items may need to modify the menu to offer healthier items.  Schools using the nutrient standard-based meal pattern are required to analyze meals prior to serving.  All food must meet the guidelines for nutrient standards before serving. 

Child Nutrition Labels and Product Specifications Sheets

If a food item is not found in the Food Buying Guide, and a product formulation statement is not obtained to identify its creditability to the meal pattern, the school must obtain a Child Nutrition (CN) label to show how a food item contributes to the meal pattern.  This information is required for all meats, meat alternates and fruit juices that contain other ingredients.  The label clearly identifies; the contribution a product makes toward the meal pattern requirements. Most products with a CN label are products that are not 100% pure, but contain other ingredients.  Listed below is a sample CN label that demonstrates the meal pattern contribution.  

For more information about CN labeled products, visit:

Click on the USDA/USDC Authorized CN Label Manufacturers for a list of companies offering CN labeled products, or click on USDA/USDC Authorized CN Labels for products and CN numbers.  This information is only used to identify products that are CN labels.  To offer creditable CN Labeled products, provide the CN information to your distributor. A CN labeled products is only creditable if you have the packaging with the CN label.  A brochure, a company listing or an invoice indicating how much product is credited as a meat, grain or juice is not sufficient documentation. 

Identifying a CN Label: 

  • It will have a CN logo with a distinct border.
  • It will have a 6-digist production identification number with CN in front of the 6 digits
  • It will have the USDA/FNS authorization statement
  • It will contain the month and year of approval. 
  • It will indicate the food serving sizes and the contribution to the meal pattern. 


CN 000000

      This 5.00 oz.-Pizza with Ground Beef and Vegetable Protein Product provides 2.00 oz. equivalent meat/meat alternate, ½ cup serving of vegetable, and 1 oz. equivalent servings of whole-grain rich grains/breads for the Child Nutrition Meal Pattern Requirement. (Use of this logo and statement authorized by the Food and Nutrition Service, USDA 00-98)


Product Specification Sheets or Data Submission Forms

If a CN label is not available for meat/meat alternates and juices, a product specification sheet or a data submission form is required.  The manufacturer should be provide a sheet that clearly makes a statement about the contribution the product makes toward the meal pattern requirements Unlike the CN label, the product specification sheet will provide detailed information required nutrients, ingredients, and contribution.  The school may provide production data submission form to the manufacturer for completion.  See page 33 of this chapter for Data Submission Form.

Product specification statements should provide detailed information so that the food service staff can identify the item's contribution to the required meal pattern.  Processed meat entrees, spaghetti sauces, salsas and cheese sauce are examples of food items that must have product information demonstrating how the food item can count toward a vegetable or meat component.  Products that do not demonstrate valid contribution to one of the required food components should be listed as an "other" food item on the daily production sheets.

In order to determine a product's contribution toward the meal pattern, documentation must state the contribution, and an officer of the manufacturer must sign it.  Listed below is other information that should be included on the product specification sheet:  

 • weight of raw portion • percent of raw meat or poultry • percent fat of raw meat  • certification that the vegetable protein product       used meets USDA-FNS requirements. • percent dry vegetable protein products (VPP) if    product contains VPP • percent protein of the vegetable protein product   (on an as purchased basis)

Procurement and Creditable Food Items

Many manufacturers do not provide product specification information or may provide insufficient information.  Schools cannot use products that do not have a complete statement on file.  During the procurement process, food service staff must communicate the program's need for sufficient product information from potential vendors.  Remember if the school cannot find the product in the Food Buying Guide and does not have a CN label, the product cannot contribute to the meal pattern.  Serving these items may result in non-reimbursable meals. 

Other Meal Pattern requirements

Extra Item

Extra items can be offered during breakfast and lunch when it is not contributed as part of the meal pattern.  However, when a school chooses to offer larger portion sizes or extra items that are not contributable towards the meal pattern, it must consider what effect it will have on the dietary specifications.  Calories, saturated fat, trans-fat and sodium are all limited by the new meal patterns.  Adding extra items or extra servings can lead to noncompliance and will require schools to alter their menu plans. 

Meat is not a required component for breakfast.  If a school would like to add meat in place of a grain, it may do so as long as the minimum daily requirement of grain is met.  For example, high school is required to serve 1 ounce of grain daily but needs 9-10 ounces of grain for the week. The school must serve at least one ounce of grain and can add an additional 1 ounce of meat in substitution of the grain.  School may also serve meat as an extra item.  When served as an extra item, schools should take steps to ensure that the weekly requirements are on the menu and add meat on any day.  However, when serving extra items, schools should be careful not to add additional items that will cause the calorie, saturated fat and sodium to exceed maximum limits.    

Examples of extra items:

Sour cream


Non-whole- grain rich desserts

Meat (when it is not substituted for a grain)

Desserts with fruit and whole grain rich

The fruit in the dessert can credit toward the fruit component, regardless of whether there is added sugar in the dessert recipe or not. For grain-based desserts, such as pies, cobblers, or crisps, only the grain portion (e.g., crust) counts toward the grain-based dessert limit. A sweetened fruit dessert without grains, such as fruited gelatin or a baked apple, does not count toward the weekly limit on grain-based desserts. However, schools should offer sweetened fruit in moderation to stay under the weekly calorie maximum at lunch.

Schools may offer fruit that is fresh, canned in 100 percent juice, light or extra light syrup, or, frozen without sugar. (Please refer to FNS memorandum SP 49-2013 for additional information). In addition, this requirement does not apply to frozen grain-based desserts that contain fruit. Therefore, grain-based desserts that contain frozen fruit with added sugar may be credited toward both the grain and fruit components. The grains portion of the dessert remains subject to the weekly limit of 2 oz. eq for grain-based desserts.

Breakfast substitutions

For breakfast, vegetables may be substituted for fruits,  but the first two cups planned per week of any such substitution must be from the dark green, red/orange, beans and peas (legumes) or "Other vegetables"   subgroups as defined in §210.10(c)(2)(iii).  Starchy vegetables or other vegetables can only be planned for the week after the other subgroups are planned, if a starchy is being substituted as a fruit.  However, any vegetable can be offered as an extra food item if it is not credited toward the meal pattern. 

Salad Bars

Salad bars containing fruits and vegetables and credited towards a reimbursable meal must be stationed before the Point of Service (POS).  This is to ensure that each student's selections from the salad bar meet the required portions for an entrée or food/menu item.  If a school is not able to position the salad bar in a location prior to the POS, the school must get SA approval to use an alternate POS to ensure the meal is reimbursable.  If the fruits and vegetables are located in an approved location beyond the POS, there must be a system in place to ensure that each reimbursable meal selected by the student includes a fruit or a vegetable, and that the total of any fruit or vegetable item selected under OVS equals at least 1/2 cup.

Schools are encouraged to use utensils in the proper serving size so that children can take appropriate the food amounts.  Food service staff must ensure that the portions on the student's tray meet the meal pattern requirements.  Cashiers and other food service staff and staff responsible for POS counts must be able to visually identify the correct portions.  Proportioning in cups or other packages is another way to ensure proper serving sizes. 

An unmonitored salad bar will not count as part of the reimbursable meal, unless there is a system in place to ensure that the required components are taken and that system is approved by the SA.  Salad bars may be offered as additional food items that do not count as part of the reimbursable meal.  However, if not sold a la carte, those items will be included in the dietary specifications and nutrient analysis during the administrative review. 

In an effort to ensure that all of the vegetable subgroups are offered, the school can place all five subgroups on the salad bar daily.  On any given day, if a subgroup is not on the salad bar, it must be placed on the serving line.    Remember, if the school is not ovs, the school must ensure that students receive all five subgroups in a week.  

Schools with salad bars need to track all food items on a salad bar production sheet.  Salad bar production records require information such as total weight or volume of each item placed on salad bar, total meals served, and total weight or volume not used.  The leftover amount of each item is subtracted from the total amount placed on the salad bar to determine meals were planned properly and to determine the nutrient standards. 

When offering grains/breads and meat/meat alternates, schools must ensure that students can select the foods in the correct serving sizes to complete with daily and weekly requirements.  Schools may consider pre-portioning specific items to ensure the correct serving size or provide utensils with the correct portion size.  In many cases, salad bars can be challenging and school may wish to serve it a la carte and not count it towards a reimbursable meal.   

Multiple Serving Lines

If a school has multiple serving lines, all required food components, including vegetable subgroups must be planned weekly for that serving line to ensure that each line complies with weekly meal patterns.   For example, if a school has three serving lines, the meals planned for that line should be planned to ensure that the daily serving size for each food component is offered for that line and that it complies with weekly requirements for that line.  Schools must also ensure that each vegetable subgroup is planned for that line.  Schools cannot plan a weekly menu for one line with a missing component or subgroup because a different line offers that food components.  The only exception to this rule is if one serving line is an a la carte line and meals served are not counted as reimbursable. 

Exceptions to the Meal Pattern and Nutrient Standards

Schools are allowed, on a cases-by-case basis, to offer age-appropriate meals to individual students in unique situations (for example: a 16-year old teen with developmental issues placed with age/grade group K-5).  The State agency may require the school/SFA to seek permission prior to deviating from the required meal pattern for the prevalent age/grade group. This is important because the State agency is responsible for promoting proper implementation of the meal requirements.

The nutrition standards for the reimbursable school meal were designed based on age-appropriate nutrition and physical activity habits of the average student. USDA will provide States flexibility and options to both comply with the nutrition standards and meet the needs of these students who may require additional calories and protein. There are no limits on the amount of food students may purchase as a la carte items.

The average daily amount of calories for a week must be within the range (at least the minimum and no more than the maximum values) of each grade group.  Discretionary sources of calories (solid fats and added sugars) may be added to the meal pattern if within the specifications for calories, saturated fat, trans-fat, and sodium. 

One way to ease menu planning for these 2 grade groups within one school is to start with a menu that is appropriate for grades 6-8, then add in a few additional foods to serve to the older grade group. For the older children (grades 9-12), the fruit and vegetable minimums must be met. Therefore, on top of the requirements for the 6-8 group, schools must make available to the older children: ½ cup more fruit daily, ¼ cup more vegetables daily and across the week: ½ cup more red/orange, ¼ cup other, ½ cup additional (any subgroup) vegetables.

An alternative suggestion is to make the full 1 cup fruit and vegetables required for grades 9-12 available to both grade groups (same menu plan for these 2 food components), if such offerings do not exceed the calorie limit for the 6-8 grade group.  One potential method of doing this would be offering a salad bar to all students. 


For weekend meals, the RCCI must follow the daily and weekly meal pattern requirements. The operator may add three weekends together to create a 6-day school week and follow the Short and Long Week Calculation meal chart provided at the end of the QAs. Only the "additional vegetables" category is adjusted, and no adjustment to any of the dietary specifications is required since they are weekly averages (the same value applies, whether it is a school week of 6- or 7-days). For a sporadic meal offered during the week, only the daily meal pattern requirements would apply. The sporadic meals would not be included in the nutrient analysis.

Family Style

Family style will continue to be allowed in RCCIs, but the operator must plan and offer the required food quantities for each child participating in the meal. These offered amounts must meet the food component and dietary specification requirements.

Field Trips

Children on a field trip must be offered lunches that meet the daily meal component requirements. However, the menu planner does not have to adjust the planned weekly menu to account for occasional field trips, and does not have to pack the same vegetable offering from that day's "hot" lunch menu for a field trip. The menu planner has the option to offer a different vegetable, or a different vegetable from the same subgroup. However, the meals from field trips would need to be included when planning meals that meet the weekly grain and meat/meat alternate ranges and weekly dietary specifications (calories, saturated fat, and sodium).

Long and Short Weeks

Schools that regularly serve lunch 6 or 7 days per week must increase the weekly grains quantity by approximately 20 percent (1/5) for each additional day. When schools regularly operate less than 5 days per week, they must decrease the weekly quantity by approximately 20 percent (1/5) for each day less than five.

For schools with occasional decreases in the school week length due to holidays, for example, the menus do not have to be adjusted, but menu planners must plan their menus in a way that is consistent with the intent of the meal patterns. Planners should make sure they do not consistently fail to offer certain vegetable subgroups, or offer meat/meat alternates and/grains in portions that would exceed the weekly requirements.

Vending Machines

A vending machine that provides a reimbursable school meal is subject to all program regulations and represents an extension of the school food service area. Therefore, school meal vending machines are subject to the same procedures, menu planning requirements, competitive food rules, and offer versus serve requirements that are applicable to meals offered on a service line with a cashier. Also, as a reminder, any use of Program Funds for obtaining and maintaining vending machines to provide reimbursable meals must be in accordance with the procedures set forth in 7 CFR 210.21, as applicable, concerning the procurement of supplies, food, equipment, and services.

It is the SFA's responsibility for ensuring that a vending machine used to serve reimbursable meals is operated in compliance with program regulations. For example, the SFA must ensure that a machine can properly dispense a reimbursable meal and accurately document when a reimbursable meal has been selected by an eligible student. Moreover, SFAs will need to ensure that the use of the vending machine does not allow an eligible student to receive more than one reimbursable meal per service

period (e.g., one meal through the lunch line and a second meal through the vending machine). It is critical that any identity confirmation procedure does not overtly identify a child as receiving a free or reduced price meal. Additionally, as a reminder, all reimbursable school meals, including vended meals, must be priced as a unit.

Prior to the use of vending machines to serve reimbursable meals, an SFA must notify their State agency (SA) of their intent to do so. The SA would include the vending machines in any administrative review to ensure that these machines, and their use, are in compliance with Program regulations.

Extra Food, Second Servings, Leftovers

There is no limit on the foods that can be offered for sale to students. However, any extra food that is offered to the student as part of, not in addition to, a reimbursable meal must be included in the nutrient analysis and count toward the limits on calories, saturated fat, sodium and trans fat.

If second helpings or second meals are sold a la carte, they do not contribute toward the components or dietary specifications for reimbursable meals. However, if a school elects to offer second servings of any part of the reimbursable meal without any additional charge, these foods must be counted toward the weekly dietary specifications.  Schools may charge to extra servings.  If a second serving is part of the considered a routine part of the reimbursable meal, the menu production record needs to identify that it is part of the reimbursable meal. 

Additional foods offered to children at no charge who have a reimbursable meal count toward the dietary specifications (calories, sodium, saturated fat, and trans-fat). In addition, if the food items are creditable toward a food component in the school meal pattern, they would also be counted and must fit within the weekly requirements.

A school may offer extra beverages at no charge (except Foods of Minimal Nutritional Value) after POS, but these must be considered when analyzing the calorie, saturated fat, and sodium levels associated with the reimbursable meal. The menu planner must be very cautious not to exceed the maximum calorie limit by offering extra beverages after POS, as milk must still be offered with the reimbursable meal. In addition, full-strength juice offered after POS counts toward the weekly juice limit established for the reimbursable meal (no more than half of the total fruit or half of the vegetable offerings over the week may be in the form of juice). Offering juice after the POS would limit the opportunity to include juice as part of the school meal. It could also discourage students' consumption of fluid milk. Additionally, SFAs are reminded that potable water must be made available at no charge to students in the place where lunch meals are served during the meal service.

It is at the school's discretion to charge for additional servings of meal components. If a school charges for second servings, then they are considered a la carte foods and are not included in the nutrient analysis for the reimbursable school meal. We encourage schools to clearly identify the number of servings that students may take as part of the reimbursable meal.

Schools can easily minimize the impact to the nutrient analysis by modifying the way in which vegetables are offered in the menu. For example, allow students to "choose 0-1" of the food items that would negatively alter the nutrient analysis if chosen as a second or extra, while allowing students to take seconds or extras of those vegetables that do not negatively alter the nutrient analysis if chosen as a second or extra. For example the school could allow the students to "choose 1 or more" of these vegetables. It is important that each school determine how seconds and extras impact their nutrient analysis and plan menus appropriately.

Desserts such as pudding and ice cream are not considered part of the reimbursable meal. If offered, with the meal it must be included in the dietary specifications of the meal (i.e., calories, saturated fat, trans fat and sodium).

Occasional, small quantities of leftover food served on another day will not be counted toward the meal component requirements, including the vegetable subgroups. The State has discretion to determine whether such leftovers are of a reasonable amount and are not occurring on a regular basis. SFAs may also freeze leftovers and serve them first on the serving line, following standard HACCP protocols, the next time that particular item reappears in the menu cycle.

However, if leftovers (such as chef salads) are being offered to students on the serving line as part of the reimbursable meal, they must be included in weighted nutrient analyses and are subject to the weekly dietary specifications. If the school consistently has leftovers to add to each day's menus, schools need to consider participation trends in an effort to provide one reimbursable lunch for each child every day.

Leftovers served to students on the same day as they are initially offered are considered seconds.

The meal pattern requires a variety of vegetables be offered over the school week and does not put any limits on the amount of vegetables (or fruits) children may take. However, to stay under the required calorie, sodium and saturated fat limits, a school may want to limit some vegetable dishes because they must include second servings and extra foods into the nutrient analysis. Therefore, schools should consider the types of foods that students are more likely to select as a second serving and determine how these alter the nutrient analysis.

Multiple Servings and Multiple Serving Lines

The daily minimum requirement applies to fruits, vegetables, grains, meat/meat alternates, and milk (all 5 components) at lunch, and fruits, grains, and milk (all 3 components) at breakfast. For menu planning purposes, all offerings must meet the minimum requirement (be equal to or above that amount).

Example 1: In grades 9-12 the minimum daily grain requirement is 2 oz eq. So, if a student is offered a choice between pizza with 2 oz eq of grain OR a stir fry with a 1 ounce equivalent of grains, only 1

of those offerings meets the 2 ounce minimum. The student would need to have another ounce equivalent offered with the stir fry, such as a side item, in order to meet the daily grains minimum.

A weekly range requirement applies to both the grain and meat/meat alternate components.

For menu planning purposes, SFAs must offer a weekly menu such that the sum of all daily minimum offerings meets at least the weekly minimum requirement. For grades K-5 and 6-8, the daily grains minimum is only 1 oz eq and the weekly grains minimum is 8 oz eq. The offering of the minimum of only 1 oz eq daily would only total 5 oz eq across the week. So, on some days, schools would have to offer more than 1 oz eq of grains as a minimum offering. The same applies to the weekly minimum amount of meat/meat alternate.

Example 2a: If a grade K-5 school offers a 1 oz eq grain item (salad) and a 3 oz eq grain item (pizza) every day (and instructs the student to select one option only), the minimum weekly offering is 5 oz eq grain (1 oz eq x 5 days). This menu would not meet the required weekly minimum of 8 oz eq.

SFAs must also plan their menus so that the sum of the daily maximum offerings for grains and meat/meat alternates is equal to or less than the weekly maximum limit. Therefore, the sum of daily minimums must meet the weekly minimum requirement AND sum of daily maximums must meet the weekly maximum requirement.

Example 2b: If every day a grade 9-12 school offered an item with 3 oz eq of grain (even if other items with lower weights were also options), this would add to a total of a possible 15 oz eq offered over the week (child could select that 3oz grain item every day). This menu would not meet the required weekly maximum of 12 oz eq.

As required in Section 210.10(k)(2), each independent line must meet the daily and weekly requirements (including subgroups), in order to ensure that a child is able to take a reimbursable meal every day in any line they may choose. If the school sets up serving stations, where a student is able to go to several different places to select different components of the meal (e.g., first goes to a salad bar, then goes into a pasta station) before passing the point of service, then all of the stations as a whole must meet the daily component and weekly vegetable subgroup requirements.

Each of the subgroups must be available to all children in at least the minimum amounts during the week. A child should not have to choose one subgroup over another on a day, and lose the opportunity to select the other subgroup that week. If the menu is planned in a way that limits the student's opportunity to select all vegetable subgroups over the week, the school needs to modify the week's menu to prevent such conflict. For example, if the required dark green vegetable subgroup is offered in one food item/entree and the beans/peas subgroup is offered in a different food item/entrée on the same day, and the student can only pick one, the school must provide another opportunity to select either dark green vegetables or beans/peas later in the week in order to prevent a subgroup conflict.


A production record must be completed for each day's menu.  The production record documents the meal prepared then served.  This record indicates whether meals served meet the meal requirements set forth by USDA.  It also serves as a planning tool for the food purchasing and preparation stages of the meal.  Prior to completing a production record, food service staff should plan meals to include all required components and the minimum serving sizes.  With proper planning, schools can complete part of the production record prior to the meal service.  During daily production, the food service staff should record the number of students, number of servings, and the total amount prepared. 

At a minimum, the production record should contain the following information for each daily menu:

  • The menu and date served
  • Foods used to meet requirements including all condiments
  • Total amount of foods prepared
  • Number of meals prepared
  • Number of meals served
  • Portion size
  • Leftovers

If a school is using the offer-versus-serve method, the staff can forecast the quantity of food needed for preparation by determining which menu items most students will pick.  Example:  if a school offers two entrees, a hamburger or a hot dog, and more students choose a hamburger; the school should plan to serve more hamburgers on the menu.  Forecasting popular food items can reduce food costs.  Schools can offer several choices among the required food components.  Based on the number of choices offered students, the food production record may be very simple or very detailed.  Schools may use the production record on page 27 of this chapter.     
A standardized recipe has been tested and is known to produce the same results and yield every time it is used.  It defines the procedures, the equipment, quantity, and quality of ingredients used in a meal.  When serving reimbursable meals, standardized recipes are necessary to produce a sufficient number of servings and the correct serving sizes for required food components.  A standardized recipe can also identify required nutrients. 

USDA provides standardized recipes to assist in the production and planning process.  USDA recipes list serving sizes for each required component, number of servings, nutrients, and critical control points necessary to ensure food safety.  All schools are required to use standardized recipes.

When a school chooses not to use USDA recipes, it must create standardized recipes for food items prepared.  Schools may use the standardized recipe form on page 29 of this chapter.  To ensure proper serving sizes, correct yield, and nutrients, schools must follow the recipes as written, including ingredients, brands, and grade of meat and other food items.   


Rules for FMNV have been replaced with the Smart Snack Requirements.  It is important all that food service staff and school administrators understand the requirements for the Smart Snack rule because the nutrient standards may affect the way SFAs raise funds for the school food service program and other organizations.  Refer to Chapter 8 for requirements for a la carte items, other food sold on campus, and foods sold for fundraisers.


Medical or Special Dietary Needs

According to federal regulations, substitutions must be made to the meal pattern for students who have disabilities that restrict their diet.  Substitutions are not required for students who are not disabled but are unable to consume regular program meals because of medical or other special dietary needs. Refer to USDA-FNS Accommodating Children with Disabilities in the School Meal Programs: Guidance for School Food Professionals (07/25/17, available at, for more information.  

Statement for Children with Disabilities

According to the American with Disabilities Act (1990) the term disability means: A physical impairment that substantially limits one or more major life activities of such individual; a record of such impairment; or being regarded as having such impairment (USDA-FNS Accommodating Children with Disabilities in the School Meal Programs: Guidance for School Food Service Professionals, 07/25/17, available at  If a student's disability is episodic, substantially limits a major life activity, the child must be provided reasonable meal modification(s).  Temporary disabilities must be resolved on a case by case basis.  USDA regulations 7 CFR Part 15(b) require substitutions or modifications of school meals for children whose disabilities restrict their diets. When possible the meal modifications for children should be made within the meal patterns.  A child with a disability must be provided food substitutions that change the meal pattern when a statement signed by a licensed medical professional (who is authorized to write prescriptions in the state of Oklahoma) supports the need.  Meal accommodations that do not change the meal pattern can be made without a statement from a medical professional.

The medical professional's (who is authorized to write prescriptions in the state of Oklahoma) statement must identify:

  • the note should identify the child as being disabled, but should not include the specific diagnosis for the child;
  • information about the child's physical or mental impairment that is sufficient to allow an understanding of how it restricts the child's diet;
  • An explanation of what must be done to accommodate the child's disability;
  •     the food or foods to be omitted from the child's diet, and the food or choice of foods that must be substituted.

Food Allergies
Generally, children with food allergies or intolerances do not have a disability as defined under either Section 504 of the Rehabilitation Act or Part B of IDEA.  The school food service may, but is not required to, make food substitutions for them. However, when the licensed medical professional (who is authorized to write prescriptions in the state of Oklahoma) assessment states food allergies may result in severe and life-threatening (anaphylactic) reactions, the child's condition would meet the definition of "disability," and the substitutions prescribed by the licensed physician must be made.

Other Special Dietary Needs
The school food service may make food substitutions, at their discretion, for individual children who do not have a disability, such determinations are only made on a case-by-case basis.  The accommodations must be made within the meal patterns (see page 2-2).  School Food Authorities (SFA) may request a medical statement for accommodations made for such children, but may not require the statement.  This provision covers those children who have food intolerances or allergies but do not have life-threatening reactions (anaphylactic reactions) when exposed to the food(s) to which they have problems. 

Schools must charge the same price for substituted foods as the regular price meal.  Although substituted foods may cost the foodservice program more, reimbursement rates for substituted meals will be the same reimbursement for each meal per each student by eligibility category. 

For children with disabilities and special dietary needs, the school and food service personnel should work with family members, other school personnel, and medical personnel responsible for the health, and education of individual students to ensure that reasonable accommodations are made to allow participation in the meal service.


Offer Versus Serve
SFAs participating in Offer Versus Serve (OVS) cannot make meal accommodations by asking a child to exclude the food component/item from their meal selection.  Children in SFAs that participate in OVS must have the option to select all food components/items made available to other children.  For more information see USDA-FNS Accommodating Children with Disabilities in the School Meal Programs: Guidance for School Food Professionals (07/25/17, available at and Offer Versus Serve Guidance for the National School Lunch Program and the School Breakfast Program (07/21/15, available at

Religious, Ethnic or Economic Needs      
If a school or RCCI wishes to implement a variation in the food components for religious, ethnic or economic needs, the school must get approval from USDA, Food and Nutrition Service (FNS).  There must be evidence that such variations are nutritionally sound and are necessary to meet religious, ethnic, or economic needs. The sponsor must submit a letter to the SNP unit indicating the substitutions and the reasons for their necessity. The letter is then forwarded to USDA. 
Milk – Substitutions for Non-Medical Reasons

Currently, by regulation, schools must make substitutions for fluid milk for students with a disability when the request is authorized by a licensed physician and may make substitutions for students with medical or other dietary needs if requested by recognized medical authority.  Public Law 108-265 amended the current law to allow schools to substitute non-dairy beverages nutritionally equivalent (as established by the Secretary) to fluid milk for medical or other special dietary needs at the request of a parent/guardian.

SFAs are allowed to accept a written statement from a parent or guardian in lieu of a statement from a recognized medical authority when substituting milk. The supporting statement must identify the student's medical or other special dietary need that precludes cow's milk.  It is the SFAs discretion to select the acceptable substitutes that meet the nutritional standards established by USDA requirements. 

When a nondairy beverages is offered as a fluid milk substitutes, schools must ensure that it is nutritionally equivalent to fluid milk and provide specific levels of calcium, protein, vitamins A and D, magnesium, phosphorus, potassium, riboflavin, and vitamin B-12.

When offering milk substitutes to students who do not rise to the level of disability, the SFA must inform the State agency.  SFAs will pay for substitution expenses that exceed Federal meal reimbursements.


Schools must designate specific serving times for lunch breakfast and snacks.  All meals should be consumed in the dining area unless another area is designated for meal service.  Meals taken out of the designated food service areas, taken home, or eaten at a later time than the designated lunch times cannot be claimed as a reimbursable meal. 

Meals taken on school field trips may be reimbursed only if the meal meets the meal pattern requirements.  On field trips, milk must be available according to the meal pattern requirements, and therefore, must be stored at the proper temperature to ensure safety.  When serving meals away from the food service area, the school staff must take extra steps to ensure sanitation and food safety. 

Family Style Meals

Family style is an offer-versus-serve meal service option that allows children to serve themselves from common platters of food with assistance from supervising adults. Family style meals are often served in independent living programs and RCCIs.  House parents and school staff can use family style meals as an opportunity to educate students about health, wellness and living skills. 

Additionally, SFAs serving preschool children through NSLP and SBP have the option to use family style meal service.  However our office does not recommend offer versus serve for preschool children because it may interfere with nutrition standards.  Schools should use family styles meals to provide a choice in similar foods and a choice in serving sizes. 

When providing family style meals, the following practices must be conducted:

1. Sufficient amount of prepared food must be placed on each table to provide the full

 required portion of each of the food components for all children at the table, and to

 accommodate supervising adult(s) if they eat with the children.

2. During the course of the meal, supervising adults must actively encourage each child  

    to accept service of the full required portion for each food component of the meal pattern.

3. The family style meal service allows children to make choices in selecting foods and the size of the initial servings. Children should initially be offered the full required portion of each meal component.
Flexibility of Meal Patterns for RCCIs

RCCIs are often faced with a challenge of serving different meal patterns to different age/grade groups.  This may be a potential for violence among students at certain types of facilities when they are not served the same portion sized meal.  RCCIs that serve special populations, such as students with severe mental illness or who are at-risk for incarceration, often have legitimate concerns about student unrest at meal times

With State agency approval, RCCIs may serve the National School Lunch Program (NSLP) meal pattern in effect for the highest age/grade group served to all residential students if they candemonstrate 1) operational limitations to separating age/grade groups and 2) canshow legitimate safety concerns if students are served different portions.  See page 35 for form. 

RCCIs must submit a request to the State agency to utilize this flexibility and clearly articulate the safety concerns to the satisfaction of the State.  State agencies must consider RCCI requests to implement this option on a case-by-case basis and ensure that the above criteria are met.  An

approved exception extends additional meal pattern and dietary specification flexibility to RCCIs for both lunch and breakfast.  To request a flexibility extension, complete the Policy Exception Request to Serve One Meal Pattern (page 35) and submit to the State Office for approval. 

Availability of Water

The Healthy, Hunger-Free Kids Act of 2010 (the Act), Public Law 111-296, Section 203, establishes a requirement for making potable water available to children at no charge in the School Breakfast Program (SBP), National School Lunch Program (NSLP); this includes the Afterschool Snack Program.

  • Water must be in the place where meals are served during the meal service or adjacent to the meal service area.  Schools can offer water pitchers and cups on lunch tables, a water fountain, or a faucet that allows students to fill their own bottles or cups with drinking water. Whatever solution is selected, the water must be available without restriction in the location where meals are served. 
  • Students must have sufficient time to use the water fountain during their meal period.  It is important to consider the amount of time it takes students to obtain water, children should not have to wait in long lines. 
  • If schools choose to supply cups at the water fountain to reduce long lines, schools cannot charge for cups.  Schools cannot require children to bring their own cups. 
  • For multiple locations, water must be available in each location.  If meals are served in lunch room, water must be available. 

  • Charges to the food service account for supplying water must be a reasonable cost.  When selecting a method for supply water, it must be efficient and practical.  Water pitchers may be more practical than constructing a water fountain. 
  • If the school is participating in Afterschool Snack Program, water must be available. 
  • Water cannot be flavored.
  • Water cannot be restricted during meal service.  If a child has to raise their hand to get water, that is restricted access. 

Notification of Reimbursable meals and Breakfast Program

All SFAs must provide student notification of reimbursable meals at the beginning of the meal line.  Through the use of meal identification signage, students are instructed on how much food to select from each component daily in order to have a reimbursable meal. State agencies and SFAs may establish requirements to fit their menu, facilities, layout and other considerations. Providing detailed information about the components, such as identifying the vegetable subgroups, is an excellent teaching tool, but is not required.

Additionally, all SFAs participating in the School Breakfast Program must outreach information to all student households in an effort to help more children benefit from the School Breakfast Program.  The goal is to increase participation, especially for those students who might otherwise not eat breakfast.  Notifications should:  go out in information packets at the beginning of the year; be listed in bulletins; and be posted on internet sites. 

In addition to household and public notification, SFAs are required to provide notification of reimbursable meals at the beginning of the serving line.  Food service programs may use posters, marker boards, or any other resource informs students what constitutes a reimbursable meal. 

Although all the foods that are a part of the reimbursable meal do not have to be adjacent to each other, they must be labeled, listed, or otherwise identified near or at the beginning of the serving line, so the students can easily choose all the components for a reimbursable meal. If some of the components of the reimbursable meal (such as the fruits and vegetables) are offered beyond the point of service, the school must ensure that students are aware that every reimbursable meal must include a fruit or a vegetable, and that the total of any fruit or vegetable item selected under OVS must equal at least 1/2 cup.  There must be a system in place to ensure that each reimbursable meal selected by the student under OVS includes a fruit or a vegetable (at least 1/2 cup).

 *All Referenced forms are available upon request.
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