I wanted to let you know that the US Department of Agriculture is proposing healthier meal standards in the Child and Adult Food Program (CACFP).
As many of us are CACFP participants and have day-to-day experience with it, we need to make sure that our voices as child care providers are heard during this rule making process.
As child care providers, we can offer important information to the USDA about what's good in the new rule, what needs improvement, and tips for implementation that will make the CACFP better for kids and child care providers.
What could change?
CACFP’s nutritional standards have not been revised in decades. This rule attempts to increase the variety of fruits, vegetables, and whole grains, while reduce fat and sugar.
Here are two summaries of what could change for infant meals and for children's meals.
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Thank you for taking the time to provide the USDA with valuable input from your point of view as a child care provider. These comments will help make CACFP a better program.
Oregon Child Care Providers Together
Tina Namian, Branch Chief
Policy and Program Development Division
Child Nutrition Programs, USDA
RE: Docket ID FNS-2011-0029
Dear Ms. Namian:
I am a child care provider in Oregon and a member of Oregon Child Care Providers Together (Oregon CCPT), a union affiliated with Council 75 and the American Federation of State, County, and Municipal Employees (AFSCME). Oregon CCPT represents about 3,200 certified and registered family child providers throughout the state.
CACFP is important to me. The program allows me to serve nutritious food and teach kids how to make healthy choices outside of my program.
Based on my day-today experience with CACFP, below are my recommendations:
* Allow the introduction of solid foods consistent with parents’ plans for their infants instead of prescribing the start at six months of age.
* Adopt a clear and concise definition of frying if disallowing the practice for on-site food preparation, such as “deep fat frying i.e. submerging food in hot oil.” Stir frying, sautéing, and searing should be allowed.
* Maintain the current policy of two servings of fruit or vegetables at meals without moving to a requirement for one fruit and one vegetable. Separating the fruit and vegetable components takes away important flexibility and raises cost concerns in certain seasons.
* Adopt the WIC sugar limit for breakfast cereals.
* Children under five should not have flavored milk.
* The specified sugar limits on yogurt and flavored milk served to children over the age of five should be a recommendation and not a requirement.
* Allow flexibility for infants at snack time: formula and cereal or a fruit/vegetable
Too often, kids in my program are not getting good food outside of my program, so I’ll provide snacks and meals that are not reimbursed. I’m concerned that without increasing reimbursement rates or reimbursing additional meals and snacks, I will have to stretch my limited resources even more to comply. I know other providers who have had to drop out of CACFP because of inadequate reimbursements. As USDA considers how to elevate more providers into the best practice recommendations, training and increased reimbursements together are critical.
Implementation of the new rules will require ample lead time, phased-in changes, and grace periods to help ensure that providers have time to be trained, thoroughly learn, and implement the meal pattern standards before they are enforced. USDA should provide two years to comply without risk of being charged with non-compliance. Training materials should be available in English, Spanish, and other languages as needed in advance of implementation. Compliance with the new requirements should be assessed during on-site monitoring reviews, rather than through monthly audits and meal reimbursement deductions. I urge USDA to avoid complexity, creating more record-keeping requirements, and raising the risk of losing much needed reimbursements.
Thank you for the opportunity to share my thoughts about this important program.