[X] Informational
Action if needed

September 13, 2010

TO: Sponsors of the Child and Adult Care Food Program and Summer Food Service Program

RE: Documentation of Commercially-Prepared Combination Foods for Meal Pattern Requirements (MPR)

The Oregon Department of Education Child Nutrition Programs (ODE CNP) is reissuing guidance for accepting documentation on commercially-prepared combination foods for Meal Pattern Requirements. This information is not new.

ODE CNP Child Nutrition Specialists are encountering findings and issues during administrative reviews and wanted to reinforce this information to help improve success in achieving program compliance.

Sponsors are responsible for maintaining menu documentation that demonstrates compliance with meal pattern requirements. The only acceptable documentation for commercially-prepared combination foods is:

1. The original Child Nutrition (CN) Label from the product packaging; or

2. The original label showing the product meets USDA Standards of Identity; or

3. A signed Manufacturer's Product Analysis Sheet (MPAS) provided by the manufacturer

Note: The manufacturer's product literature, product labels and fact sheets are not a CN Label or a MPAS. Food manufacturers' fact sheets and product labels communicate with Sponsors about how their products may fit into the menu for meals served under USDA's Child Nutrition Programs.

Acceptable documentation is described below:

CN Labels are only available for items that contribute to the meat/meat alternate component and for certain 50-percent juice drinks and juice drink products.

Sponsors are not required to offer commercially-prepared combination foods with CN Labels; however, CN Labeled products state and provide a warranty on the contribution toward the Child Nutrition meal pattern requirements. CN Labeled foods are processed under a Quality Control plan administered by the Agricultural Marketing Service or National Marine Fisheries Service using guidelines provided by USDA.

Products with USDA Standards of Identity are listed in the USDA Food Buying Guide under the following headings: Bean Products, Beef Products, Chicken Products and Turkey Products. They credit for meat/meat alternate only, but are combination foods that do not require an MPAS or CN Label.

When purchasing a commercially-prepared combination food without a CN Label or the original product label showing the product meets USDA Standards of Identity, a sponsor must have a completed and signed MPAS on manufacturers' letterhead that demonstrates how the commercially-prepared combination food contributes to the meal pattern requirements.

Guidance for Reviewing MPAS An acceptable MPAS provides information about the product and shows how the credit is obtained, citing child nutrition program resources and/or regulations.

Sponsors must review the following information on a food item before purchasing, serving, and claiming reimbursement for commercially-prepared combination foods:

1. Review the MPAS to make sure it includes the following information (Child Care Center Sponsors refer to the USDA CACFP Center Manual (Big Red) Chapter 8 page 8.15):

In order for a product to claim a meat/meat alternate contribution, the MPAS must have a visible meat/meat alternate present such as a sausage link, beans, cheese, or peanut butter.

2. Verify that the MPAS proves how the claimed credit was obtained. The manufacturer must indicate how the claimed credit was determined. It is never acceptable for a manufacturer to simply state that the product provides a certain amount of credit for the child nutrition meal pattern. Example: fruit filled pancakes may not provide meat alternate because it is not clear how the product contributes to the meat alternate component.

If you have questions about the MPAS, contact your assigned Child Nutrition Specialist.

Attached is a sample letter to Manufacturer's and a sample form to use when requesting an MPAS. These documents are also posted on the ODE CACFP web page at: http://www.ode.state.or.us/search/results/?id=209 or the ODE SFSP web page at: http://www.ode.state.or.us/search/results/?id=208 as Microsoft Word documents to allow Sponsors to customize the letter.

UDSA has become increasingly aware of misleading and inaccurate information on product fact sheets. USDA encourages Sponsors to review product literature carefully since Sponsors are responsible if menus do not meet meal pattern requirements.

It is important to note that CN Labeled products provide Sponsors with a warranty against administrative review financial assessments when the product is used according to the manufacturer's instructions. A Manufacturer's Product Analysis Sheet does not provide any warranty against administrative review financial assessments.

ODE CNP strongly encourages Sponsors to review the documentation they have on file for commercially-prepared combination foods to verify that the documentation is acceptable and current. ODE CNP Child Nutrition Specialists review this information while conducting administrative reviews.

If you have any questions regarding the information contained in this guidance, please contact your assigned Child Nutrition Specialist.

Sincerely,

Lynne Reinoso

Manager, Community Nutrition

Child Nutrition Programs

Office of the Superintendent