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Age-grade groups:

The NSLP and SBP provide meals for children age two and older (generally, under 21). The meal programs group children according to age-grade and establish meal patterns with minimum portion sizes and servings to help menu planners design meals that are age-appropriate and meet the diverse nutritional needs of school children. Nutrient and calorie requirements are also determined for each age-grade groups. In light of the childhood obesity trend, FNS is concerned that school meals provide age-appropriate portion sizes and promote the development of healthy eating behaviors. We request that the committee recommend age-grade groups that are consistent for all menu planning approaches and reflect the stages of growth and development in children and adolescents.

School grade structures and meal service operations must be considered to ensure that age-grade group recommendations can be successfully implemented. Specifically, in the NSLP, some schools currently use a single age-grade group to plan meals for children and adolescents. The Department is concerned that for lunch meals intended to provide ⅓ of the RDAs without providing excessive calories, this practice may result in meals that fail to meet the nutritional needs of either group. While the same may be true for SBP, where the meals are intended to provide ¼ of the RDAs, FNS recognizes that there are different operational constraints. In the SBP, children typically participate as they arrive at school, rather than by grade level or other service schedule that would be common in lunch. The single age-grade group currently allowed for SBP menu planning is intended to provide flexibility to meet the needs of the SBP foodservice operation. Also of note, many schools have implemented alternative methods of delivering meals to promote student participation, such as Breakfast in the Classroom or Grab-and-Go Breakfasts. FNS requests that the committee consider the potential impacts that age-grade group requirements may have on the unique aspects of NSLP and SBP meal service, operations, and participation.

Nutrient standards:

FNS requests that in addition to the current required nutrients, the IOM committee consider the DGA recommendations to minimize trans fats, as well as the intake recommendations for sodium, cholesterol, and fiber, which currently do not have quantitative standards in the school meal programs. Program operators are currently required to reduce sodium and cholesterol levels and to increase fibers levels. Monitoring these nutrients has been facilitated by the Nutrition Labeling and Education Act requirement that sodium, cholesterol, and fiber amounts be included on food labels and

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