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Dear USDA,

As a participant on the Child and Adult Care Food Program, I strive every day to give children the nutritious meals and snacks that help them grow strong bodies and minds so they can reach their full potential.

I am submitting my comments on Federal Register Number 0584-AE18 “Child and Adult Care Food Program: Meal Pattern Revisions Related to the Healthy, Hunger-Free Kids Act” as a family child care provider who will be directly affected by the decisions you make in the final rule.

INFANTS

Proposed Revision / My Comment and Explanation
Create two infant age groups (birth-5 months, 6 months – 1st birthday)
Allow service of only breastmilk and/or infant formula through 5 months of age
Introduce additional meal components (1-4 Tbsp. infant cereal or meat/meat alternate AND 1-2 Tbsp. fruit or vegetable) at 6 months of age
Allow providers to receive reimbursement when the mother comes to the day care center or home and directly breastfeeds her infant (under 6 months old) and no additional meal component is provided
Fruit juice and cheese/cheese products do not contribute toward the meal pattern for infants

CHILDREN

Proposed Revision / My Comment and Explanation
A new age group to address the needs of older children ages 13 through 18 years old (note: the meal pattern for 13-18 year olds is the same as 6-12 year olds)
Divide the vegetable and fruit into separate categories (note: lunch and supper would require one fruit and one vegetable)
Require breakfast cereals conform to WIC limits on sugar content and other nutrient requirements (note: the Minnesota Department of Health maintains a list of approved WIC cereals. There are many generic brand cereals on the list)
Requiring at least one serving per day of grains be whole grain‐rich. (note: whole grain-rich means at least 50% whole grain)
Disallowing grain‐based desserts from counting towards the grain component (note: grain-based desserts have not been defined by USDA. They welcome your suggestions).
Allowing a meat or meat alternate to substitute up to one‐half of the required grains at breakfast meals.
Allowing tofu as a meat alternate.
Requiring unflavored whole milk be served to children from their 1st birthday to their 2nd birthday
Require 1 percent or fat‐free milk be
served to children two and older (note: this requirement is already in place)
Requiring flavored milk to be fat‐free only AND either:
(For children under 5)
  1. Not allow flavored milk to be served
  2. Not allow flavored milk with more than 22g of sugar per 8 oz. to be served
(For children 5 and older)
  1. Not allow flavored milk with more than 22g of sugar per 8 oz. to be served, or
  2. Refer to the 22g sugar limit as a “best practice” but allow flavored milk of any sugar content to be served

For yogurt, either:
  1. Not allow yogurt with more than 30g of sugar per 6 oz. to be served, or
  2. Refer to the 30g sugar limit as a “best practice” but allow yogurt of any sugar content to be served

Allowing non‐dairy milk substitutions that are nutritionally equivalent to milk to be served if requested in writing by a child’s parent or guardian (note: the only non-dairy milk substitutes that count and are available in Minnesota are certain brands of soymilk)
Disallowing frying as a way of preparing food onsite. (note: USDA suggested definition of frying is “cooking in added fat or oil” as a definition for frying, but is asking for suggestions on a definition.)
Make water available throughout
the day to all children upon their request (note: this requirement is already in place)
Allow parents or guardians to provide up to one component of the reimbursable meal (at their discretion)

Please include any additional comments you have about what is needed to help support you in serving nutritious meals and snacks to the children in your care.

Thank you for considering these comments.

Sincerely,

(NAME)
Licensed family child care provider since (date)
Participating in the Child and Adult Care Food Program since (date)