Enhancing Child Nutrition Program Meal Standards
June 2, 2025
The USDA released a memorandum stating that they support and encourage states and school districts to experiment with meals to provide interesting, healthy, and diverse meals. USDA encourages States to implement stronger state-level requirements for child nutrition programs. In particular, USDA encourages States to restrict Ultra-Processed Foods (UPFs), food additives and sugar.
However, USDA does clarify that state agencies cannot withhold federal reimbursement based on state-level requirements.
Why It Matters
This administration’s Make America Healthy Again Commission has had a clear goal of limiting UPFs, food additives, and sugars in the American diet. Through this guidance, USDA is encouraging States to improve meal quality now, as federal policy changes could take an extended amount of time. The CACFP already has best practices for operators to serve diverse meals with a variety of fresh, whole foods and to limited added sugars in creditable meals.
Memo
The goal of the U.S. Department of Agriculture’s (USDA) child nutrition programs is to provide healthy, balanced meals to children. Every day across the Nation, the National School Lunch Program and School Breakfast Program serve around 30 million and 15 million students, respectively. In the summer months, USDA programs offer meals to nearly 4 million children at schools, summer camps, rural pick-up sites, and other approved settings.
As Secretary of Agriculture, Brooke Rollins has emphasized states’ role as innovative collaborators and policy incubators. For too long, the USDA’s school meal programs have been known by the regulations and rules they enforce instead of the flexibilities they provide. Schools should and do have the ability to provide children with interesting, healthy, and diverse meals. Whether it is purchasing from a local farmer or testing out a new recipe, the USDA supports and encourages states and school districts experimenting with the meals they provide.
The USDA maintains meal pattern guidelines to ensure that children are getting a variety of nutrients and are offered all the components of a healthy diet. While meals and snacks served through the child nutrition programs must meet minimum federal nutrition standards, additional state-level standards can further promote children’s health. These stronger state-level standards can address reimbursable school meals as well as the food and beverages sold to students on campus throughout the school day through the competitive food requirements, also known as Smart Snacks in School (Smart Snacks). For example, state standards could require that yogurts served as part of reimbursable school meals and as a Smart Snack include less added sugars than federal guidelines allow. Similarly, while the U.S. Food and Drug Administration (FDA) governs food additives like synthetic dyes, states have the flexibility to require schools to stop serving meals and snacks with these harmful additives ahead of the planned phase-out directed by FDA1. Other examples of state standards include limiting the sale of ultra-processed foods, further limiting how often juices can be served in place of whole fruits, and implementing a minimum amount of time children must be given to eat their meal.
As a reminder, meals and snacks offered through the child nutrition programs may be claimed for federal reimbursement if they meet the federal nutrition requirements and other federal regulations. State agencies may not withhold federal reimbursement for meals that meet the federal requirements, even if additional state requirements are not met. However, if a state provides an additional reimbursement above the federal reimbursement, they may withhold the state reimbursement.
USDA encourages states to take this opportunity to implement innovative ideas that support healthy choices and healthy outcomes for our nation's children. In developing these ideas, states also are encouraged to work with local partners to pursue policies that best serve their communities and enhance the health of children. States are invited to share their creative ideas with their Food and Nutrition Service (FNS) regional office, as they could become the model for other states and USDA.
Read the full memo, Enhancing Child Nutrition Program Meal Standards (SP-1-2025).