In a letter issued to regional and state director of child nutrition programs nationwide, the USDA’s Food & Nutrition Service (FSN) notes that school food authorities (SFAs) will be required to implement Target 2 sodium reduction requirements beginning July 1, 2017, but “SFAs that are working toward compliance with Target 2 but not yet fully in compliance will not incur fiscal action during administrative reviews.”
The letter acknowledges confusion caused by a series of Congressional Appropriation Acts since the passage of the original Healthy Hunger-Free Kids Act of 2010 that prohibited the use of appropriated funds to implement sodium reductions beyond the original step (Target 1) that went into effect for the 2014-2015 school year “until the latest scientific research establishes that the reduction is beneficial for children.”
FNS now says that requirement has been satisfied as the second intermediate sodium reduction step (Target 2) is consistent with conclusions published in The Scientific Report of the 2015 Dietary Guidelines Advisory Committee and the 2015-2020 Dietary Guidelines for Americans, which, the letter says, “confirm that the current scientific research and evidence affirm that sodium reduction is beneficial for children.”
However, the FNS recognizes that the delay in confirming that the requirement needs to be met has caused uncertainty among not only school nutrition programs that didn’t know whether to proceed with implementing Target 2 requirements, but also manufacturers that “require significant lead time to conduct product development that results in acceptable products with lower sodium and product availability” for their K-12 customers.
So, while FNS will still implement the Target 2 requirements for school meals effective July 1 as required by current regulations, and “SFAs are expected to comply with these requirements…State agencies should consider an SFA compliant with the sodium requirements if the SFA meets Target 1 requirements, regardless of whether or not the Target 2 requirements are met.”
As for levying penalties for non-compliance, the letter advises that “State agencies should not reconsider or recertify any SFAs already certified as eligible to receive the 6 cent reimbursement to determine compliance with Target 2. In lieu of assessing fiscal action for not meeting Target 2 requirements, State agencies are encouraged to maintain an open dialogue during the review process and to provide collaborative technical assistance that includes an action plan with reasonable timeframes to achieve and maintain compliance with the dietary specifications for sodium.”