CACFP Roundtable's comment letter re: USDA proposed rule for alignment with dietary guidelines
As you probably already know, USDA published the proposed rule FNS-2022-0043 – “Child
Nutrition Programs: Revisions to Meal Patterns Consistent With the 2020 Dietary Guidelines for Americans in February this year. It's a big rule focused on aligning school meals with the 2020 Dietary Guidelines for Americans. There are several items that impact CACFP as well, and some summer meal service program items. Those specific items are outlined by USDA here.
When USDA publishes a proposed rule, they post it for public comment on regulations.gov. They encourage the community to provide feedback about certain questions but also how these rules might impact you. USDA then analyzes all of the comments - they are required to consider each and every single comment before they finalize the rule. If you have not already submitted your comment, you have two days left to do it, comments are due May 10th. You can do that by following this link and clicking the blue comment button on the top left.
The CACFP Roundtable has come to the conclusion that USDA did not engage in adequate stakeholder feedback or do a full regulatory analysis to understand what these proposed changes would mean for the Child and Adult Care Food Program operators and participants. We also think that now is not the time to make changes to an already overburdened and stressed community. Our main recommendations to USDA are:
USDA engages with CACFP stakeholders and food industry stakeholders who have a CACFP lens, before finalization and implementation of the proposed rule. This must occur in order to understand the actual impact this rule change would have on CACFP operators and stakeholders.
USDA prioritizes policies that will measurably increase equitable access to the program.
USDA creates more opportunities for CACFP programs to be adequately and equitably reimbursed.
You can find our whole letter here, which also addresses the specific items that will impact CACFP. Feel free to use any part of the letter for your own comment. There is also a simple comment form you can use geared toward family child care providers but you can change the text to make it your own.
It's not too late to make your voice heard! Tell USDA your thoughts about these proposed changes.
Join us on May 11 for Food With Early Care Virtual Discussion! You will hear from advocates working along providers to push for impactful and urgent improvements to programs such as WIC and the Child and Adult Care Food Program (CACFP).
It's time to submit your proposal to speak at the 32nd Annual CACFP Conference in Long Beach! Learn more here.