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State agency summarizes new USDA memos giving schools more flexibility on milk and local beef

Tennessee Department of School Nutrition · April 15, 2026

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Summary

Senior compliance staff reviewed three USDA memos — SPO 01/2026 (Whole Milk for Healthy Kids Act), SPO 02/2026 (Dietary Guidelines 2025–2030) and SPO 03/2026 (local beef guidance) — and explained new flexibilities for nondairy substitutes at lunch and procurement considerations for local beef.

Rhonda Mead, senior compliance and data manager for the Tennessee Department of School Nutrition, told attendees the agency is implementing guidance from three recent USDA policy memos that affect school meal operations.

"SPO 01/2026, which is Whole Milk for Healthy Kids Act, goes over implementation requirements for the National School Lunch Program," Mead said, noting the memo allows schools to offer whole milk as one of the fluid milk options at lunch and clarifies how nondairy beverages may be offered.

Mead said the new memos require two different types of fluid milk be offered daily and that flavored milk still must not exceed 10 grams of added sugar per fluid ounce. The dietary guidance memo (SPO 02/2026) outlines updated dietary priorities — such as emphasizing nutrient‑dense proteins, vegetables and whole grains — but Mead said those guidelines do not immediately change program meal pattern requirements; any change to meal patterns would require rulemaking and public comment.

The agency also reviewed SPO 03/2026, which provides resources and procurement strategies to incorporate local beef into child nutrition programs. Mead said operators may use informal and formal procurement methods and should ensure product specifications and food‑safety requirements are met when sourcing local beef.

On nondairy substitutes, Mead explained a key change: if an SFA chooses to offer a nutritionally equivalent nondairy beverage to all students at lunch, the district will not need to notify the state agency and students no longer must supply a written request for nondisability reasons. Meal pattern rules for breakfast remain unchanged (for example, 2% milk is not allowed as part of the breakfast meal pattern). For substitutions tied to disability reasons, parents may submit a written statement and non‑equivalent beverages still require a medical statement from a licensed health care professional.

Mead pointed attendees to the nutrient profile in 7 CFR provisions for fluid milk substitutes and offered to follow up with any examples of compliant nondairy products. She urged districts to review current bid documents and procurement contracts to ensure any product choices align with solicitations and specifications.

The compliance overview closed with a reminder to consult the USDA memos (SPO 01/2026, SPO 02/2026, SPO 03/2026) and 7 CFR nutrition tables when adopting nondairy options or local procurement strategies.