Nutrition Services Division
To: Child and Adult Care Food Program Sponsors
Attention: Food Program Director
Date: May 2005
Subject: Training and Monitoring
|Reference: Child and Adult Care Food Program (CACFP) Second Interim Rule: Title 7, Code of Federal Regulations, Part 226, Sections 6(m)(3)(viii), 15(e)(12) and 15(e)(14), 16(d)(2), 16(d)(3), and 16(d)(4)(i)(C), 18(b)(2), 19(b)(6), and 19a(b)(11) for Training; Sections 15(e)(4) and 16(d)(4) for Monitoring. The U.S. Department of Agriculture CACFP Policy Memo 05-03, Second Interim Rule Guidance.|
This Management Bulletin clarifies current program requirements and transmits new requirements for the training of program staff and the monitoring of sponsored facilities. The training requirements apply to all CACFP institutions, whereas the monitoring requirements apply only to CACFP sponsoring organizations (sponsors).
The training requirement has three parts:
- new sites;
- annual training by institutions; and
- annual training by state agencies.
A CACFP institution must train the program staff of a new site (whether the site is a child or adult care center or a family day care home) in the duties and responsibilities of the CACFP prior to the site’s participation in the program. Such training must include record keeping requirements, claim reimbursement procedures, the meal pattern, and monitoring requirements as applicable.
Annual Training by Institutions
A CACFP institution (sponsors, child care centers, adult day care centers, and family day care homes) must train program staff on the CACFP requirements on an annual basis. The training, whether on selected topics or a general overview, should be appropriate to the experience and duties of the staff.
Annual Training by the Nutrition Services Division (NSD)
Appropriate staff from all CACFP institutions must attend the NSD’s annual training on the CACFP. Please refer to Management Bulletin 04-206 regarding mandatory attendance at NSD training.
The monitoring requirement applies only to sponsors of centers, homes, or both. A "sponsor" is defined as an institution that administers the CACFP on behalf of one or more day care homes or two or more centers that have separate physical locations. The term "center" encompasses child care centers, adult day care centers, outside-school-hours centers, at-risk centers, and emergency shelters. (These centers may be owned and operated by the institution or legally and administratively separate from the sponsor except for the operation of the program.) The term "site" applies to both homes and centers approved to participate in the CACFP.
A sponsor must review program operations at each of its sponsored sites at least three times per year (see Review Averaging on page 3). A year is defined as a consecutive twelve-month period that may or may not coincide with the program year of October 1 to September 30. To meet the review requirements, a sponsor must:
- Conduct at least two of the three visits unannounced.
- Ensure that at least one of the unannounced visits includes a meal observation.
- Review all new sites during the first four weeks of their program operation.
- Ensure that no more than six months elapse between visits to each of the sites. (See Review Averaging on page 3 for exceptions).
Note: Sponsors must inform sites (both centers and homes) that unannounced visits are allowable. Furthermore, sponsor, state, and federal representatives may only conduct an unannounced visit to a site during the site’s normal hours of operation and must show photo identification that confirms their employment with the sponsor or the governmental agency.
The Second Interim Rule explicitly states that a sponsor must assess the site’s compliance with the following basic program requirements during each site review:
- Meal pattern
- Meal counts
- Menus and menu records
- Attendance at training (see above)
- Enrollment records (see Management Bulletin 05-205)
In addition, the Second Interim Rule introduces a new review element, the reconciliation of meal counts. A sponsor must reconcile the meal counts at each of its sites for five consecutive days during a current or prior claim month. To do so, a sponsor must use enrollment and attendance records to determine the number of participants in care during each claimed meal service and match those numbers against the claimed breakfasts, lunches, snacks, and suppers in order to ascertain whether the meal counts are accurate or in error. Meal count errors may be grounds for an over-claim and even a declaration of serious deficiency.
Please refer to Management Bulletin 05-205 for a discussion of the new enrollment information requirements for child care centers and homes.
If a sponsor uncovers one or more serious deficiencies during a site review, the next visit to the site must be unannounced. Please observe the guidelines for unannounced visits outlined above. Sponsors of day care homes must follow the serious deficiency process found in Management Bulletin 05-208 in order to declare the day care home provider seriously deficient.
The Second Interim Rule permits sponsors to conduct what is termed “review averaging” in meeting their monitoring requirements. If a sponsor conducts two unannounced visits to one of its sites and finds no serious deficiencies, the sponsor may skip the third visit to the site, provided that it averages three reviews per year for all of its sites, meaning that a sponsor may visit certain sites more than three times a year. If a site is monitored only twice during a review year (per review averaging), the sponsor’s first review of the site in the next review year must occur within nine months of the last review in the prior year. For example, if the sponsor’s last review in the prior year occurred in February, the first review of the site in the next review year must take place by November.
If you have questions, please contact the CACFP specialist assigned to your agency in the Child Nutrition Information Payment System (CNIPS). You will find a list of contact information for specialists in the Download Forms section of the CNIPS. You may also contact the Help Desk by phone at 800-952-5609, option 6.