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Five-day Meal Count Reconciliation Update

Nutrition Services Division Management Bulletin
Purpose: Policy, Action Required, Beneficial Information

To: Child and Adult Care Food Program Sponsoring Organizations

Number: NSD-CACFP-03-2013

Attention: Food Program Director

Date: April 2013

Subject: Five-day Meal Count Reconciliation Update

Reference: Title 7, Code of Federal Regulations, sections 226.6(m)(3)(ii) and (4), 226.16(d)(4)(i) and (ii), 226.17(b)(4), 226.18(e); USDA Policy Memorandum CACFP 07-2005; Management Bulletin 05-219, December 2005 Second Interim Rule: Five-day Meal Count Reconciliation; June 2011 Final Rule: Improving Management and Program Integrity; California Department of Education Management Bulletin NSD-CACFP-05-2012

Supersedes: California Department of Education Management Bulletin NSD-CACFP-05-2012

This Management Bulletin (MB) informs Child and Adult Care Food Program (CACFP) sponsoring organizations (SO) that at-risk, afterschool meals programs are also included in the requirement to conduct five-day meal count reconciliations. This MB supersedes MB NSD-CACFP-05-2012, which reviewed requirements and instructions for conducting five-day meal count reconciliations in the CACFP.


On June 13, 2011, the U.S. Department of Agriculture (USDA) issued the final rule for the CACFP: Improving Management and Program Integrity. It reasserts the USDA’s intention that CACFP sponsors include a five-day meal count reconciliation, by participant, when conducting each site monitoring visit. The California Department of Education (CDE) issued MB NSD-CACFP-05-2012 to review requirements and procedures conducting these reviews. The MB incorrectly listed at-risk, afterschool care centers among the programs that did not require five-day meal count reconciliations. 

Review of Instructions for Conducting Five-day Meal Count Reconciliation

For each day examined, reviewers must use enrollment and attendance records to determine the number of participants in care during each meal service and attempt to reconcile those numbers against the numbers of breakfasts, lunches, suppers, and/or snacks recorded in the site’s meal count for that day.

For the at-risk, afterschool component of the CACFP, reviewers must compare the attendance records with meal counts given that enrollment records are not required. Based on that comparison, reviewers must determine whether the meal counts were accurate. If there is a discrepancy between the number of participants enrolled or in attendance on the day of review and prior meal counting patterns, the reviewer must attempt to reconcile the difference and determine whether the establishment of an overclaim is necessary.

The method of reconciliation used is dependent upon the sponsor type and claiming method.

Required Documentation

All SOs must document the five-day meal count reconciliation in their monitoring report. The CDE will not accept a reference to the five-day reconciliation that appears in other documents, files, or records outside of the monitoring report. If SOs continue to omit five-day meal count reconciliations in their site monitoring reports, the CDE will declare the sponsor seriously deficient.

Please note: Five-day meal count reconciliation is not required in outside-school-hours care centers and emergency shelters.

Reference Materials

All items referenced below are located in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS):

Action Required

Please ensure that your site monitoring practices and reports are consistent with USDA requirements and CDE instructions.

If you have questions regarding this MB, please contact the CACFP specialist assigned to your agency. You will find a list of contact information for your specialist in the Download Forms section of the CNIPS.
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