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CACFP At-risk Afterschool Meal for SFAs


Nutrition Services Division Management Bulletin

Purpose: Policy, Action Required, Beneficial Information

Date: May 2014

Number: SNP-21-2014; CACFP-06-2014

To: School Nutrition Program Sponsors

Attention: Food Program Directors

Reference: Title 7, Code of Federal Regulations, sections 210.21, 210.16, 226.6(b) and (b)1, 226.17 a(a), 226.20(o), 226.21, and 226.22; U.S. Department of Agriculture Policy Memos SP 09-2013 and CACFP 04-2013; and SP 17-2012 http://www.fns.usda.gov/cnd/governance/policy.htm

Subject: Streamlining Child and Adult Care Food Program At-risk Afterschool Meal Participation for School Food Authorities

Supersedes: Management Bulletin USDA-CACFP-03-2013; NSD-CACFP-12-2012; NSD-SNP-18-2012


This Management Bulletin (MB) provides updated information on streamlining the requirements for a school food authority (SFA) that is applying to participate, or is already participating, in the Child and Adult Care Food Program (CACFP) At-risk Afterschool Meals.

This MB corrects an error in and supersedes MB USDA-CACFP-03-2013, regarding the monitoring requirement for CACFP At-risk Afterschool Meals. U.S. Department of Agriculture (USDA) Policy Memo CACFP 04-2013 states that SFAs must continue to monitor their at-risk sites, though monitoring requirements of CACFP At-risk Afterschool Meal sites may be aligned with those of the National School Lunch Program (NSLP). The California Department of Education (CDE) interpreted this to mean that the frequency of site visits for CACFP At-risk Afterschool Meals could be the same as the NSLP. This is not correct. SFAs must monitor their At-risk sites three times per year with at least two unannounced site visits. The USDA clarified that “aligned with those of the NSLP” means one of the three CACFP site visits could be conducted on the same day as the NSLP site visit. Therefore, SFAs must correct their monitoring practices to ensure compliance with this corrected policy.

In addition, this MB clarifies that although SFAs may use CACFP reimbursement to pay expenses related to other Child Nutrition Programs (CNP), SFAs are required to separately track revenue and expenses for each program. 

Background

The Healthy, Hunger-Free Kids Act of 2010 authorized the service of afterschool meals for SFAs through the CACFP. The USDA recognizes that schools located in low-income areas that are participating in the NSLP are in an excellent position to offer meals and snacks through their afterschool programs. Although Congress did not authorize the service of at-risk afterschool meals through the NSLP, streamlining the requirements for SFAs participating in the CACFP provides significant relief without compromising the integrity of an SFA’s meal programs.

In November 2012, the USDA announced the streamlining requirements for SFAs applying to participate in, or that already participate in, CACFP At-risk Afterschool Meals.

Agreements

The USDA requires state agencies that administer more than one CNP to enter into a permanent single agreement with SFAs for the operation of any combination of CNPs. Because SFAs participating in the NSLP already have an agreement with the CDE, the CDE can add the CACFP to the SFA’s permanent single agreement and no additional signatures are required from the SFA. However, the SFA must still apply to participate in separate CNPs with the CDE.

Application

SFAs that apply to participate in CACFP At-risk Afterschool Meals are required by Title 7, Code of Federal Regulations (7 CFR), Section 226(b), to provide the following information to the CDE:

The CDE considers successful operation of the NSLP as sufficient evidence of administrative capability and financial viability, and waives the requirement that an SFA submit a separate management plan for serving At-risk Afterschool Meals. SFAs are also not required to submit a separate CACFP budget. The CDE will notify SFAs which forms are required and which portions of the online application are waived during the CACFP application process.

Training

SFAs participating in the NSLP are familiar with operating a federal CNP and therefore, are not required to attend the routine preapproval training by CDE prior to participating in CACFP At-risk Afterschool Meals. SFAs must still take the necessary CACFP mandatory training prior to participation and annually each year thereafter.

In addition, food service staff that receive meal service training from the SFA as a requirement for the NSLP are not required to attend a second meal service training by the SFA for CACFP At-risk Meals. While SFAs are not required to receive the routine preapproval training from the CDE prior to participation in CACFP At-risk After School Meals, the SFA must ensure they train their administrative staff about CACFP requirements and ensure they understand how to implement the CACFP At-risk Afterschool Meals according to federal regulations.

The SFA’s CACFP Program Specialist and the USDA’s At-risk Afterschool Meals Handbook are excellent resources for the SFA when questions arise.

Meal Patterns

CACFP regulations allow SFAs participating in the NSLP to substitute NSLP meal pattern requirements for CACFP meal pattern requirements (7 CFR Section 226.20[o]). This means that SFAs may opt to use either the CACFP or NSLP meal pattern when serving CACFP At-risk Afterschool Meals.

SFAs participating in CACFP At-risk Afterschool Meals may also adopt the use of Offer Versus Serve (OVS) in their meal service using either the CACFP or NSLP meal patterns. However, the use of OVS is not allowed when serving snacks under the CACFP or NSLP.

The CACFP meal pattern consists of four required components (milk, fruit/vegetable, grain/bread, meat/meat alternate). However, because the meal pattern requires two different kinds of fruits and/or vegetables, there are actually five items in the CACFP meal pattern. The table below shows the five items and gives an example of food items that meet the CACFP meal pattern.

Item

Components

Food Item

1

Milk

Milk 1%

2

A serving of a fruit/vegetable

Apple

3

A serving of a different fruit/vegetable

Carrots

4

Grain/bread

Bread

5

Meat/meat alternate

Ham

When SFAs use OVS, children must select three of the five food items. If using the CACFP meal pattern, a child is not required to select a fruit/vegetable.

For example, when using the CACFP meal pattern, a child could select a ham sandwich (Items 4 and 5) and milk (Item 1), but refuse the apple (Item 2) and carrots (Item 3). Unlike the NSLP meal pattern, the CACFP meal pattern does not require a child to select any fruit or vegetable.

While the CACFP meal pattern allows children to potentially select fewer fruits and/or vegetables, the CDE encourages SFAs to make all foods, including fruits and vegetables, as appealing as possible to encourage selection and consumption of a nutrient-rich meal.

Procurement and Contracting Requirements

In order to simplify participation in CACFP At-risk Afterschool Meals, SFAs may follow the NSLP procurement standards found in 7 CFR Section 210.21, instead of the CACFP procurement standards found in 7 CFR Section 226.22. Compliance with the comprehensive NSLP requirements satisfies the CACFP requirements.

Please note that SFAs do not need to separately store food inventories for the various CNPs. As stated earlier, although CACFP reimbursements may be used to pay expenses related to other CNPs, SFAs are required to separately track the revenue and expenses for each program until we receive further instructions from USDA. SFAs must charge indirect costs appropriately to the nonprofit school food service account. For details, please refer to USDA Policy Memorandum SP 41-2011: Indirect Cost Guidance at http://www.fns.usda.gov/sites/default/files/SP41-2011_os.pdf.

SFAs may choose to comply with the NSLP requirements for contracting with food service management companies (FSMC) outlined in 7 CFR Section 210.16, instead of following the CACFP requirements in 7 CFR Section 226.21. However, SFAs should note that if they add CACFP At-risk Afterschool Meals to an existing FSMC contract, this may represent a material change to the FSMC contract, which would require the SFA to rebid the contract. For guidance about material changes, the CDE encourages SFAs to refer to USDA Policy Memorandum SP 17-2012: Procurement Questions and Answers to Assist in the Implementation of the Final Rule titled Nutrition Standards in the National School Lunch and School Breakfast Programs, available on the USDA School Meals Policy Web page at http://www.fns.usda.gov/nslp/policy.

SFAs that contract with FSMCs for some or all aspects of the management of the food service program may allow the FSMC to conduct the same activities for the CACFP that are performed for the NSLP. Please note that SFAs are responsible for conducting the following activities:

Monitoring

SFAs must continue to monitor their at-risk sites three times per year with at least two unannounced site visits. SFAs must adhere to all CACFP monitoring requirements at each visit. Monitors may find that they can save time if they conduct one of the CACFP site visits on the same day when they conduct an NSLP site visit.

With regard to state monitoring, the CDE is required to combine the monitoring of the financial management portion of the CACFP with the NSLP to ease the burden on SFAs and ensure that the complete nonprofit food service is reviewed.

CACFP deficiencies identified through CDE or SFA monitoring must be addressed according to CACFP regulations, including the requirements regarding termination, disqualification, and submission to the CACFP National Disqualified List. Additionally, the CDE must assess and collect overclaims in accordance with CACFP regulations.

Questions

If you are already participating in the CACFP and have questions regarding this updated guidance, please contact the CACFP Specialist assigned to your agency. A contact list of CACFP Specialists is available in the Download Forms section of the Child Nutrition Information and Payment System, Form ID CACFP 01.

If you are not participating in the CACFP and have questions about doing so, please contact Nancy Charpentier, Office Technician, CACFP Unit, by phone at 916-327-2911 or by e-mail at ncharpentier@cde.ca.gov.

Questions:   Nutrition Services Division | 800-952-5609
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