Nutrition Services Division Management Bulletin
|Purpose: Policy, Action Required, Beneficial Information|
Child and Adult Care Food Program
Attention: Food Program Director
Date: August 2010
Subject: Record Retention Requirements for Day Care Home Providers
Reference: United States Department of Agriculture Memo CACFP 03-2009; CACFP Regulations, 7 CFR 226.10(d) and 226.18; CACFP Standard Agreement (NSD 2053A Rev. 7/10)
This Management Bulletin (MB) clarifies the record retention requirements for Day Care Home (DCH) providers within the Child and Adult Care Food Program (CACFP). This MB is in response to the United States Department of Agriculture (USDA) Memo CACFP 03-2009, which clarifies existing requirements set forth in the Code of Federal Regulations, Title 7 Part 226.10(d) and 226.18.
Existing program regulations require DCH providers to retain the following program records:
- Menus and types of foods served to enrolled children at each meal
- Number of meals by type served to enrolled children
- Number of enrolled children served at each meal
- Number of children in attendance
Existing program regulations also require DCH providers to retain these records for the:
- Month(s) in which meals were served but a claim has not yet been submitted
- The federal fiscal year (FFY) in which the last final claim was submitted
- Three FFYs prior to the current FFY
(If a provider submits an adjusted claim that has not been paid, the month covered by the adjusted claim would not be considered the month that the last final claim was submitted.)
For example, if the current month is October 2014, and the provider’s last final claim was submitted for September 2014, the provider should have records for:
- October 2014 (the month in which meals were served but a claim has not yet been submitted)
- October 2013–September 2014 (the FFY the last final claim was submitted)
- October 2010–September 2013 (three prior FFYs)
In the above example, a provider should have records for 49 months.
In another example, if the current month is February 2014 and the provider’s last final claim was submitted for January 2014, the provider should have records for:
- February 2014 (the month in which meals were served but a claim has not yet been submitted)
- October 2013–January 2014 (the FFY the last final claim was submitted)
- October 2010–September 2013 (three FFY’s prior)
In this example, a provider should have records for 41 months.
Providers also need to retain records beyond this time frame if there is an unresolved audit or review finding. Once the audit or review finding has been resolved, the provider is required to maintain the records covered by the audit or review for three years from the date the audit or review finding was resolved.
To minimize storage concerns, providers are only required to have program records on hand for the current month and the previous twelve months. Older records may be stored offsite as long as they are accessible within a reasonable time frame upon request. In addition, a provider may retain the records in hard copy or electronic format, as long as the records are available for review.
A revised sample Standard Agreement Between a Sponsoring Organization and a Day Care Home Provider that includes required record retention requirements may be found on the California Department of Education Web page at http://www.cde.ca.gov/ls/nu/cc/fm.asp.
After October 1, 2010, DCH sponsors should require corrective action of DCH providers that do not have records as of October 1, 2010. For the first offense, the corrective action should require the provider to retain these records for the time period outlined above. The second offense may require the agency to determine the DCH provider seriously deficient for not retaining the required records.
If you have any questions regarding this MB, please contact Josh Michel, Program Analyst, by phone at 916-327-6466 or by e-mail at firstname.lastname@example.org, or Michael Smith, Program Analyst, by phone at 916-323-5755 or by e-mail at email@example.com.