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At-Risk, Afterschool Meals Component Q and A


Nutrition Services Division Management Bulletin
Purpose: Beneficial Information

To: Child and Adult Care Food Program, All Child Care Agencies

Number: USDA-CACFP-11-2012

Attention: Food Program Director

Date: May 2012

Subject: At-risk, Afterschool Meals Component of the Child and Adult Care Food Program, Questions and Answers

Reference: The Healthy, Hunger-Free Kids Act of 2010, Public Law 111-296; U.S. Department of  Agriculture Policy Memo CACFP 08-2012; California Department of Education Management Bulletins USDA-CACFP-01-2011 and USDA-CACFP-02-2011

Supersedes: California Department of Education Management Bulletins 00-100 and 03-219

This Management Bulletin (MB) provides additional information to the Child and Adult Care Food Program (CACFP) agencies regarding the expansion of the at-risk, afterschool program to include the availability of meal reimbursement.

Background

The California Department of Education (CDE) announced the expansion of the at-risk, afterschool program in MB USDA-CACFP-02-2011, dated January 2011. The CDE announced the availability of an at-risk, afterschool program handbook, published by the U.S. Department of Agriculture (USDA), in MB USDA-CACFP-01-2011, dated July 2011. The following questions and answers were provided by the USDA in Policy Memo CACFP 08-2012 and consolidate and update previous guidance issued regarding the at-risk, afterschool meal program.

Eligible Programs
  1. Q: What are the basic eligibility criteria for at-risk, afterschool programs?

    A: To participate in the at-risk, afterschool meals component of the CACFP, a public or private nonprofit organization (including a school) must operate an afterschool program organized primarily to provide care for children after school hours or on weekends, holidays, or school vacations during the regular school year. The afterschool program must also:
    • Provide children with regularly scheduled activities in an organized, structured, and supervised environment
    • Include education or enrichment activities
    • Be located in a geographical area served by a school in which 50 percent or more of the children enrolled are eligible for free or reduced-price school meals [Title 7, Code of Federal Regulation (7 CFR) Section 226.17a(b)]

    Additionally, although federal law does not require afterschool programs to be licensed, they must meet state or local health and safety standards in order to participate. [See Question A-14 for information on for-profit eligibility.]
  2. Q: Are there any afterschool programs that may not be approved?
    A: Yes. Organized athletic programs engaged in interscholastic or community level competitive sports only (for example, youth sports leagues such as “Babe Ruth” and “Pop Warner” sports leagues, community soccer and football leagues, area swim teams, etc.) may not be approved. However, afterschool programs that include supervised athletic activity may participate provided that they are “open to all” and do not limit membership for reasons other than space or security or, where applicable, licensing requirements. For example, an afterschool police athletic league program that uses sports and recreational activities to provide constructive opportunities for community youth could be approved to participate [7 CFR Section 226.17a(b)].
  3. Q: Does the “open to all” criterion apply to programs other than interscholastic sports programs?
    A: No. Afterschool programs designed to accommodate special needs, or that have other limiting factors, may be eligible to participate. They may include, but are not limited to, programs targeted to children who have learning disabilities or programs for children who are academically gifted.
  4. Q: Do at-risk, afterschool programs have to be drop-in or can enrolled programs also participate?
    A: At-risk, afterschool programs may be either drop-in or enrolled.
  5. Q: Can an at-risk, afterschool program charge “tuition,” similar to a regular child care facility?
    A: Similar to non-pricing child care centers, there may be a fee for the care provided or a “tuition” charge, but there can be no separate charge for the food service. Although the regulations do not specifically prohibit or specifically authorize tuition charges, should the state agency encounter a situation where a substantial participation fee is being charged that might adversely affect the ability of needy children to participate, the state agency should consult with their regional office prior to approving participation.
  6. Q: Does an at-risk, afterschool program have to be open to the full age range up to eighteen?
    A: No. There is no requirement that each facility must serve the full age range of eligible children. For example, a program could operate at a high school and serve only high school age students.
  7. Q: Is licensing required for an at-risk, afterschool program?
    A: Eligible afterschool programs do not need to be licensed in order to participate unless there is a state or local requirement for licensing. If there is no state or local requirement for licensing, then afterschool programs must meet state or local health and safety standards. Organizations should check with their state and local health departments to determine the requirements they must meet to operate an afterschool program in their community. Existing afterschool programs that have not had a meal service as part of their program in the past should also check with state and local health department officials to determine whether any additional requirements apply as a result of the service of an afterschool meal or snack [7 CFR Section 226.6(d)].
  8. Q: If the state or locality does not require licensing for afterschool centers and has no existing health and safety standards for afterschool centers, can organizations still participate in the program?
    A: No. Meeting state and local health and safety standards is a requirement for participation. In the absence of state or local health and safety standards, state agencies are encouraged to work with the appropriate state and local officials to create such standards.
  9. Q: Can a traditional child care center already participating in the CACFP qualify for at-risk, afterschool meal and snack reimbursements?
    A: Yes. A child care center located in the attendance area of a school in which at least 50 percent of the enrolled children are eligible for free or reduced-price meals may qualify for the CACFP at-risk afterschool reimbursements for free meals and snacks served to children who attend the center after their school day has ended. Children who do not attend school would continue to participate in the traditional CACFP meal service provided by the center.
  10. Q: Are programs that operate on weekends eligible for reimbursement?
    A: Meals and snacks may be reimbursed if they are served on weekends or holidays, including vacation periods (e.g., spring break), during the regular school year only [7 CFR Section 226.17a(b)].
  11. Q: Are programs that operate during summer vacation eligible for reimbursement?
    A: At-risk afterschool meals and snacks may not be reimbursed during summer vacation. Organizations that wish to operate programs during the summer when school is not in session may be eligible to receive reimbursement for meals and snacks through the Summer Food Service Program (SFSP). In areas where schools operate on a year-round basis (i.e., the regularly scheduled school year is year-round), afterschool programs may receive reimbursement for at-risk meals and snacks through the CACFP all year if these programs are set up to serve children attending the year-round schools [7 CFR Section 226.17a(b)i].
  12. Q: Are there any restrictions on afterschool programs switching from the CACFP at-risk during the school year to SFSP during the summer when school is not in session?
    A: Yes, there are restrictions. Question 10 applies to an organization that serves meals and/or snacks to children only through the at-risk afterschool meals component of the CACFP during the school year. Such an organization could serve meals to all children through age eighteen under the SFSP during the summer months, subject to approval of their SFSP application by the state agency.

    However, a traditional child care center that also serves at-risk afterschool meals and/or snacks (i.e., the center has enrolled preschool children in care during the day, but also serves at-risk afterschool meals and/or snacks to school-age children) must comply with the Food and Nutrition Service (FNS) Instruction 782-4, rev. 3. This instruction states that traditional child care centers may only claim some or all of their meals under the SFSP during the summer when there is a substantial change in program activities or a significant increase in enrollment. Institutions approved to participate in both the CACFP and the SFSP must ensure that the same children are not served meals in both programs, and separate records must be kept for each program.

    Generally, institutions may not establish separate entities using separate tax identification numbers to serve the same children under different child nutrition programs in order to avoid the program restrictions or to earn higher reimbursement. However, if there is a legitimate need for a separate organization and it meets the requirements in the preceding paragraph, then it may be approved to participate in the SFSP if it meets the SFSP eligibility criteria.

    If a traditional child care center did not substantially change its activities or significantly increase its enrollment during the summer months, it could only receive reimbursement through the SFSP for meals served to children who participate in the afterschool program during the school year. Such a center would receive free, reduced-price, and paid reimbursement through the CACFP for all other children enrolled for care (through the age of 12). Per FNS Instruction 782-4, rev. 3, the determination to either approve the institution for participation in both the CACFP and the SFSP or solely for the CACFP should be based on the institution’s program objectives.

  13. Q: What are the differences between outside-school-hours care centers (OSHCC’s) and at-risk, afterschool care centers in the CACFP?

    Requirement OSHCC’s At-risk, Afterschool Centers
    Eligible Institutions

    Public, private nonprofit, or qualifying for-profit centers
    [7 CFR Section 226.19(a)]

    Public, private nonprofit, or qualifying for-profit centers
    [7 CFR Section 226.17a(a)]

    Licensing

    Licensing not required unless there is a state or local requirement for licensing. If there is no state or local requirement for licensing, then centers must meet state or local health and safety standards
    [7 CFR Section 226.6(d)]

    Licensing not required unless there is a state or local requirement for licensing. If there is no state or local requirement for licensing, then centers must meet state or local health and safety standards
    [7 CFR Section 226.6(d)]

    Determination of Reimbursement

    Program may operate in any area. Individual free and reduced-price applications are collected to determine level of reimbursement (free, reduced-price, and paid)
    [7 CFR Section 226.19(b)(7)(i)]

    Program must be located in a geographic area served by a school in which 50 percent or more of the children enrolled are eligible for free or reduced-price meals. All meals and snacks are reimbursed at the free rate
    [7 CFR Section 226.17a(i)]

    Age of Participants

    Twelve years of age and under, children age fifteen and under who are children of migrant workers, and persons of any age who meet the definition of "Persons with disabilities"
    [7 CFR Section 226.19(b)(3)]

    School-age children through age eighteen (or nineteen if the individual turns nineteen during the school year) and persons of any age who meet the definition of "Persons with disabilities"
    [7 CFR Section 226.17a(c)]

    Type of Meals Eligible for Reimbursement

    Breakfast, snack, and supper. Lunch may be served during school vacations during the regular school year
    [7 CFR Section 226.19(b)(4)]

    Snack and supper. Breakfast or lunch may be served in lieu of supper on weekends, holidays, or during school vacations during the regular school year
    [7 CFR Section 226.17a(k)]

    Number of Reimbursable Meals

    Maximum of two meals and one snack or two snacks and one meal per child per day
    [7 CFR Section 226.19(b)(5)]

    Maximum of one snack and one meal per child per day
    [7 CFR Section 226.17a(k)]

    Meal Patterns

    CACFP meal patterns
    [7 CFR Section 226.20(c)]

    CACFP meal patterns
    [7 CFR Section 226.20(c)]

    Meal Service Periods

    School days, weekends, and holidays; no weekend-only programs
    [7 CFR Section 226.19(b)(4)]

    School days, weekends, and holidays during the regular school year
    [7 CFR Section 226.17a(b)]

    Time Restrictions for Meal Service None

    Meals must be served after school, except on weekends and holidays, when meals may be served at any time of day, as approved by the state agency
    [7 CFR Section 226.17a(m)]

  14. Q: Are for-profit centers eligible to receive reimbursement for at-risk, afterschool meals?
    A: Yes. For-profit centers may receive reimbursement for at-risk afterschool meals if they:
    • Meet all at-risk afterschool eligibility requirements (see Question A1); and
    • Are eligible to receive reimbursement as a for-profit center through the traditional child care component of the CACFP [7 CFR Section 226.17a(a)(2)(ii)]

    Therefore, if a for-profit child care center meets the criteria set forth in the regulations (7 CFR Section 226.2), it may also receive reimbursement for afterschool meals through the CACFP if it operates an afterschool care program. To be eligible for the CACFP reimbursement, 25 percent of the children in the traditional child care component (enrolled or licensed capacity, whichever is less) must be eligible for free or reduced-priced meals or eligible for compensation under Title XX of the Social Security Act. Children who only participate in the at-risk component may not be considered in calculating the 25 percent of children in care. In addition, in order to claim reimbursement in any calendar month, the center must meet the 25 percent criterion in that month.

    In determining a for-profit center’s eligibility for afterschool meal and/or snack reimbursement, only the enrollment/licensed capacity of the traditional child care component of the center should be considered in calculating whether the center meets the 25 percent criterion. For example, a for-profit child care center has 32 preschool children enrolled for care and also operates an afterschool care program for school-age children. The center would be able to claim reimbursement through the CACFP for meals served under the traditional child care component and for afterschool snacks and meals served to school-age children participating in the afterschool program in any month in which at least 8 of the 32 pre-school children are Title XX recipients or are eligible for free or reduced-price meals [7 CFR Section 226.17a(a)].
  15. Q: Can a school system participating in both the School Breakfast Program (SBP)/National School Lunch Program (NSLP) and the at-risk component of the CACFP receive reimbursement under the CACFP for a meal and snack served to children who also received breakfast and lunch under the SBP/NLSP?
    A: Yes. Based on the nature of the at-risk afterschool meals component of the CACFP, the expectation is that most of the participating children attend school and receive free or reduced-price meals. With that in mind, schools that serve children meals through the NSLP are eligible for reimbursement for a meal and a snack served to children in an at-risk afterschool program through the CACFP. However, schools may not serve children an afterschool snack through the NSLP and then serve those same children an additional snack through the CACFP.
  16. Q: Can extended day schools participate in the at-risk, afterschool component?
    A: A school operating longer than the traditional school day may be eligible for afterschool snack reimbursement through the NSLP or the CACFP, provided that it operates a school day that is at least one hour longer than the minimum number of school day hours required for the comparable grade levels by the local educational agency in which the school is located.
  17. Q: Are there policies in place to streamline participation for School Food Authorities (SFAs)?
    A: Yes, the following policies are in place in an effort to streamline participation of the SFAs in the at-risk component of the CACFP:
    • SFAs that are already successfully operating the NSLP do not need to submit a separate CACFP management plan.
    • State agencies that administer the NSLP and the CACFP are required to enter into a single agreement with the SFAs with respect to the operation of any combination of the Child Nutrition Programs (CNPs). Therefore, an addendum to the existing agreement is sufficient for the SFAs interested in participating in the at-risk afterschool meals component of the CACFP.
    • State agencies may consider requests to align the monitoring requirements of the CACFP at-risk afterschool meal sites with those of the NSLP.
    • SFAs may choose to use the NSLP and the SBP meal pattern or the CACFP meal pattern.
    • Schools that participate as at-risk afterschool care centers in the CACFP do not have to meet any additional health and safety requirements. Participation in the NSLP or the SBP requires a health and safety inspection. Therefore, participation in the NSLP or the SBP is proof of meeting health and safety requirements for the CACFP [USDA Policy Memo CACFP 08-2008 Streamlining At-risk, Afterschool Meal Participation for School Food Authorities Currently Participation in the National School Lunch Program, June 6, 2008].
  18. Q: Can Residential Child Care Institutions (like juvenile justice facilities or boarding schools) in which all children are eligible for free meals be eligible for three meals and two snacks per day if they enroll in both the NSLP (breakfast, lunch, and snack) and the CACFP (supper and snack)?
    A: Generally, programs that serve only residential children (with the exception of homeless shelters) are not eligible to participate in the CACFP. However, a residential facility may be eligible to serve at-risk afterschool meals if it has nonresidential care programs and these programs offer afterschool education and enrichment programs for nonresidential children [7 CFR Section 226.2 definitions; At-risk afterschool care center].
  19. Q: Must an afterschool program receiving reimbursement for afterschool meals "manage" the day-to-day activities of the afterschool care program?
    A: No. An institution may contract with another organization to provide enrichment or educational activities for the afterschool program. However, the sponsor or independent center must retain administrative and fiscal responsibility for the meal service. Furthermore, the sponsor or independent center must be the party that enters into the agreement with the state agency and must assume responsibility for meeting all meal service requirements, including ensuring that meals are served in eligible sites.
  20. Q: Must the educational and enrichment activities offered by a non-profit afterschool program be provided by non-profit entities?
    A: No. For-profit entities may provide the educational or enrichment activities for non-profit afterschool programs participating in the at-risk afterschool meals component of the CACFP as a non-profit entity.
Area Eligibility For Reimbursement Purposes
  1. Q: How does an at-risk, afterschool site qualify as area eligible?
    A: An at-risk afterschool site qualifies as area eligible if it is located in the attendance area of a public school (i.e., elementary, middle, or high school) at which at least 50 percent of the students are eligible for free or reduced-price meals [7 CFR  Section 226.17a(i)].
  2. Q: May afterschool programs use private or charter school free and reduced-price enrollment data to qualify as area eligible?
    A: If an afterschool program site is located in a private or charter school, then that site may use the free and reduced-price enrollment data for that private or charter school, or free and reduced-price enrollment data for the public school in whose attendance area the private or charter school is located, to qualify as an area eligible site. However, since most private and charter schools do not have defined attendance areas, an afterschool program may not use private or charter school free and reduced-price enrollment data for purposes of determining area eligibility unless the afterschool program is actually located in the private or charter school.
  3. Q: How should organizations operating at-risk afterschool care programs obtain free and reduced-price school enrollment data?
    A: These organizations should contact the state agency that administers the CACFP. The state agency receives free and reduced-price enrollment data on an annual basis from the state agency that administers the NSLP. Section 210.19(f) of the NSLP regulations requires each state agency that administers the NSLP to annually provide to the CACFP state agency a list of all public schools in the state in which 50 percent or more of the enrolled children have been determined eligible for free or reduced-price meals [7 CFR Section 226.17a(i); USDA Policy Memo CACFP 5-2011, Area Eligibility for Family Day Care Homes, December 22, 2010].
  4. Q: Can school district wide data be used to establish area eligibility or must data from individual school buildings be used?
    A: Only data from the appropriate individual school may be used to establish a site’s area eligibility [7 CFR Section 226.17a(i)].
  5. Q: If a school district has mandated busing of students, can free and reduced-price school data be used to determine a site’s area eligibility?
    A: Yes. If an at-risk afterschool care program is located in an area that has mandated busing of students, site eligibility based on school data may be determined using one of two methods. The program sponsor may determine eligibility based on the enrollment/attendance data obtained for:
    • The school the children attend and are bused to, or
    • The school the children would have attended were it not for the school’s busing policy (the neighborhood school where the children live)
    Area eligibility may be determined as described above only if the SFA is able to document the percentage of children eligible for free and reduced-price meals at each school before and after students are reassigned. The same method of determining site eligibility must be used for all sites participating under that program sponsor to avoid duplicate counting [USDA Policy Memo CACFP 02-2011, Effects of Busing on Area Eligibility in Child and Adult Care Food Program, December 6, 2010].
  6. Q: If schools have unassigned attendance areas (i.e., parents can choose where to send their children from among several schools), what data should be used to determine a site’s area eligibility?
    A: In school districts with unassigned school attendance areas, at-risk afterschool care programs located in school buildings should use the free and reduced-price enrollment data from that particular school for purposes of determining area eligibility. The USDA will work with state agencies on a case-by-case basis to determine the area eligibility of at-risk afterschool care programs operating in non-school sites in areas with unassigned attendance areas. State agencies should contact their FNS regional office if they encounter this situation.
  7. Q: If area eligibility was determined by a school that closes, may census data be used instead?
    A: Census data may not be used to establish area eligibility for the at-risk afterschool component of the CACFP. The CACFP regulations require that, except for emergency shelters, at-risk afterschool programs must be located in the attendance area of a public school (an elementary, middle, or high school) where at least 50 percent of the students are eligible for free or reduced-price meals under the NSLP [7 CFR Section 226.17a(i)].
  8. Q: Is there a particular month of school data that must be used?
    A: Under the CACFP, the NSLP data collected in the most current October, or another month selected by the NSLP state agency, must be used to establish a site as area eligible. For example, if a site applies for area eligibility in August 2011, the most current October data would be October 2010. If a site applies for area eligibility in December 2011, the most current October data would be October 2011 [7 CFR Section 226.17a(i)2].
  9. Q: How long is a determination of a site’s area eligibility valid?
    A: A site’s area eligibility determination made under the CACFP is valid for five years. The state agency may determine the date in the fifth year in which the next five-year cycle of area eligibility will begin  [7 CFR Section 226.17a(i)3].
  10. Q: Do emergency shelters have to prove that they are located in a low-income area to participate?
    A: Emergency shelters that operate afterschool programs with education or enrichment activities for homeless children and youth during the school year may participate without regard to location [7 CFR Section 226.2  Definitions]. Emergency shelters may only claim a total of three meals or two meals and one snack, per child per day.
  11. Q: I run an afterschool program that is not in an eligible area, but 50 percent of the children I serve receive free and reduced-price school meals? Is my center eligible to participate in the program?
    A: No. The CACFP regulations require that, except for emergency shelters, at-risk, afterschool programs must be located in an eligible area to participate. There is no alternate method, such as relying on census data or individual income eligibility, to determine area eligibility.
Applications/Agreements
  1. Q: How do interested schools and organizations participate in these programs?
    A: The state agency must establish application procedures for interested organizations. At a minimum, the application must enable the state agency to determine whether the eligibility criteria for the CACFP are met. Additionally, the application must identify all at-risk afterschool program sites and provide documentation of the attendance area within which the applicant sites are located. If an institution is approved, it must enter into a permanent agreement with the state agency that specifies the terms and conditions of participation. An addendum to the existing agreement is sufficient for the SFAs interested in participating in the at-risk afterschool meals component of the CACFP if the NSLP and the CACFP are administered by the same state agency (see question A-17) [7 CFR Section 226.17a(e)(2)].
  2. Q: For a school or organization that is already participating in the CACFP and now wants to provide at-risk afterschool meals and/or snacks, does its agreement with the state agency need to be amended?
    A: Yes. Once the state agency approves an institution’s application to provide at-risk afterschool meals and/or snacks, the agreement with the state agency needs to be amended to reflect this additional meal service and its requirements. This can be accomplished by signing a simple addendum to the CACFP or the NSLP agreement.
Reimbursement and Recordkeeping
  1. Q: What are the reimbursement rates for the CACFP at-risk afterschool meals and snacks?
    A: All meals and snacks are reimbursed at the free rate. The reimbursement rates are adjusted annually every July 1. Current reimbursement rates are available at the USDA CACFP Web page at http://www.fns.usda.gov/cacfp/child-and-adult-care-food-program-cacfp.
  2. Q: How does a child care center that uses claiming percentages or blended rates claim free meals and/or snacks for its at-risk afterschool meals component in the CACFP?
    A: All organizations participating in the at-risk afterschool meals component of the CACFP must submit separate meal counts for the at-risk afterschool meals program. This includes child care centers that are currently participating in the CACFP and using claiming percentages or blended rates. State agencies are responsible for amending their reimbursement forms and payment systems to recognize a separate entry for at-risk afterschool meals and snacks.
  3. Q: What records are required to receive reimbursement for meals and snacks served?
    A: In the at-risk, afterschool component of the CACFP, the following records must be maintained:
    • Daily attendance rosters, sign-in sheets, or with the state agency approval, other methods which result in accurate recording of daily attendance
    • Records of the number of snacks and/or meals prepared or delivered for each meal service
    • The number of at-risk, afterschool snacks and/or meals served to participating children for each meal service
    • Menus for each at-risk, afterschool snack and meal service [7 CFR Section 226.17a(o)]
  4. Q: Are point-of-service meal counts and production records required?
    A: Point-of-service meal counts are required in California’s at-risk, afterschool component of the CACFP to ensure accurate meal count records are maintained. Production records are not required for sites operating the at-risk, afterschool meal program. Documentation of compliance with the meal pattern and records of all necessary, reasonable, and allowable costs, including food are required under the CACFP [7 CFR Section 226.17a(o)].
Eligible Children
  1. Q: Are at-risk, afterschool meal and snack reimbursements restricted to children ages thirteen through eighteen?
    A: No. Reimbursement may be claimed for meals and snacks served to all children through the age of eighteen in eligible afterschool programs. Reimbursement also may be claimed for those children who turn age nineteen during the school year [7 CFR Section 226.17a(c)].

    Additionally, states may not restrict participation in the at-risk, afterschool meals component of the CACFP to children of a certain age. However, individual afterschool programs may limit the ages of the children they serve. [See Question A-6.]
  2. Q: Are at-risk afterschool programs eligible to receive reimbursement for meals and snacks served to pre-primary children?
    A: Meals and snacks served to children who are attending classes of pre-primary grade in a school (for example, Head Start or Even Start) and who are participating in an eligible afterschool program after their regularly scheduled school program may be claimed for reimbursement. For example, serving lunch and an afternoon snack to children after half-day kindergarten or a half-day Head Start Program is allowable because their school day has ended.
Meal Service Requirements
  1. Q: Must a certain amount of time elapse between meal services when schools or organizations operate other nutrition programs in addition to the at-risk, afterschool meals component of the CACFP?
    A: There are no time restrictions for meal or snack service. In California, at least two hours must elapse between a meal service and a snack service. Organizations may request a waiver to this requirement from their assigned Program Specialist.
  2. Q: Is there any length of time tied into the conclusion of school and the service of a meal or snack?
    A: No. There is no federally mandated time limit between the end of school and service of the meal or snack.
  3. Q: Is there a particular time of day that the CACFP at-risk afterschool programs must serve meals and snacks on weekends and holidays?
    A: No. Although meals and snacks served on weekdays when school is in session must be served after the child’s school day has ended, meals and snacks served through the at-risk afterschool component of the CACFP on weekends or holidays may be served at any time of day with state agency approval [7 CFR Section 226.17a(m)].
  4. Q: If an afterschool program serves both a supper and snack under the CACFP, does the snack need to be served before the supper?
    A: No. We recognize some children, especially those who have eaten lunch early in the day, arrive at the center hungry and ready to eat a full meal. In such cases, it may be more appropriate to serve an early supper and then serve a snack later in the evening.
  5. Q: Are afterschool programs permitted to serve two snacks instead of one meal and one snack?
    A: The Richard B. Russell National School Lunch Act clearly states that institutions participating in the at-risk afterschool meals component of the CACFP may be reimbursed for only one meal and one snack. However, because serving an additional snack in lieu of a meal would not exceed the maximum meal benefit allowed by law and therefore would not increase cost to the program, state agencies are authorized to waive this requirement on a case-by-case basis and allow institutions to serve two snacks instead of one meal and one snack. This will allow state agencies to provide additional flexibility to institutions that may not have the capacity to serve a full meal. We strongly encourage institutions to provide a full meal whenever possible in order to meet the nutritional needs of the children served.
  6. Q: Is there an offer-versus-serve (OVS) option for at-risk, afterschool meals and snacks?
    A: OVS is available only to schools or facilities sponsored by or receiving meals from schools, but may not be used for snacks [USDA Policy Memo CACFP 23-2011, Clarification on the Substitution of NSLP Meals and the Use of Offer Versus Serve and Family Style Meal Service, May 17, 2011]. However, family style meal service is an option available to all CACFP institutions.
  7. Q: May USDA Foods be used for at-risk, afterschool meals and snacks?
    A: Yes. Afterschool programs may use the USDA Foods in their afterschool snack and/or meal service. Please note, however, that the school or institution will not earn additional entitlement foods as a result of serving afterschool snacks. The amount of entitlement foods earned will continue to be based solely upon the number of lunches or suppers served to children.
  8. Q: When an at-risk, afterschool program operates during the week and on weekends, do the weekday and weekend meal service times need to be the same?
    A: No. Meals and snacks served through the CACFP on weekends or holidays may be served at any time of day as approved by the state agency.
  9. Q: May two different fruits or vegetables be used to make up one meal component?
    A: Yes. Two different fruits and/or vegetables may be served, but they only meet the requirement of one component. Therefore, at snack another component must be served with the fruits and vegetables. For example, celery stalks, carrot sticks, and peanut butter could be a reimbursable snack. However, celery sticks and carrot sticks alone would not.
  10. Q: Must institutions participating in multiple CNPs (for example, NSLP, CACFP, and SFSP) keep their food inventories separate?
    A: There is no federal requirement that food inventories used for the various CNPs be stored separately. However, accurate records must be maintained for the individual programs, including allocation of food costs between multiple programs.
  11. Q: May all meals be served cold? Is there any requirement for a certain number of hot meals?
    A: There is no federal requirement that any meals be served hot. All requirements for meals are outlined in 7 CFR Section 226.20. It is possible to meet the meal pattern requirements without serving hot meals.
  12. Q: Are there any resources available to assist in menu planning?
    A: Yes. The Healthy Meals Resource System (HMRS) is an online information center for USDA Child Nutrition that provides several menu planning tools including; food buying guides, calculators, cycle menus, and recipes. You may access the HMRS on the at the USDA HMRS Web site at http://healthymeals.nal.usda.gov. Other resources are available on the USDA FNS Team Nutrition Web Site at http://teamnutrition.usda.gov.
Monitoring
  1. Q: What are the monitoring requirements for sponsors receiving reimbursement for snacks and/or meals in at-risk afterschool programs?
    A: Sponsors of sites participating in the at-risk, afterschool meals component of the CACFP must review their sites at least three times each year. At least two of the three reviews must be unannounced; and one of the unannounced reviews must include observation of a meal service. The timing of the unannounced reviews must be varied so that they are unpredictable to the sponsored facilities. Also, at least one of these reviews must be made during each site’s first four weeks of program operations, and not more than six months may elapse between reviews [7 CFR Section 226.16(d)(4)(iii)].
  2. Q: What are the state administrative review requirements for at-risk afterschool institutions?
    A: In the CACFP, state agencies must comply with 7 CFR Section 226.6(m) in conducting reviews of those institutions that have agreements with the state agency to provide at-risk, afterschool meals or snacks. According to these regulations, state agencies must annually review 33.3 percent of all CACFP institutions, including those operating at-risk, afterschool programs. At least 15 percent of the required reviews must be unannounced. Additionally, the current regulations require that state agencies ensure that:
    • Independent centers and sponsors of 1 to 100 facilities are reviewed at least once every three years; a review of such sponsors must include reviews of 10 percent of the sponsors’ facilities.
    • Sponsors with more than 100 facilities must be reviewed at least every three years. These reviews must include reviews of 5 percent of the first 1,000 facilities and 2.5 percent of the facilities in excess of 1,000.
    • Reviews of newly participating sponsoring organizations with five or more child care facilities must be completed within the first 90 days of program operations.

    In conducting these reviews, state agencies must ensure that sponsors are operating eligible at-risk afterschool care programs (i.e., programs that provide children with regularly scheduled activities in an organized, structured, and supervised environment), and are complying with all program requirements.
Additional Questions

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 Child Nutrition Information and Payment System Download Forms section.

Questions:   Nutrition Services Division | 800-952-5609
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