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Water Availability in the CACFP

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

To: Child and Adult Care Food Program

Number: USDA-CACFP-13-2011

Attention: Food Program Director

Date: August 2011

Subject: Water Availability in the Child and Adult Care Food Program

Reference: The Healthy, Hunger-Free Kids Act of 2010, Public Law 111-296, Section 221; United States Department of Agriculture, Food and Nutrition Services, Policy Memo CACFP 20-2011

This Management Bulletin (MB) notifies Child and Adult Care Food Program (CACFP) agencies that the United States Department of Agriculture (USDA) has issued a policy memo regarding Water Availability in the CACFP.

This policy memo is available at the following USDA Web page:

Water Availability in the CACFP

Section 221 of the Healthy, Hunger-Free Kids Act of 2010 establishes a requirement to make drinking water available to children in the CACFP, as nutritionally appropriate.

Throughout the day, including at meal times, water should be made available to children to drink upon their request, but does not have to be available for children to self-serve. While drinking water must be made available to children during meal times, it is not part of the reimbursable meal and may not be served in lieu of fluid milk.

This requirement does not apply to adult day care centers, though NSD encourages agencies  to ensure drinking water is available to all participants.

The 2010 Dietary Guidelines for Americans do not establish a daily minimum intake for water consumption, but do recommend that water be consumed daily. However, caregivers should not serve young children too much water before and during meal times; excess water may lead to meal displacement, reducing the amount of food and milk consumed by the children. If a child requests water during meal time, water should be given in a separate cup from the milk so that milk is also served. Agencies should encourage facilities to serve water with snacks when no other beverage is served, and in lieu of other high caloric, sweetened beverages (juice drinks, soda, sports drinks, etc.) that are served outside of meal times.

CACFP facilities and providers can make water available to children in a variety of ways which include but are not limited to: having cups available next to the kitchen sink faucet, having water pitchers and cups set out, or simply providing water to a child when it is requested.

The NSD expects implementation of this provision will have no or very low cost. Circumstances may arise, however, in which safe water is not readily available in a facility. In these instances, purchasing water for children may be considered a reasonable and allowable cost for participating facilities. The purchasing of water continues to be an unallowable cost if purchased for adult or employee consumption.

This provision is effective immediately; however, in order to allow CACFP agencies to prepare for these changes, full implementation is not mandatory until October 1, 2011.

If new guidance becomes available from the USDA, the California Department of Education, Nutrition Services Division will develop a more detailed MB on this issue.

Please submit any questions regarding this new USDA policy by e-mail to with “Water Availability” in the subject line.

If your agency has questions regarding this MB, please contact the CACFP Specialist assigned to your agency. You will find a list of contact information for specialists in the Download Forms section of the Child Nutrition Information and Payment System. You may also contact Nancy Charpentier, CACFP Office Technician, by phone at 916-327-2991 or by e-mail at

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Wednesday, February 15, 2017
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