Documentation Requirements for the CACFP
Nutrition Services Division Management Bulletin
Purpose: Policy, Beneficial Information
To: Child and Adult Care Food Program Operators (including Day Care Home Sponsoring Organizations)
Attention: Child and Adult Care Food Program Operators (including Day Care Home Sponsoring Organizations)
Date: September 2020
Reference: Refer to Section XII Regulations, Policies, and Resources in this management bulletin
Supersedes: Management Bulletins CACFP–02–2018, Documentation Requirements in the CACFP, October 2018, and CACFP–07–2017, Clarification on Documenting Meals in the CACFP, October 2017
Subject: Documentation Requirements for the CACFP Meal Patterns
This management bulletin (MB) provides guidance for Child and Adult Care Food Program (CACFP) Operators regarding the documentation requirements for the meal patterns referenced in Title 7, Code of Federal Regulations (7 CFR), Section 226.20. The documentation requirements in this MB pertain only to CACFP federal regulations and the California Department of Education (CDE) requirements related to the CACFP meal patterns.
All sample forms and templates referenced in this MB are accessible in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS) website at https://www.cnips.ca.gov/Splash.aspx.
For information pertaining to the California Health and Safety Code and the California Code of Regulations (CCR), Title 22, applicable to California’s licensed child care centers, access the California Department of Social Services (CDSS) Community Care Licensing Laws and Regulations web page at https://www.cdss.ca.gov/inforesources/community-care/policy/laws-and-regulations.
For health and safety information and the CCR, Title 22 applicable to adult care agencies, access the CDSS Adult Care Licensing Resources for Providers web page at https://www.cdss.ca.gov/inforesources/adult-care-licensing/resources-for-providers.
Table of Contents
Hyperlinks to the various sections in this MB are provided below to help the reader find requirements related to specific topics quickly.
- Infant Meals
- Child and Adult Menus
- Meal Modifications for Participants without a Disability
- Meal Modifications for Participants with Disabilities
- Declining Participation in the CACFP
- Transport Records
- Record Retention
- CDE AR Process for Determining Creditable Food Components and Food Items
- Documentation Checklist and Sample Forms
- Regulations, Policies, and Resources
- Contact Information
The term CACFP Operators used in this MB refers to all entities that provide meals and snacks as part of participation in the CACFP. CACFP Operators include all types of centers (child and adult care centers, at-risk afterschool [ARA] programs, emergency shelters [ES]) and all day care home (DCH) providers.
Some requirements in this MB do not pertain to DCH providers. In these scenarios, the requirement will refer to centers only. There are some requirements that do not pertain to specific types of centers, e.g., ARA programs and ESs. In these scenarios, the requirement will refer to centers and exclude specific types of centers.
DCH sponsors are responsible for ensuring that DCH providers comply with the documentation requirements outlined in this MB.
On April 25, 2016, the U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS) published the final rule CACFP: Meal Pattern Revisions Related to the Healthy, Hunger-Free Kids Act of 2010. The final rule updated the meal pattern requirements in 7 CFR, Section 226.20 (82 Federal Register 56716), to better align the CACFP with the Dietary Guidelines for Americans. Although the final rule did not change the CACFP recordkeeping requirements in 7 CFR, Section 226.15(e), the USDA FNS provided additional clarification on documentation and compliance in the USDA policy memos in Section XII of this MB, Regulations, Policies, and Resources.
CACFP Operators are required to demonstrate that they are serving meals that meet the meal pattern requirements and must keep records of menus (7 CFR, Section 226.15[e]). The USDA authorizes state agencies to determine other types of acceptable recordkeeping documents required to demonstrate compliance with the meal patterns (7 CFR, Section 226.15[e]). The CDE documentation requirements for the CACFP Meal Patterns are included in this MB.
Note: Per 7 CFR, Section 226.20(i), CACFP Operators serving meals to children 5 years old and older, which are prepared by schools participating in the NSLP and SBP, may substitute the NSLP and SBP meal pattern requirements instead of the CACFP meal patterns. This would include ARA programs and child care programs for school-age children. CACFP Operators serving meals to preschool children under 5 years old, including school food authorities, must follow the CACFP child meal patterns, regardless of whether children are served meals comingled with older children.
All CACFP Operators with infants in care must:
- Offer CACFP program benefits to all infants. CACFP Operators with infants enrolled for care do not have the option to limit participation in the CACFP to children only.
- Notify parents or guardians that an iron-fortified infant formula is provided by the program operator at no cost (by either including a notification in a parent handbook, on the enrollment record, on the program operator’s website, or another document available to parents) or obtain a signed written statement from a parent or guardian who chooses to provide an alternate infant formula, acknowledging that they are declining the CACFP Operator’s infant formula.
Sample Form: Form ID CACFP 12, Parent/Guardian’s Form for Declining a Provider’s Infant Formula or Food
- Maintain daily meal records for each infant (0 through 11 months) for all meals and snacks claimed for reimbursement, which documents the following:
- The type of infant milk offered, i.e., breastmilk, iron-fortified infant formula, or a combination of both
- The name of all solid foods offered when infants are developmentally ready to accept them, e.g., carrots, 1 Tbsp
- The quantity of expressed breastmilk or iron-fortified infant formula offered, and the quantity of all solid foods offered regardless of the age of the infant (DCH providers are exempt from these requirements)
- The type of infant milk offered, i.e., breastmilk, iron-fortified infant formula, or a combination of both
- Label containers of expressed breastmilk with the infant’s name and date and keep no longer than 72 hours after expressed. If breastmilk was frozen, keep no longer than 72 hours after thawed.
- Include the current version of the federal nondiscrimination statement on menus if menus are available to the public and they contain other information regarding the CACFP.
CACFP Operators are not required to offer all meal components while infants are transitioning to solid foods. The infant meal pattern lists a range for the serving size for some food items, e.g., 0–4 Tbsp. This allows CACFP Operators the option to not offer the food item or meal component during the transition period and still claim the meal for reimbursement.
Best Practices (Optional)
- Note on the menu whether infants are breastfed onsite or offered expressed breastmilk in a bottle, and use acronyms such as BFOS (breastfed onsite) or EBM (expressed breast milk).
- Share the American Academy of Pediatrics guidelines for determining when an infant is developmentally ready for solid foods with parents or guardians. For more information regarding infant feeding, access the guide, USDA Feeding Infants in the CACFP, referenced in Section XII Regulations, Policies, and Resources.
- Communicate frequently with the infant’s parents or guardians about when to introduce solid foods and which creditable solid foods to offer the infant.
- Obtain written documentation from parents or guardians that show their preferences for when to introduce solid foods and which creditable solid foods to offer.
All CACFP Operators must:
- Maintain a daily dated menu listing the food items served to meet the CACFP meal pattern requirements.
- Document on the menu, for each age group, the fat content of all types of milk served, e.g., whole, 1 percent (low-fat), fat-free (nonfat or skim), and whether each milk type is unflavored (plain) or flavored. Examples are listed below.
Licensed child care centers: Whole, unflavored milk is served to children 12 through 23 months of age and 1 percent, unflavored milk is served to all children 2 years of age and older.
Unlicensed ARA programs: Children aged 6 and older are offered a choice of unflavored fat-free or 1 percent milk, or flavored fat-free milk. Children ages 5 and younger are only offered 1 percent, unflavored milk.
Reminder: In California, the Healthy Beverages in Child Care Act does not allow licensed child care centers or DCH providers to serve flavored beverages to children of any age.
- Document on the menu at least one food item per day which meets the criteria for whole grain-rich (WGR). Suggestions for clearly identifying the WGR item on the menu include writing WGR after the food item, highlighting or bolding the WGR food item on the menu, or using an asterisk after the WGR item(s) with an accompanying notation at the bottom of the menu indicating the asterisk represents WGR.
CACFP Operators who input more than two meals and one snack, or two snacks and one meal, into a computer system that determines which meals and snacks are submitted for reimbursement, are responsible for ensuring that one daily meal or snack claimed for reimbursement includes a WGR food item.
- Document all menu substitutions.
- Include the nondiscrimination statement on the menu if it is available to the public and includes additional information regarding the CACFP. If the nondiscrimination statement is required and the menu is one page or less, the short nondiscrimination statement can be used to meet this requirement; otherwise, the full nondiscrimination statement must be included.
ARA programs and ESs must post a dated, daily menu; quantities are not required.
Centers must post a dated, daily menu with serving sizes per age group for every meal and snack claimed (ARA programs and ESs are exempt). Centers are no longer required to complete menu production records (MPR), effective October 1, 2020; they are optional.
The requirement for menus with serving sizes can be met by maintaining one of the documents listed below.
- CDE Daily Menu with Serving Sizes for Multiple Age Groups template (Form ID CACFP 89) or CDE Weekly Menu with Serving Sizes for One Age Group template (Form ID CACFP 90).
These templates include instructions, a sample completed menu with serving sizes, and a template for agencies to electronically complete.
- CACFP Operator-developed menu form with serving sizes per age group.
CACFP Operators that choose to develop their own template to fulfill the menu with serving sizes requirement are required to document the menu for each meal and snack served and the serving size of each food item for each age group served.
- CDE Agency MPR—Centers (Form ID CACFP 28) or CDE Agency MPR—Adult Day Care Centers (Form ID CACFP 78).
CACFP Operators that choose to continue to use the MPR to meet the requirement for a menu with serving sizes are only required to complete the two columns titled Menu and Serving Size (for each age group served). All other columns on the MPR are optional. The CDE developed instructions (Form ID CACFP 28A for child care centers, and Form ID 78A for adult care centers) to assist CACFP Operators with completing the MPR.
- Transport Record CACFP Operators who receive vended meals can continue to use the CDE Sample Transport Record (Form ID CACFP 66) or their own transport record template to fulfill the requirement for a menu with serving sizes listed. As a reminder, all fields must be completed, including the serving size or scoop number sizes for bulk foods.
Tip: CACFP Operators should use the Food Buying Guide (FBG), which is available as an online interactive tool and a mobile application (app), to determine the minimum quantity of foods to purchase and prepare to provide the minimum serving sizes for each age group and to meet the CACFP meal pattern requirements. To access the online FBG URL and mobile app, refer to Section XII Regulations, Policies, and Resources.
CACFP Operators must:
- Document all parent or guardian-supplied (or CACFP Operator-supplied) foods and beverages offered as a meal or snack modification. The CACFP Operator can document these modifications in a document that they already maintain (e.g., infant meal record, menu with serving sizes, enrollment record), on a specific form that the CACFP Operator develops for this purpose, or using the specific form that the CDE developed for this purpose, listed below. Accommodating participants without disabilities is encouraged, but not required.
Sample Form: Form ID CACFP 12, Parent/Guardian’s Form for Declining a Provider’s Infant Formula or Food; Form ID CACFP 84, Parent/Guardian’s Form for Declining a Provider’s Food for Older Children
- Ensure parents or guardians supply no more than one reimbursable food component at each meal and snack.
- Ensure all parent or guardian-supplied (or program operator-supplied) food and beverages offered as a meal or snack modification are creditable when served as part of a reimbursable meal or snack.
- Obtain a signed written request from a child’s parent or guardian, or a household member of an adult participant, when a request is made for a fluid milk substitution and a medical statement is not on file (7 CFR, Section 226.20[c]). The CDE sample form, Form ID CACFP 49, Request for a Fluid Milk Substitution, may be used or requests can be incorporated into an existing form, such as an enrollment record.
Note: CACFP Operators may include a policy that does not allow food to be brought from home unless program participants have a signed written medical statement on file in order to reduce:
- Documentation requirements for food brought from home
- The program operator’s risk for meal disallowances
- Food safety concerns
- Differences between meals that each participant receives
For more information on meal modifications for participants without disabilities, access the CDE Menu Modifications in the CACFP tip sheet referenced in Section XII Regulations, Policies, and Resources.
CACFP Operators must:
Obtain a signed medical statement when food and beverage substitutions are requested by parents or guardians and do not meet the meal pattern requirements. The medical statement must be signed by a physician, physician’s assistant, or nurse practitioner and must include a description of the participant’s physical or mental impairment. The description must be sufficient for a program operator to understand how it restricts the participant’s diet and include an explanation of what is required to accommodate the disability.
CACFP Operators should not delay meal modifications while waiting for the parent or guardian to submit a medical statement. CACFP Operators can claim meals with dietary modifications that do not meet the meal pattern requirements without a signed medical statement provided that they:
- Maintain documentation of the initial conversation with the family where they first learned of the need for an accommodation and requested a signed written medical statement from a state licensed physician, physician’s assistant, or nurse practitioner;
- Document all follow up with the parent or guardian if the CACFP Operator does not receive the requested medical statement;
- Continue to follow up with the parent or guardian until a medical statement is obtained or the request is withdrawn; and,
- Provide at least one required food component when meal modifications are made for participants with a disability. Parents or guardians may supply one or more creditable food component of a reimbursable meal when there is a disability.
Sample Form: Form ID CNP 925, Medical Statement to Request Special Meals and/or Accommodations (Revision 08/2018) CACFP Operators should use this updated form when a new medical statement is requested. The current form defines disability without requiring the disability to be disclosed. The form must include a description of the participant’s physical or mental impairment that is sufficient to allow the CACFP operator to understand how it restricts the participant’s diet, and an explanation of what is required to accommodate the disability.
Note: A medical statement does not need to be updated unless there is a change in the dietary restriction.
For more information on meal modifications for participants with disabilities, access the MB CACFP–08–2017; SFSP–02–2017, Modifications to Accommodate Disabilities in the CACFP and the Summer Food Service Program (SFSP) and the CDE Menu Modifications tip sheet referenced in Section XII Regulations, Policies, and Resources.
When participation in the CACFP is declined, a signature from the parent or guardian or household member of an adult participant is not required, but recommended.
For CACFP Operators that choose to obtain a parent, guardian, or household member’s signature the Sample Form is available, as Form ID CACFP 11, Declining Participation in the CACFP.
All CACFP Operators that serve food that is prepared off site and delivered must maintain transport records with the same level of detail as found in the sample form below.
Sample Form: Form ID CACFP 66, Sample Transport Record
CACFP Operators must retain all documents to verify that the meal pattern requirements were met for the current Federal Fiscal Year (FFY), October 1 through September 30, plus the prior three FFYs, such as:
- MPRs (required for all centers, except ARA and ES, prior to October 1, 2020)
- Child Nutrition labels, product formulation statements, and standardized recipes, if applicable
- Transport records, if applicable
- Medical statements or requests for medical statements, if applicable
- A written request from a parent or guardian of an infant or child or a household member of an adult participant for a nondairy milk substitute when there is no medical statement on file, if applicable
- Food and beverage receipts, invoices, and vending contracts, if applicable (DCH providers are exempt from this requirement)
- Payroll records of labor cost charged to the CACFP and job descriptions associated with the CACFP tasks, if applicable
Note: In cases where there are open audits or ARs, these records must be kept until the audit or AR is closed. Failure to maintain the above program records as required may result in denial of reimbursement for meals and snacks served during the period associated with the records and may also result in a serious deficiency designation. All accounts and records pertaining to the CACFP shall be made available, upon request, to representatives of the CDE and the U.S. Government Accountability Office for audit or review at a reasonable time and place.
The CDE modified the CACFP AR process to address compliance with the updated CACFP meal patterns.
Reviewers will check for compliance by: (1) analyzing the menu for the month of review (defined as the last month the CACFP Operator submitted a claim for reimbursement); (2) observing meal preparation (if time permits) and meal services on the day of the onsite meal observation; and (3) reviewing documents related to the meal services on the day of the onsite meal observation. This day is selected by the reviewer and is usually unannounced. (Not all CDE DCH provider site monitoring visits include a meal observation.)
For more information about what documents reviewers will request for the month of review and the day of the onsite meal observation during a CDE AR, refer to Section 16, Administrative Review Process for Compliance with the CACFP Meal Patterns, in the CDE CACFP Administrative Manual referenced below in Section XII Regulations, Policies, and Resources.
The CDE consolidated two checklists (CACFP Form ID 82, the CACFP Child Care Agency Task List, and CACFP Form ID 89, CACFP Meal Pattern Documentation Checklist) into one comprehensive checklist for all required CACFP documentation. This checklist is an optional tool that will assist CACFP Operators in assessing compliance with required program documentation prior to an administrative review (AR).
The new consolidated checklist is titled, CACFP Checklist of Requirements by Timeframe for Centers (Form ID CACFP 82). This checklist, and all sample forms provided by the Nutrition Services Division (NSD) and referenced in this MB, are in the Download Forms section of the CNIPS website at https://www.cnips.ca.gov/Splash.aspx.
- 7 CFR, sections 226.15 and 226.20 at https://www.govregs.com/regulations/expand/title7_chapterII_part226_subpartE_section226.20
- CACFP 17–2016, Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the CACFP, Questions and Answers (Q&A) at https://fns-prod.azureedge.net/sites/default/files/cacfp/CACFP17_2016os.pdf
- SP 53–2016, CACFP 21–2016, Crediting Tofu and Soy Yogurt Products in the School Meal Programs and the CACFP at https://fns-prod.azureedge.net/sites/default/files/cn/SP53_CACFP21_2016os.pdf
- CACFP 08–2017, Q&A on the Updated Meal Pattern Requirements for the CACFP at https://fns-prod.azureedge.net/sites/default/files/cacfp/CACFP08-2017os.pdf
- CACFP 09–2017, Vegetable and Fruit Requirements in the CACFP, Q&A at https://fns-prod.azureedge.net/sites/default/files/cacfp/CACFP09-2017os2.pdf
- CACFP 14–2017, SFSP 10–2017, Modifications to Accommodate Disabilities in the CACFP and the SFSP policy memo at https://fns-prod.azureedge.net/sites/default/files/cacfp/CACFP14-2017_SFSP10-2017os.pdf
- CACFP 17–2017, Documenting Meals in the CACFP at https://fns-prod.azureedge.net/sites/default/files/cacfp/CACFP17-2017os.pdf
- CACFP 02–2018, Feeding Infants and Meal Pattern Requirements in the CACFP, Q&A at https://fnsprod.azureedge.net/sites/default/files/cacfp/CACFP02-2018os.pdf
- CACFP 09–2018, Grain Requirements in the CACFP, Q&A at https://fns-prod.azureedge.net/sites/default/files/cacfp/CACFP09_2018os.pdf
- MB CACFP–08–2017; SFSP–02–2017, Modifications to Accommodate Disabilities in the CACFP and the SFSP on the CDE CACFP Modifications to Accommodate Disabilities web page at https://www.cde.ca.gov/ls/nu/cc/mbcacfp082017sfsp022017.asp
- SP 37–2019, CACFP 16–2019, Questions and Answers on the Final Rule Child Nutrition Programs: Flexibilities for Milk, Whole Grains, and Sodium Requirements at https://www.fns.usda.gov/cn/questions-and-answers-final-rule-child-nutrition-programs-flexibilities-milk-whole-grains.
- CDE CACFP Administrative Manual at https://www.cde.ca.gov/ls/nu/cc/cacfpmanualtablecontent.asp
- CDE CACFP Meal Patterns web page at https://www.cde.ca.gov/ls/nu/he/cacfpresource.asp
- CDE CACFP Food Buying Guide Calculator web page at https://www.cde.ca.gov/ls/nu/ed/fbgcalculator.asp
- CDE Menu Modifications in the CACFP tip sheet at https://www.cde.ca.gov/ls/nu/he/documents/menumodifications.pdf
- Navigating the Food Buying Guide Calculator online course on the CDE Course Catalog web page at https://www.cde.ca.gov/ls/nu/ed/cnpcoursecatalog.asp
- USDA FBG for Child Nutrition Programs website at https://foodbuyingguide.fns.usda.gov
- USDA FBG Mobile App available (free) for download in the Apple App store or in the Google Play Store
- USDA Feeding Infants in the CACFP Guide at https://www.fns.usda.gov/tn/feeding-infants-child-and-adult-care-food-program
- USDA Monitoring Handbook for State Agencies, November 2018 at https://fns-prod.azureedge.net/sites/default/files/resourcefiles/2014Monitoring_Handbook_SA.pdf
If you have any questions regarding the meal pattern documentation requirements outlined in this MB, contact your CACFP Specialist. The CACFP Contact Specialist list is available in the Download Forms section of the CNIPS, Form ID CACFP 01.
If you have questions about the AR process, contact your CACFP Child Nutrition Consultant (CNC). To identify your CNC, access the Directory of Staff County Assignments, Form ID Caseload, in the Download Forms section of the CNIPS or contact the Field Services Unit main line at 916-323-4558.