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Documentation Requirements for CACFP Meal Patterns

Management Bulletin CACFP-02-2018: Documentation Requirements for the CACFP Meal Patterns.

Nutrition Services Division Management Bulletin

Purpose: Policy, Beneficial Information

To: Child and Adult Care Food Program

Attention: Program Operators (Including Day Care Home Sponsoring Organizations)

Number: CACFP–02–2018

Date: October 2018

Reference:

  1. U.S. Department of Agriculture (USDA) Policy Memorandum CACFP 17–2016, Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the Child and Adult Care Food Program (CACFP), Questions and Answers (Q&A)
  2. USDA Policy Memo CACFP 08–2017, Q&A on the Updated Meal Pattern Requirements for the CACFP
  3. USDA Policy Memo CACFP 14–2017, SFSP 10–2017, Modifications to Accommodate Disabilities in the CACFP and the Summer Food Service Program (SFSP)
  4. USDA Policy Memo CACFP 17–2017, Documenting Meals in the CACFP
  5. USDA Policy Memo CACFP 02–2018, Feeding Infants and Meal Pattern Requirements in the CACFP, Q&A
  6. USDA Policy Memo CACFP 09–2018, Grain Requirements in the CACFP, Q&A
  7. Title 7, Code of Federal Regulations (7 CFR), sections 226.15 and 226.20

Supersedes: Management Bulletin CACFP–07–2017, Clarification on Documenting Meals in the Child and Adult Care Food Program, October 2017

Subject: Documentation Requirements for the CACFP Meal Patterns


This management bulletin provides guidance for CACFP Operators regarding the documentation requirements for the meal patterns under 7 CFR, Section 226.20. This management bulletin supersedes the California Department of Education (CDE) Management Bulletin CACFP–07-2017: Clarification on Documenting Meals in the CACFP, issued October 2017.

The term program operators used in this management bulletin refers to all entities that provide meals and snacks as part of participation in the CACFP. Program operators include all types of centers (licensed child and adult care centers, at-risk afterschool programs, emergency shelters, etc.) and all day care home (DCH) providers.

There are some requirements that 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., at risk afterschool programs and emergency shelters. In these scenarios, the requirement will refer to centers and exclude specific types of centers. 

DCH sponsors do not provide meals and snacks as part of participation in the CACFP.  However, DCH sponsors are responsible for ensuring that DCHs comply with the documentation requirements outlined in this management bulletin.

Background

On April 25, 2016, the 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 following USDA Policy Memos:

  • CACFP 17–2016, Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the CACFP; Q&A

  • CACFP 17–2017, Documenting Meals in the CACFP

  • CACFP 02–2018, Feeding Infants and Meal Pattern Requirements in the CACFP; Q&A

  • CACFP 09–2018, Grain Requirements in the CACFP; Q&A

Program 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][10]). USDA authorizes state agencies to determine other types of acceptable recordkeeping documents required to demonstrate compliance with the meal patterns (7 CFR, Section 15[e]). The CDE strives to meet this obligation with reasonable flexibility and accountability.

Meal Pattern Documentation Checklist and Sample Forms

The CDE created the Meal Pattern Documentation Checklist (Form ID CACFP 89), which summarizes the meal pattern documentation requirements outlined in this management bulletin. This checklist, and all sample forms provided by the Nutrition Services Division (NSD) and referenced in this management bulletin, are on the Download Forms section of the Child Nutrition Information and Payment System (CNIPS) web page at https://www.cnips.ca.gov/Splash.aspx External link opens in new window or tab.

Table of Contents

Hyperlinks to the various sections are provided below to help the reader find requirements related to specific topics.

  1. Infant Participation
  2. Child and Adult Menus
  3. Menu Production Records (MPR)
  4. Creditable Food Components and Food Items
  5. Meal Modifications for Participants Without a Disability
  6. Meal Modifications for Participants with Disabilities
  7. Declining Participation in the CACFP
  8. Transport Records
  9. Meal Receipts and Allowable Costs
  10. Records Retention
  11. Policies and Procedures

I. Infant Participation

Requirements: All program operators with infants in care must:

  • Offer CACFP program benefits to all infants. Program operators do not have the option to limit participation in the CACFP to children only.

  • Notify parents/guardians that an iron-fortified infant formula is offered 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

    • Obtaining the signature of a parent/guardian who provides an alternate infant formula, acknowledging that they are declining the program 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 infants (zero through eleven months) for all meals and snacks claimed for reimbursement, which documents the following:

    • The type of infant milk offered, i.e., breastmilk, 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 infant formula offered, and the quantity of all solid foods offered regardless of the age of the infant (DCH providers are exempt from this requirement)

Sample Forms: Form ID CACFP 31, Meal Record for Infants; Form ID CACFP 32, Individual Infant Meal Record; Form ID CACFP 45, Individual Infant Meal Record with Meal Pattern

  • Label 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.

Helpful Tip: Program 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 portion size for some food items, i.e., 0–4 Tbsp. This allows program operators the option to not offer the food item or meal component during the transition period

Best Practices (Optional):

    • Distinguish whether infants were 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/guardians. (See USDA Policy Memorandum CACFP 02-2018, Feeding Infants and Meal Pattern Requirements in the CACFP; Q&A).
       
    • Communicate frequently with the infant’s parent/guardian about when to introduce solid foods and what creditable solid foods to offer the infant.

    • Obtain written documentation from parents/guardians that show their preferences for when to introduce solid foods and what creditable solid foods to offer.

II. Child and Adult Menus

Requirements: All program operators must:

  • Maintain dated, daily menus for children and adults that demonstrate compliance with the meal pattern requirements. Reminder: Although CACFP regulations do not require menus to be posted, California regulations for licensed child care centers require menus to be posted at least one week in advance.

Note: DCH providers can meet this requirement by entering menu items offered daily into an electronic database or by maintaining a daily written menu.  

  • List the food items served on the menu to document that meals and snacks include the required meal pattern components.

  • Specify on the menu or MPR, 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. When adult day care or at-risk afterschool centers use offer versus serve and offer different types of milk, the menu must reflect all of the types of milk offered. 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.

Helpful Tip: A notation on the bottom of the menu can satisfy the documentation requirement. Examples are listed below.

    • Licensed child care centers: Whole, unflavored milk is served to children one year of age and 1 percent, unflavored milk is served to all children two years of age and older.

    • Unlicensed at-risk afterschool centers: Children aged six and older are offered a choice of 1 percent, unflavored milk or fat-free, flavored milk. Children ages five and younger are only offered 1 percent, unflavored milk.

  • Identify at least one food item per day on the menu or MPR which meets the criteria for whole grain-rich (WGR).

Note: DCH providers that input more than two meals and one snack, or two snacks and one meal, into a system that determines which meals and snacks are submitted for reimbursement, are responsible for ensuring one daily meal or snack claimed for reimbursement includes a grain item that is

Helpful Tip: 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.

  • Limit meat/meat alternate (M/MA) substitutions for the entire grain component at breakfast to no more than three times per week.

  • Limit fruit or vegetable juice that is used to meet the vegetable or fruit requirement to one meal or snack per day.

  • For Adult Day Care Only: limit yogurt as a substitution for milk to once per day.

  • Indicate menu substitutions by handwriting the substitution directly on the menu, MPR, or transport records, electronically updating the menu to reflect the substitution, or by any other method as long as the program operator has documentation to show what was actually served.

  • Exclude deep-fat fried foods on the menu when meals and snacks are prepared onsite. Meals prepared in a central kitchen are considered to be prepared on site. Deep-fat fried foods are defined as cooking by submerging food in hot oil or other fat.

  • Exclude grain-based desserts on the menu for the grain component. Refer to food items that have a superscript 3 or 4 in Exhibit A of the USDA Food Buying Guide (FBG) for Child Nutrition Programs. 

  • Include the current version of the federal Nondiscrimination Statement on the menu if the menu is available to the public and it contains other information regarding the CACFP.

Best Practices (Optional):

    • Include the quantities of each food component on the menu, e.g., ½ cup broccoli, to ensure that all food service staff are aware of the quantities required of each component to comprise a reimbursable meal.

    • All CACFP operators should post menus in a public location to ensure that parents, guardians, or other household members can view what food items are offered. As a reminder, California regulations for licensed child care centers require menus to be posted at least one week in advance.

III. Menu Production Records

Requirements: With the exception of at-risk afterschool centers and emergency shelters, all centers must:

  • Maintain daily MPRs for children ages 12 months and older and for adults in adult day care to verify that the quantity of food prepared meets the minimum serving size in the meal pattern for each age group.

  • Include the following details on the MPR:

    • Number of children and adults estimated to be served by age group and the actual number served

    • Menu and serving size per age group

    • Specific types and forms of food items must be noted (such as apple or apple juice, instead of fruit or juice) and their contribution to the meal pattern components

    • Purchase unit and servings per purchase unit

    • Estimated quantity of each food item to prepare and the actual quantity prepared

    • Amount of leftovers, which may be used in another meal or snack

Helpful Tip: Program operators that keep the original milk carton(s) in an ice bath at or near the table (to maintain the temperature of the milk at 41 degrees or below during the meal service) and return the unused portion of milk to the refrigerator, must ensure that the MPR reflects the quantity of milk that was returned to the refrigerator to be served in a future meal or snack. Agencies should consult with their local health department to determine whether maintaining the original milk carton(s) in an ice bath during meal service complies with local health and safety rules.

Sample Form: Form ID CACFP 28, Agency Menu Production Record—Centers

Best Practice (Optional): When juice is served, document on the MPR that juice is pasteurized and full-strength, as this is the only type of juice that can be served in the CACFP, e.g., pasteurized, full-strength, apple juice (full-strength juice is 100 percent fruit or vegetable juice).

IV. Creditable Food Components and Food Items

Note: A food component is one of the food groups that comprise a reimbursable meal. A food item is a specific food offered within the food components.

Requirements: While program operators must demonstrate that the food components and food items served as part of CACFP meals and snacks are creditable, the USDA provides authority for state agencies to determine how program operators will demonstrate compliance. In the USDA Policy Memorandum, CACFP 17-2017, Documenting Meals in the CACFP, the USDA clearly indicates that state agencies should not impose additional paperwork requirements to demonstrate compliance with the updated meal pattern requirements.

Given this flexibility, and the CDE’s desire to ease the burden of recordkeeping requirements, the NSD has modified the existing program review process to the following:

  • During the administrative review (AR) month (the month of the last claim for reimbursement submitted) at the time the AR is conducted, program reviewers will look at the menu for that month only to ensure that all food components for a reimbursable meal and snack were offered. Program reviewers will also check:

    • The type of milk and whether it is flavored or unflavored for each age group is indicated on the menu

    • At least one food item per day, on the menu or MPR is identified as WGR

    • M/MAs are not substituted for the grain component at breakfast more than three times per week

    • Vegetable or fruit juice is only used to meet the vegetable or fruit requirement once per day

    • Yogurt is on the menu to meet the milk requirement only once per day (allowable in adult day care only)

    • Deep-fat fried foods are not on the menu as part of a reimbursable meal or snack if meals are prepared on site

    • Grain-based desserts are not on the menu as part of a reimbursable meal or snack

  • During one week of the AR month (selected by the program reviewer), the reviewer will look more closely at what the program operator served during the one week to validate that the types and quantities of food met the meal pattern requirements. Program operators must provide the following documents during NSD program reviews: MPRs (for licensed centers), Child Nutrition (CN) labels and product formulation statements (PFS) for processed foods, standardized recipes if meals were made from scratch, medical statements, documentation of parent-supplied food, transport records, receipts for food and beverages, etc.

Note: With the exception of CN labels, food package labels demonstrating that the updated meal pattern requirements were met are not required to be provided to the program reviewer during this one week of menu review.

  • On the day of the on-site meal observation, program reviewers will request the original, or copies of, product packages from foods and ingredients used in standardized recipes for meals and snacks served on that one day. Product packaging must include the Nutrition Facts label, ingredient list, or any other information that verifies compliance with the meal pattern requirements. Product package labels are not required if there are other means to verify the food component or food item is creditable, i.e., a breakfast cereal is listed in any state agency’s Women, Infants, and Children (WIC) Authorized Food List Shopping Guide. If meals or snacks are prepared off site and the product packages are not available the program operator has five business days to provide the program reviewer with the required product packages.

On the day of the on-site meal observation, program reviewers will check whether the menu matches the meals and snacks observed, and will review food package labels to verify that program operators are meeting the following requirements listed below: 

    • For Infants Only: Infant formula served (including infant formula brought from home) must contain at least 1 milligram of iron per 100 calories and be regulated by the Food and Drug Administration (unless a signed medical statement is available).

    • For Infants Only: All infant cereal served at meals and snacks must be made from dry, iron-fortified infant cereal. Ready-to-eat cereals (are only allowable for infants at snacks), must be either fortified or made from enriched or whole grain meal or flour and contain no more than 6 grams (g) of sugar per dry ounce (oz).

    • Milk served to children and adults must not exceed the fat content allowable for the age of the participant and flavored milk must not be served to participants five years of age and younger. Reminder: In California, the Healthy Beverages in Child Care Act does not allow licensed child care centers to serve flavored beverages to children of any age.

    • Nondairy milk substitutes served to participants (without a medical statement) must be nutritionally equivalent to milk and be requested in writing by the child’s parent/guardian, or by, or on behalf of, an adult participant (7 CFR, 226.20[c][3]). This request must be maintained and available during an AR.

Note: The nondairy milk substitute’s Nutrition Facts label must be available to verify that the milk substitute is nutritionally equivalent to milk. The nondairy milk substitute name and brand only is not considered sufficient documentation.

Helpful Tip: A written request from a parent/guardian may be incorporated into an existing form, such as an enrollment record, or program operators could use the sample form below.

Sample Form: Form ID CACFP 49, Request for a Fluid Milk Substitution

    • Grains must be creditable, which means they are made from enriched or whole grain meal or flour, or bran or germ, and are served in minimum quantities as specified in the meal patterns.  

    • WGR food items must meet the criteria for WGR listed in the most recent USDA Policy Memo CACFP 09–2018, Grain Requirements in the CACFP, Q&A. Documentation required to demonstrate the food item meets the criteria for WGR will depend upon the method used in the USDA policy memo to determine whether the food item is WGR.

    • Breakfast cereals must contain no more than 6 g of sugar per dry oz, and must be fortified or made from enriched or whole grain meal or flour. Demonstrating that the name and brand of breakfast cereal is listed in any state agency’s WIC Supplemental Nutrition Program Authorized Food List Shopping Guide is an alternative to providing the Nutrition Facts label and ingredient list.

Helpful Tip: When food is removed from the original package and stored in containers, e.g., breakfast cereal put in plastic containers, attach the package label with the Nutrition Facts label and ingredient list to the container, or provide other documentation to demonstrate that the food item is creditable.

    • Tofu served as the M/MA component must be commercially prepared, be easily recognizable as a meat substitute (e.g., sausage link, tofu chunks in a stir fry) and contain at least 5 g of protein per 2.2 oz (equivalent to ¼ cup).

    • Yogurt served must not contain more than 23 g of sugar per 6 oz.

    • M/MAs must be listed in the USDA FBG or the most current Crediting Handbook for the CACFP.

    • Processed M/MA and combination foods such as pizza, burritos, and chicken nuggets, must have a CN label or a PFS, signed by the manufacturer, to verify the product’s contribution to the meal pattern requirements.

Note: If the day of the on-site meal observation does not occur during the month of the AR, program reviewers will also check that the following requirements are met:

    • The required food components and the minimum quantities of food items served that day met the meal pattern requirements for each meal and snack by reviewing the MPR (if applicable) for that day.

    • Deep-fat fried foods are not on the menu as part of reimbursable meals or snacks when prepared on site.

    • Grain-based desserts are not on the menu as part of a reimbursable meal or snack.

V. Meal Modifications for Participants without Disabilities

Requirements: Program operators must:

  • Document all parent/guardian-supplied (or program operator-supplied) foods and beverages offered as a meal or snack modification on either an existing form, e.g., the infant meal record, the child menu, MPR, the enrollment record, or on a specific form, such as the sample form below.

  • Ensure parent/guardians supply no more than one reimbursable food component at each meal and snack.

  • Ensure all parent/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.

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

Note: Program 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

VI. Meal Modifications for Participants with Disabilities

Requirements: Program operators must make reasonable food and beverage substitutions on a case-by-case basis for individual participants who are considered to have a disability that restricts their diet. Program operators must:

  • Obtain a signed medical statement when food and beverage substitutions 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.

    Sample Form: Form ID CNP 925, Medical Statement to Request Special Meals and/or Accommodations
  • Provide at least one required component when meal modifications are made for participants with a disability. Parents/guardians may supply one or more creditable components of a reimbursable meal when there is a 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 Management Bulletin, CACFP-08-2017; SFSP-02-2017, Modifications to Accommodate Disabilities in the CACFP and the SFSP on the CDE Modifications to Accommodate Disabilities web page at https://www.cde.ca.gov/ls/nu/cc/mbcacfp082017sfsp022017.asp.

VII. Declining Participation in the CACFP

The federal regulations for the CACFP do not require a parent/guardian signature when program benefits are declined.

Best Practices (Optional): Obtain a written signature from parents/guardians of infants and children or household members of adult participants when they decline participation in the CACFP.

Sample Form: Form ID CACFP 11, Declining Participation in the CACFP

VIII. Transport Records

Requirements: All program 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. Transport records may be requested by program reviewers at any point during an AR.

Sample Form: Form ID CACFP 66, Sample Transport Record

IX. Meal Receipts and Allowable Costs

Requirements: Centers only must:

  • Retain legible receipts and invoices of all food items purchased with program funds that contribute toward a reimbursable meal. Receipts and invoices may be requested by program reviewers at any point during an AR.

  • Purchase only creditable food items with program funds.

Notes:

    • While condiments, herbs, and spices cannot credit towards the meal pattern requirements, condiments served with creditable foods and herbs and spices used to prepare and enhance the flavor of meals may be purchased with program funds.

    • Program reviewers may review receipts and invoices to verify that the amount of milk purchased meets the minimum amount required for the number of participants served at each meal and snack.

Helpful Tip: Centers should copy, scan, or photograph receipts as they often fade over time to ensure that the receipt is legible during an AR.

X. Record Retention

Requirements: Program operators must retain the following documents related to verify that the meal patterns are met for the current Federal Fiscal Year (FFY), October 1 through September 30, plus the prior three FFYs:

  • Menus

  • Food and beverage receipts and invoices, if applicable

  • MPRs, if required

  • CN labels, PFSs, and standardized recipes, if applicable

  • Transport records, if applicable

  • Medical statements, if applicable

  • A written request from a parent/guardian of an infant or child or a household member of an adult participant for a nondairy milk substitute when there is no disability, 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.

XI. Policies and Resources

For a comprehensive and up-to-date listing of policy memos, resources, and training opportunities related to the CACFP new meal patterns, visit the CDE CACFP New Meal Patterns web page at https://www.cde.ca.gov/ls/nu/he/cacfpresource.asp.

If you have any questions regarding the meal pattern documentation requirements outlined in this management bulletin, contact your CACFP Specialist. The CACFP Specialist list is available in the Download Forms section of the CNIPS, Form ID CACFP 01. You may also contact Nancy Charpentier, CACFP Unit Office Technician, by phone at 916-327-2991 or 800-952-5609, Option 3, or by email at ncharpentier@cde.ca.gov to be directed to your CACFP Specialist.

If you have questions during an AR, 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.

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Tuesday, October 9, 2018
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