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Monitoring Requirements for Participation in CACFP

Nutrition Services Division Management Bulletin

Purpose: Policy, Beneficial Information

To: Child and Adult Care Food Program Operators

Attention: Program Operators

Number: CACFP-02-2019

Date: April 2019

Reference: Title 7, Code of Federal Regulations, sections 226.6(c)(3)(ii)(O), 226.16(d)(4), 226.16(e), and 226.16(l)(2); Management Bulletin CACFP-05-2015: Updates to the Serious Deficiency Process–Day Care Home Providers; U.S. Department of Agriculture (USDA) Policy Memoranda CACFP 10-2018: Conducting Five-day Reconciliation in the Child and Adult Care Food Program (CACFP), with Questions and Answers; and CACFP 16-2011: Child Nutrition Reauthorization 2010: Varied Timing of Unannounced Reviews in the CACFP; USDA Final Rule: CACFP: Improving Management and Program Integrity

Subject: Monitoring Requirements for Participation in the Child and Adult Care Food Program

Supersedes: Management Bulletin CACFP-07-2018: Revised: Training and Monitoring Requirements for Participation in the Child and Adult Care Food Program

This management bulletin (MB) clarifies monitoring requirements for Child and Adult Care Food Program (CACFP) sponsors of centers and day care homes (DCH). This MB supersedes MB CACFP-07-2018: Revised: Training and Monitoring Requirements for Participation in the CACFP. Updated guidance on training requirements in the CACFP is provided in MB CACFP-03-2019: Training Requirements in the CACFP which is located on the California Department of Education (CDE) CACFP Bulletins web page at

CACFP Operators include child care centers, adult day care centers, child and adult day care center sponsors (collectively referred to as a center), and DCH sponsors. The monitoring requirements apply only to sponsors of centers or DCHs.
Monitoring Requirements

The monitoring requirements of Title 7, Code of Federal Regulations (7 CFR), Section 226.16(d)(4) apply only to sponsors of centers, DCHs, or both. A sponsor is defined as an operator that administers the CACFP on behalf of two or more centers or one or more DCHs that have separate physical locations.

Centers include child care centers, adult day care centers, outside-school-hours centers, at-risk centers, and emergency shelters. A center may be owned and operated by the CACFP Operator or legally and administratively separate from the sponsor except for the operation of the CACFP.

  1. Making Site Visits

A site is a center or DCH that is approved to participate in the CACFP. A sponsor must review program operations at each of its sponsored sites at least three times per year. A year is defined as a consecutive twelve-month period that may or may not coincide with the federal program year of October 1–September 30.

To meet the review requirements of 7 CFR, Section 226.16(d)(4)(iii), a sponsor must:

    • Conduct at least three visits, two of which must be unannounced
    • Ensure that at least one of the unannounced visits includes a meal service observation
    • Ensure that the timing of unannounced visits is varied so that they are unpredictable to the center or DCH
    • Review all new sites during the first four weeks of the site beginning operation in the CACFP
    • Ensure that no more than six months elapse between visits to each of the sites  
  1. Reviewing Site Operations

Sponsors must inform sites, both centers and DCHs, that unannounced visits per 7 CFR, Section 226.16(d)(4)(vi) are a CACFP administrative requirement and should be anticipated. Sponsors and state and federal representatives may only conduct unannounced visits during a site’s normal hours of operation and must show photo identification that confirms their employment with the sponsor or the governmental agency.

According to 7 CFR, Section 226.16(d)(4)(i), a sponsor must assess the site’s compliance with the following basic program requirements during each site review:

    • The meal pattern
    • Licensing or approval
    • Attendance at training
    • Meal counts
    • Menus and menu production records
    • The annual updating and content of enrollment forms

A reconciliation of meal counts at each site is required by 7 CFR, Section 226.16(d)(4)(ii). The sponsor must reconcile the meal counts at each of its sites for five consecutive days during a current or prior claiming month.

To reconcile meal counts, the sponsor must use enrollment and attendance records to determine the number of participants in care during each claimed meal service, then match those numbers against the claimed breakfasts, lunches, snacks, or suppers in order to ascertain whether or not the meal counts are accurate. Meal count errors may be grounds for an overclaim and result in a declaration of serious deficiency (SD).

  1. Review Averaging

In accordance with 7 CFR, Section 226.16(d)(4)(iv), sponsors are permitted to conduct review averaging in meeting their monitoring requirements. Review averaging allows a sponsor to conduct fewer than three visits at some sites, while conducting more visits at sites needing greater monitoring of program operations. The sponsor must ensure that the total number of visits performed averages three reviews for all of its sites that year and that it conducts an average of two unannounced visits of all of its sites during that year.

For example, a sponsor may conduct two unannounced visits to one of its sites and find no SDs; however, two unannounced visits to a different site may indicate a need for increased monitoring and follow-up. The sponsor has the option to skip the third visit to the compliant site and instead perform a fourth visit to the site that needs greater monitoring. While one site is receiving only two visits and the other is receiving four, the total number of visits for both sites still results in an average of three per year.

If a site is monitored only twice during a review year due to review averaging, its review in the next review year must occur no more than nine months after the previous review. For example, if the last site review occurred in February of the prior year, the first review of the site in the next review year must take place by November.

  1. Monitoring Review Reports

Regardless of the monitoring schedule a sponsor uses, the sponsor must complete a monitoring review report for each site review, in fulfillment of the recordkeeping requirements in 7 CFR, sections 226.10(d), 226.15(e), and 226.16(e). A sample report is in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS) as Form ID CACFP 16: Center Monitoring Review Report for center sponsors, or Form ID DCH 13: Provider Monitoring Review Report for DCH sponsors. At-risk afterschool centers, school-age centers, and emergency shelters are not required to maintain enrollment documents and will instead reconcile meal counts to attendance records.

Daily meal counts should not exceed the center’s or DCH provider’s enrollment or attendance. For example, if a center’s enrollment is 55 and the attendance for a given day is 50, the meal count for each meal type claimed that day should not exceed 50.

If the five-day reconciliation uncovers meal count findings or other program issues with the center’s or DCH provider’s operation, the sponsor must take appropriate action to correct the problems. Otherwise, uncorrected findings may cause the Nutrition Services Division (NSD) to designate the sponsor as seriously deficient, which may result in termination of its participation in the CACFP.

For more information regarding the five-day reconciliation process, refer to U.S. Department of Agriculture (USDA) Policy Memorandum CACFP 10-2018: Conducting Five-day Reconciliation in the CACFP, with Questions and Answers, on the USDA CACFP Policy web page at

  1. Follow-up Reviews

Per 7 CFR, Section 226.16(d)(4)(v), if a sponsor uncovers one or more SDs during a site review, the next visit to the site must be unannounced. A list of SDs can be found in 7 CFR, Section 226.16(l)(2). In order to declare the DCH seriously deficient, sponsors of DCHs must follow the SD process found in MB CACFP-05-2015: Updates to the SD Process—DCH Providers. This MB is located on the CDE CACFP Bulletins web page on

Consequences if Monitoring Requirements are Not Met

Pursuant to 7 CFR, Section 226.6(c)(3)(ii)(O), any failure of a CACFP Operator to adhere to the monitoring requirements cited above may result in the CDE NSD declaring their agency seriously deficient. If the operator fails to fully and permanently correct the SD, the CDE NSD may propose to terminate the operator’s CACFP agreement and disqualify the agency and its responsible principal(s) from future CACFP participation. The agency and its responsible principal(s) will also be on the USDA’s National Disqualified List for up to seven years.

Contact Information

If you have any questions regarding this subject, please contact your assigned CACFP Specialist. A contact list of assigned specialists is located in the Download Forms section of the CNIPS, Form ID CACFP 01. You may also contact Nancy Charpentier, CACFP Office Technician, by phone at 916-327-2991 or by email at

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Friday, April 19, 2019
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