Skip to main content
California Department of Education Logo

Documenting Employee Time and Effort in the Child


Important Notice: CACFP Program Moved to CDSS

The Early Childhood Development Act of 2020 (Senate Bill (SB) 98, Chapter 24, Statutes of 2020) authorized the transfer of child care and development programs administered by the California Department of Education to the California Department of Social Services (CDSS) effective July 1, 2021. The content on this page may not be current and involves the Child and Adult Care Food Program (CACFP) that has moved to CDSS. Visit the CDSS CACFP web page External link opens in new window or tab. or call 1-833-559-2420 for more information.

Nutrition Services Division Management Bulletin

Purpose: Policy, Action Required, Beneficial Information

To: Child and Adult Care Food Program Agencies

Attention: Authorized Representative and Program Contact

Number: CACFP-03-2015

Date: January 2015

Reference: Title 2, Code of Federal Regulations, Part 225 (also referred to as Office of Management and Budget Circular A-87), Appendix B, Item 8.h, Cost Principles for State, Local, and Indian Tribal Governments; U.S. Department of Agriculture Food and Nutrition Service Instruction 796-4, Revision 4, Section VI C2 and IX B 3c(4), and Section VIII I 23c (2) and (3); Title 2, Code of Federal Regulations, Part 230 (also referred to as Office of Management and Budget Circular A-122), Appendix 8.m; and Title 7, Code of Federal Regulations, Section 226.10(d).

Supersedes: California Department of Education Office of Child Nutrition Services Notification Number 84-223, November 1984, and Child Nutrition and Food Distribution Division Policy Memorandum 38-708: Allowable Administrative Costs Instruction for Day Care Home Sponsors,June 1988

Subject: Documenting Employee Time and Effort in the Child and Adult Care Food Program


This Management Bulletin (MB) provides updated guidance to agencies participating in the Child and Adult Care Food Program (CACFP) regarding federal requirements pertaining to documentation of time and effort for employees whose salaries and wages are paid for with CACFP funds. This MB supersedes California Department of Education (CDE) Office of Child Nutrition Services Notification Number 84-223, issued in November 1984, and Child Nutrition and Food Distribution Division Policy Memorandum 38-708: Allowable Administrative Costs Instruction for Day Care Home Sponsors issued in June 1988.

Note: School food authorities that participate in the CACFP (i.e., food service directors, school business officials, district superintendents, and school administrators) must follow the time and effort documentation requirements explained in SNP-06-2014, located on the CDE School Nutrition Programs Management Bulletins Web page at http://www.cde.ca.gov/ls/nu/sn/mb.asp.

All other agencies participating in the CACFP must follow the requirements explained below:

Background

Title 2, Code of Federal Regulations (2 CFR), Part 225, Appendix B, Item 8.h, requires employees who are paid with federal funds to document their time and effort within the federal program. The federally funded portion of the employee’s salary must be equivalent to the actual time and effort the individual spends on duties directly associated with that federal program.

Personnel Activity Report Definition

All CACFP employees whose compensation is paid at least in part with CACFP funds must maintain time distribution reports—also known as personnel activity reports (PAR). The purpose of a PAR is to ensure that agencies participating in the CACFP do not use CACFP funds to compensate employees for time spent working on non-CACFP activities, which is not allowed under the terms and conditions of the CACFP federal award (U.S. Department of Agriculture [USDA] Food and Nutrition Service (FNS) Instruction 796-2, Revision 4 [FNS 796-2, Rev. 4], Section VIII I 23 c[2] and [3]).

A PAR should provide an after-the-fact certification of an employee’s actual labor. PARs must be signed after the employee’s tasks are completed. A separate PAR must be kept for each employee and the PAR requirements apply to both exempt (i.e., salaried) and nonexempt (i.e., paid hourly) employees per 2 CFR, Part 230, Appendix B, Item 8.m.

A PAR is not required if an employee charges 100 percent of his or her labor to the CACFP, and the CACFP activities are listed on the employee’s duty statement. In this case, the agency may use a standard timesheet to document the hours the employee worked. The timesheet must accurately reflect labor worked and must be signed at the end of the pay period by the employee and supervisor after the tasks are completed.

Personnel Activity Report Documentation Requirements

The requirements for a PAR or equivalent documentation, which can be found in 2 CFR, Part 225, Appendix B, Item 8.h(5), and FNS 796-2, Rev. 4, Section VIII I 23 c(3), state that a PAR must: 

  • State the employer’s name and the employee’s name and position

  • Show the actual after-the-fact breakdown of the employee’s hourly work schedule for CACFP and non-CACFP activities, and the actual after-the-fact breakdown of the employee’s administrative and operating labor worked within the CACFP activities

  • Account for the total activity for which the employee is compensated, including part-time work or overtime (total activity means all of the time an employee worked, not just the amount of time the employee spends on activities directly associated with the CACFP)

  • Be prepared at least monthly and coincide with one or more pay periods

  • Be signed and dated by the employee and supervisor after the tasks are completed
Budgeted or estimated labor reporting is not allowable. For example, an employee may not estimate that they complete approximately four hours every day for CACFP activities and four hours every day for non-CACFP activities. The PAR must accurately reflect the actual hours worked on CACFP and non-CACFP activities each day.

Neither the CDE nor federal regulations require agencies participating in the CACFP to use a specific PAR form. A sample PAR is available in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS), Form ID CACFP 73. The agency may use this sample PAR, or its own PAR, as long as the PAR satisfies all of the federal requirements found in 2 CFR, Part 225, Appendix B, Item 8.h(5), and in FNS 796-2, Rev. 4, Section VIII I 23 c(3).

The CACFP participating agency must keep all PARs, timesheet documents, and duty statements on site for at least three years plus the current fiscal year, or longer, pending the outcome of an administrative review or audit (2 CFR Section 226.10[d]).

Other Personnel Activity Report Documentation Requirements for Center Sponsors and Sponsors of Unaffiliated Centers

Administrative funds are provided to day care home sponsors based on the current USDA reimbursement rate multiplied by the number of providers approved on their program. Sponsoring agencies of centers may apply no more than 15 percent of their annual reimbursement to administrative costs (FNS 796-2, Rev. 4, sections VI C 2 and IX B 3 c[4]). Administrative costs consist of all administrative activities including: 

  • Eligibility determinations
  • Claim preparations
  • Monitoring
  • Training

Operating costs that include food and food service labor are not considered administrative costs. Sponsoring agencies may use any amount of reimbursement to cover operating costs.

Summary

Federal regulations pertaining to documentation of employee time and effort require that employees paid in part from CACFP funds must document all labor charges through the use of PARs or equivalent documentation. If an agency participating in the CACFP pays for the CACFP share of its labor costs with CACFP funds and fails to maintain proper PARs, the CDE Nutrition Services Division may issue a finding that disallows the costs and may bill the agency’s general fund for repayment.

Contact Information

If you have any questions regarding this MB, please contact your CACFP specialist. A contact list of CACFP specialists is available in the Download Forms section of the CNIPS, Form ID CACFP 01. You can also contact Kayla Christensen, Community Nutrition Programs Administration Unit Office Technician, by phone at 916-324-6153 or by e-mail at KChristensen@cde.ca.gov to be directed to your CACFP specialist.

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Thursday, June 10, 2021
Related Content
Recently Posted in Nutrition
  • Pandemic EBT Local Administrative Grant (added 18-Jan-2022)
    Pandemic EBT Local Administrative Cost Grant Award for School Year 2020–21. The CDE will issue P-EBT Local Administrative Cost Grant awards to eligible LEAs in March 2022.
  • Interstate Meat Dist. Inc. Recalls Ground Beef (added 10-Jan-2022)
    Interstate Meat Dist. Inc. recalls ground beef products due to possible E. Coli O157:H7 contamination.
  • Updates to the Federal Micropurchase Threshold (added 03-Jan-2022)
    This information contains updates to the official policies surrounding the new micropurchase threshold.
  • ECR Funds Now Available for Eligible SNP Operators (added 22-Dec-2021)
    The California Department of Education (CDE) has disbursed the Emergency Operational Costs Reimbursement (ECR) Program funds to all eligible School Nutrition Program (SNP) Operators through the Child Nutrition Information and Payment System (CNIPS).
  • ECR Funds Available for Eligible CACFP Operators (added 22-Dec-2021)
    The California Department of Education (CDE) has disbursed the Emergency Operational Costs Reimbursement Program funds to all eligible Child and Adult Care Food Program Operators through the Child Nutrition Information and Payment System.

  • USDA Policy Memo SP 11-2021 Extensions (added 21-Dec-2021)
    This web page advises SFAs of the extension issued by USDA FNS that 1) extends the ability to serve 1% low-fat flavored milk and 2) extends the prohibition on the use of poultry products from China in the CNPs through February 18, 2022.
  • Webinar: Universal Meals Listening Session #1 (added 21-Dec-2021)
    Recorded by the California Department of Education, Nutrition Services Division on October 5, 2021 is a discussion on California Universal Meals Program and best practices for implementation in the school year 2022-2023.
  • Webinar: Tuesdays at 2 School Nutrition Town Hall (added 21-Dec-2021)
    Recorded by the California Department of Education, Nutrition Services Division on October 26, 2021 is a discussion on best practices for operating school nutrition programs to navigate nationwide waivers and planning quality services for SY 2021–22.
  • Webinar: Universal Meals Listening Session #2 (added 21-Dec-2021)
    Recorded by the California Department of Education, Nutrition Services Division on October 5, 2021 is a discussion on California Universal Meals Program and best practices for implementation in the school year 2022-2023.
  • Universal Meals Listening Session January 11, 2022 (added 14-Dec-2021)
    On January 11, 2022 at 2 p.m. the Nutrition Services Division (NSD) is hosting the third in a series of listening sessions for the newly established California Universal Meals Program.