Training and Monitoring RequirementsFor Agencies Participating in the Child and Adult Care Food Program.
Nutrition Services Division Management Bulletin
Purpose: Policy, Beneficial Information
To: Child and Adult Care Food Program Operator
Attention: Authorized Representative and Program Contact
Date: September 2018
Reference: U.S. Department of Agriculture Final Rule: Child and Adult Care Food Program: Improving Management and Program Integrity: Title 7, Code of Federal Regulations, Part 226.6(m)(3)(viii), 226.15(e)(4), (12) and (14), 226.16(d)(2)–(4)(i)(C) and (4)(iv), 226.18(b)(2), 226.19(b)(7), and 226.19a(b)(11); Management Bulletin USDA-CACFP-06-2010: Serious Deficiency Process–Day Care Home Providers
Supersedes: Management Bulletins 01-205: Attendance at Nutrition Services Division Training; 04-206: Mandatory Institution Attendance at State Agency Child and Adult Care Food Program Training; 05-207: Training and Monitoring
Subject: Training and Monitoring Requirements for Participation in the Child and Adult Care Food Program
This management bulletin (MB) clarifies the current program requirements for mandatory training of all Child and Adult Care Food Program (CACFP) staff and reviews the monitoring requirements for sponsored facilities. This MB supersedes MB 01-205: Attendance at Nutrition Services Division (NSD) Training; MB 04-206: Mandatory Institution Attendance at State Agency CACFP Training; and MB 05-207: Training and Monitoring.
CACFP Operators include child care centers, adult day care centers, child and adult day care center sponsors (collectively referred to as a center), and day care home (DCH) sponsors. The training requirements apply to all CACFP Operators. Monitoring requirements apply only to sponsors of centers or DCHs.
A CACFP Operator must train the program staff of a new site in the duties and responsibilities of the CACFP prior to the site’s participation in the program. The training must include record keeping requirements, claim reimbursement procedures, meal pattern requirements, civil rights requirements and procedures, and monitoring requirements as applicable.
Annual Training by Program Operators
A CACFP Operator must train program staff on the CACFP requirements on an annual basis. Training can be conducted throughout the year or in one annual session prior to the new program year. Training topics should be appropriate to the experience and duties of the staff and, at a minimum, should include:
- Meal patterns
- Record keeping
- Meal counts
- Reimbursement system
- Claim submission and review procedures
- Civil Rights compliance
Annual Training by the Nutrition Services Division
Key staff are required to complete any online or in-person, annual mandatory training given by the California Department of Education (CDE) NSD. Key staff are defined as the CACFP Operator’s authorized representative or staff who are designated by the agency to complete the training. Key staff with direct CACFP-related responsibilities at the agency must participate in the NSD mandatory training. The operator must have a procedure requiring key staff to train other relevant staff on the information shared at the mandatory CDE NSD training.
The monitoring requirement applies 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.
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 through September 30.
To meet the review requirements, 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 observation
- Ensure 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
Reviewing Site Operations
Sponsors must inform sites, both centers and DCHs, that unannounced visits are allowable 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 the U.S. Department of Agriculture Final Rule, Title 7, Code of Federal Regulations (7 CFR), Section 226.16(d)(4)(i)(C), a sponsor must assess the site’s compliance with the following basic program requirements during each site review:
- Meal pattern implementation
- Meal counts
- Menus and menu production records
- Training attendance and completion
- Maintenance of enrollment records
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 claim 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, and 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).
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 less 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.
Monitoring Review Reports
Regardless of the monitoring schedule a sponsor uses, the sponsor must for each site review complete a monitoring review report. This report is in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS) as Form CACFP 16 for center sponsors, or Form DCH 16 for DCH sponsors. During the visit, the sponsor must conduct a five-day reconciliation to gauge the accuracy of meals claimed. The monitor will select five consecutive days during the current or prior claiming period and use enrollment documents and attendance records to determine the number of children attending each meal service. They will then reconcile those numbers with the meal counts. 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 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, located on the USDA CACFP Policy web page at https://www.fns.usda.gov/cacfp/policy .
If a sponsor uncovers one or more SDs during a site review, the next visit to the site must be unannounced. 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.
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 CACFP 01.