Revised: 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, sections 226.6(c)(3)(ii)(O), 226.15(e)(12) and (14), 226.16(d)(2)–(4)(i-vii), 226.16(e), 226.16(l)(2), 226.17(b)(10), 226.18(b)(2), and 226.19a(b)(11); Management Bulletin CACFP-05-2015: Updates to the Serious Deficiency Process–Day Care Home Providers; USDA Policy Memorandum CACFP 10-2018: Conducting Five-day Reconciliation in the CACFP, with Questions and Answers
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: Revised: 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 mandatory training requirements apply to all CACFP Operators. The monitoring requirements apply only to sponsors of centers or DCHs.
A CACFP sponsor must meet the requirements of the U.S. Department of Agriculture (USDA) Final Rule, Title 7, Code of Federal Regulations (7 CFR), Section 226.16(d)(2) by training the key 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, at a minimum, must include instruction on CACFP meal patterns, recordkeeping, meal counts, an explanation of the reimbursement system, claims submission and review procedures, and civil rights compliance.
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 should have a written procedure requiring key staff to train other relevant staff in the agency on the information shared at the annual mandatory NSD training.
Annual Training Provided to CACFP Staff by CACFP Operators
As required by 7 CFR, sections 226.17(b)(10), 226.18(b)(2), and 226.19a(b)(11), a CACFP Operator must train key staff involved in the administration of the CACFP on the CACFP requirements at a minimum of one training annually during the Program Year October 1–September 30 and maintain documentation of the date, topics, and staff in attendance at each training for the current program year plus three program years. The California Department of Education (CDE) developed a template to track training(s), Form ID CACFP 57, which is available in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS).
Training may be conducted throughout the year or in one annual session. There is not a requirement for the length of the training(s) provided.
In accordance with 7 CFR, Section 226.15(e)(12) and (14), operators must maintain records regarding training sessions, and training topics must be appropriate to the experience and duties of the staff. Training topics, at a minimum, must include:
- CACFP meal patterns
- Meal counts
- Reimbursement system
- Claims submission and review procedures
- Civil Rights compliance (required for all CACFP staff at the site)
Annual Mandatory Training by the CDE NSD
In accordance with 7 CFR, sections 226.17(b)(10), 226.18(b)(2), and 226.19a(b)(11), key CACFP staff are required to complete any online or in-person, annual mandatory training given by the CDE NSD. Through the Fresno City College California Professional Nutrition Education and Training (Cal-Pro-NET) Center, the NSD offers online mandatory training each program year as well as other elective training for child nutrition professionals in child care centers, DCH sponsoring agencies, adult day care centers, emergency shelters, and at-risk afterschool care centers participating in the CACFP. Please note the elective trainings do not count towards the mandatory training. For more information, please visit the Cal-Pro Net Center web page at https://www.fresnocitycollege.edu/academics/career-and-technical-education/cal-pro-net-center/index.html.
In order to document that the CACFP Operator completed the annual mandatory NSD training, the operator must maintain the NSD-issued certificate of completion for the current program year plus three program years.
Note: For CACFP Operators in their first program year of participation, the NSD preapproval visit to their agency counts as the annual mandatory training.
The monitoring requirements of 7 CFR, Section 226.16(2)-(4)(i-vii) 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.
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 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 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
- 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, and/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).
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 complete a monitoring review report for each site review, in fulfillment of the recordkeeping requirements in 7 CFR, sections 226.15(e) and 226.16(e). A sample report is in the Download Forms section of the CNIPS as Form ID CACFP 16 for center sponsors, or Form ID DCH 13 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 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 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 https://www.fns.usda.gov/cacfp/policy.
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 Serious Deficiency Process—Day Care Home Providers.
Consequences if Training and 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 training and 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.
Child Nutrition Programs Course Catalog web page at https://www.cde.ca.gov/ls/nu/ed/cnpcoursecatalog.asp
CACFP Administrative Manual (Centers and Day Care Home Sponsors) web page at https://www.cde.ca.gov/ls/nu/cc/cacfpmanualtablecontent.asp
CACFP Meal Patterns web page at https://www.cde.ca.gov/ls/nu/he/cacfpresource.asp
Cal-Pro-NET Center Resources
Fresno City College CACFP Online Courses web page at https://www.fresnocitycollege.edu/academics/career-and-technical-education/cal-pro-net-center/elective-courses.html
Program Integrity Now (PIN) Training
This free two-day training strengthens managerial and operational practices, and provides regulatory and nutritional information for CACFP child care staff. The training covers eligibility and enrollment requirements, monitoring and training requirements, financial management, child nutrition, recordkeeping, and administrative reviews. Register for this training at the following Fresno City College PIN training web page at https://www.fresnocitycollege.edu/academics/career-and-technical-education/cal-pro-net-center/pin-training.html.
USDA Resources (Team Nutrition)
The USDA Team Nutrition developed materials for CACFP operators to implement the CACFP meal pattern. These materials can be found on the Team Nutrition CACFP Training Tools web page at https://www.fns.usda.gov/cacfp-training-tools.
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.