Missouri Department of Health and Senior Services Child and Adult Care Food Program Manual for At-Risk Afterschool Care Centers and Outside School Hours Care Centers

In accordance with federal civil rights law and USDA civil rights regulations and policies, the USDA, its agencies, offices, employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident.

Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the state or local agency that administers the program or contact USDA through the Telecommunications Relay Service at 711 (voice and TTY). Additionally, program information may be made available in languages other than English.

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at How to File a Program Discrimination Complaint and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632- 9992. Submit your completed form or letter to USDA by:

1. Mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Mail Stop 9410, Washington, D.C. 20250-9410;
2. Fax: (202) 690-7442; or
3. Email: program.intake@usda.gov. 

USDA is an equal opportunity provider, employer, and lender

CACFP serves nutritious meals and snacks to eligible children who participate in an approved afterschool program and are 18 or older at the start of the school year.

Afterschool Care Centers and Outside School Hours Care Centers participating in CACFP must follow program regulations.

How to Contact the Program

For questions about the Child and Adult Care Food Program (CACFP), requests for technical assistance, or instructions on how to schedule training, please contact:

Missouri Department of Health and Senior Services
Community and Public Health
Community Food and Nutrition Assistance

P.O. Box 570
930 Wildwood Drive
Jefferson City, MO 65102

1-800-733-6251
1-573-751-6269
Fax: 573-526-3679
Email: cacfp@health.mo.gov

For information about the CACFP, visit our website.

Contact Information for District Nutritionists

Contact information for the District Nutritionists is available at the CACFP website on the right side of the screen under Contact.

Training

1. Training for the At-Risk Afterschool Care Program and the Outside School Hours Program will be provided via Webex. Contact CFNA to register.
2. Online CACFP Training for At-Risk Afterschool Care Program and the Outside School Hours Program is available at the CACFP website under Training.
3. Online Civil Rights Training is available at the CACFP website under Training.

Training Objectives

• Understand the staff, site supervisor, and director's responsibilities for the afterschool program or sponsoring organization’s (SO) participation in the Child and Adult Care Food Program (CACFP).
• Understand the responsibilities of the Department of Health and Senior Services Community Food and Nutrition Assistance (DHSS-CFNA) in administering the CACFP.
• Understand how sponsors meet and comply with CACFP performance standards.
• Understand the importance of accurate recordkeeping and its role in verifying the facility’s claims for reimbursement.
• Identify the records that must be maintained by facility staff to meet regulatory requirements. Explain the procedures for completing each record.
• Understand Civil Rights compliance requirements.
• Use the meal pattern requirements and menu planning process to create nutritious and creditable meals.
• Explain how to use the United States Department of Agriculture Food Buying Guide (FBG) for Child Nutrition Programs and the Crediting Handbook for the CACFP to assist with menu planning.
• Explain the importance of good nutrition in the afterschool program setting.

Benefits of the Child and Adult Care Food Program

The Child and Adult Care Food Program (CACFP) can help your afterschool centers and the families you serve.

Afterschool care centers provide a much-needed service to their communities. They give children a safe place to go after school and nutritious food that gives them the energy they need to concentrate on homework and join their friends in physical, educational, and social activities. The Food and Nutrition Administration (FNA) acknowledges the dedication and commitment of sponsors and centers, ensuring that the meals claimed for reimbursement meet the CACFP requirements and that meal time is a pleasant, nutritious, and sociable experience for the children in their care. At-Risk Afterschool Care Centers and Outside School Hours Care Centers serve an important role in helping children develop good eating and physical activity habits.

The CACFP plays a vital role in improving the quality of organized afterschool programs, making them more affordable for organizations. Benefits include:

• Centers may be approved to claim up to one meal and one snack per participant in attendance each day.
• Training and technical assistance are available on nutrition, food service operations, program management, nutrition education, and recordkeeping.
• Improved health and well-being of children through age 18 by providing nutritious, well-balanced meals.
• Development of healthy eating habits in children that will last through a lifetime.

Key points to remember about the CACFP:

• The organizations participating in CACFP may be called sponsors. A CACFP sponsor can be either an independent facility or a sponsoring organization (SO) of two or more facilities.
• The primary goal is to provide nutritious meals and snacks. The mission of the Food and Nutrition Administration (FNA) is to provide children and families better access to food and a more healthful diet through its food assistance programs, such as CACFP, and nutrition education efforts in compliance with 7 CFR 226.
• The CACFP is a supplementary program, not an entitlement program, which requires accurate recordkeeping and program compliance.
• United States Department of Agriculture’s (USDA) FNA administers the CACFP at the national level, and the Department of Health and Senior Services-Community Food and Nutrition Assistance (DHSS-CFNA) is the State Agency (SA) that administers the program in Missouri.
• The CACFP is regulated by Congress and the USDA.
• The DHSS-CFNA will conduct CACFP monitoring reviews at all participating independent centers and sponsoring organizations pursuant to 7 CFR 226.

Performance Standards

Financial Viability, Administrative Capability, Program Accountability

The executive director and the board chair or owner of the CACFP facility or sponsoring organization (SO) and those named as a responsible individual and food program contact must, due to their position in the facility, accept final administrative and financial responsibility for the Child and Adult Care Food Program (CACFP) and ensure that the CACFP is operated with program integrity.

Each new independent facility, SO of two or more facilities, or renewing facility must submit information sufficient to document that it is financially viable, is administratively capable of operating the program in accordance with CACFP regulations, and has internal controls in place to ensure accountability. To document this, any new sponsor, which may include an independent facility or an SO of two or more facilities, must demonstrate in its application that it is capable of operating in conformance with the CACFP performance standards.

The Department of Health and Senior Services-Community Food and Assistance (DHSS-CFNA) must only approve the applications of those new sponsors that meet these performance standards and deny the applications of those new sponsors that do not meet the standards. In ensuring compliance with these performance standards, the DHSS-CFNA establishes rules and procedures and makes decisions based on information from internal controls at the federal and state level that includes information obtained during the application process, information from audits and complaints, results of edit checks, claim reviews, monitoring reviews; and notice of civil and criminal action.

Each new independent facility, SO of two or more facilities, or renewing facility must submit information sufficient to document that they are operating in accordance with the CACFP Performance Standards – Viability, Capability, and Accountability (VCA) outlined in 7 CFR 226.6(b)(1):

1. The organization must be Financially Viable. The facility must have a budget and demonstrate it has adequate financial resources to operate the CACFP on a daily basis, has adequate sources of funds to continue to pay employees and suppliers during periods of temporary interruptions in CACFP payments and/or to pay debts when fiscal claims have been assessed against the sponsor, and can document financial viability through audits or financial statements. Sponsors must ensure that CACFP funds are expended and accounted for in accordance with CACFP regulations, 2 CFR 400, and the requirements in FNA Instruction 796-2, rev. 4.
   
   The organization should expect that DHSS-CFNA will review the SO’s financial records at least annually.
2. The organization must be Administratively Capable. The facility must have appropriate and effective management practices in place to provide program benefits to all participants and an adequate number and type of qualified staff to operate the CACFP. An SO of two or more facilities must document in its management plan that it employs staff sufficient to meet the ratio of monitors to facilities, taking into account the factors that DHSS-CFNA will consider in determining an SO’s staffing needs, as set forth in CACFP regulations. An SO must have written program policies and procedures that assign program responsibilities and duties. An SO’s policies and procedures must also ensure compliance with civil rights requirements.
3. The organization’s program must be Accountable. The facility must have internal controls and other management systems in effect to ensure fiscal accountability and ensure that the CACFP will operate in accordance with requirements. To demonstrate program accountability, the sponsor must document that it meets the following criteria:
   1. Board of Directors – have adequate oversight of the program by an independent governing board of directors.
   2. Fiscal Accountability – have a financial system with management controls specified in writing. These written operational policies must ensure the following:
      • Fiscal integrity and accountability for all funds and property received, held, and disbursed.
      • The integrity and accountability of all expenses incurred.
      • Claims will be processed accurately and in a timely manner.
      • Funds and property are properly safeguarded and used.
      • Expenses incurred are for authorized program purposes.
      • A system of safeguards and controls is in place to prevent and detect improper financial activities by employees.

   3. Recordkeeping - maintains appropriate records to document compliance with CACFP requirements, including budgets, accounting records, approved budget amendments, management plans, and appropriate records on facility operations. There must be documentation in the management plan that the organization will provide adequate and regular training of its staff and sponsored facilities.

      Documents that prove compliance with CACFP regulations, including, but not limited to, menus, production records, delivery receipts, income eligibility forms, meal count records, and attendance records, must be completed in permanent ink and shall not be altered. If additions/corrections are required, they must be made using permanent ink. The incorrect information must be crossed out using one line so that the original information can still be read. Changes using pencils or whiteout shall be prohibited. All changes must be initialed and dated by the person making the correction.

   4. SO operations - documentation in the management plan that the SO will perform monitoring to ensure the sponsored facilities accountably and appropriately operate the program, and have a system in place to ensure that administrative costs do not exceed the regulatory 15 percent limitation.
   5. Meal Service and other operational requirements - follow the practices that result in the operation of the program in accordance with the meal service, recordkeeping, and other operational requirements of the federal regulations. These practices must be documented and must demonstrate that the independent facility or sponsored facilities will:
      • Provide meals that meet meal pattern requirements.
      • Comply with licensure or approved requirements.
      • Have food service that complies with applicable state and local health and sanitation requirements.
      • Comply with civil rights requirements.
      • Maintain complete and appropriate records on file.
      • Submit claim reimbursement only for eligible meals.

Program Integrity

CACFP regulations define Seriously Deficient (SD) as the status of an independent facility or SO of two or more facilities that has been determined to be non-compliant in one or more aspects of its operation of the program. If a sponsor is unwilling or unable to correct serious problems, the SD process protects program integrity by removing the institution from the program.

The chairman of the Board of Directors, the executive director, or owner, as well as other person(s) responsible for the Child and Adult Care Food Program (CACFP) operation, such as the responsible individual and the food program contact, noted on the Center and/or Sponsor Info Sheets on the Application/Claims database are considered the “responsible individual(s)” or “responsible principal(s)” of the organization. By virtue of the management position as a “responsible principal,” you have administrative and financial responsibility for the oversight, management, and integrity of the CACFP and compliance with applicable regulations.

Should a sponsor ever be classified as SD and terminated due to mismanagement of the CACFP, the name(s) of the “responsible principal(s)” and “responsible individual(s)” will be placed on the United States Department of Agriculture’s (USDA) National Disqualified List (NDL). Once on the NDL, the named responsible parties would not be able to work directly with CACFP or any other Child Nutrition Program for up to seven years.

Financial Review

In August of 2023, the USDA-FNA published a final rule on program integrity to ensure that child nutrition programs are properly operated and managed, protecting federal taxpayer dollars. As part of this final rule, the state agency is required to review your financial records at least annually. The following records must be made available upon request:

• At least one month of all bank account activity associated with CACFP will be reviewed against other associated records to verify that the financial transactions meet program requirements.
• The actual expenditures of CACFP funds and the amount of reimbursement funds retained from unaffiliated centers to support the sponsoring organization’s administrative costs will be reviewed.
• The reported expenditures will be reconciled with program payments to ensure that funds are accounted for fully.

Management Tools and Resources

CACFP sponsors enter into a contract with Department of Health and Senior Services Community Food and Nutrition Assistance (DHSS-CFNA) to participate in the CACFP. The following management tools and resources are available on the Missouri CACFP website .

• Child and Adult Care Food Program Manual for At-Risk Afterschool Care Centers and Outside School Hours Care Centers
• United States Department of Agriculture Food Buying Guide for Child Nutrition Programs
• Crediting Handbook for the Child and Adult Care Food Program
• “And Justice For All” poster
• Building for the Future flyer and pamphlet
• Missouri WIC outreach poster

Single Audit Compliance

Under 2 CFR 200.501—Audit Requirements, SFSP Sponsors are required to submit a Single Audit within nine months of the close of your fiscal year for any fiscal year in which you expend $1,00,000.00 or more in federal funds.

A Single Audit is when a professional auditor reviews a grantee’s financial management processes, including its financial management system and compliance with all federal grant requirements. It is called a Single Audit because it combines one audit covering all of a grantee’s federal grants. The purpose is to ensure that grantees receiving federal grant funds use the funds in compliance with the government’s requirements. It was created to promote sound financial management, establish uniform audit guidelines and deploy audit resources efficiently.

Failure to comply will result in a declaration of Serious Deficiency by the state and possible program termination.

Sponsor Agreements

Afterschool sponsors may be affiliated or unaffiliated with the centers/sites that provide the afterschool program. A sponsor of unaffiliated centers must enter into a formal agreement with the centers conducting the afterschool program activities. A sponsor of affiliated centers is not required to enter into a formal agreement; however, if an afterschool care program is operating at a location they do not own, such as a school, they must enter into an agreement with the site owner, manager, or school contact to use that location.

Unaffiliated Sponsoring Organization Agreements

Afterschool sponsors who do not own the afterschool program and do not provide the enrichment portion of the program must enter into an agreement with afterschool centers for the centers to participate in the CACFP. Two examples of the agreement, one for Self Prep and one for Meals Provided by Sponsor, are provided in this manual. You may use one of the state agreement forms or develop one of your own as long as it contains all of the required information.

Affiliated Sponsoring Organization Agreements

Afterschool sponsors who provide the meal and enrichment activity portion of the program, but do not own the location where the program is held, are required to have an agreement with the site at which they are providing the meals and enrichment activity.

The afterschool sponsor must sign an agreement with the property owner, manager, or school contact to provide permission to disperse meals at this location. An example of that agreement follows the two unaffiliated agreements.

Discovering Problems

The following is a management assessment tool that describes some of the more common indicators of program mismanagement identified through federal and state-level internal controls.

Child and Adult Care Food Program Institutions Indicators of Potential or Existing Problems (Red Flags!)

Budget/Claim for Reimbursement

• Year-to-date claims do not reflect the approved budget.
• Questionable or potentially fraudulent meal-claiming practice (e.g., meals claimed when the facility is closed).
• Expenditures charged to the nonprofit food service that are not listed on the budget approved by the state agency.

Operational Oversight

• No qualified accountant or an adequate accounting information system.
• Lack of internal controls (e.g. inadequate separation of duties, position held by family member limits internal control).
• Related party transactions (e.g., when the director or family member is the owner of the catering company used for contracted meals or owner of the rented property housing the CACFP facility).
• Absentee management.
• Substantial difference between the number of participants observed at meal time during the monitoring review and the Average Daily Participation (ADP) for the same meal for the review month.

Audits

• Required audits or monitoring reviews are not performed by SOs.
• Management/Board of Directors does not follow up on corrective action taken.

Other

• Health and safety concerns reported from any source.

At-Risk Afterschool Care Centers and Outside School Hours Care Centers participating in CACFP are required to maintain records to verify that the meals and snacks served to resident participants meet guidelines and to justify the claim for reimbursement.

Eligibility Requirements

Program Eligibility

To be eligible to participate in the At-Risk Afterschool meals component of the Child and Adult Care Food Program (CACFP), an At-Risk Afterschool program must:

• Be organized, primarily to provide care for children after school and, with the Community Food and Nutrition Assistance (CFNA) approval, on weekends, holidays or school vacations during the regular school year.
• Provide organized, regularly scheduled education or enrichment activities in a structured and supervised environment.
• Be located in an attendance area of a school where at least 50 percent or more of the enrolled students are eligible for free or reduced-price meals.

Activities

The programs must provide educational or enrichment activities that are open to all children in an organized, structured, and supervised environment. Although there are no specific requirements for the type of educational or enrichment activities a program can offer, examples include but are not limited to arts and crafts, homework assistance, life skills, computers, tutoring, and organized fitness activities. There is no requirement that all children receiving meals participate in the offered activities. Sponsors may contract with another organization to provide enrichment or educational activities for the afterschool program. However, the sponsoring organization or independent center must retain administrative and fiscal responsibility for the meal service.

Athletic Programs

Organized athletic programs that only participate in the interscholastic or community level competitive sports, for example, youth sports leagues such as “Babe Ruth” and “Pop Warner” baseball leagues, community soccer and football leagues, area swim teams, etc., may not be approved as sponsors or independent in the program. However, students who are part of school sports teams and clubs can receive afterschool snacks or meals as part of a broad, overarching educational or enrichment program, but the program cannot be limited to a sports team.

Weekends, Holidays, and Vacations

The CACFP At-Risk Afterschool meals and snacks may be reimbursed if they are served on weekends or holidays, including vacation periods, for example, spring break, during the regular school year only and may be served at any time of day when approved by CFNA. Enrichment activities must be provided during these times.

Summer Food Service Programs

The CACFP sponsors currently in good standing are well-positioned to offer summer meals. Although CACFP At-Risk Afterschool meals may not be served during the summer months, these organizations may be eligible to serve meals through the Summer Food Service Program (SFSP). The Food and Nutrition Service (FNS) encourages participation in both programs to establish a year-round presence in the communities they serve.

Both organizations and communities benefit when meals are offered to children in low-income communities year-round by participating in both At-Risk Afterschool meals and the SFSP. Organizations benefit from having the ability to hire year-round staff, a continuous flow of reimbursements providing additional financial stability, and recognition in the community as a stable source of resources. Communities benefit by having a partner that provides year-round nutrition services for children and brings increased federal funds into the local economy.

Organization Eligibility

At-Risk Afterschool programs that meet the above requirements must be operated by an eligible organization to receive reimbursement. Eligible organizations must meet state and local licensing or health and safety standards and be operated by one of the following:

• Public agencies such as schools or city governments.
• Tax-exempt nonprofit organizations.
• For-profit centers that meet the requirements described below.
• Are currently participating in another federal program requiring nonprofit status [7CFR 226.17a(a)(iv)].

For-Profit Centers

A for-profit child care center may receive reimbursement for the At-Risk Afterschool meals component of the CACFP if it meets the program eligibility requirements discussed above and is eligible to participate in the CACFP through its traditional child care center. As with the CACFP child care component, this means at least 25 percent of the children served by the for-profit center through its traditional child care components are:

• Eligible for free or reduced-price meals based on their family income; or
• Receive benefits under title XX of the Social Security Act, and the center receives compensation under title XX.

This 25 percent threshold is based on the center’s enrollment or the licensed capacity, whichever is less. It is calculated during the calendar month preceding the application for program participation. In addition, to claim a reimbursement in any calendar month, the center must meet the 25 percent threshold in that month (for more information, see the definition of a for-profit center in 7 CFR 226.2).

In determining a for-profit center’s eligibility for At-Risk Afterschool meal reimbursement, only the enrollment and/or licensed capacity of the traditional child care component of the center may be considered in calculating whether the center meets the 25 percent criterion.

Example: A for-profit child care center is located in a school attendance area where more than 50 percent of the children are eligible for free or reduced-price meals. This for-profit center has 32 preschool children enrolled for care and operates an afterschool program for school-age children. The center would be able to claim reimbursement through the CACFP for meals served under the traditional child care component and for afterschool snacks in any month in which at least eight of the 32 preschool children are eligible for free or reduced-price meals or are Title XX recipients. The school-age children who only participate in the afterschool programs cannot be used in the calculation.

Traditional Child Care Centers

While the At-Risk component of the CACFP is primarily geared towards non-traditional child care centers such as drop-in afterschool programs, traditional child care centers already participating in the CACFP may participate. In this situation, children would attend the center after their school day or on weekends, holidays, or school vacation. Children who do not attend school would continue to participate in the traditional CACFP meal service provided by the center, even during the afterschool hours.

The centers operating both the traditional and At-Risk components of the CACFP may only claim a total of two meals and one snack or one meal and two snacks, per child, per day including the afterschool snack or meal [7 CFR 226.17a(k)].

Schools

Many afterschool programs are operated by school food authorities at school centers. There are existing USDA policies in place to streamline At-Risk Afterschool meal participation for school food authorities.

A school that operates longer than the traditional school day may be eligible for afterschool meal reimbursement, provided that it operates at least one hour longer than the minimum number of school day hours required for the comparable grade levels by the local education agency in which the school is located. In such instances, the snack or supper may be served during school hours.

Other Programs

Generally, afterschool programs that serve only residential children (with the exception of homeless shelters) are not eligible to participate in the CACFP. However, a residential facility may be eligible to serve At-Risk Afterschool meals if it has nonresidential care programs and these programs offer afterschool education and enrichment programs for nonresidential children.

Area Eligibility

As noted above, to be eligible to participate in the At-Risk Afterschool meals component of the CACFP, a program must be located in an eligible area. This means that the center must be located in the attendance area of a public elementary, middle, or high school where at least 50 percent of the students are eligible for free or reduced-price meals under the National School Lunch Program (NSLP). This is referred to as area eligibility. State agencies have current area eligibility data for all public schools to help determine if a center is area-eligible. For information regarding area eligibility, go to the Missouri Department of Elementary and Secondary Education website, then scroll down and click “Free and Reduced Price Lunch Percentage By Building.” Click on “Enable Editing” if the relevant data is not visible.

Area eligibility determinations must be based on the total number of children approved for free or reduced-price school meals for the preceding October or another month designated by the NSLP agency. The CFNA has the discretion to use school data from a more recent month in the school year to establish eligibility for an otherwise ineligible location. In both cases, the site’s area eligibility determination under the CACFP is valid for five years.

If an afterschool program is not area eligible, it may qualify to participate in the CACFP as an Outside School Hours Care Center (OSHCC). OSHCCs, like At-Risk Afterschool Centers (ASCS), provide organized nonresidential child care services to children during hours outside of school. Refer to the OSHCC and ASCS program comparison chart.

Participant Eligibility

At-Risk Afterschool programs may claim reimbursement only for meals and snacks served to children who participate in an approved afterschool program and who are age 18 or under at the start of the school year. Reimbursement may also be claimed for participants who turn 19 years of age during the school year. Programs may be either drop-in or enrolled. There is no requirement that all children receiving meals participate in the scheduled activities, but children should remain on site while consuming food.

Federal law has no minimum age for at-risk program participants. Meals and snacks served to children enrolled in preschool, Even Start, Head Start, etc., and participating in an eligible afterschool program are eligible for reimbursement. An At-Risk Afterschool program is not required to serve the full age range of eligible children. For example, a program could operate at a high school and only serve high school students.

Licensing, Health, and Safety Requirements

Determining Applicable Status

To participate in the CACFP (ASCS or OSHCC), a center must be either licensed or determined exempt from licensure. The Missouri Department of Elementary and Secondary Education, Office of Childhood-Child Care Compliance (DESEOOC), makes the licensing determination. Each center must also meet Missouri or local public health and safety standards. Health and safety standards differ across the state and depend in part on the type of facility involved and on local health and safety ordinances. Each license-exempt center shall submit a sanitation and fire inspection at initial application, no more than one year old.

School Participation in CACFP

School-owned afterschool programs are automatically exempt from licensure. Schools that participate in the NSLP or the School Breakfast Program (SBP) must obtain a minimum of two food safety inspections per the NSLP and the SBP regulations. Therefore, schools participating in the NSLP or the SBP and as ASCS/OSHCC in the CACFP do not have to meet additional health and safety standards.

Summer Food Service Program Health and Safety Inspections

Where the state or local health and safety inspection standards for the ASCS/OSHCC and the SFSP sites are the same, CACFP may accept documentation of a current inspection obtained by an SFSP sponsor pursuant to SFSP regulations, as long as the current SFSP inspection has not expired or been revoked.

Public Programs

At-Risk Afterschool programs are those owned or operated by city, county, or state governmental entities. Public programs must be licensed or license-exempt and meet health and safety standards.

Outside School Hours Care Centers (OSHCC) and At-Risk Afterschool Care Centers (ASCS) Comparison Chart

The chart below highlights the differences between the two components of the Child and Adult Care Food Program that provides reimbursement for meals served. Reference: USDA 2017 At-Risk Afterschool Meals Guide

*Community Food and Nutrition Assistance meal time restriction for At-Risk requires a minimum of one hour between the end of one meal or snack to the beginning of the next meal or snack service.

Attendance Records

Documentation of Daily Attendance is a Child and Adult Care Food Program (CACFP) requirement – Original documentation of daily attendance records must be maintained for each afterschool participant. Accurate attendance records are very important for the submission of the monthly claim for reimbursement.

The attendance records cannot be used to complete the meal count records; however, the attendance records must support the meal count records. For example, the October 17 meal count cannot exceed the total number of participants documented in attendance on October 17. For CACFP compliance, the site may choose to use the Daily Attendance Record (CACFP213) to document attendance. This form can be found at the CACFP website under Forms.

Documentation of Daily Attendance Guidelines:

• The center may use daily rosters, sign-in/out sheets, program roll books, or other methods that accurately record daily attendance.
• Optional – type or print names alphabetically, last name first; information must be legible.
• Require participants to sign in as they arrive, or if staff takes attendance, do so at the same time each day so it becomes routine. If attendance is only based on participant-provided attendance documentation, the full name must be legible.
• Count the number of children each day. Keep a running total of participants in attendance for the monthly claim.
• Keep the original completed Attendance Records in a monthly folder with other CACFP documents for the claim month.

Instructions for completing the Daily Attendance Record (CACFP-213):

• This is a one-page form for each month.
• Enter the month and year in the heading.
• Either have the staff list each participant’s name in alphabetical order by last name or have each participant legibly enter their complete name.
• The center may use its own method to record attendance, but some common notations are: X=in attendance and A=absent.
• Total the number of children in attendance at the bottom of the form.
• On the last workday of each month, add the total daily attendance to get your monthly grand total. If more than one form is used, total all forms together to calculate the grand total sum. This number is entered on line six when the monthly claim is submitted.

Enrollment records are not required for the afterschool care programs. Participation is permitted on either a drop-in or an enrolled basis.

Meal Count Record

Daily Meal Count Records are a requirement for the Child and Adult Care Food Program (CACFP). Each monthly claim for reimbursement must be supported by the daily-dated meal count records for each meal and snack served during the month. The meal count form for the Summer Food Service Program cannot be used to document service for the At-Risk program. The At-Risk meal count form is available in 150 and 300 count forms and can be located at the CACFP Website under Forms.

Instructions for completing the At-Risk Daily Meal Count Record:

• Name of Program: Enter the name of the At-Risk program.
• Date of Service: Enter the complete date on which the meal count is being completed.
• Meal Served: Mark the box for a snack or supper.
• Meal: Mark the box for prepared or delivered.
• Meal Service Time: Enter the time the meal was served.
• Total Meals Available: Count and record the total meals available. This number could differ from the number delivered if a meal is damaged. Note the discrepancy.
• Meal Tally: As meals are served to participants, cross through each consecutive number.
• Adult Meal Tally: After all children have been served, cross through the number for each adult meal served. Adults are 19 and older and may not be claimed for reimbursement.
• Total # of Meals Served to Eligible Participants: Enter the total number of meals served to individuals 18 and under from the meal tally section. Reimbursement may also be claimed for an individual who turns 19 during the school year.
• Total # of Meals Served to Adults: Enter the total number of meals served to adults from the adult meal tally section.
• Total # of Leftover Meals: Enter the number of meals left over after service.
• Signature of Afterschool Program Representative and Date: Enter the signature and date of signature of the program representative.

Use a separate form for each meal served.

Claim for Reimbursement

Claims for meal reimbursement are filed via the internet.

Each user of the Child and Adult Care Food Program (CACFP) web-based system must have a personal user ID and password, referred to as User Access. User IDs and passwords may not be shared. It is recommended that two key people from each center have access to submit claims and make system changes. If you want to add User Access or change current access when a user is no longer employed, you must submit a Network User Access Request Form (MO 580-1854) available at the CACFP Website under Forms .

In this web-based system, each independent site is considered a sponsor of one site!

Basic Claiming Steps are available on the CACFP website under Links to Important Information at the CACFP Website.

Please read all instructions before entering your first claim.

Tips for Moving in the Web-Based System

• Do not use the “Back” button; use the menu in the orange section at the top left of the screen or use the “breadcrumb trail” (orange bar) to navigate from screen to screen.
• Each time you save the claim, no matter if it has errors, it is saved on the server and will be there if you need to leave or log off and come back.
• Use the “Tab” key to navigate from field to field, or use your cursor to click into the field you want to complete. Try not to use the “Enter” key; if you do, the claim will be saved in error status.
• If you are in “View” mode, changes will not be saved. If you want to make changes, make sure you are in “Edit” or “Revise” mode.
• Claims are saved at the site level or center level before saving a sponsor-level claim.
• Revisions can only be filed after the original or previous revision is in “Paid” status.

User Notes

• Click the “Users” tab to view individuals who have access to submit applications and claim information for your organization.
• User Access IDs and passwords are assigned to individuals and are not to be shared.
• Inform the state office immediately if an individual with access is leaving your organization so their access can be revoked.
• Submit a Network User Access Request form to request online access for new users.

Payment Notes

• Click the “Payments” tab to view upcoming and past payments for CACFP claims.
• If a claim has been approved but has not yet been processed for payment, the payment information will show in the Open Balance Transactions section. All other payments are shown in the next section.
• When checking the payments, the processed date shown is approximately 4 to 5 business days prior to the electronic funds deposit date. It is the date it was processed and the information was sent to the State of Missouri payment system.
• Deductions, if any, made from claim reimbursements due to downward revisions are reflected in the information under the “Payments” tab only, not in the claim amount under the “Claims” tab.

Filing a Claim for Reimbursement

• A site has 60 calendar days from the end of the claim month to file a claim for reimbursement. It is not the last day of the month; it is 60 calendar days. If a claim is filed online late, the site may not be paid for that month.
• Submit the completed claim online after you have reviewed your entries and are satisfied that the claim is completed accurately. The system has built-in checks that should decrease the chance of errors in the claim being submitted.
• You cannot enter a claim before the first day of the next month. For example, an October claim cannot be entered until November 1.

The Department of Health and Senior Services-Community Food and Nutrition Assistance (DHSS-CFNA) processes claims on the 10th of each month for payment by check or automatic deposit by around the 28th of the month. A second processing for claims is done on the 25th of the month for claims received from the 11th through the 25th. The second payment is made around the 13th of the following month.

DHSS-CFNA cannot guarantee an exact date; this is a projected date only.

CACFP payments are typically directly deposited. This avoids payment delays and lost checks. If you have not received your payment within 15 days of the projected payment date, please contact DHSS-CFNA. Per CACFP regulations, DHSS-CFNA will provide payment of valid claims within 45 days of receipt.

60 Day Deadline for CACFP Claims

Additional Meal Claim Information

• Creditable meals may be claimed for participants through 18 years of age when enrolled and in attendance each day of operation as follows: one meal and/or one snack per participant per day.
• Adults should not be claimed for CACFP meal reimbursement in At-Risk centers unless the adult is a mentally or physically disabled person, as defined by the state, who is enrolled in an agency or a child care facility serving a majority of persons 18 years of age and younger.
• There may be a fee for the care provided or tuition charged but there can be no separate charge for the food service.
• Meals or meal components purchased at a fast food establishment or any restaurant may not be claimed for reimbursement.
• Meals prepared or packed at the site and served off the site grounds that are supervised by site personnel, such as a field trip, may be claimed.
• Meals prepared or packed at the site and sent with a participant to eat at another location without the supervision of site personnel are not eligible to be claimed for CACFP reimbursement.
• Food items provided by parents or other unapproved food sources cannot be counted as fulfilling any of the CACFP required meal or snack components. However, there are exceptions described in CFR 226.20(g) for participants who cannot consume regular meals because of medical or special dietary needs, either due to disability or non-disability reasons.
• SNAP benefits may not be used to purchase food for CACFP.

Meal Service Times and Duration*

Reimbursement for meals will only be made when meals are served during the center’s approved meal times as listed on the Center Information Sheet of the program application on the CACFP web-based system. Meal times may be changed as needed, within the requirements of this policy, and through revision and approval of the Center Information Sheet in the CACFP web-based system. The meals approved for reimbursement are based on the site’s licensed hours of operation or on actual hours of operation within those hours. This also applies to license-exempt centers.

There are no federal requirements regarding the timing of the meal service except that meal times shall be reasonable. However, DHSS-CFNA requires a minimum of one hour between the end of one meal or snack and the beginning of the next meal or snack. In addition, there is no federally mandated time limit between the end of school and the service of a meal or snack. Also, there are no requirements for the order of the meal and snack service, but the service of a meal or snack must occur during the operation of the school's afterschool care program. On school days, afterschool snacks and/or supper meals may be served at any time after the children’s school day has officially ended, and the snack or supper can be served in any order.

Type of Meals Eligible for Reimbursement*

At-Risk Afterschool Care sites may serve up to one snack and one meal per child per day. This could be any meal, and you may serve a different meal to different groups of children. For example, a site could serve lunch and a snack to children who attend half-day kindergarten and then they could serve a snack and supper to older children who attend a full day of school.

Snacks may be approved for after school or after early supper service.

Lunch may be approved for after school for children who attend half-day kindergarten.

Supper may be approved for after school or after early snack service.

Weekends, Holidays, and Vacations - With DHSS-CFNA approval, meals, breakfast or lunch, and snacks may be served in lieu of supper on weekends, holidays, or during school vacation periods during the regular school year only. The facility may vary which meal and/or snack will be served; however, it may only claim a maximum of one snack and one meal per child per day.

*The requirements for the Outside School Hours Care Center (OSHCC) are different; refer to the OSHCC and At-Risk comparison chart.

At-Risk Afterschool Care Centers and Outside School Hours Care Centers participating in CACFP must demonstrate fiscal management and nonprofit food service.

Financial Management and Nonprofit Documentation

Meal Reimbursement Information

The At-Risk Afterschool programs are reimbursed at the free meal rate. The Outside School Hours programs are reimbursed based on the income eligibility of each child at the free, reduced-price, and paid rates. The reimbursement rates are effective from July 1st through June 30th. The reimbursement rate for the supper meal (or lunch, if approved to serve on weekends, holidays, and school breaks during the school year) includes the United States Department of Agriculture (USDA) established cash-in-lieu of commodity rate. The current meal reimbursement rates are located on the Child and Adult Care Food Program (CACFP) website under Rates.

Financial Management

The purpose of the financial management review is to verify all financial information related to the nonprofit meal service. The purpose is also to ensure costs charged to the nonprofit food service are used to meet CACFP meal requirements and that costs claimed for reimbursement under CACFP are allowable, meaning they are necessary and reasonable for the effective and efficient operation of the food service. All costs charged to the nonprofit food service must be listed in the budget approved by the state agency.

The review of the sponsor’s financial management includes a review of all income and expenses of the organization, whether it is an independent (single) facility or a sponsoring organization (SO) of multiple facilities. Organizations and facilities must maintain and retain the required documentation. Failure to maintain these records may be grounds for the denial of reimbursement.

Nonprofit food service

Nonprofit food service is defined as food service operations conducted by a sponsor principally for the benefit of enrolled participants, from which all the program reimbursement funds are used solely for the operations or improvement of such food service. (CFR 226.2)

Operating Costs

Operating Costs represent allowable expenses incurred by the sponsor for the preparation and service of meals under CACFP. Allowable operating costs include, but are not limited to, food and non-food supplies (e.g., napkins, cooking and eating utensils), compensation for food service labor costs, and costs for purchases or services.

Food Costs

Food Costs are expenditures for the food used in all meals under CACFP. Original, itemized food and milk records or receipts must be maintained to support monthly claims for reimbursement and to document nonprofit food service operations. Receipts must be machine-generated, dated, itemized, and legible. If meals are provided by a caterer or food service management company, the facility must maintain original expense documentation of catered meals and any incidental food and non-food purchases.

The Department of Health and Senior Services-Community Food and Nutrition Assistance (DHSS-CFNA) will examine original food and milk receipts and invoices to determine if the facility purchased adequate amounts of food and milk to meet the minimum meal pattern requirements and that the receipts support the menu for the review month. Food items, especially perishables, must be purchased or delivered on a regular basis due to their limited shelf life. Receipts should verify the purchase of menu items prior to the date the menu items are on the daily dated menu.

Fluid Milk Is A Required Meal Component At Breakfast, Lunch, And Supper Meals.

Program regulations require that at least the minimum amount of all components be served to allow the meals to be claimed for reimbursement. Unflavored whole milk must be served to children 1 year old. Unflavored low-fat (1%) or fat-free (skim) milk must be served to children 2 through 5 years old. Unflavored/flavored low-fat (1%) or fat-free (skim) milk must be served to participants 6 years old and older.

Document the type of milk served on the menu. Inadequate milk purchase amounts and noncompliant milk purchase types will result in meal disallowances at CACFP monitoring reviews.

Milk purchase requirements for breakfast, lunch, and supper are as follows:

Food Service Labor Costs

Facilities must document the cost of food service labor needed for the operation of the CACFP. This may include wages, salaries, employee benefits, and the share of taxes paid by the independent facility necessary to perform the following tasks: menu planning and purchasing, meal preparation, serving, and clean-up of program meals; supervision of day-to-day food service operations, including supervision of participants during the meal service; and on-site preparation of daily program meal service records

Non-Food Supply Costs

Non-Food Supply Costs include small kitchen equipment, paper goods, such as napkins and straws, and cleaning supplies used directly for the food service operation. Itemized receipts must be kept on file as documentation.

Purchased Services – Indirect Costs

Purchased Services – Indirect Costs are items such as prorated utilities (shared services), equipment rental, rental of facilities, and minor repairs. Refer to the Sponsor’s Budget tab on the CACFP web-based system for indirect expenses approved for your facility. Independent facilities and Sponsoring Organizations must submit updated budgets annually during the CACFP renewal process. CFNA will provide assistance on which records are needed to support these costs.

Administrative Costs

Administrative Costs are expenses and allowable costs incurred by an organization in planning, organizing, and managing the food service operation under CACFP. These costs may include labor for management, fringe benefits, traveling, and other costs necessary to manage and implement the program [FNS Instruction 796-2, Rev. 4 (VII D 2)]. The portion of the administrative costs to be charged to the program may not exceed 15 percent of the meal reimbursements estimated or actually earned during the budget year [(7 CFR 226.16(b)(1)].

Miscellaneous Food Purchasing Information

CACFP food purchased with a Supplemental Nutrition Assistance Program (SNAP, formerly called Food Stamps) electronic benefit transfer (EBT) card is not allowed and demonstrates a lack of business integrity. SNAP Regulation program violations consist of having intentionally used, presented, transferred, acquired, received, possessed or trafficked authorization cards. The Family Support Division (Social Services) will be notified when CACFP purchases are made using an EBT card.

Food Sources

To claim reimbursement for meals or snacks, facilities must supply all of the CACFP meal components, and the food must originate from a source that is in compliance with Missouri Food Code laws. These traditional (approved) food sources include food purchased from food service distributors, supermarket chains, convenience stores, local grocers, and other retail stores selling food and non-food items in compliance with Missouri Food Code laws. Some examples of non-traditional (approved) food sources that may be used as part of a reimbursable meal include, but are not limited to:

• Facility Gardens - costs associated with growing food that will be used in the CACFP, either as part of a meal service or for activities related to nutrition education, are allowable. These costs may include seeds, fertilizer, labor, plot rental, etc. However, the facility must maintain documentation of costs incurred.
• Food Bank and Food Pantries - nonprofit, faith-based, and public facilities may be eligible to purchase food from approved sources with appropriate documentation. Itemized receipts with the agency price per pound, for instance, price extension and food name, must be maintained. Contact CFNA to ensure food bank and pantry purchases are creditable.
• Farmers Market or Roadside Produce Stands are limited to the purchase of fresh and unpackaged, unprepared (whole, uncut) locally grown fruits, vegetables, in-shell nuts, and fresh herb sprigs. Garden donations of fresh produce grown in gardens other than the facility garden may be used as part of a reimbursable meal and include the same items.

Refer to the USDA Food Buying Guide for Child Nutrition Programs (FBG) for additional information prior to purchasing items from approved and unapproved sources. The FBG is available at the CACFP website under Resources.

Income and/or Additional Funding

Sources of funding can vary by organization type, size, and structure. In addition to the reimbursement from CACFP, some sponsors fund their operation from tuition fees and fundraising activities, while others may have other funding streams generated from activities outside of CACFP. Program income is the gross income generated from activities, local government sources, any facility funds used to subsidize the food service program, any income for adult meals, and any other income, including loans and donations to the food program. Regardless of the source, all income must be maintained in the nonprofit food service account and used only for approved costs. Please contact DHSS-CFNA if you need further guidance.

Documentation of Nonprofit Foodservice (CACFP-214)

This form may be used to document monthly food service costs and expenses, the amount of labor, and indirect costs attributable to the food service. This form is available at the CACFP website under Forms .

How to use CACFP-214:

• Compare the total expenditure on food costs to the CACFP monthly reimbursement. If the food cost expenditures for the month are greater than the monthly CACFP reimbursement, the facility does not need to document other operating costs. If the food costs for the month are less than the monthly CACFP reimbursement, the 39 facility must document food service labor costs (+ non-food supplies, if needed) on form CACFP-214.
  • Note: The food, non-food, and labor costs total typically exceeds the reimbursement, and no further action needs to be taken; however, if the food costs + labor costs + non-food costs are less than the monthly CACFP reimbursement, then expendable and non-expendable must be calculated.
    • Expendable food service equipment has a durability of under two years and costs $5,000 or less.
    • Non-expendable food service equipment has a durability of two years or more with a cost exceeding $5,000.
• Add total labor costs, total food costs, non-food costs, and total indirect costs (if applicable) on CACFP-214 to get the “Grand Total” sum. Compare this amount to the monthly CACFP reimbursement, plus meal income (if applicable).

At-Risk Afterschool Care Centers and Outside School Hours Care Centers participating in CACFP must provide training to all staff and operate in compliance with CACFP and Civil Rights regulations.

Training Requirements

Documentation of annual Child and Adult Care Food Program (CACFP) training is required. Independent centers and sponsoring organizations are responsible for the annual program training of staff. They must include instruction appropriate to the level of staff experience and duties on the following (CACFP) required topics:

• The CACFP meal pattern requirements.
• Recordkeeping requirements.
• Meal count procedures.
• Reimbursement system.
• Claim submission and review procedures.
• Adherence with Civil Rights requirements.

Reference: [7 CFR 226.15(e)(14).

This training is in addition to the orientation training provided by the Department of Health and Senior Services-Community Food and Nutrition Assistance (DHSS-CFNA). Your training can be formal or informal; however, it must be documented and per 7 CFR 226.15(e)(12) include:

• The training session dates.
• The training location.
• The CACFP topics presented.
• The names of each staff member trained (legible, printed) and position/title

The Annual CACFP Training Documentation form (CACFP-222) may be used to document your CACFP training, or you may develop a form to include the training requirements. The CACFP222 is located at CACFP website under Forms.

Online Civil Rights training is also available at CACFP website.

Civil Rights Compliance and Other Requirements

All sponsors participating in the Child and Adult Care Food Program (CACFP) are required to comply with the following civil rights obligations and to provide information as follows:

• Collection of Ethnicity and Race Data: Sponsors are required to collect ethnicity and race data once a year for the CACFP. Visual observation and identification are not allowable practices in collecting data. The preferred method is self-identification and self-reporting. CACFP sponsors should explain the importance of this data to participants as they encourage them to self-identify and self-report.
• CACFP sponsors may also obtain ethnicity and race data from other sources in which the respondent has self-identified ethnicity and race, such as school databases. Another method that an afterschool program may use to gather the required ethnic and racial data, in which the participant or parent/guardian of the participant provides this data, is by completion of the Outreach and Beneficiary Data Survey. Completion of the survey is voluntary. The data collected is used to improve outreach efforts and to ensure compliance with USDA nondiscrimination requirements. The completion of or lack of completion has no impact on program participation.

An Outside School Hours Care Facility may also use the voluntary questions on ethnicity and race that are included in the Income Eligibility Form for Child Care Centers (CACFP-205).

• Compile the Ethnic and Racial Data on the Beneficiary Data Report. Once a year, sponsors must compile the ethnic and racial data, as completed by the participant or guardian, into this report. This report must be kept on file at the center.
• Display the “And Justice For All” poster in a prominent location (visible to the public). Please contact our office for additional posters.
• Display “Building for the Future” flyer in a prominent location or “Building for the Future” pamphlet. This pamphlet explains the CACFP, who is eligible, the types of meals served, and the types of centers that serve the meals. Both are available at the CACFP website  - Posters, Flyers, & Pamphlets.
• Annual Civil Rights training for CACFP sponsors and staff. Online training is available on our website at the CACFP website .
• Services must be provided for limited English proficient (LEP) persons. Take reasonable steps to ensure meaningful access to services for LEP persons by providing information in the frequently encountered, non-English language of individuals eligible to be served or likely to be affected by the program.

Ensure that translations are accurate concerning the availability and nutritional benefits of the program.

Sponsors must ensure that interpretive services are available and that LEP participants do not have to rely on family, friends, or children as interpreters.

Make reasonable modifications in policies and procedures to ensure individuals with disabilities have equal access and effective communication when accessing the program.

• USDA nondiscrimination statement and civil rights complaint information required on Program material directed to the parents/guardians. If the center has a parent handbook or a policy booklet that indicates that the center is participating in the CACFP, the nondiscrimination statement and procedure for filing a complaint must be included and are available at the CACFP website - USDA Nondiscrimination Statement.
• Discrimination Complaint Filing. The USDA prohibits discrimination in Child Nutrition Programs (CNPs) based on race, color, national origin, age, sex, disability, and religion. If you believe you experienced discrimination when participating in a USDA program, you may file a complaint. Information on filing a civil rights complaint is available on the USDA website.
• Forward complaints of alleged discrimination to the Department of Health and Senior Services-Community Food and Nutrition Assistance (DHSS-CFNA). All complaints of discrimination, written or verbal, including anonymous complaints, must be forwarded to the DHSS-CFNA within four days of receipt. Provide all available information and details. The toll-free number is 800-733-6251.
• WIC Program Information. Missouri WIC outreach posters are available for your center to display and share the benefits of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) with parents and guardians. The poster is located at the CACFP website  - Posters, Flyers, & Pamphlets.

At-Risk Afterschool Care Centers and Outside School Hours Care Centers participating in CACFP will be reviewed to monitor compliance with program regulations.

State Agency Monitoring Review Process

The United States Department of Agriculture (USDA) requires the Missouri Department of Health and Senior Services-Community Food and Nutrition Assistance (DHSS-CFNA) to ensure that the sponsors, which include both CACFP facilities and Sponsoring Organizations (SOs), are accountable for all reimbursements received in compliance with program regulations. Each program will be reviewed for compliance with the Child and Adult Care Food Program (CACFP) Regulations 7 CFR 226 and other pertinent federal regulations. Sponsors will also be reviewed to ensure that they follow the guidelines in this manual and the guidelines in the CACFP contract and Scope of Work.

Technical Assistance Visit

DHSS-CFNA wants you to be successful, so we recommend that new sponsors receive a technical assistance review within the first six months of operation. Your District Nutritionist will contact you to offer a Technical Assistance (TA) Review within the first three to six months after you submit at least one claim.

This technical assistance review is conducted similarly to a monitoring review and will provide feedback that will help you be more successful on your first monitoring review. A technical assistance review is not required, but sponsors that have a TA review often have fewer findings at their first monitoring review.

Your technical assistance review will include a review of your records and menus, as well as your Civil Rights compliance. It may also include an observation of a meal service and a sanitation inspection.

The purpose of the TA Visit is to review your records and procedures with you for program compliance, answer any program questions you might have, and provide you with the guidance needed to help you be successful with CACFP. A TA visit is not punitive in nature and is strictly meant to help facilitate your organization’s success. This visit can help reduce findings and the need for corrective actions in the future during monitoring reviews.

Monitoring Reviews

To ensure compliance, each sponsor will be reviewed by DHSS-CFNA at least once every three years in a CACFP monitoring review, although most will be reviewed a minimum of every two years. A sponsor may be reviewed for compliance at any time

Program monitoring reviews may or may not be announced in advance. If announced in advance, the sponsor will receive a letter, and the review will be conducted within the week specified in the letter. No advance notification will be given for unannounced reviews. The center may contact our office (800-733-6251) if there are days that they know they will not be available.

The USDA requires sponsors to maintain complete and accurate original Child and Adult Care Food Program (CACFP) records. Records must be kept at the physical location noted on the Management Plan for independent facilities and multi-site SOs. It is preferable that the records be stored at the independent facilities when possible.

During monitoring reviews, all original program records must be maintained on location and made available for review within one hour of arrival by state and/or federal officials. Failure to have CACFP records available will result in findings, corrective action and/or overclaims; DHSS-CFNA may disallow up to twelve months of claims for reimbursement the center or SO must repay.

Sponsors must maintain all required original records, not copies, on file for a period of three full fiscal years after the final claim for reimbursement for the fiscal year was submitted or longer if audit findings have not been resolved. The federal fiscal year begins October 1 and ends September 30.

The Materials Needed for a CACFP Monitoring Review checklist, on the next page, is provided to help organizations prepare for the review.

The monitoring review will include a review of your records and menus, as well as your Civil Rights compliance. It will also include an observation of a meal service and a sanitation inspection.

If the State Agency (SA) reviewer finds that the sponsor did not comply with the CACFP regulations during the monitoring review, the sponsor will be given “findings” for each incident of non-compliance.

Immediately after the monitoring review, the SA reviewer and sponsor will meet for an exit review to discuss the results of the review, including positive observations and non-compliant findings.

Some findings may result in the disallowance of meals that were claimed during the month of review. There could be many reasons for this, including, but not limited to:

• Errors in counting and meal consolidation
• Not counting meals accurately
• Serving meals that did not include all of the required meal components
• Serving foods that are not creditable
• Not purchasing enough of certain foods, especially milk, for the number of meals that were claimed

The balance owed to CACFP will be recovered by deducting the funds owed from your remaining monthly CACFP claims for reimbursement payments until paid in full. If funds are owed and no additional claims are submitted, the sponsor must remit payment of the amount owed by check or money order. Failure to repay a debt will lead to a sponsor being declared seriously deficient.

After the SA reviewer has conducted the monitoring review, a letter indicating that a review has been conducted will be sent to the sponsor. If no findings are found during the review, the sponsor will receive a “No Findings” letter with a certificate celebrating this achievement.

If there were findings associated with the review, the letter will include instructions on how to view and address the findings by submitting a Corrective Action Plan (CAP) in the CNPWeb under the eReviews tab.

Corrective Action Plan

A CACFP sponsor is responsible for responding to monitoring review findings (instances of noncompliance) by completing a Corrective Action Plan (CAP).

On the “Corrective Action Responses” link on the eReviews tab of the CNPWeb, the sponsor will address each finding indicated on the report, explaining how each finding will be corrected, who will be responsible for correcting the finding, and the date by which the finding will be corrected. You will also need to upload any supporting documentation as required.

Each CAP will have a due date. The sponsor will have three weeks from the date of the review letter to respond to the findings. Failure to respond to the review letter could affect the sponsor’s ability to participate in the CACFP and may result in the sponsor being classified as Seriously Deficient. After the SA reviewer has reviewed and approved the CAP, a closeout letter will be sent to the sponsor.

How to Complete a CAP

Before the center can submit its corrective actions, it must determine what the problem is and why it is occurring.

The CAP must clearly state the following:

• How the problem can be prevented or eliminated. Do not merely restate the finding or assure that the mistake will not happen again. The solution must be a process – include specific steps that have been taken to correct the finding, and what extra steps will be taken to make sure this problem does not occur again.
• When the problem was corrected.
• Who will be responsible for ensuring the corrections were made and that written policies and/or procedures will be maintained.

Recommendations:

• It is critical that the CAP be completed thoughtfully and thoroughly.
• It is wise to send the CAP in early in case corrections are recommended.

Serious Deficiency Process

If serious violations are found during a monitoring review or a sponsor fails to pay a debt, the sponsor must be determined as Seriously Deficient (SD). USDA regulations define Seriously Deficient (SD) as the status of a sponsor that has been determined to be non-compliant in one or more aspects of its program operation. A sponsor that is determined to be currently SD or has been terminated from any federal child nutrition program may not enter into an agreement to participate in the CACFP.

The individuals noted on the Sponsor and Center Information Sheets on the Application in the CNP web-based system are considered responsible individuals or responsible principles of the program.

By virtue of the management position, the “responsible person” has administrative and financial responsibility for the oversight, management, integrity, and compliance of the CACFP and applicable regulations.

As a contracted provider of the CACFP, sponsors must maintain records and provide access to any records or documents to authorized representatives of the Department, State, and Federal government for inspection upon request.

If you are found to be seriously deficient, you will be given the opportunity to correct the findings that led to this determination. However, if an adequate CAP is not submitted on time and implemented fully at the facility, the CACFP will move to terminate the sponsor from the program.

Appeal Procedure

The request for administrative review (appeal) of adverse action taken by Department of Health and Senior Services-Community Food and Nutrition Assistance (DHSS-CFNA) must be submitted in writing to DHSS-CFNA no later than 15 calendar days after the date the notice of action is received.

Appeals of the Department of Health and Senior Services (DHSS) actions are conducted before an independent administrative hearing officer in the DHSS Appeals Unit. To contact the DHSS Appeals Unit, call (573) 522-1699, fax (573) 751-0247, or email DHSS.Appeals@health.mo.gov.

What Can Be Appealed?

A sponsor may appeal any of the following actions the DHSS takes relating to its participation in the Child and Adult Care Food Program (CACFP) or claims for reimbursement [7 CFR § 226.6(k)(2)]:

• Denial of a new or renewing sponsor’s application for participation.
• Denial of an application submitted by a sponsoring organization on behalf of a facility.
• Notice of proposed termination of a sponsor’s agreement.
• Notice of proposed disqualification of a responsible principal or responsible individual.
• Suspension of a sponsor’s participation in the program.
• Denial of a sponsor’s application for start-up or expansion payments.
• Denial of a request for an advance payment.
• Recovery of all or part of an advance in excess of the claim for the applicable period.
• Denial of all or a part of a sponsor’s claim for reimbursement (except for a denial based on a late submission under 7 CFR § 226.10(e)).
• Decision by the DHSS not to forward to the USDA’s Food and Nutrition Services (FNS) an exception request by a sponsor for payment of a late claim, or a request for an upward adjustment to a claim.
• Demand for the remittance of an overpayment.
• Any other DHSS action affecting a sponsor’s participation or its claim for reimbursement

What Cannot Be Appealed?

A sponsor cannot appeal any of the following actions [7 CFR § 226.6(k)(3)]:

• A decision by the FNS to deny an exception request by a sponsor for payment of a late claim, or for an upward adjustment to a claim.
• A determination that a sponsor is seriously deficient.
• A determination by the DHSS that the corrective action taken by a sponsor or by a responsible principal or responsible individual does not completely and permanently correct a serious deficiency.
• Disqualification of a sponsor or a responsible principal or responsible individual, and the subsequent placement on DHSS’ Seriously Deficient List and the FNS National Disqualified List (NDL).
• Termination of a participating sponsor’s agreement, including termination of a participating sponsor’s agreement based on the disqualification of the sponsor by another state agency or the FNS.
• A determination, by either the DHSS or by the FNS, that the corrective action taken by a sponsor or a responsible principal or responsible individual is not adequate to warrant the removal of the sponsor or the responsible principal or responsible individual from the NDL.
• The DHSS’ refusal to consider a sponsor’s application when either:
  • the sponsor or one of its principals is on the NDL list; or
  • the facility or one of its principals is on the NDL

How Can A Sponsor Appeal?

• Appeal requests must be in writing.
• A sponsor can either:
  • Email the appeal request to CACFP@health.mo.gov.
  • Fax the appeal request to 573-526-3679.
  • Mail the appeal request to:

Missouri Department of Health and Senior Services
Community Food and Nutrition Assistance
ATTN: CACFP Appeals
PO Box 570, Jefferson City
MO 65102

• The DHSS must receive the appeal request no more than 15 calendar days after the sponsor receives the notice of DHSS’ action.

What Should A Sponsor Include In Its Appeal Request?

• The sponsor’s name, telephone number, and mailing address.
• The name and title (printed or typed) of the sponsor’s contact person or authorized representative (if applicable).
• The DHSS action(s) that the sponsor is appealing, the reason(s) the sponsor is appealing, and the action(s) the sponsor wants the DHSS to take instead (i.e., the remedy the sponsor is seeking).
• Whether the sponsor is requesting an abbreviated administrative review and/or an administrative hearing, unless the action being appealed is one that must go through abbreviated review.

What Are The Types Of Administrative Review?

• Abbreviated administrative review: a review of written documentation only.
  • In an abbreviated review, both the sponsor and the DHSS submit written documentation and information for the hearing officer to consider when deciding the appeal.
  • A sponsor requesting a written review may choose to have an abbreviated administrative review even if it is entitled to a full, in-person hearing.
  • If the DHSS denies the sponsor’s application or proposes to terminate a sponsor’s CACFP participation based on any of the following reasons, the appeal must be an abbreviated administrative review:
    • Submission of false information on the application.
    • The sponsor or one of its principals or its facilities is on the NDL.
    • The sponsor or one of its principals or one of its facilities is ineligible to participate.
    • The sponsor or one of its principals or one of its facilities has been convicted for any activity that indicates a lack of business integrity.
  • To be considered by the hearing officer, the sponsor must submit all written documentation and information in support of its appeal to the hearing officer within 30 calendar days from the date the sponsor receives the notice of DHSS’ action.
  • A sponsor cannot request an in-person administrative hearing after the abbreviated administrative review has taken place.
• Administrative hearing: an in-person hearing at which the sponsor and the DHSS submit verbal testimony and evidence.
  • The Appeals Unit hearing officer can hold a hearing in addition to, or instead of, an abbreviated administrative review only if it qualifies for an administrative hearing and the sponsor requests a hearing in its appeal request.

Additional Information

• The DHSS will send the sponsor a letter acknowledging receipt of the appeal request within 10 days of receiving the request.
• The Appeals Unit hearing officer will send the sponsor a letter giving the date, time, and location of the administrative hearing (if an administrative hearing was requested) and/or the date any written documentation and information in support of the sponsor’s appeal is due and submission information.
• If the sponsor requests an administrative hearing and fails to appear at the hearing, the sponsor waives the right to an in-person appearance before the Appeals Unit hearing officer unless the hearing officer agrees to reschedule the hearing.
• The sponsor may retain private legal counsel or may be represented by another person. 7 CFR 226.6(k)(5)(iii).
• The DHSS will have legal counsel representation for both in-person hearings and abbreviated administrative reviews.
• The Appeals Unit hearing officer must make a decision within 60 days of the date DHSS receives the sponsor’s appeal.

Remember These Deadlines

• The DHSS must receive the sponsor’s appeal request within 15 calendar days of the sponsor receiving notice of the DHSS’ action(s).
• The sponsor must submit any written documentation to the hearing officer within 30 calendar days of receiving the DHSS notice of action.

For more information: Call the DHSS at 800-733-6251.

Sponsors have the responsibility to monitor the operations of their facilities.

Sponsor Monitoring Reviews

Each sponsor must provide adequate supervisory and operational personnel for the effective management and monitoring of the program at all of their facilities. Each sponsor must provide pre-approval visits, training, and ongoing monitoring of the facilities it oversees.

Pre-Approval Visits

Visits to each new facility to discuss program benefits and verify that the proposed food service does not exceed the capability of the facility.

Training

Key staff from all sponsored facilities must be trained on program duties and responsibilities prior to the beginning of program operations. At a minimum, such training must include instruction appropriate to the level of staff experience and duties on program meal patterns, meal counts, claims submission and review procedures, recordkeeping requirements, reimbursement system, and civil rights compliance.

Monitoring Review Visits

Each facility under the sponsor’s jurisdiction must be monitored for CACFP compliance. The sponsor must document all reviews and retain them in the sponsor location identified in the Management Plan.

Sponsors must conduct three monitoring review visits for each facility every year**:

• At least two of the three reviews must be unannounced; however, Department of Health and Senior Services-Community Food and Nutrition Assistance (DHSS-CFNA) recommends that all monitoring visits be unannounced.
• The timing of the unannounced reviews should be varied in a way that would ensure that they are unpredictable to the sponsored facility.
• At least one unannounced monitoring visit must be conducted during a meal service.
• The unannounced reviews should also vary the type of meal service that is reviewed.
• If a facility operates on weekends or holidays, one review must be conducted each year on weekends or holidays when claiming meals under these conditions.
• No more than six months may lapse between monitoring visits.
• The sponsor must review all new facilities within the first four weeks of program operation.
• All monitoring visits must be documented on the Sponsored Centers Site Visit Report – Review by Sponsor form (CACFP-404) or a form approved by DHSS-CFNA.
• The sponsor must follow up with facilities noted as having problems during monitoring visits.
• The follow-up visit must be conducted no less than one week after the initial finding, and the visit must be documented.

**Sponsors that operate the Summer Food Service Program (SFSP) and CACFP afterschool care meals may follow the CACFP monitoring schedule year-round. If sponsors choose to follow the CACFP monitoring schedule year-round, one of the three annual reviews must occur during the summer. The review for SFSP requirements includes the review of a meal service, and the review must be unannounced. The two reviews for CACFP requirements must occur during the school year; at least one must include the review of a meal service, and at least one must be unannounced.

Reconciliation of Meal Counts

As part of the monitoring review visits, a sponsor must examine the meal counts recorded by the sponsored facility for five consecutive days during the current and /or prior claiming period. For each day examined, the reviewer will compare meal count records to attendance records to reconcile those numbers to the number of suppers and/or snacks or other meals recorded on the meal count records to determine if meal counts were accurate. A five-day reconciliation of attendance/meal count verification is included in the Sponsored Centers Site Visit Report – Review by Sponsor form (CACFP-404).

At-Risk Afterschool Care Centers and Outside School Hours Care Centers participating in CACFP must provide meals that meet meal pattern requirements.

Healthy Meals and Nutrition Environment

CACFP afterschool sites provide a much-needed service to their communities. They give children a safe place to go after school and nutritious food that gives them the energy to concentrate on homework and join their friends in physical, educational, and social activities. At-Risk Afterschool Centers and Outside School Hours Care Centers (OSHCC) serve an important role in helping young children develop good eating and physical activity habits.

The Child and Adult Care Food Program (CACFP) meal pattern requires afterschool sites to serve meals that meet the nutritional needs of children, are consistent with the Dietary Guidelines for Americans (DGAs), and are appetizing. Meal pattern requirements assist the menu planner in providing well-balanced meals and snacks that provide the appropriate amount of energy and nutrients a child needs during critical stages of growth. The At-Risk Afterschool meal pattern lists the requirements for children 6 to 12 years of age. Children 13 to 18 must be served the minimum or larger than those portions specified for ages 6 to 12.

The DGAs are jointly issued and updated every five years by the United States Department of Agriculture and the Department of Health and Human Services. They are designed for policymakers and nutrition and health professionals. The aim of the DGAs is to promote health and prevent disease. The DGAs provide four overarching guidelines that encourage healthy eating patterns at each stage of life and recognize that individuals will need to make shifts in their food and beverage choices to achieve a healthy pattern.

The 2025-2030 DGAs recommend that Americans to prioritize diets built on whole, nutrient-dense foods – protein, dairy, vegetables, fruits, healthy fats, and whole grains, paired with a reduction in highly processed foods, laden with refined carbohydrates, added sugars, excess sodium, unhealthy fats, and chemical additives. 

The Key Recommendations call for Americans to:

• Eat the Right Amount for You
• Prioritize Protein Foods at Every Meal
• Consume Dairy
• Eat Vegetables & Fruits Throughout the Day
• Incorporate Healthy Fats
• Focus on Whole Grains
• Limit Highly Processed Foods, Added Sugars, & Refined Carbohydrate
• Limit Alcoholic Beverages 

More information about the 2025-2030 DGAs is available at https://cdn.realfood.gov/DGA.pdf. 

Water Availability

Drinking water must be available to children throughout the day, including at meal times. While water must be made available to children during meals, it is not part of the reimbursable meals and cannot be served in lieu of milk. Water can be made available to children in a variety of ways, including simply providing water to a child when it is requested. Contact the CACFP for questions pertaining to this requirement. (CACFP 20-2011 Child Nutrition Reauthorization 2010: Water Availability in the CACFP, May 11, 2011)

For more information, see the Team Nutrition worksheet, Offering Water in the USDA Child and Adult Care Food Program, available here.

Menu Planning Guidelines

The Child and Adult Care Food Program (CACFP) Meal Pattern Requirements, the Crediting Handbook for the CACFP, and the United States Department of Agriculture (USDA) Food Buying Guide (FBG) for Child Nutrition Program ensure that children participating in the CACFP are served foods that supply the nutrients they need. Site menus have a major influence on the development of children’s eating habits. It is important that menus help establish patterns for healthy eating.

Follow These Guidelines When Developing Menus:

• Select a form to document your daily menus. The menu template is recommended; these forms list the meal components required for each meal and snack. A five and seven-day version is available at the CACFP Website - Forms.
• Choose the type of menu format you will use; a three-to-four-week cycle menu format is recommended. A cycle menu is a set of menus that are repeated in the same order for a period of time, typically two, three, or four weeks. Cycle menus provide variety by offering different foods and/or different food combinations each day during the cycle.
• When there are substitutions from the planned menu, mark through the original menu item and enter the substitution. The original daily dated menu that notes substitutions must be kept with the monthly records and retained for three years plus the current year.
• Know the cooking abilities of the person(s) preparing the meals. Review the menu and recipes with the cook and provide training as necessary. Select or develop standardized recipes for menu items.
• Plan menu items based on the equipment available in the facility’s kitchen.
• Include all meal components in at least the minimum portion sizes required for reimbursement. It is usually easiest to start by planning the main dish or entrée.
• Plan menus that keep the nutritional needs of children in focus. Be sure to include a good source of iron and Vitamins A and C.
  • Iron sources include asparagus, lima beans, sweet potatoes, squash, 100% vegetable juice, turkey, tuna, apricots, cherries, dried fruit, dried peas, eggs, meat, and green beans.
  • Vitamin A sources include apricots, cantaloupe, cherries, plums, egg yolk, asparagus, broccoli, carrots, kale, peas, and sweet potatoes.
  • Vitamin C sources include citrus fruit and juice, broccoli, asparagus, brussel sprouts, cauliflower, snow pears, peppers (green and red), cantaloupe, honeydew melon, mango, papaya, kiwi, and strawberries.
• Limit high-fat and sodium meats to no more than one time per week. This includes but is not limited to hot dogs, sausage, lunchmeat, and processed meats.
• Grain-based desserts do not count toward the grain requirement with the exception of sweet crackers, which includes graham crackers of all shapes and animal crackers.
• Specify the type of fruit, juice, or vegetables on your menus to assure a variety of food is served and to document the nutritional value of the meal.
• Specify the type of cereal and yogurt to ensure sugar requirements are met. Maintain documentation with the CACFP records.
• Make sure the meals look and taste good. Introduce new foods along with familiar foods that children already like.
• Include foods that are different shapes: round, square, rectangular, and different colors: yellow, orange, red, and green.
• Combine foods that have different textures: soft, crunchy, crisp, creamy, and smooth, and different tastes: sweet, sour, tart, salty, spicy, and mild.
• Consider the different ethnic and cultural food habits and preferences of children.
• Fat-free or low-fat milk is required at each meal for participants who are two years of age or older. Milk served to one-year-olds must be unflavored whole milk. Serve breastmilk or iron-fortified infant formula to infants through 11 months of age. Flavored fat-free or low-fat milk may be served to participants six years old or older. Document the type of milk served on the menu. This includes listing the fat content (whole, low-fat/1%, fat-free/skim) and whether the milk is flavored.
• The facility may not add syrup or other forms of flavoring to unflavored milk or sugar to the unflavored milk because doing so would turn the beverage into flavored milk. Flavored milk is not allowed as part of a CACFP reimbursable meal for children 1 through 5 years old.
• Use fats and oils sparingly in food preparation and limit the use of salt and high-sodium foods.

Standardized recipes: A standardized recipe is one that has been tried several times using the same method and equipment. A standardized recipe produces consistency in product quality and yields the same number of servings every time it is used if the same procedures, equipment, and ingredients are used. Because standardized recipes specify exact amounts of ingredients, it is easier to manage the cost and storage of foods. A link to the USDA Standardized Recipes is available on the CACFP website .

The USDA FBG for Child Nutrition Programs is available as an interactive web-based tool, as a mobile app, and as a downloadable PDF. USDA resources help you determine the right amount of food and the appropriate type of food to purchase for your program. These resources aid in determining the specific meal contribution each food makes towards the meal pattern requirements, as well as providing information on recipe analysis. The FBG, Web-based Interactive FBG, The FBG Mobile App, and The FBG Calculator are available online at the USDA website. The Crediting Handbook for CACFP is a companion guide to the FBG that contains additional information on creditable foods served in adult day care centers. Links to both resources are also available on the CACFP website .

Offer Versus Serve Meal Service Option

Regulations permit the use of Offer Versus Serve (OVS) meal service option for At-Risk Afterschool programs. OVS is allowable for breakfast, lunch, and supper meals, but it is not allowed at snack meals.

OVS is an approach to menu planning and meal service where participants are offered all of the components of the meal pattern but are not required to take all of them. OVS can help teach children to make choices and is a way to decrease food waste because participants choose only those foods they wish to eat. A School Food Authority (SFA) may choose to follow the National School Lunch Program (NSLP) and School Breakfast Program (SBP) meal pattern, including the OVS requirements, or the Child and Adult Care Food Program (CACFP) meal pattern.

Assistance with meal selection may be necessary in order to provide well-balanced meals. Participants are not required to decline foods that are offered, but may do so if they choose. OVS is not considered appropriate for preschool children participating in At-Risk Afterschool programs, as it may interfere with program nutrition goals and the center’s efforts to introduce new foods to children.

The centers must notify the Department of Health and Senior Services-Community Food and Nutrition Assistance (DHSS-CFNA) for approval to use OVS. The center’s option to participate in OVS must be noted on their application. This includes an SFA following the OVS requirements for the NSLP and/or SBP. The DHSS-CFNA must also be notified if the center changes the OVS option.

OVS at Breakfast

The CACFP breakfast meal pattern requires three food components to be offered: milk, fruits and vegetables, and grains. As a reminder, fruit and vegetables are a combined component in the breakfast meal patterns.

When using OVS at breakfast, at least the following four food items, in the required minimum serving sizes, must be offered:

• A serving of milk.
• A food item from the fruit and vegetable component.
• A food item from the grains component.
• A food item from the meat/meat alternate component, or one additional item from the fruit and vegetable component, or the grains component.

All the food items offered must be different from each other. For example, while a flake cereal, such as bran flakes with raisins, and a puffed cereal, such as puffed rice cereal, are two types of cereals that are not identical, they are the same food item.

OVS at Lunch or Supper

The CACFP lunch and supper meal patterns require the offering of all five food components: milk, meat/meat alternates, vegetables, fruits, and grains.

When using OVS at lunch or supper, at least one food item from each of the five food components, in the required minimum serving sizes, required at lunch and supper, must be offered:

• A serving of milk.
• A food item from the meat/meat alternate component.
• A food item from the vegetable component.
• A food item from the fruit component.
• A food item from the grain component.

Unlike OVS at breakfast, at lunch or supper meals, a child must take at least three food components, rather than three items, to ensure the child takes an adequately nutritious meal. A child must select at least the minimum required serving size of the components for them to be counted. It is the child’s choice to select or decline a food component. At-Risk Afterschool programs may not specify what food components a child must select.

Adequate food and milk purchases will be verified at the CACFP monitoring reviews in compliance with the OVS meal option. The center must demonstrate that it offers all program meal components in the regulatory amounts. If the center is ordering milk based on previous consumption patterns, it should have a plan to ensure that enough milk will be provided should the demand increase for any given day of operation.

The amount of milk purchased should correlate with the food preference of participants who routinely choose to drink milk in the eight-ounce (1/2 pint) minimum serving size offered. It is the responsibility of program personnel to offer milk as a beverage choice to participants, according to the At-Risk Afterschool Food Chart. The At-Risk Afterschool program should document daily portions served to justify that adequate milk is purchased for the number of participants who choose to drink milk. There are 16 eight-ounce servings per gallon of milk.

Share Tables

Sponsors must provide reimbursable meals that meet the CACFP meal pattern requirements; however, children may not always want to consume certain food or beverage items included in their meals. Using “share tables” is a strategy that sponsors of At-Risk Afterschool Care Programs may utilize to encourage the consumption of nutritious foods while reducing waste.

Afterschool care programs may create a sharing table or stations where children may return whole items that they choose not to eat. Unopened, unused, whole food items left on a share table are then available to other children who may want additional servings. Other children may take food from the share table if they want additional servings.

• Sponsors must check that “share tables” are in compliance with state and local health and safety codes first.

Afterschool care programs must follow food safety requirements when choosing to include share tables in their meal service!

Sponsor must establish guidelines for the use of share table or stations:

• Must follow federal, state, and local health safety codes.
• Must establish clear guidelines for food components that may and may not be shared or reused as part of a reimbursable meal.
  • Must be unopened prepackaged items, unused, whole items.
  • Leftover, unopened cartons of milk may be left on the share table but must be held at 41 degrees Fahrenheit or below.
• Must supervise the share table at all times to ensure compliance with food safety requirements.
• Promote the share table to children and families and provide guidelines.
  • Display signage outlining the share table “rules.”

For more information, refer to FNS Memo CACFP 13-2016 “The Use of Share Tables in Child Nutrition Programs”. [BROKEN LINK]

At-Risk Afterschool Care Centers and Outside School Hours Care Centers participating in CACFP must provide reasonable modifications to meals and snacks to accommodate disabilities that restrict a participant’s diet.

Food Substitutions and Variations

Program regulations require program operators to make reasonable modifications to meals and snacks, including providing special meals at no extra charge to accommodate disabilities that restrict a participant’s diet. In many cases, disabilities can be managed within the Child and Adult Care Food Program (CACFP) meal pattern requirements when a well-planned variety of nutritious foods is available to participants.

However, in other cases, the needs of a participant with a disability may involve requests for accommodations that result in the service of meals that do not meet the meal pattern requirements.

Program regulations require CACFP operators to provide modifications for participants with disabilities on a case-by-case basis only when requests are supported by a written statement from a registered dietitian or a state-licensed healthcare professional, which is defined as an individual authorized to write medical prescriptions under state law. In Missouri, state-licensed healthcare professionals include physicians, physician assistants, and nurse practitioners. Meals that do not meet the meal pattern requirements are not eligible for reimbursement unless supported by a medical statement. However, CACFP operators may choose to accommodate requests related to a disability that are not supported by a medical statement if the requested modifications can be accomplished within the meal pattern requirements. Such meals are reimbursable. (Reference CACFP 14-2017 Policy Memorandum on Modifications to Accommodate Disabilities in the Child and Adult Care Food Program and Summer Food Service Program)

Medical Statement Requirements

In order to claim a meal that does not conform to the regulatory meal pattern, there must be a medical reason or a special dietary need and a signed statement on file. Use of the Medical Statement to Request Special Meals and/or Accommodations (CACFP-227) is recommended; however, an equivalent form provided by a medical authority that documents the requirements is acceptable.

Disability

When a participant has a disability that affects the food the participant can consume, the participant, the participant’s family, or guardian must provide a medical statement form signed by a physician, physician assistant, nurse practitioner, or registered dietitian. The statement must be kept on file, handled confidentially, and include the following:

• A description of the participant’s physical or mental impairment that is sufficient to allow the program operator to understand how it restricts the participant’s diet.
• An explanation of what must be done to accommodate the participant’s disability.
• The food or foods to be omitted from the participant’s diet.
• The appropriate food substitutions.

Afterschool centers participating in the CACFP are required to make substitutions or modifications to the meal pattern when a disability restricts the diet. Substitutions must be made only when supported by a written statement signed by a physician, physician assistant, nurse practitioner, or registered dietitian.

If it is necessary for a parent to furnish a particular food item(s) for medical reasons as described in 7 CFR 226.20(g), the meal may still be claimed for reimbursement if the request is supported by a written statement signed by a physician, physician assistant, nurse practitioner, or registered dietitian and the center supplies at least one required meal component.

Note: Reimbursement for meals served with documented food substitutions is claimed at the same reimbursement rate as meals that meet the meal pattern. The center may not charge for the substituted food item. Substitutions that exceed program reimbursement are at the center’s expense.

Modifications for Dietary and Cultural Preferences

Meal or meal service modifications, such as food or beverage substitutions, may be made at the sponsor's discretion for participants with dietary and cultural preferences that are not considered a disability. Any modification that does not meet the meal pattern requirements is not reimbursable unless supported by a medical statement signed by a registered dietitian or recognized medical authority (licensed physician, physician’s assistant, or nurse practitioner). The written statement must contain the information detailed above. 

While sponsors are not required to accommodate dietary and cultural preferences, such as vegetarian diets, sponsors are highly encouraged to do so within the existing meal patterns. The CACFP meal pattern allows for a variety of food items within the required meal components and is flexible and adaptable enough to accommodate dietary preferences. It is recommended that requests for meal modifications that are not due to a disability be made in writing, specifying the foods to be omitted and the foods to be substituted, and that the written requests be kept on file. 

Fluid Milk (Non-Dairy) Substitutions

Milk substitutions that are made due to special dietary needs that are not a disability must be nutritionally equivalent to fluid milk. The facility may make such substitutions at its discretion, but it is not required. A written request for a fluid milk substitution may be made by a physician, physician assistant, nurse practitioner, registered dietitian, or parent or guardian. The request must identify the medical or other special dietary need that restricts the child's diet. Fluid milk substitutes must contain all nutrients in the minimum quantities specified to be considered nutritionally equivalent to fluid cow’s milk.

Fluid Milk Substitute - Minimum Nutrient Requirements*

Non-dairy beverages served to children 1 through 5 years old must be unflavored due to the higher sugar content of flavored varieties.

*A medical statement is required for non-dairy substitutions due to a disability that do not meet the nutritional standards of cow’s milk as described above.

Non-dairy beverages that meet USDA Substitution criteria per eight fluid ounces include:

• 8th Continent: Original Soy Milk
• Silk: Original Soy Milk
• Bettergoods: Plant-Based Original Soymilk
• Pacific Foods: Original Ultra Soy Milk
• Kikkoman: Pearl Organic Soymilk
• Ripple: Original Plant-Based Milk

Note: The Missouri Department of Health and Senior Services-Community Food and Nutrition Assistance (DHSS-CFNA) does not endorse the companies or products listed. This list is not all-inclusive. Read the nutrition facts panel or contact the manufacturer to ensure that product formulations are current. Non-dairy beverages served to children 1 through 5 years old must be unflavored due to the higher sugar content of flavored varieties. (Reference: CACFP 17-2016)

Fluid milk substitutes are not required to be low-fat or fat-free when served to children 2 years old and older and adults. Non-dairy beverages must be fortified to meet the nutrient requirements for fluid milk substitutes, and some fat is often needed to help mask the flavor of the nutrient packet added. To ensure that independent facilities and SOs with 2 or more facilities have access to a variety of fluid milk substitutes that are nutritionally equivalent to cow’s milk, and thus special dietary needs of participants are more likely to be met, there is no standard for fat content in fluid milk substitutes.

Any reasonable parent or guardian's written request for a non-dairy milk substitution that is nutritionally equivalent to fluid milk could be accepted at the center's discretion without providing a medical statement. For example, if a parent has a child who follows a vegan diet, the parent can submit a written request to the child’s caretaker asking that soy milk be served in lieu of cow’s milk. The written request must identify the medical or other special dietary need that restricts the diet of the child. Non-dairy milk substitutions are an option and an expense for the facility. Other examples that may be considered reasonable written requests would be for religious, cultural, or ethical reasons. However, a request that only states that a child “does not like milk” would not be a reasonable request for a fluid milk substitute.

Processed Food Documentation

Child and Adult Care Food Program (CACFP) sponsors are responsible for ensuring that their menus fulfill meal pattern requirements. Therefore, they must maintain documentation demonstrating how a food item meets the program requirements in 7 CFR 226.

Some centers choose to purchase commercially processed meat/meat alternate (m/ma) products rather than prepare these main dish items on site, which is commonly referred to as “homemade” or “cooked from scratch.” Some reasons a center may purchase these convenience items are due to the lack of skilled labor or inadequate kitchen preparation equipment. The quality of commercially processed foods varies widely from manufacturer to manufacturer and product to product. Because the meal pattern contribution for commercially processed foods cannot be verified, all centers must maintain documentation to verify the meal pattern contribution to the Child and Adult Care Food Program (CACFP).

If the processed (commercially prepared) food item is not found in the “Food Buying Guide for Child Nutrition Program” (FBG), then documentation should be obtained from the manufacturer prior to purchasing and serving/claiming the food item.

In November 2024, the United States Department of Agriculture (USDA) released an updated policy memo (CACFP 04-2025) regarding the documentation of processed foods which supersedes previous guidance. This memo details the two types of acceptable documentation approved to verify meal pattern compliance: Child Nutrition (CN) label OR a manufacturer’s Product Formulation Statement (PFS).

The CN label and a manufacturer’s PFS are documents that provide a way for a manufacturer to demonstrate how a processed food product contributes to the meal pattern requirements. Both a CN label and PFS are voluntarily provided by manufacturers at the request of program sponsors.

A CN label is authorized by USDA and provides a warranty of a product’s meal pattern contribution when the processed product is used according to the manufacturer’s instructions. A PFS is typically provided for processed products that do not have a CN label. It is the program operator’s responsibility to request and verify that the supporting documentation for the PFS is accurate.

CN Labels

The Child Nutrition Labeling Program is administered by the United States Department of Agriculture, Food and Nutrition Service (USDA, FNS) in cooperation with the following agencies: Agriculture Marketing Service (AMS), Food Safety and Inspection Service, and National Marine Fisheries Service. Main dish products that contribute to the meat/meat alternate component of the meal pattern requirements are eligible for a CN label. Examples of these products include beef patties, cheese or meat pizzas, meat or cheese and bean burritos, egg rolls, and breaded fish portions

Advantages of using a CN-labeled product include:

• A CN label statement clearly identifies the contribution of a product toward the meal pattern requirements. It protects Child Nutrition program sponsors from exaggerated claims about a product.
• A CN label provides a warranty against audit claims if the CN-labeled product is used according to the manufacturer’s directions.
• CN labels simplify cost comparisons of like products.

CN-labeled products will always contain:

• The CN logo, which has a distinct border;
• The meal pattern contribution statement;
• A unique 6 digit product identification number assigned by USDA/FNS appearing in the upper right hand corner of the CN label
• The USDA/FNS authorization statement;
• The month and year of the final approval.
• Plus the remaining required label features: product name, inspection legend, ingredient statement, signature/address line, and net weight.

Note: The X’s in the sample CN Logo are only used to demonstrate the placement of the CN identification number and the final date. If you receive a CN-labeled product containing all X’s (all zeroes or non-number symbols) for the CN identification number, the label is not valid. If a CN label is not valid, FNS cannot provide a warranty for its use toward meal pattern requirements.

The CN label is the gold standard for verifying the crediting of menu items and provides a warranty against audit claims when the product is used according to the manufacturer’s instructions.

Acceptable and valid documentation for the CN label includes:

• The original CN label removed from the product carton.
• A photocopy of the CN label shown attached to the original product carton.
• A photograph of the CN label shown attached to the original product carton.
• A CN label copied with a watermark displaying the product name and CN number provided by the vendor and the Bill of Lading (invoice).

CN labels that are photocopied or photographed must be visible and legible.

CN Label Verification System

The CN Label Verification System is available at the USDA website to assist the CACFP sponsors in verifying the status of a CN label as well as the crediting information.

Dates related to CN Labels

Once authorized, CN labels are valid for five years under the condition that the manufacturer remains an authorized CN producer and the product formulation does not change. The date printed on the CN label is the original date of authorization or the date of the most recent authorization for use of that CN label. This is different from the “Valid Until” date shown on the CN Label Verification Report, which indicates when the current authority to use the label expires. Manufacturers may choose to leave the original authorization date on the label when they receive reauthorization of their CN label so that the label inventories do not go to waste. For example, if a CN label was originally authorized on February 15, 2024, it is valid until February 15, 2029. The manufacturer may resubmit the same product for reauthorization of the CN label. If reauthorization is granted, the “Valid Until” date is updated to five years from the most recent date of the authorization on the CN Label Verification Report, but the date on the CN label may remain as 02/24.

Requirements for Documenting Watermarked CN Labels

A CN label copied with a watermark is used when the CN logo and contribution statement are presented on product information separate from the actual product carton. Manufacturers may provide program sponsors with a watermarked CN label during the bidding process. (Note: original CN labels on product cartons will not have a watermark.) Program sponsors should be aware that product information on the watermarked CN label can be changed. Therefore, program sponsors are encouraged to verify that the watermarked CN label came from a product that was purchased and accurately reflects that product.

A watermarked CN label along with the Bill of Lading (invoice) is acceptable documentation for a state agency monitoring process. Valid and acceptable documentation for the watermarked CN label includes:

1. a hard copy of the CN label copied with a watermark displaying the product name and CN number provided by the vendor; or
2. an electronic copy of the CN label with a watermark displaying the product name and CN number provided by the vendor.

Product Formulation Statements (PFS)

The PFS should only be requested when reviewing a processed product without a CN label. PFSs are written and provided by individual manufacturers and are not commonly seen with CACFP sponsors. It is the sponsor’s responsibility to request and verify that the processed food documentation is accurate prior to purchasing processed products.

PFS templates for each meal component are available on USDA’s CN labeling website. Manufacturers may use PFS templates as a guide to help develop a PFS, which are available at the USDA website. However, they are not required to use the same format as the USDA’s template, but they must present the same information on their company letterhead. It should be noted that a PFS does not provide any warranty against audit claims. Unlike CN labels, a PFS that claims a meal pattern contribution is not a guarantee of USDA meal pattern compliance and can be disputed during a CACFP monitoring review.

The answer to each of the following questions should be yes:

• Is the PFS on signed company letterhead? The signature can be handwritten, stamped, or electronic.
• Does the PFS include product name, product code number, and serving/portion size?
• Do the creditable ingredients listed on the PFS match or have a similar description to the ingredients listed on the product label? For example, if the PFS lists ground beef (not more than 20% fat), the product label should also list ground beef (not more than 20% fat).
• Do the creditable ingredients listed on the PFS match or have a similar description to a food item listed in the USDA Food Buying Guide for Child Nutrition Programs?
• If the product is a meat/meat alternate, does it contain an Alternate Protein Product (APP) such as soy concentrate? If yes, does the manufacturer provide supporting documentation that meets USDA APP requirements?
• Does the PFS demonstrate how creditable ingredients contribute toward the meal pattern requirements?
• Are the manufacturer’s calculations correct and verified?

The PFS should include:

• Weight of raw portion; percent of raw meat or poultry; percent of fat of raw meat.
• Weight of an APP, if applicable; percent of an APP on an as-is basis for the as-purchased product; certification that an APP meets the USDA, FNS requirements.
• Product’s total creditable amount of product per portion towards the meal pattern.
• Certification statement that the PFS is an accurate verification of meal pattern compliance.
• Original signature and title of company official and date.

Helpful Resources

Additional guidance and technical assistance related to CN labels and PFS may be found on the “Manufacturer Documentation: Child Nutrition Labels and Product Formulation Statements” website and Tips for Evaluating a Manufacturer's Product Formulation Statement | Food and Nutrition Service (usda.gov).

USDA’s CN Labeling Website includes a general background of the CN Labeling Program and provides helpful information for food manufacturers and child nutrition programs. It can be accessed at the USDA website or from the USDA Food Buying Guide for Child Nutrition Programs - Appendix C.

The CN Label Verification Reporting System can also be accessed from the link and from Appendix C. The system was developed to assist state reviewers, program sponsors, and the food industry in verifying the status of a CN label and the validity of a CN label. The system produces two reports monthly:

• CN Label Verification Report includes all information pertaining to the valid CN label, which includes the crediting information (meal pattern contribution statement), label expiration date, and the manufacturer’s establishment number.
• CN Label Manufacturers Report includes contact information for manufacturers that are authorized to produce CN labeled products. This report allows users to link the manufacturer’s list from the CN Label Verification Report.

These reports can be found at the USDA website.

Product Formulation Statement (PFS) – Approved Example:

All documentation regarding processed foods must be maintained in the sponsor files. If no information is available at the time of a monitoring review, meals containing the processed foods may be disallowed.

At-Risk Afterschool Care Centers and Outside School Hours Care Centers participating in CACFP who plan to purchase meals or services from outside sources must follow procurement procedures.

Sponsors participating in the Child and Adult Care Food Program (CACFP) who plan to purchase meals or services from outside sources must follow proper procedures in purchasing these services.

All procurement of food, supplies, goods, and other services with program funds must comply with procurement standards in 2 CFR 200.317-326, 2 CFR part 400 and part 415, and Food and Nutrition Services (FNS) Instruction 796-2, Rev. 4, program-specific regulations in 7 CFR 226.22, as well as State Regulations and local policies. These standards ensure that such materials and services are obtained for the program efficiently and economically and in compliance with applicable laws and executive orders.

Important Terms

• Bid means an offer to perform for a fixed price in accordance with the specifications and conditions set forth in an invitation for bids.
• Food Service Management Company (FSMC): Under the CACFP, an FSMC means an organization other than a public or private nonprofit school with which a sponsor may contract for preparing and, unless otherwise provided for, delivering meals, with or without milk for use in the program (7 CFR 226.2).
• Procurement means the process of obtaining goods and/or services in accordance with applicable rules and regulations.
• School Food Authority (SFA) means the governing body that is responsible for the administration of one or more schools and has legal authority to operate the National School Lunch Program (NSLP) or School Breakfast Program (SBP) therein or be otherwise approved by FNS to operate the program.
• Vendor means a merchandiser of complete meals, meal components, or raw materials.

Methods of Procurement

There are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures, consistent with the standards of this section and 7 CFR 200.317, 7 CFR 200.318, and 7 CFR 200.319.

• Informal Procurement Methods for Small Purchases: These procurement methods expedite the completion of transactions, minimize administrative burdens, and reduce costs. Informal procurement methods may be used when the value of the procurement transaction under the Federal award does not exceed the simplified acquisition threshold as defined in 7 CFR 200.1. The CACFP sponsor may also establish a lower threshold. Informal procurement methods include:
  • Micro-purchases are those purchases that do not exceed $15,000 per transaction. These purchases can be awarded without soliciting competitive quotations if the price is reasonable based on research, experience, purchase history, or other information, and the sponsor maintains related documentation on file. The sponsor should also equitably distribute purchases among qualified suppliers rather than buying all supplies from one source.
  • Simplified Acquisitions (Small Purchases) are those between $15,000 and $350,000 per transaction. These purchases can be made using informal methods, such as price or rate quotations for securing products or services. The methods used must ensure free and open competition. The sponsor must contact at least three reputable companies to obtain price quotations for any purchase they plan to make. This information must be documented. If an aggregate purchase is $50,000 or more or the selected bid is not the lowest price, it must be submitted to the State Agency for approval before acceptance. These quotes/bids must meet all federal regulations, including not contracting with a company that poses a conflict of interest.
    
    A bid packet that includes the informal competitive bid procedures and forms for meal service contracts $350,000 or less can be found at the CACFP website under Food Service Management Contracts. All food service management contracts must be submitted to the State Agency for approval before acceptance.
• Large Purchases or Competitive Sealed Bids: When purchases are estimated to exceed the simplified acquisition threshold of $350,000, a sponsor must conduct a price analysis and follow a formal competitive sealed bid process. Bids are publicly solicited from two or more responsible bidders, and a bid opening evaluation must be completed by the Department of Health and Senior Services, Community Food and Nutrition Assistance (DHSS-CFNA). Competitive sealed bid procedures include preparing the invitation for bid, publicly announcing not less than 14 days before bids are opened, notifying the DHSS-CFNA of the time and place at least 14 days before bid opening, publicly opening all bids, and submitting a selected bid to the DHSS-CFNA before accepting the bid. These bids must be approved by the State Agency before the final acceptance. These bids must meet all federal regulations, including not contracting with a company that poses a conflict of interest.

A bid packet that includes the formal competitive bid procedures and forms for meal service contracts greater than $350,000 can be found at the CACFP website under Food Service Management Contracts.

When using vended meals, FSMC contracts must be current to receive reimbursement for those meals. Be proactive about renewing your FSMC contract to avoid the expiration of the contract. Ensure that your FSMC contract and supporting documentation are fully completed and accurate prior to submitting them. Submit them to the State agency as soon as possible to allow time for processing and approval of the contract.

If your FSMC contract expires, vended meals served during the period without a valid FSMC contract may not be eligible for reimbursement. Meal reimbursement will only resume after your FSMC contract is renewed and approved by the State agency.

Sponsors participating in the Child and Adult Care Food Program (CACFP) who plan to purchase meals or services from outside sources must follow proper procedures in purchasing these services.

All procurement of food, supplies, goods, and other services with program funds must comply with procurement standards in all state and local laws and regulations, as well as the Federal Standards identified in 7 CFR 226.22, 2 CFR 200.317-326, 2 CFR parts 400 and 415, and Food and Nutrition Services (FNS) Instruction 796-2, Rev. 4. These standards ensure that such materials and services are obtained for the program efficiently and economically and in compliance with applicable laws and executive orders.

Federal regulations 2 CFR 200 require that all sponsors of federally funded child nutrition programs maintain written procurement documents, which include a code of conduct and procurement procedures. These can be written in two separate documents or combined into one document.

Code of Conduct

Sponsors must maintain written standards of conduct covering conflicts of interest and governing the actions of their employees engaged in the selection, award, and administration of contracts as described in 2 CFR 200.318(c).

• No employee, officer, agent, or board member with a real or apparent conflict of interest may participate in the selection, award, or administration of a contract supported by the Federal award.
• A conflict of interest includes when the employee, officer, agent, or board member, any member of their immediate family, their partner, or an organization that employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from an entity considered for a contract.
• An employee, officer, agent, or board member of the sponsor may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors. However, the sponsor may set standards for situations where the financial interest is not substantial or a gift is an unsolicited item of nominal value.
• The sponsor’s standards of conduct must also provide for disciplinary actions to be applied for violations by its employees, officers, agents, or board members.

If the CACFP sponsor has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian Tribe, the sponsor must also maintain written standards of conduct covering organizational conflicts of interest. Organizational conflicts of interest mean that, because of relationships with a parent company, affiliate, or subsidiary organization, the CACFP sponsor is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization.

Procurement Procedures

Sponsors must maintain and use written procurement procedures that are consistent with state and local laws and regulations, as well as the Federal Standards identified in 7 CFR 226.22, 2 CFR 200.317-326, and Food and Nutrition Services (FNS) Instruction 796-2, Rev. 4, for all procurements made with CACFP funds. The procedures must also conform to procurement requirements that may be established by the State agency, with the approval of FNS, to prevent fraud, waste, and Program abuse.

Sponsors may use their own procurement procedures that reflect applicable State and local laws and regulations, if procurements made with Program funds conform with the provisions of this section and with procurement requirements that may be established by the State agency, with the approval of FNS, to prevent fraud, waste, and Program abuse.

The written procurement procedures should include the applicable method(s) of procurement. The following information, as well as additional information found in 7 CFR 226.22, 2 CFR 200.317-326, and Food and Nutrition Services (FNS) Instruction 796-2, Rev. 4 should also be included in the written procedures as appropriate to the needs of the sponsor:

Oversight of Contractors/Vendors

2 CFR 200.318(b)

CACFP sponsors must also maintain oversight to ensure that their contractors perform according to the terms, conditions, and specifications of their contracts or purchase orders.

Avoidance of Unnecessary or Duplicative Items

2 CFR 200.318(d)

The sponsor's procedures must avoid the acquisition of unnecessary or duplicative items. Consideration should be given to consolidating or breaking out procurements to obtain a more economical purchase. When appropriate, an analysis should be made between leasing and purchasing property or equipment to determine the most economical approach.

Procurement Arrangements Using Strategic Sourcing

2 CFR 200.318(e)

When appropriate for the procurement or use of common or shared goods and services, CACFP sponsors are encouraged to enter into State and local intergovernmental agreements or inter-entity agreements for procurement transactions. These or similar procurement arrangements using strategic sourcing may foster greater economy and efficiency. Documented procurement actions of this type (using strategic sourcing, shared services, and other similar procurement arrangements) will meet the competition requirements of this part.

Use of Excess and Surplus Federal Property

2 CFR 200.318(f)

Sponsors are encouraged to use excess and surplus Federal property instead of purchasing new equipment and property when it is feasible and reduces project costs.

Responsible Contractors/Vendors

2 CFR 200.318(h)

CACFP sponsors must award contracts only to responsible contractors who possess the ability to perform successfully under the terms and conditions of a proposed contract. When conducting a procurement transaction, the sponsor must consider contractor integrity, public policy compliance, proper classification of employees (see the Fair Labor Standards Act, 29 U.S.C. 201, chapter 8), past performance record, and financial and technical resources. See also 2 CFR 200.214.

Procurement Records

2 CFR 200.318(i)

The CACFP sponsor must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price.

The following records will be maintained for a period of three years plus the current year:

• Written rationale for the method of procurement;
• Copy of the IFB or RFP;
• The selection of contract type;
• The bidding and negotiation history and working papers;
• The basis for contractor selection;
• Approval from the State agency to support a lack of competition when competitive bids or offers are not obtained;
• The basis for award cost or price;
• The terms and conditions of the contract;
• Any changes to the contract and negotiation history;
• Billing and payment records;
• A history of any contractor claims; and/or any contractor breaches.
• Logs of all emergency and noncompetitive purchases

Settlement of Contractual and Administrative Issues

2 CFR 200.318(k)

The CACFP sponsor is responsible for the settlement of all contractual and administrative issues arising out of its procurement transactions. These issues include but are not limited to, source evaluation, protests, disputes, and claims. These standards do not relieve the sponsor of any contractual responsibilities under its contracts. The Federal agency will not substitute its judgment for that of the sponsor unless the matter is primarily a Federal concern. The sponsor must report violations of law to the Federal, State, or local authority with proper jurisdiction.

Inclusion of Small Businesses, Minority Businesses, Women’s Business Enterprises, Veteran-Owned Businesses, and Labor Surplus Area Firms

2 CFR 200.321

Sponsors must follow the practices specified in 2 CFR part 200 Subpart D and USDA implementing regulations 2 CFR part 400 and part 415, as applicable, with respect to small businesses, minority businesses, women's business enterprises, veteran-owned businesses, and labor surplus area firms:

1. These business types are included on solicitation lists,
2. These business types are solicited whenever they are deemed eligible as potential sources,
3. Dividing procurement transactions into separate procurements to permit maximum participation by these business types,
4. Establishing delivery schedules that encourage participation by these business types,
5. Utilizing organizations such as the Small Business Administration and the Minority Business Development Agency of the Department of Commerce, and
6. Requiring a contractor under a Federal award to apply this section to subcontracts.

Contract Cost and Price

2 CFR 200.324

The CACFP sponsor must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold of $250,000. The method and degree of analysis conducted depend on the facts surrounding the particular procurement transaction, but as a starting point, the sponsor must make independent estimates before receiving bids or proposals. Costs or prices must be allowable and must comply with 7 CFR 226 and 2 CFR Part 200 Subpart E. The use of “cost plus a percentage of cost” and “percentage of construction costs” methods of contracting is not allowed.

Competition Requirements in Procurement

2 CFR 200.319

All CACFP procurement transactions must be conducted in a manner that provides full and open competition and is consistent with the standards of 2 CFR 200.319 and 2 CFR 200.320. The sponsor must have written procedures for procurement transactions that ensure that all solicitations:

1. Are made to ensure objective contractor performance and eliminate an unfair competitive advantage; contractors that develop or draft specifications, requirements, statements of work, or invitations for bids must be excluded from competing on those procurements. Examples of situations that may restrict competition include, but are not limited to:
   • Placing unreasonable requirements on firms for them to qualify to do business.
   • Requiring unnecessary experience and excessive bonding.
   • Noncompetitive pricing practices between firms or between affiliated companies.
   • Noncompetitive contracts to consultants that are on retainer contracts.
   • Organizational conflicts of interest.
   • Specifying only a “brand name” product instead of allowing “an equal” product to be offered and describing the performance or other relevant requirements of the procurement.
   • Any arbitrary action in the procurement process.
2. Incorporate a clear and accurate description of the technical requirements for the property, equipment, or service being procured. The description may include a statement of the qualitative nature of the property, equipment, or service to be procured. When necessary, the description must provide minimum essential characteristics and standards to which the property, equipment, or service must conform. Detailed product specifications should be avoided if possible. When it is impractical or uneconomical to describe the technical requirements clearly and accurately, a “brand name or equivalent” description of features may be used to provide procurement requirements. The specific features of the named brand must be clearly stated.
3. Identify any additional requirements that the offerors must fulfill and all other factors that will be used in evaluating bids or proposals.

The sponsor must ensure that all prequalified lists of persons, firms, or products used in procurement transactions are current and include enough qualified sources to ensure maximum open competition. When establishing or amending prequalified lists, the sponsor must consider objective factors that evaluate price and cost to maximize competition. The sponsor must not preclude potential bidders from qualifying during the solicitation period. To the extent consistent with established practices and legal requirements applicable to the sponsor, the sponsors are not prohibited from developing written procedures for procurement transactions that incorporate a scoring mechanism that rewards bidders that commit to specific numbers and types of U.S. jobs, minimum compensation, benefits, on-the-job-training for employees making work products or providing services on a contract, and other worker protections. Sponsors are also not prohibited from making inquiries of bidders about these subjects and assessing the responses. Any scoring mechanism must be consistent with the U.S. Constitution, applicable Federal statutes and regulations, and the terms and conditions of the Federal award.

In accordance with 2 CFR 200.320(c), non-competitive procurement may only be used if one of the following circumstances applies:

1. The aggregate amount of the procurement transaction does not exceed the micropurchase threshold (see paragraph (a)(1) of this section);
2. The procurement transaction can only be fulfilled by a single source;
3. The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation;
4. The sponsor requests in writing to use a non-competitive procurement method, and the Federal agency or State agency provides written approval
5. After soliciting several sources, the competition is determined to be inadequate.

Federal Agency or State Agency Review

2 CFR 200.325

The Federal agency or State agency may conduct a procurement review as described in 2 CFR 200.325. The CACFP sponsor must submit documents when requested for the procurement review.

Bonding Requirements

2 CFR 200.326

Large purchases which exceed the simplified acquisition threshold of $250,000 have the following bonding requirements:

• A bid bond must be provided at the bid in an amount not less than five (5) percent and not more than ten (10) percent, as determined by the sponsor, of the value of the contract for which the bid is made.
• A performance bond must be provided in an amount not less than 10 percent or more than 25 percent of the value of the contract for which the bid is made.

Contract Provisions

2 CFR 200.327

The sponsor’s contracts must contain the applicable provisions contain the applicable provisions described in Appendix II to Part 200 – Contract Provisions for Non-Federal Contracts Under Federal Awards.

Geographic Preference

7 CFR 226.22(c)

Sponsors participating in the Program may apply a geographic preference when procuring unprocessed locally grown or locally raised agricultural products, including the use of “locally grown,” “locally raised,” or “locally caught” as procurement specifications or selection criteria for unprocessed or minimally processed food items. When utilizing the geographic preference to procure such products, the sponsor making the purchase has the discretion to determine the local area to which the geographic preference option will be applied, so long as there are an appropriate number of qualified firms able to compete.

For the purpose of applying the optional geographic preference, “unprocessed locally grown or locally raised agricultural products” means only those agricultural products that retain their inherent character. The effects of the following food handling and preservation techniques shall not be considered as changing an agricultural product into a product of a different kind or character:

• Cooling; refrigerating; freezing.
• Size adjustment made by peeling, slicing, dicing, cutting, chopping, shucking, and grinding.
• Forming ground products into patties without any additives or fillers.
• Drying/dehydration.
• Washing.
• Packaging (such as placing eggs in cartons), vacuum packing and bagging (such as placing vegetables in bags or combining two or more types of vegetables or fruits in a single package).
• Addition of ascorbic acid or other preservatives to prevent oxidation of produce.
• Butchering livestock and poultry.
• Cleaning fish.
• The pasteurization of milk.

The best method of meal preparation will depend on factors such as the type of menu desired, the availability of food service equipment, space and personnel, and the budget of the organization.

Meal Preparation Methods

• On-Site: On-site preparation, commonly called “self-prep,” is the most commonly used food service method. Meals are prepared at the same physical location where they are served. This is the most economical method when the center has a kitchen, sufficient food preparation equipment, and available staff. The sponsor will follow the basic recordkeeping requirements of the Child and Adult Care Food Program (CACFP).
  
  All or part of the food may be prepared on-site, and the remainder purchased by the sponsor from an outside source, such as a school, hospital, commercial vendor, or farmers market. The Food and Nutrition Service (FNS) Instruction 796-2, Rev. 4 provides guidance for funding food grown by and used in the child care center’s meals. This option offers education opportunities and may decrease food costs.
• Central Kitchens: Meals are prepared in a kitchen at one of the sponsor’s physical locations or sites by the sponsor’s employees and delivered to another one or more of the sponsor’s sites. The sponsor will follow the basic recordkeeping requirements of the CACFP. When applicable, the central kitchens should use daily meal delivery tickets when delivering food to the sites, such as the Daily Meal Receiving Log, which is available on the CACFP webpage under Forms. Contact the Department of Health and Senior Services Community Food and Nutrition Assistance (DHSS-CFNA) for specific requirements for your circumstances.
• Vended: Meals are purchased from a School, a Food Service Management Company (FSMC), or a Commercial vendor. This includes an FSMC that operates within a school.
  • Purchasing from a School: Meals may be purchased from a public or private nonprofit school that participates in the National School Lunch Program (NSLP) or the School Breakfast Program (SBP), either in bulk or as individually packaged units. An independent center that receives meals from a school must enter into a written agreement with that school or district. An example of this type of agreement is when a school provides meals to a Head Start center.
    
    This annual agreement must contain the basic provisions of the program requirements and the non-competitive bid process. A sponsor may use the Sponsor Agreement with a School or Affiliated Organization to Furnish Food Service for the CACFP located on the CACFP website. Federal regulations exempt organizations from having to bid competitively for catered meals when those meals are purchased through schools participating in the NSLP or SBP. Signing an agreement with a school to provide meals does not relieve the independent center of its program responsibilities for monitoring and recordkeeping. Additional recordkeeping is required when a sponsor obtains meals from a school; recordkeeping requirements are listed below.
  • Purchasing from another Department within the Organization: Organizations that receive meal services obtained through a competitive process by another department of the same organization, such as a university child care center whose meal services are provided by the campus dining hall or campus student union, may also use a non-competitive process to obtain CACFP meals. Such organizations may sign an agreement with the food service caterer contracted by the organization to provide meals for the entire organization. This type of situation is common in large organizations such as hospitals, nursing homes, schools, governmental entities, and universities, where food services are centralized. As long as the meals provided to the centralized food service were obtained through a competitive manner within a formal bid process, those same services may be used by the CACFP organization. A sponsor may use the Sponsor Agreement with a School or Affiliated Organization to Furnish Food Service for the CACFP located on the CACFP website when obtaining meals in this manner.
  • Purchasing from a Food Service Management Company: Food service management companies are organizations that prepare and deliver meals. An independent center that purchases meals from an FSMC must enter into a written contract with the company. The bid prototypes and CACFP guidance on meeting procurement standards are located on the CACFP website. Signing a contract with an FSMC does not relieve the center of its program responsibilities for monitoring and recordkeeping. Regulations require that a copy of the contract be submitted to DHSS-CFNA before the beginning of program operations under the contract, and all bids totaling over $350,000 shall be submitted for state agency approval before the sponsor accepts and signs any contract. In addition, all bids shall be submitted to the state agency for approval before accepting a bid that exceeds the lowest bid. DHSS-CFNA shall respond to any request for approval within ten working days of receipt (7 CFR 226.21).
  • Purchasing from a Commercial Vendor: Commercial vendors are public organizations, hospitals, college cafeterias, etc., private commercial enterprises, caterers, or individuals that provide non-food items or individual food items but not complete meals. An independent center that purchases from a commercial vendor must enter into a written contract with the vendor following the guidelines for the formal or informal competitive bid process, depending on annual meal expenditures.

Additional recordkeeping is required when a CACFP sponsor obtains meals from a school. The school or school district that provides meals to sponsors under an agreement must provide the following documentation to the CACFP contractor on a weekly or no less than a monthly basis:

• Food costs to substantiate the reimbursement.
• Daily dated menus using a minimum of a two-week menu cycle.
• Daily meal delivery tickets to verify the amount of food and/or number of meals provided to the center.
• Food Production Records.

In addition to the records required under the agreement, the commercial vendor must provide the following documentation to the CACFP sponsor on a daily, weekly, or no more than a monthly basis:

• Documentation of paid invoices to verify contractual accountability.
• Meals per labor hour recordkeeping to document staff allocation.

Federal regulations prohibit sponsors from contracting out the management responsibilities of the CACFP, including but not limited to:

• Ordering meals.
• Maintaining program records.
• Submitting claims for meal reimbursement.
• Training and monitoring.
• Determining eligibility for free or reduced-price meals.

The sponsor must monitor the conditions set forth in the food service contract and ensure compliance with CACFP requirements. The DHSS-CFNA will not intervene in contract disputes.

Meals served must conform to the cycle menus upon which the bid was based and to menu changes agreed upon by the facility and FSMC per 7 CFR 226.6(i)(4).

In accordance with 7 CFR 226.6(i)(7), the FSMC shall not be paid for meals delivered outside of the agreed-upon delivery time, which are spoiled or unwholesome at the time of delivery, or which do not otherwise meet the meal requirements contained in the contract.

The FSMC shall maintain such records (supported by invoices, receipts, or other evidence) and shall promptly submit invoices and delivery reports to the facility no less frequently than monthly. (7 CFR 226.6(i)(2))

It is the responsibility of the sponsor to monitor the requirements of the agreement for compliance with the CACFP requirements. First-occurrence meal disallowances will be taken at the CACFP monitoring reviews in the following instances:

• There is no or inadequate processed food documentation, such as CN labels.
• There are no production records.
• The production records indicate that the caterer did not provide enough food to meet the minimum portion requirement.

A Daily Meal Receiving Log and a Meal Communication and Credit Log are available in this manual and on the MO DHSS CACFP webpage under Forms for sponsors to document the date and time food was received at the center, food temperatures, and any problems with the foods received.

The procedures for the informal and formal bid processes are available on the CACFP website at the CACFP website   under Food Service Management Contracts. These include:

• Bid Packet for Contracts $350,000.00 or less
• Bid Packet for Contracts greater than $350,000.00
• Annual Extension for Contracts greater than $350,000.00
• Sponsor Agreement with a School or Affiliated Organization

Maintaining accurate records is vital to ensure CACFP reimbursement accurately reflects the center’s program operations.

Maintaining accurate records is vital to ensure Child and Adult Care Food Program (CACFP) reimbursement accurately reflects the center’s program operations. CACFP forms are available at the CACFP website under Forms, and posters are available under Posters, Flyers, & Pamphlets.

CACFP original records, not photocopies, must be maintained on-site for independent facilities, be accessible during licensed business hours, and be available for review within one hour of a state representative’s arrival. Sponsoring Organizations (SOs) of two or more facilities must maintain original records during licensed business hours at the location identified in the Management Plan and be available for review within one hour of a state representative’s arrival. Community Food and Nutrition Assistance (CFNA) reviewers will request CACFP records for one month or more and have the authority to disallow up to twelve months of claims. Program records must be retained for three full fiscal years, plus the current year (October 1 through September 30), after the final claim for the fiscal year is submitted and for longer if audit findings have not been closed.

As a reminder, documents that prove compliance with CACFP regulations, including, but not limited to, menus, production records, delivery receipts, income eligibility forms, meal count records, and attendance records, must be completed in permanent ink and shall not be altered. If additions/corrections are required, they must be made using permanent ink. The incorrect information must be crossed out using one line so that the original information can still be read. Changes using pencils or whiteout shall be prohibited. All changes must be initialed and dated by the person making the correction.

Required Records

Meal Service Records

• Daily Meal Count Records (DHSS-CACFP-641 or DHSS-CACFP-642) - The daily meal count tally records are required for each meal and snack that the site is approved to claim for reimbursement. Keep current month records on a clipboard or in a binder. File these records with the daily attendance records. File completed records in a binder or envelope labeled with the month and year.
• Daily Menu Records - For each approved meal, breakfast, lunch, snack, and supper, daily dated menus are required to verify CACFP meal pattern compliance. The original menu, noting any substitutions, must be retained. Keep the current active menu on a clipboard or in a folder. When completed, file the menu in the binder or envelope for the month.
• Medical Statement to Request Special Meals and/or Accommodations (CACFP-227) - Required when food substitutions are necessary and authorized by a medical authority for children with a diagnosed disability and with medical or special dietary needs. Keep confidential and place in the individual child’s file.
• Commercially Processed Food Documentation - If your center uses commercially processed foods, documentation of meal pattern contributions is required. It should include a Child Nutrition label or the manufacturer's Product Formulation Statement. File in the binder or envelope for the month.
• Additional Meal Requirements - A center must maintain documentation to verify the whole grain-rich requirement is met. This may include the grain product’s ingredient label. A center must maintain documentation to verify that the cereal and yogurt served are within the required sugar limits. This may include the product’s nutrition facts label.

Participant Records

• Daily Attendance Records (CACFP-213); Monthly Time In/Time Out Record (CACFP224); or Time In/Time Out Record (CACFP-221) - A daily attendance record of each child is required to complete reimbursement claims. Keep the current monthly attendance record on a clipboard or in a binder. File completed monthly records in a binder or envelope labeled with the month and year.
• Income Eligibility Form for Child Care Centers CACFP-205 (Required for Outside School Hours Centers only; NOT required for At-Risk Afterschool Care Programs) This form is very important as it determines program eligibility and meal reimbursement rates. The IEF can be found in the CACFP Income Eligibility Guidance for Child Care Centers at the CACFP website  under Manuals. Give IEFs to all parents/guardians to complete with their enrollment packet and then annually thereafter. New IEFs must be placed with expired IEFs annually. File completed forms alphabetically by last name in a 3-ring binder. Place blank copies in a folder.
• Title XX Documentation - For-Profit Centers Only. Documentation includes Family Support Division vendor invoices, a copy of the contract with FSD for vendor children, and an enrollment roster marked with the names of vendor children. File in a folder or binder.

Records Pertaining to Financial Management and Administrative Costs

• Administrative Costs - Costs incurred by the sponsor for activities relating to planning, organizing, and administering the program. Administrative costs may include:
  • Labor costs
  • Office costs
  • Transportation costs
• Operating Costs - Allowable expenses for the preparation and service of meals include, but are not limited to, food costs, food service labor, certain non-food supplies, and purchased services.
  • Food Costs - Are expenditures for the food used in all meals included? Original, intact and legible, itemized food and milk receipts and invoices for food service supply purchases must be retained to verify that CACFP funds are used to support the food service. Handwritten receipts are not acceptable. File in a folder or envelope labeled with the month and year.
  • Food Service Labor - Costs Independent centers must document.
  • Non-food Supplies - Non-food supplies used in the preparation and service of meals, such as napkins, trays, and utensils.
• Documentation of Nonprofit Foodservice CACFP-214 - This form must be completed monthly when total food costs are less than the CACFP claim. Place in a folder or envelope labeled with the month and year.

Training Records

• Annual CACFP Training Documentation CACFP-222 - Documentation of annual CACFP training for the center staff is required. The use of the CACFP form is not required, but training must include the topics required by the CACFP. File in a folder or notebook.

Other Required Records

• Original Contract Agreement, along with Amendments for the sponsoring agency.
• Beneficiary Data Report CACFP-226 - Documentation of the annual completion of this form is required. File in a folder or notebook.
• Sanitation and Fire Inspection Records - File in a folder or notebook.
• Procurement Plan and Code of Conduct - File in a folder or notebook.
• Catered or Vended Meals, if applicable. Sponsor must maintain:
  • Food service management company contract or agreement.
  • Current state or local health certification.
  • Production Records required and meal delivery records, if applicable.
  • Evidence that the contractor was obtained using fair and competitive practices.
  • Business License of contractor procured through formal bid procedures greater than $250,000.00.

Sponsoring Organizations (SOs)

Contractors responsible for two or more centers, either under the sponsor’s jurisdiction (affiliated) or under the corporate umbrella (unaffiliated), are required to maintain:

• Pre-approval visits to each new center under an SO.
• Sponsored Centers Site Visit Report (CACFP-404) - Each SO must monitor every center for program compliance at least three times per year, in accordance with the regulations.
• Disbursements (unaffiliated centers only) - Documentation of the dates and amount of reimbursement disbursed to each facility within 5 working days from the CACFP claim processing date is required.

Suggested items to help you stay organized:

• 3-ring binders
• 3-hole punch
• Clipboards
• Colored highlighters
• File folders
• File box or cabinet
• 12 large envelopes, one for each month

Daily Duties

Complete these records daily and maintain them on a clipboard or in a folder. Ensure that all documents are dated. At the end of each month, file the original dated records with the monthly records in an envelope or binder.

• Attendance records or sign in/sign out records.
• Meal count records: documented daily.
• Menus: verify that each meal served meets Child and Adult Care Food Program (CACFP) meal pattern requirements.
• Food Production Records: required for centers using a caterer or contract food service management company.
• Delivery Receipts: required for centers using a central kitchen or contract food service management company/caterer.
• Child Nutrition (CN) Labels and Product Formulation Statements (PFS): required for commercially processed food

Monthly Duties

Retain these legible and intact original, dated records:

• Consolidate financial records: Machine-generated dated and itemized food and milk receipts; Child Nutrition (CN) labels and PFS; itemized non-food program supplies; program labor costs; and documentation of non-profit foodservice.
• Prepare and submit the claim for reimbursement: consolidate and determine total attendance; consolidate meal counts and determine the total number of meals served for each meal. For-profit centers must calculate to determine if you are eligible to claim. Submit the claim via CNPweb by the 10th of the month for payment around the 28th or by the 25th for payment around the 13th of the following month.

Yearly Duties

Centers must maintain the original dated records by fiscal year, October 1st through September 30th.

• Annual CACFP Training Documentation: all required topics are covered at least once a year.
• Medical Statement to Request Special Meals and/or Accommodations.
• Current sanitation and fire inspections.
• Documentation of racial/ethnic data completed annually, self-identified and self-reported.
• Site visit monitoring reports for Sponsoring Organizations, three per site per year.
• For contracted/catered meals, original contract or agreement and annual renewal with Food Service Management Company.
• Child care license, if applicable.
• Enrichment program documentation.
• Current Income Eligibility Forms for Outside School Hours Centers only.
• Procurement Plan and Code of Conduct

All required records must be maintained on location during licensed hours of business and available within one hour of arrival by state officials. CACFP records must be retained for three fiscal years, October 1st through September 30th, plus the current year.

Monthly: Place in a binder or envelope labeled with the month and year

• Daily dated menus
• Daily dated attendance records
• Dated point of service meal count records
• Financial records: food service expenses; labor and indirect cost records summarized on the Documentation of Non-Profit Service Form

Yearly: Place in a binder or envelope labeled with the year

• Annual CACFP training documentation
• Medical Statement to Request Special Meals and/or Accommodations
• CN labels or Product Formulation Statements
• Beneficiary Data Report
• Vended/catered meal agreements or contracts and annual contract renewals, if applicable
• Procurement Plan and Code of Conduct
• Site visit monitoring reports, if applicable
• Sanitation and safety inspection

Outside School Hours Care Centers Only

This section provides a list of many resources available to assist At-Risk Afterschool Care Centers and Outside School Hours Care Centers participating in the CACFP.

The internet has a vast amount of information that can assist child care providers with their food service operations and the education of staff and children. Below are some resource recommendations that may also be found at our webpage  under Resources.

• A Flash of Food Safety
• Choose My Plate
• DHSS Food Safety  
• Academy of Nutrition and Dietetics; eatright.org
• Farm to Early Care and Education (ECE) 
• Food Product Thermometer Calibration – Food Safety
• Institute of Child Nutrition
  • ICN Child Care Center Food Allergy Fact Sheets
  • Food Safety
• Resources Nutrition for Kids
• Recipes for Healthy Kids
• Serving Traditional Indigenous Foods
• Team Nutrition
  • CACFP Meal Pattern Training Worksheets (English and Spanish)
  • Crediting Tip Sheets in Child Nutrition Programs
  • Mealtimes with Toddlers in the Child and Adult Care Food Program
  • Offering Water in the USDA CACFP
  • Tips for Family Style Dining
  • Milk Aide
  • Serving Meats and Meat Alternates at Breakfast
  • Serving Meats and Meat Alternates at Lunch and Supper in the USDA CACFP
  • Serving Vegetables in the CACFP
  • Adding Whole Grains to your CACFP Menu
  • Crediting Single-Serving Packages of Grains in the CACFP
  • Crediting Store-Bought Combination Baby Foods in the CACFP
  • Spanish Materials Available for Team Nutrition
  • Training Resources on Using Ounce Equivalents for Grains
  • Team Nutrition Quizzes
  • Feeding Infants in the Child and Adult Care Food Program (English and Spanish)
• USDA Child and Adult Care Food Program
• USDA Civil Rights
• USDA Food Buying Guide for Child Nutrition Programs
• USDA Procuring Local Foods
• USDA Standardized Recipes
• WIC Approved Food List