CACFP Resources CACFP Administrative Manual Section 9.2

CACFP Administrative Manual Section 9.2

Note: For Child and Adult Care Food Program (CACFP) meal pattern requirements, access the California Department of Social Services (CDSS) CACFP Administrative Manual Section 8.1.

Section 9.2 Meal Pattern Documentation Requirements

This section outlines U.S. Department of Agriculture (USDA) and CDSS meal pattern documentation requirements for CACFP meals and snacks.

Centers and day care homes (DCH) are required to demonstrate that they are serving meals that meet the meal pattern requirements per Title 7, Code of Federal Regulations (7 CFR), § 226.20.

Centers and DCHs must keep records of menus, and the state agency (CDSS) has the authority to determine other types of food service records that must be maintained to demonstrate compliance with the meal patterns per 7 CFR § 226.15(e).

Access the CDSS CACFP Administrative Manual Section 9.1 for menu documentation requirements.

Meal Pattern Documentation Requirements for CACFP Meals and Snacks Served to all Participants

All CACFP operators must retain the following documentation to demonstrate compliance with the CACFP meal patterns:

Processed food items that are not included in the USDA Food Buying Guide include most commercially-purchased combination foods that contain more than one meal component (e.g., pizza and chicken nuggets) and processed meats/meat alternates (M/MA) (e.g., veggie patties, lunch meat, and turkey bacon). For more information on crediting processed M/MAs, access the CDSS Crediting Luncheon and Other Processed M/MAs in the CACFP web page.

Commercially-purchased combination baby foods that contain a mixture of two or more meal components (e.g., chicken and sweet potatoes), require a PFS unless the volume or percentage of each creditable ingredient is listed on the baby food container or on the manufacturer’s website. For more information, access the USDA Crediting Store-Bought Combination Baby Foods in the CACFP resource.

  • Recipes that include the recipe name, quantity of each creditable ingredient (including form and preparation – e.g., raw, cooked, peeled, drained), serving size, and number of servings for the categories of homemade foods listed below to demonstrate that they meet the CACFP meal pattern requirements per 7 CFR § 226.20. Note: This CDSS meal pattern documentation requirement is in effect as of October 1, 2026.
    • Combination foods that contribute to more than one meal component in either of the following situations:
      • The meal components cannot be separated (i.e., they are combined or mixed together) and are typically, but not always, prepared in quantity. Examples include soups/stews, casseroles, and stir-fried dishes.
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      • Only the name of the recipe, and not the individual food items that comprise the food, are listed on the menu. Examples include ‘Turkey Sandwich’, ‘Quesadilla’, and ‘Cheeseburger’.
    • Foods that contribute to only one meal component in either of the following situations:
      • Other non-creditable ingredients are present in substantial amounts. Examples include cream of potato soup (in addition to potatoes, the food contains substantial amounts of broth and milk), meatloaf (in addition to meat, the food contains substantial amounts of eggs, grains, and sauces), and homemade muffins (in addition to flour, the food contains substantial amounts of eggs, sugar, and fat).
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      • One serving includes two or more food items that contribute to the same meal component but only the name of the recipe, and not the individual food items that comprise the food, are listed on the menu. Examples include ‘Omelet’ (containing eggs and cheese), ‘Mixed Fruit Salad’ (containing grapes and berries), and ‘Grain Trail Mix’ (containing pretzels, granola, and ready-to-eat cereal rounds).

Access the CDSS Recipe Requirements in the CACFP web page for additional information.

  • Product labels that include the name of the food, Nutrition Facts label, and Ingredients list from all packaged foods, including foods used as ingredients in recipes, until the end of each day only during the year that the CDSS CACFP administrative review is scheduled, to demonstrate the meal pattern requirements are met per 7 CFR § 226.20; for example, product labels are required to verify that all grain products are creditable and yogurt and breakfast cereal meet added sugars limits.
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  • Transport records for CACFP operators who receive meals prepared and delivered by a vendor or central, satellite kitchen to demonstrate the meal pattern requirements are met per 7 CFR § 226.20 and the storing, preparing, and service of food items comply with applicable State and local laws and regulations per 7 CFR § 226.20(l).

Transport records must include the same level of detail as found in the CDSS optional template in the Child Nutrition Information and Payment System (CNIPS): Form ID CACFP 66 (Daily Transport Record) and CACFP 66A (Daily Transport Record–Instructions), which includes:

    • Preparation kitchen location and name
    • Meal and/or snack service
    • Number of meals and/or snacks ordered
    • Date the foods are transported
    • Receiving site location and name
    • Name of person who placed the order
    • Time the order was placed
    • Food items prepared for delivery
    • Serving size of each food item
    • Amount of each hot food item sent and received (bulk or pre-portioned)
    • Amount of each cold food item sent and received (bulk or pre-portioned)
    • Amount of fluid milk sent and received (bulk quantity or individual portions)
    • Temperature of each food and beverage item upon delivery and serving
    • Signature of person receiving delivery of meals and/or snacks
    • Pertinent comments (e.g., unacceptable temperatures upon receipt)
  • Meal modification documentation

CACFP operators who accommodate meal modifications to the planned menu must retain documentation of the substitutions made to the menu on behalf of each participant for both operator– and household–supplied meal components to demonstrate the meal pattern requirements are met per 7 CFR § 226.20.

Note: CACFP operators are required to accommodate meal modifications for participants with a disability at no cost to the participant per 7 CFR § 226.20(g)(1) and are encouraged to accommodate meal modifications for participants with a dietary preference per 7 CFR § 226.20(g)(2).

    • For meal modifications that do not meet the meal pattern requirements: In order to receive CACFP reimbursement, operators must obtain from the household a medical statement signed by a State licensed healthcare professional or registered dietitian (RD) that provides sufficient information about the child or adult participant's dietary restrictions, such as foods to be omitted and recommended alternatives. A medical statement is required for each participant who has a disability that affects their diet only when the meal modification does not meet the CACFP meal pattern requirements per 7 CFR § 226.20(g)(1).

CDSS optional template in the CNIPS: Form ID CACFP 97–Medical Statement to Request Special Meals or Accommodations in the CACFP for Participants with a Disability (available in English and Spanish).

    • For creditable fluid milk substitutes: Operators must retain a written request from a child’s parent or guardian, an adult participant, a person on behalf of an adult participant, a State licensed healthcare professional, or RD for a creditable fluid milk substitute identifying the reason for the substitute per 7 CFR § 226.20(g)(3)(i). The fluid milk substitute must meet the minimum federal nutrient requirements for fluid milk substitutes per 7 CFR § 226.20(g)(3)(ii).

CDSS optional template in the CNIPS: Form ID CACFP 49–Request for a Creditable Fluid Milk Substitute.

    • For creditable meal component substitutions other than fluid milk: Operators must retain written documentation for all creditable food item substitutions made to the planned menu to demonstrate the meal pattern requirements are met per 7 CFR § 226.20.

CDSS optional template in the CNIPS for infants: Form ID CACFP 12–Request for Creditable Meal Modifications for Infant Participants

CDSS optional template in the CNIPS for children and adults: Form ID CACFP 84–Request for Creditable Meal Modifications for Children and Adult Participants

Access the ‘CACFP Meal Patterns: Modifications, Variations, and Flexibilities’ section of the CDSS CACFP Administrative Manual Section 8.1: Meal Pattern Requirements and the CDSS Meal Modifications in the CACFP web page for additional information.

  • For CACFP operators with an approved fluid milk exemption: Retain the email sent by the CDSS to the CACFP operator that documents approval for the CACFP operator to either serve meals:
    • Without the fluid milk component or with an alternate form of fluid milk due to temporary emergency conditions.
     
    • With an equivalent amount of canned, whole dry, or fat-free dry milk due to a continuing inability to obtain fluid milk.

Access the CDSS CACFP Fluid Milk Exemption Requests web page for additional information.

      • Serve an equal amount of a nondairy beverage that is nutritionally equivalent to fluid milk.
     
      • Serve an equal amount of full-strength juice in place of fluid milk with lunch or supper.
     
      • Serve fluid milk at an appropriate time before or after the meal service period, in accordance with applicable Jewish Dietary Law.
     
      • Serve the snack’s juice component at breakfast, lunch, or supper, and serve the corresponding meal’s fluid milk component as part of the snack

Access the ‘Modifications for Jewish Institution and Facilities’ section of the CDSS Meal Modifications in the CACFP web page for additional information.

  • For CACFP operators serving primarily American Indian or Alaska Native participants who choose to substitute vegetables to meet the grains requirement per 7 CFR § 226.20(f): Retain one of the four documents listed below.
    • Certifying statement: School Food Authorities (SFAs) that are tribally operated or operated by the Bureau of Indian Education could use a certifying statement indicating that the SFA is tribally operated or operated by the Bureau of Indian Education.
     
    • Aggregate data: SFAs, sponsors, institutions, or facilities that serve primarily American Indian or Alaska Native children could use aggregate data reporting student demographics, such as participant self-reporting, school data, or census data.
     
    • Certifying statement: For enrolled sites (i.e., sites with enrolled children or adult participants, as defined in 7 CFR § 226.2), the sponsor, institution, or facility provides a certifying statement indicating that the site primarily serves American Indian or Alaska Native participants.
     
    • School or census data: For non-enrolled sites, the sponsor, institution, or facility determines that American Indian or Alaska Native participants represent the largest demographic group of participants served by the site, based on school or census data.

CACFP operators may also contact the CDSS CACFP Operator Support and Fiscal Oversight Bureau (OSFOB) to request an alternate documentation option. For a list of OSFOB reviewers by county, access the CDSS CACFP Field Services Contact List web page.

Access the USDA policy memo CACFP 03-2025, Substituting Vegetables for Grains in American Samoa, Guam, Hawaii, Puerto Rico, the U.S. Virgin Islands, and Tribal Communities for additional information.

Additional Meal Pattern Documentation Requirements for CACFP Meals and Snacks Served to Infant Participants

Iron-Fortified Infant Formula

All CACFP operators with infants ages 0 through 11 months enrolled in care must offer CACFP benefits to all infants per 7 CFR § 226.20(b). Per 7 CFR § 226.20(b)(2), CACFP operators must offer at least one type of iron-fortified infant formula. To demonstrate that these federal requirements are met, the CDSS requires that CACFP operators notify parents or guardians that an iron-fortified infant formula is provided by the CACFP operator at no cost. Options to notify parents or guardians include, but are not limited to, the following:

  • Include a notification in a parent/guardian handbook;
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  • Document on the enrollment record or another document signed by the parent or guardian;
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  • Document on the CACFP operator's website; or,
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  • Obtain a signed, written statement from a parent or guardian who chooses to supply expressed breastmilk or an alternate iron-fortified infant formula instead. (Optional CDSS template: CNIPS Form ID CACFP 12, Creditable Meal Modifications for Infant Participants).

Expressed Breastmilk

The CDSS requires CACFP operators to label containers of expressed breastmilk with the infant’s name and date it was expressed (or thawed). Per USDA policy memo CACFP-06-2025, Feeding Infants and Meal Pattern Requirements in the Child and Adult Care Food Program; Questions and Answers, bottles of expressed breast milk must be stored in a refrigerator kept at 40° Fahrenheit (4° Celsius) or below for up to four days from the date the breastmilk was expressed. Previously frozen breast milk that is thawed and stored in the refrigerator should be used within 24 hours and should never be refrozen.

Record Retention

Per 7 CFR § 226.10(d), all records to support CACFP claims shall be retained for a period of three years after the date of submission of the final claim for the fiscal year to which they pertain, except that if audit findings have not been resolved, the records shall be retained beyond the end of the three year period as long as may be required for the resolution of the issues raised by the audit. All accounts and records pertaining to the CACFP shall be made available upon request to the CDSS, USDA, and the U.S. Government Accountability Office for audit or review. Exception: Product labels (including Nutrition Facts labels and Ingredients lists) from packaged foods are required to be retained only until the end of each day and only during the year that the administrative review is scheduled. For comprehensive information on record retention requirements, access the CDSS CACFP Administrative Manual, Section 14: Recordkeeping.

Resources:

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