Documentation Requirements for the CACFP Meal Patterns

This management bulletin (MB) provides guidance for Child and Adult Care Food Program (CACFP) Operators regarding the documentation requirements for the meal patterns referenced in Title 7, Code of Federal Regulations (7 CFR ), Section 226.20.  Per 7 CFR, Section 226.15(e)(10).  CACFP Operators must maintain copies of menus, and any other food service records required by the California Department of Social Services (CDSS).  The documentation requirements in this MB pertain only to CACFP federal regulations and the CDSS requirements related to the CACFP meal patterns.

All sample forms and templates referenced in this MB are accessible in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS) website. 

For information pertaining to the California Health and Safety Code and the California Code of Regulations (CCR), Title 22, applicable to California’s licensed child care centers, access the CDSS Community Care Licensing Laws and Regulations web page. 

For health and safety information and the CCR, Title 22, applicable to adult care agencies, access the CDSS Adult Care Licensing Resources for Providers web page. 

Table of Contents

Hyperlinks to the various sections in this MB are provided below to help the reader quickly find requirements related to specific topics.

1. Definitions
2. Background
3. Infant Meals
4. Child and Adult Menus
5. Meal Modifications for Participants without a Disability
6. Meal Modifications for Participants with a Disability
7. Declining Participation in the CACFP
8. Transport Records
9. Record Retention
10. CDSS AR Process for Determining Creditable Food Components and Food Items
11. Documentation Checklist and Sample Forms
12. Regulations, Policies, and Resources
13. Contact Information

I. Definitions

The term CACFP Operators used in this MB refers to all entities that provide meals and snacks as part of participation in the CACFP.  CACFP Operators include all types of centers (child and adult care centers, at-risk afterschool [ARA] programs, emergency shelters [ES]) and day care home (DCH) providers.

Some requirements in this MB do not pertain to DCH providers.  In these scenarios, the requirement will refer to centers only.  There are some requirements that do not pertain to specific types of centers, e.g., ARA programs and ESs.  In these scenarios, the requirement will refer to centers and exclude specific types of centers.

DCH sponsors are responsible for ensuring that DCH providers comply with the documentation requirements outlined in this MB, when applicable.

II. Background

On April 25, 2016, the U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS) published the final rule CACFP: Meal Pattern Revisions Related to the Healthy, Hunger-Free Kids Act of 2010.  The final rule updated the meal pattern requirements in 7 CFR, Section 226.20, to better align the CACFP with the Dietary Guidelines for Americans.  Although the final rule did not change the CACFP recordkeeping requirements in 7 CFR, Section 226.15(e), the USDA FNS provided additional clarification on documentation and compliance in the USDA policy memos listed in Section XII: Regulations, Policies, and Resources.

CACFP Operators are required to demonstrate that they are serving meals that meet the meal pattern requirements and must keep copies of menus, and any other food service records required by the CDSS per 7 CFR, Section 226.15[e][10].  The CDSS recordkeeping requirements for the CACFP meal patterns are included in this MB.

Note:  Per 7 CFR, Section 226.20(i), CACFP Operators serving meals to children 5 years old and older, which are prepared by school food authorities (SFA) participating in the National School Lunch Program (NSLP) and School Breakfast (SBP) may substitute the NSLP and SBP meal pattern requirements instead of the CACFP meal patterns.  This would include ARA programs and child care programs for school-age children.  CACFP Operators serving meals to preschool children under 5 years old, including SFAs, must follow the CACFP child meal patterns, regardless of whether children are served meals comingled with older children.

III. Infant Meals

All CACFP Operators with infants in care must:

• Offer CACFP program benefits to all infants.  CACFP Operators with infants enrolled in care do not have the option to limit participation in the CACFP to children only.
  
  
• Notify parents or guardians that an iron-fortified infant formula is provided by the CACFP Operator at no cost (by either including a notification in a parent handbook, on the enrollment record, on the CACFP Operator's website, or another document available to parents) or obtain a signed written statement from a parent or guardian who chooses to provide an alternate infant formula, acknowledging that they are declining the CACFP Operator’s infant formula.
  
  Sample Form:  Form ID CACFP 12, Parent/Guardian’s Form for Declining a Provider’s Infant Formula or Food (in the Download Forms Section of the CNIPS)
  
  
• Maintain daily meal records for each infant (0 through 11 months) for all meals and snacks claimed for reimbursement, which documents the following:
  
  
  • The type of infant milk offered, i.e., breastmilk, iron-fortified infant formula, or a combination of both
    
    
  • The name of all solid foods offered when infants are developmentally ready to accept them, e.g., carrots, 1 Tbsp
    
    
  • The quantity of expressed breastmilk or iron-fortified infant formula offered, and the quantity of all solid foods offered regardless of the age of the infant (DCH providers are exempt from these requirements)
    
    
  Sample Form:  Form ID CACFP 32, Individual Infant Meal Record (in the Download Forms Section of the CNIPS)
  
  
• Label containers of expressed breastmilk with the infant’s name and date and keep no longer than 72 hours after expressed.  If breastmilk was frozen, keep no longer than 72 hours after thawed.
  
  
• Include the nondiscrimination statement on the menu only if the menu is both (1) available to the public and (2) includes additional information regarding the CACFP.  If the nondiscrimination statement is required and the menu is one page or less, the short nondiscrimination statement (This institution is an equal opportunity provider) may be used to meet this requirement; otherwise, the full nondiscrimination statement must be included.

CACFP Operators are not required to offer all meal components while infants are transitioning to solid foods.  The infant meal pattern lists a range for the serving size for solid food items, e.g., 0–4 Tbsp.  This allows CACFP Operators the option to not offer a solid food component when the infant is transitioning to solids, and still claim the meal for reimbursement.

Best Practices (Optional)

• Note on the menu whether infants are breastfed onsite or offered expressed breastmilk in a bottle.  CACFP operators can use acronyms to communicate this, such as BFOS (breastfed onsite) or EBM (expressed breast milk).
  
  
• Share the American Academy of Pediatrics guidelines for determining when an infant is developmentally ready for solid foods with parents or guardians.  For more information regarding infant feeding, access the USDA Feeding Infants in the CACFP guide.
  
  
• Communicate frequently with the infant’s parents or guardians about when to introduce solid foods and which creditable solid foods to offer the infant.
  
  
• Obtain written documentation from parents or guardians that show their preferences for when to introduce solid foods and which creditable solid foods to offer.
  

IV. Child and Adult Menus

All CACFP Operators must:

• Maintain a daily dated menu listing the food items served to meet the CACFP meal pattern requirements.

• Child and adult centers only:  Dated, daily menus must be posted (e.g., in the area where food is being prepared) and list the serving sizes of food items for each age group for every meal and snack claimed.  Daily menus with serving sizes replaced the previous requirement to maintain menu production records (MPR) on October 1, 2020.  MPRs are now an optional documentation requirement.  Refer to the Menus with Serving Sizes section below for guidance on complying with this requirement. 

• ARA programs and ESs only:  Dated, daily menus must be posted (e.g., in the area where food is being prepared).  The serving sizes of food items are not required to be listed. 

• DCH providers:  Menus are required, but they do not have to be posted.
  
  
• Document on the menu, for each age group, the fat content of all types of milk served, e.g., whole, 1 percent (low-fat), fat-free (nonfat or skim), and whether each milk type is unflavored (plain) or flavored. 
  
  Reminder:  In California, the Healthy Beverages in Child Care Act, as outlined in Section 1596.808 of the California Health and Safety Code, does not allow licensed child care centers or DCH providers to serve flavored beverages to children of any age.
  
  
• Document on the menu at least one food item per day which meets the criteria for whole grain-rich (WGR).  Suggestions for clearly identifying the WGR item on the menu include writing WGR after the food item, highlighting or bolding the WGR food item on the menu, or using an asterisk after the WGR food item with an accompanying notation in a legend or at the bottom of the menu indicating the asterisk represents a WGR food item.
  
  CACFP Operators who input more than two meals and one snack, or two snacks and one meal, into a computer system that determines which meals and snacks are submitted for reimbursement, are responsible for ensuring that one daily meal or snack claimed for reimbursement includes a WGR food item.
  
  
• Document all menu substitutions.  For example, if broccoli is listed on the menu but carrots were substituted, this substitution must be documented on the menu.
  
  
• Include the nondiscrimination statement on the menu only if the menu is both (1) available to the public and (2) includes additional information regarding the CACFP.  If the nondiscrimination statement is required and the menu is one page or less, the short nondiscrimination statement  (This institution is an equal opportunity provider) may be used to meet this requirement; otherwise, the full nondiscrimination statement must be included.

Menus with serving Sizes

A menu with serving sizes is typically a menu used by food service staff.  The purpose of this menu is to communicate what foods and how much of each food to serve for each age group.  The menu with serving sizes is typically a different, separate document than the menus referenced in the California Code of Regulations (CCR) (Licensing Regulations), which do not require the serving sizes for each food.  The Licensing Regulations for menus are as follows: 

• Child care centers:  Per Title 22 CCR § 101227(6), menus must be posted at least one week in advance in an area accessible for review by the child’s authorized representative.

• Adult day care centers:  Per Title 22 CCR § 82076(a)(4), menus must be written at least one week in advance and made available for review by the clients or their authorized representatives upon request.

The requirement for menus with serving sizes can be met by maintaining one of the documents listed below.

• CDSS Daily Menu with Serving Sizes for Multiple Age Groups template (Form ID CACFP 89  in the Download Forms Section of the CNIPS) or CDSS Weekly Menu with Serving Sizes for One Age Group template (Form ID CACFP 90  in the Download Forms Section of the CNIPS).
  
  These templates include instructions, a sample completed menu with serving sizes, and a blank menu for agencies to electronically complete.
  
  
• CACFP Operator-developed menu template with serving sizes for each food item for each age group.
  
  CACFP Operators that choose to develop their own template to fulfill the menu with serving sizes requirement are required to document the menu for each meal and snack served and the serving size of each food item for each age group served. 
  
  CACFP Operators should review the CDSS Developing a Menu with Serving Sizes web page to learn how to develop a menu with serving sizes that meets the CDSS requirements. 

• CDSS Agency MPR—Centers (Form ID CACFP 28 in the Download Forms Section of the CNIPS) or CDSS Agency MPR—Adult Day Care Centers (Form ID CACFP 78 in the Download Forms Section of the CNIPS).
  
  CACFP Operators that choose to continue to use the MPR to meet the requirement for a menu with serving sizes are only required to complete the two columns titled Name and Form of Food Used and Serving Size (for each age group served).  All other columns on the MPR are optional.  The CDSS developed instructions (Form ID CACFP 28A for child care centers and Form ID 78A for adult care centers in the Download Forms Section of the CNIPS) to assist CACFP Operators with completing the MPR.
  
  
• Transport Record CACFP Operators who receive vended meals can continue to use the CDSS Sample Transport Record (Form ID CACFP 66 in the Download Forms Section of the CNIPS) or their own transport record template to fulfill the requirement for a menu with serving sizes.  All applicable fields must be completed on the CDSS Transport Record, including the serving size or scoop number sizes for bulk foods.  Agencies are not required to use this sample form, however, they must maintain the same level of detail on alternative templates.
  
  Tip:  CACFP Operators should use online USDA Food Buying Guide (FBG), which is also available as a mobile application (app) available for download in the Apple App store or in the Google Play Store, to determine the minimum quantity of foods to purchase and prepare to provide the minimum serving sizes for each age group to meet the CACFP meal pattern requirements.
  

For additional information, access the CDSS Developing a Menu with Serving Sizes web page.

V. Meal Modifications for Participants without a Disability

CACFP Operators must:

• Document all parent or guardian-supplied (or CACFP Operator-supplied) foods and beverages offered as a meal or snack modification.  The CACFP Operator can document these modifications in a document that they already maintain (e.g., infant meal record, menu with serving sizes, enrollment record), on a specific form that the CACFP Operator develops for this purpose, or using the specific form that the CDSS developed for this purpose, listed below.  Accommodating participants without disabilities is encouraged, but not required.
  
  Sample Forms:  Form ID CACFP 12, Parent/Guardian’s Form for Declining a Provider’s Infant Formula or Food; Form ID CACFP 84, Parent/Guardian’s Form for Declining a Provider’s Food for Older Children (available in the Download Forms Section of the CNIPS)
  
  
• Ensure parents or guardians supply no more than one creditable food component when served as part of a reimbursable meal and snack (7 CFR, 226.20[g][2][ii]).

• Obtain a signed written request from a child’s parent or guardian, or a household member of an adult participant, when a request is made for a fluid milk substitution that meets the minimum federal nutrient requirements for fluid milk substitutes and a medical statement is not on file (7 CFR, Section 226.20[g][3]).  Written requests may be obtained using the sample form listed below or requests may be incorporated into an existing form, such as an enrollment record.
  
  Sample Form:  Form ID CACFP 49, Request for a Fluid Milk Substitution (available in the Download Forms section of the CNIPS)

Note:  CACFP Operators may develop a policy that does not allow food to be brought from home unless CACFP participants have a signed written medical statement on file to reduce:

• Documentation requirements for food brought from home
• The CACFP Operator’s risk for meal disallowances
• Food safety concerns
• Differences between meals that each participant receives

For more information on meal modifications for participants without disabilities, access USDA policy memo CACFP 14-2017, SFSP 10-2017, Modifications to Accommodate Disabilities in the CACFP and Summer Food Service Program (SFSP), and the CDSS Meal Modifications in the CACFP web page.

VI. Meal Modifications for Participants with a Disability

CACFP Operators must:

Obtain a signed medical statement for participants with a disability who require foods and/or beverages that do not meet the meal pattern to be substituted in place of the planned meal to accommodate the disability.  Access the CDSS Meal Modifications in the CACFP web page for additional medical statement documentation requirements.

Sample Form:  Form ID CACFP 97, Medical Statement to Request Special Meals and/or Accommodations in the CACFP (available in the Download Forms section of the CNIPS).

VII. Declining Participation in the CACFP

When participation in the CACFP is declined, a written request from the parent or guardian or household member of an adult participant is not required, but recommended.

Sample Form:  Form ID CACFP 11, Declining Participation in the CACFP (available in the Download Forms section of the CNIPS).

VIII. Transport Records

All CACFP Operators that serve food that is prepared off site and delivered must maintain transport records with the same level of detail as found in the sample form listed below.

Sample Form:  Form ID CACFP 66, Sample Transport Record (available in the Download Forms section of the CNIPS)

IX. Record Retention

CACFP Operators must retain all documents to verify that the meal pattern requirements were met for the current Federal Fiscal Year (FFY), October 1 through September 30, plus the prior three FFYs, such as:

• Menus (with serving sizes, if applicable)
  
  
• MPRs (required for all centers, except ARA and ES, prior to October 1, 2020)
  
  
• Child Nutrition labels, product formulation statements, and standardized recipes, if applicable
  
  
• Transport records, if applicable
  
  
• Medical statements or requests for medical statements, if applicable
  
  
• A written request from a parent or guardian of a child or a household member of an adult participant for a nondairy milk substitute when there is no medical statement on file, if applicable
  
  
• Food and beverage receipts, invoices, and vending contracts, if applicable (DCH providers are exempt from this requirement)
  
  
• Payroll records of labor cost charged to the CACFP and job descriptions associated with the CACFP tasks, if applicable

Note:  In cases where there are open audits or administrative reviews (AR), these records must be kept until the audit or AR is closed.  Failure to maintain the above program records as required may result in denial of reimbursement for meals and snacks served during the period associated with the records and may also result in a serious deficiency designation.  All accounts and records pertaining to the CACFP shall be made available, upon request, to representatives of the CDSS and the U.S. Government Accountability Office for audit or review at a reasonable time and place.

X. CDSS AR Process for Determining Creditable Food Components and Food Items

The CDSS modified the CACFP AR process to address compliance with the updated CACFP meal patterns.

Reviewers will check for compliance by:  (1) analyzing the menu for the month of review (defined as the last month the CACFP Operator submitted a claim for reimbursement); (2) observing meal preparation (if time permits) and meal services on the day of the onsite meal observation; and (3) reviewing documents related to the meal services on the day of the onsite meal observation. This day is selected by the reviewer and is usually unannounced.  (Not all CDSS DCH provider site monitoring visits include a meal observation.)

For more information about what documents reviewers will request for the month of review and the day of the onsite meal observation during a CDSS AR, refer to Section 16, Administrative Review Process for Compliance with the CACFP Meal Patterns, in the CDSS CACFP Administrative Manual.

XI. Documentation Checklist and Sample Forms

The CDSS consolidated two checklists (CACFP Form ID 82, the CACFP Child Care Agency Task List, and CACFP Form ID 89, CACFP Meal Pattern Documentation Checklist) into one comprehensive checklist for all required CACFP documentation.  This checklist is an optional tool that will assist CACFP Operators in assessing compliance with required program documentation prior to an AR.

The new consolidated checklist is Form ID CACFP 82, CACFP Checklist of Requirements by Timeframe for Centers (available in the Download Forms section of the CNIPS). 

XII. Regulations, Policies, and Resources

Regulations

• 7 CFR, Sections 226.15 and 226.20
  
  

USDA Policies

• CACFP 17–2016, Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the CACFP, Questions and Answers (Q&A)
  
  
• SP 53–2016, CACFP 21–2016, Crediting Tofu and Soy Yogurt Products in the School Meal Programs and the CACFP
  
  
• CACFP 08–2017, Q&A on the Updated Meal Pattern Requirements for the CACFP
  
  
• CACFP 09–2017, Vegetable and Fruit Requirements in the CACFP, Q&A
  
  
• CACFP 14–2017, SFSP 10–2017, Modifications to Accommodate Disabilities in the CACFP and the SFSP
  
  
• CACFP 17–2017, Documenting Meals in the CACFP
  
  
• CACFP 02–2018, Feeding Infants and Meal Pattern Requirements in the CACFP, Q&A
  
  
• CACFP 09–2018, Grain Requirements in the CACFP, Q&A

• SP 37–2019, CACFP 16–2019, Questions and Answers on the Final Rule Child Nutrition Programs: Flexibilities for Milk, Whole Grains, and Sodium Requirements
  

Resources

• CDSS CACFP Administrative Manual
  
  
• CDSS CACFP Meal Patterns
  
  
• CDSS USDA Food Buying Guide Calculator 

• CDSS Menu Modifications in the CACFP
  
  
• USDA Navigating the Food Buying Guide Calculator online course
  
  
• USDA FBG for Child Nutrition Programs
  
  
• USDA Feeding Infants in the CACFP Guide
  
  
• USDA Monitoring Handbook for State Agencies
  

XIII. Contact Information

For questions about the CACFP meal pattern documentation requirements, contact the CDSS CACFP Nutrition Team at CACFPmealpatterns@dss.ca.gov.

For questions about the AR process, contact your CACFP Child Nutrition Consultant (CNC). To identify your CNC, access the Directory of Staff County Assignments, Form ID Caseload (available in the Download Forms section of the CNIPS).

This institution is an equal opportunity provider.
Esta institución es un proveedor que ofrece igualdad de oportunidades.