Appendix D. Report: Reducing Paperwork in the Child and Adult Care Food Program

Report to Congress:

Reducing Paperwork
in the Child and Adult
Care Food Program

August 2015
Appendix D

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Report to Congress:
Reducing Paperwork in the Child and Adult Care Food Program
This Report to Congress is submitted by the U.S. Department of Agriculture, Food and Nutrition
Service on behalf of the Child and Adult Care Food Program (CACFP) Paperwork Reduction Work
Group. This report examines the feasibility of reducing unnecessary or duplicative paperwork for
States, sponsoring organizations, and child care homes and centers.
CACFP was created as a pilot program to support working families in 1968. It was permanently
authorized in 1975 under section 17 of the Richard B. Russell National School Lunch Act, 42 U.S.C.
1766. The Program assists States through grants-in-aid and other means to initiate and maintain
nonprofit food service programs for children in various forms of child care. Although CACFP is also
available in adult day care centers and emergency shelters, this report focuses on paperwork
requirements in traditional child care settings.
In fiscal year 2014, 780,000 children in child care homes and 3 million children in child care centers
received meals through CACFP at a total meal cost of $2.72 billion. More than 890 sponsoring
organizations administered CACFP in 118,000 child care homes and 39,000 sponsored centers.
Another 20,000 centers chose to participate directly with the State agency.

Contents
The Purpose…………………………………………………………....…………………….....…1
Making Improvements to CACFP………………………………..….…..………….……...….....6
Recommendations to Congress……..……………………………………………….…………....9
Recommendations to USDA.……….………..……………..………..…………….………........10
In Closing..………..………..…………………….………..……………………….………........19
Appendix A: Healthy, Hunger-Free Kids Act of 2010..…………………..…………….............20
Appendix B: CACFP Paperwork Reduction Work Group Members……………………….......21
Appendix C: Memoranda Issued in 2013.………..……..………………...............…………….22
Appendix D: Memoranda Issued in 2007 – 2008..…………...……………………..…………..23
Appendix E: Recommendations and Actions…………………………...……..………………..24

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The Purpose
The Child and Adult Care Food Program (CACFP) is the most important source of funding for
nutrition for children in early childhood education and care programs. CACFP provides grantsin-aid to States that allow child care homes and centers to provide the nutritious foods that young
children need for healthy growth, development, and wellness.
The complexity of CACFP requirements creates unique administrative challenges for the child
care homes, centers, and agencies that are responsible for delivering the Program’s essential
benefits to children. This report, submitted on behalf of the CACFP Paperwork Reduction Work
Group (Work Group), examines the paperwork that is needed to comply with the requirements.
The Work Group explored how to make CACFP requirements more efficient, while maintaining
Program integrity.
In this report, the Work Group proposes that Congress make improvements to CACFP that
would:
•
•
•

Extend the use of location in eligible areas to child care centers to determine
CACFP eligibility;
Extend community eligibility and other approaches to facilitate a child’s
participation in CACFP; and
Engage a representative work group to continue to guide paperwork reduction
efforts.

This report also addresses the Work Group’s recommendations to the U.S. Department of
Agriculture (USDA) to make improvements to CACFP. These recommendations would:
•
•
•
•
•
•
•
•
•
•

Work with State agencies to implement existing flexibilities to reduce
paperwork;
Make a child’s eligibility for CACFP benefits easier to document and improve
access through direct certification;
Align monitoring requirements to streamline reviews of child care homes and
centers;
Establish a single, blended-rate method of payment, which is determined
annually for centers;
Simplify the documentation of food service records required by the State
agency;
Establish annual eligibility determinations for certain for-profit centers;
Simplify verification of the nonprofit food service status of sponsored centers;
Eliminate budget requirements that are counterproductive to a fiscally
responsible Program operation;
Further streamline the CACFP renewal process for sponsoring organizations
and centers;
Support the sponsoring organization’s ability to mediate and fix problems
through improvements in the serious deficiency process;
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•
•

Expand the appeals process to resolve disputes over State-specific
requirements; and
Embrace technology solutions to improve integrity and reduce paperwork.

All of the Work Group’s recommendations for improvement are intended to streamline
paperwork and remove barriers to participation without compromising the integrity of CACFP.
CACFP benefits our children
The benefits of CACFP are clear. CACFP provides nutrition and nutrition education to improve
health and wellness of more than 3.56 million children receiving child care each day. This
Program is a leading source for information about health and wellness so that our Nation’s
children get the best start when it comes to healthy eating and physical activity. It inspires
innovative State and local improvements to enhance nutrition and promote physical activity of
our children.
CACFP makes it possible to provide the good nutrition infants and children need in child care
homes, centers, and a variety of nontraditional child care settings, including after-school
programs for children and youth. CACFP meals are an essential part of the early childhood
education and care each child receives. Participating child care homes and centers receive
reimbursement for serving meals to children that meet USDA guidelines.
Sponsoring organizations conduct training, monitor compliance, process claims for
reimbursement, and provide other Program assistance to child care homes and centers. While a
child care home must participate in CACFP under a sponsoring organization, a center may
participate directly with the State agency or elect to participate through a sponsoring
organization. Centers may be sponsored by an organization with which they are affiliated, such
as a day care chain corporate office, or an unaffiliated, not-for-profit organization with which
they have no preexisting relationship.
With its unique combination of training and oversight, CACFP is effective at sustaining and
enhancing the quality of early childhood care experiences for children. The Program plays a
vital role in creating and maintaining higher quality, affordable care for infants, young children,
school-age children, and youth. However, the diversity of CACFP settings and forms of
participation also create unique administrative challenges.
The CACFP community has long been concerned about the level of complexity that is required
for administration of the Program. There is strong advocacy to support efforts to reduce
paperwork requirements, within a framework of integrity, and make CACFP less burdensome
and more cost-effective to administer. Sponsoring organizations, which bear a significant burden
in CACFP, have pushed for greater flexibility in determining how records are reported and
stored, wider application of electronic solutions, and a streamlining of paperwork for sponsored
child care homes and centers.
Central goals include guaranteeing the integrity of CACFP and also ensuring that administrative
requirements for improving Program management produce the outcomes for which they were
designed. There is a balance, between the goal to increase access on the one hand and the goal to
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maintain integrity on the other, which drives USDA and stakeholders to improve CACFP. There
is also a strong urgency to reduce complexity and streamline administrative burden so that this
Program can continue to do what it does best – deliver nutritious meals to children in various
forms of early childhood education and care.
A mandate from Congress to examine the feasibility of reducing paperwork
The Healthy, Hunger-Free Kids Act of 2010, Public Law 111-296, directs USDA to work with
State agencies and sponsoring organizations to reduce paperwork and improve Program
administration. Section 336 requires USDA to continue to examine the feasibility of reducing
unnecessary or duplicative paperwork resulting from regulations and recordkeeping requirements
for State agencies, sponsoring organizations, child care homes, and centers participating in
CACFP. Additionally, USDA is provided discretion, in conjunction with State agencies and
sponsoring organizations, to examine any other aspect of administration of the Program. Section
336 also requires USDA to submit a report to Congress detailing the results of the examination.
The provisions of section 336 are found under Appendix A.
USDA formed a representative Work Group to help the Food and Nutrition Service (FNS) meet
the requirements outlined in section 336. The Work Group includes a cross-section of CACFP
professionals from State and local agencies and national associations, as well as experts in early
childhood education and care, nutrition, and technology. A list of Work Group members is
found under Appendix B. Engaging State agencies and sponsoring organizations was critically
important to help USDA understand the needs and concerns of the CACFP community, develop
recommendations for Program improvement, and produce a report to Congress on paperwork
reduction efforts.
The Work Group set out to review and evaluate recommendations, policy guidance, and
regulatory priorities that USDA had implemented to comply with previous paperwork reduction
efforts authorized under the Child Nutrition and WIC Reauthorization Act of 2004, Public Law
108-265. The Work Group also looked at paperwork and administrative requirements that were
established since February 23, 2007, to consider further reductions and simplifications.
Tasked with exploring how to make CACFP requirements more efficient, within a framework
that maintains Program integrity, the Work Group established goals to:
•
•
•
•

Identify regulations and policies related to paperwork that present barriers to
participation, particularly among lower income families and child care
providers;
Encourage USDA to issue guidance addressing these barriers to participation
prior to releasing the final Report to Congress;
Simplify CACFP administration while maintaining Program integrity; and
Increase CACFP participation.

The Work Group’s research of CACFP requirements resulting from compliance with the Child
Nutrition and WIC Reauthorization Act, as well as requirements for which no regulatory action
or policy guidance had been taken, generated recommendations that would have an immediate
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impact on reducing paperwork for sponsoring organizations and State agencies. The Work
Group recommended that USDA:
•
•
•
•
•
•
•

Reduce the frequency of eligibility determinations for for-profit child care
centers and outside school hours care centers serving low-income children;
Encourage State agencies to allow an annual blended-rate determination;
Maintain a clear division of oversight responsibility between CACFP and
child care licensing agencies, and also clarify CACFP’s role regarding
imminent harm to children;
Streamline the CACFP renewal process for sponsoring organizations and
independent centers;
Reduce CACFP paperwork requirements for Head Start and Child Care
Development Fund grantees;
Fully utilize technology to streamline CACFP reporting and recordkeeping
systems and maintain integrity for State agencies, sponsoring organizations,
child care homes, and centers; and
Reduce unnecessary additional State requirements.

USDA responded by examining practical solutions that were within FNS legal authority and
consistent with ongoing efforts to consolidate, simplify, and reduce CACFP requirements.
A final rule is under development, for publication in 2016, which would implement several
changes to the application and renewal process. USDA has also issued six memoranda to
address many of the Work Group’s recommendations, provide clarification of CACFP
requirements resulting from compliance with the Child Nutrition and WIC Reauthorization Act,
and address requirements for which no regulatory action or policy guidance had been taken.
A list of the memoranda issued in 2013 is found under Appendix C.
Members of the Work Group also inventoried and conducted an analysis of CACFP
requirements, and developed tools to engage their associates in a discussion of paperwork. In
February 2013, a consortium of CACFP and child care organizations and advocates, including
the National CACFP Sponsors Association, the National CACFP Forum, the Child Care Food
Program Roundtable, the Food Research and Action Center, the CACFP National Professional
Association, Minute Menu Systems, and the National Head Start Association, reached out to
members to request feedback. The opportunity to advise the Work Group on a wide-range of
administrative issues generated broad interest. Nearly 3,000 respondents, estimated to represent
over 95 percent of sponsoring organizations of child care homes and centers, answered an
extensive list of questions regarding a comprehensive set of CACFP procedures and
requirements.
In June 2013, the CACFP National Professional Association, which represents CACFP State
employees, contacted its members to obtain their feedback. Members coordinated with their
State agency colleagues to respond to questions regarding opportunities to improve Program
effectiveness. The association provided feedback to the Work Group on behalf of 47 of the
54 State agencies that have responsibility for administering the child care component of CACFP.

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Work Group members also consulted extensively with their counterparts at association meetings
and national conferences. It was vitally important for members to listen to their associates,
represent them, and share their perspectives, challenges, and promising practices with the entire
Work Group. These exchanges of ideas guided the members to help the Work Group reach
consensus.
Analysis of the responses from sponsoring organizations and State agencies suggests the
persistence of many of the unnecessary or duplicative administrative processes that were
identified in the Paperwork Reduction Work Group Final Report, authorized under the Child
Nutrition and WIC Reauthorization Act. The report, released in February 2007, advised USDA
to:
•
•
•
•
•
•

Reduce the burden associated with the annual submission of information from
sponsoring organizations, child care homes, centers, and parents;
Reduce the paperwork for sponsoring organizations and child care homes and
centers, especially non-traditional centers in CACFP;
Ensure additional requirements established by State agencies are consistent
with Federal regulations;
Promote uniformity among State agencies in terms of the documentation they
require during reviews;
Streamline the collection of children’s “enrollment for care” documentation;
and
Support the increased use of technology solutions to streamline Program
administration.

Many of the recommendations emphasized the use of technology or the sharing of effective
strategies among State agencies. USDA issued guidance to address the report’s top priorities.
A list of memoranda issued during 2007 and 2008 in response to these recommendations is
found under Appendix D.
Despite broad agreement by USDA and CACFP stakeholders with the 2007 report’s priorities,
the current feedback to the Work Group suggests that concrete action to address many of the
recommendations has not been effective or fully utilized. Although implementation of
provisions of the Healthy, Hunger-Free Kids Act offered further streamlining of application and
oversight requirements, it became increasingly clear to members of the Work Group that
additional actions would be needed.

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Making Improvements to CACFP
Major themes emerged from the responses that the Work Group received from sponsoring
organizations and State agencies:
•
•
•
•

Existing flexibilities at the State-level are not being fully realized;
There is a compelling need to eliminate unnecessary and ineffective reporting
requirements;
Opportunities exist to embrace and update technology solutions to improve
integrity and reduce paperwork; and
CACFP success is dependent upon partnerships.

Existing flexibilities at the State-level are not being fully realized
Flexibilities in USDA regulations and policies provide opportunities for State and local
administering agencies to manage resource challenges, particularly in the face of reductions in
their operating budgets. The Work Group recognizes that State agency flexibilities enable
sponsoring organizations to improve business processes and find efficiencies in managing scarce
resources.
However, in practice, State agencies, and sometimes sponsoring organizations, may add
requirements in an effort to protect their agencies from audit findings. State-specific
requirements may also increase the complexity of the Program in ways that discourage
participation.
In addition, State agencies may not be fully embracing flexibilities to reduce paperwork that
already exist. For example, the paperwork savings won by allowing child care homes to collect
documentation directly from parents or extending categorical eligibility to children in foster care
are lost when State agencies require new forms of certification to implement these policies.
The Work Group urges USDA to think through strategies that would ensure State agencies are
supporting streamlining efforts. For example, the Management Evaluation process, an
assessment by FNS of CACFP administration in every State, would be a useful opportunity to
analyze additional State policies and publicize best practices among State agencies.
There is a compelling need to eliminate unnecessary and ineffective reporting requirements
CACFP regulations include monitoring tools and reporting processes that were designed to
improve Program oversight and management controls. With more than a decade of experience
implementing the regulations, State agencies and sponsoring organizations expressed to the
Work Group their uncertainty about reporting processes, which may be reasonable tools in some
circumstances, but are frequently required in ways that may not be the best application of scarce
CACFP resources.
For example, a majority of State agencies acknowledged to the Work Group that requiring the
collection of a child’s normal days, hours, and meals in care has not improved CACFP integrity
6

in their States. Sponsoring organizations repeatedly advised the Work Group that oversight
requirements, such as timing of reviews and contacting of households to verify children’s
enrollment and attendance, are time-consuming and costly, and yet, ineffective at improving
CACFP integrity.
In addition, CACFP paperwork requirements do not often distinguish between the center that
participates directly under the State agency and the center that elects to participate through a
sponsoring organization. When centers choose to be sponsored, they are agreeing to daily
monitoring of menus, meal counts, and attendance, as well as three onsite reviews of all areas of
compliance each year. While it is reasonable for State agencies to receive more reporting from
centers when there is a 3-year gap between reviews, much of the paperwork that sponsored
centers are required to submit could be reviewed by the sponsoring organization onsite instead.
Because of their extensive oversight through monitoring visits, the Work Group agrees that
sponsoring organizations should have more flexibility to determine the best methods for
verifying the accuracy of meal counts, enrollment, meal production, nonprofit status, attendance,
and other paperwork requirements.
The Work Group urges USDA to support flexibilities and eliminate unnecessary or duplicative
reporting requirements that have not been effective at improving integrity. For example,
sponsoring organizations should have flexibility to determine the best methods for verifying
compliance with Program oversight requirements and corrective actions in their child care
homes. State agencies should be encouraged to accept a variety of methods to address
compliance with CACFP paperwork requirements and not require one specific method for the
ease of the reviewer.
Opportunities exist to embrace and update technology solutions to improve integrity and
reduce paperwork
Paperwork reduction and technology implementation should be quality indicators for State
agencies and sponsoring organizations. However, CACFP lags far behind other Federal
programs in modernization and utilization of available technologies. There are clear preferences
among many State agencies for “pen-to-paper” solutions, when the emphasis should be on the
required units of information that must be reported and not the report formats.
Requiring that only State-specific report formats and handwritten forms be used, when
information could be easily printed out from existing data systems, prevents sponsoring
organizations from taking advantage of new technology solutions and innovative business
processes. When established technologies, such as distance learning, are met with undue
skepticism, State agencies and sponsoring organizations are further discouraged from
implementing new solutions.
The Work Group’s consultation with CACFP stakeholders reveals examples of reporting and
recordkeeping that create inefficiencies, such as when reporting must be generated for the benefit
of the reviewer, even when the reviewer has electronic access to data already available in another
format. The reporting may include producing multiple copies of the same document, or
reformatting existing data to match a reviewer checklist, or some other unnecessary or
duplicative process that creates inefficiencies.
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The Work Group urges USDA to work with State agencies to promote modernization and
support policies that encourage replacement of obsolete methods with modern business tools,
such as handheld devices that allow onsite recording of data, secure cloud services and storage,
digitized historic records, electronic backup systems, and software applications. The Work
Group also encourages USDA and State agencies to support the investments in technology that
will pay off over long periods of time, reduce the incidence of errors in the daily records that
child care homes and centers must maintain, and help sponsoring organizations overcome
barriers to participation of child care homes and centers in underserved communities.
CACFP success is dependent upon partnerships
Paperwork reduction is an ongoing effort, and its continuing success depends upon a solid,
working partnership among USDA, State agencies, sponsoring organizations, child care homes,
and centers.
The Work Group urges USDA to continue to engage a representative advisory group to provide
insight into determining how Program requirements may continue to be streamlined and
improved. Members would be available to help USDA evaluate potential solutions for
effectively reducing paperwork.
USDA, State agencies, and sponsoring organizations have a shared commitment to making
CACFP work better. This commitment is rooted in collaboration and facilitating process
improvements, highlighting best practices, and working with Federal, State, and local partners to
find efficiencies without compromising Program integrity. The Work Group urges USDA to
continue efforts to streamline CACFP operations, support partnerships with State agencies and
sponsoring organizations, and operate with a strong accountability for Program outcomes.

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Recommendations to Congress
Perhaps the most important advantage CACFP gives our children is a diet full of the good
nutrition they need to grow up healthy and strong. Access to CACFP will help lead them on the
path to becoming part of a healthier generation. However, Federal programs like CACFP face
dual challenges of rising demand for services and declining administrative resources.
The Work Group is keenly aware that Congress is operating in tight fiscal times with little room
for new spending. Even in this budgetary climate, there are significant ways Congress can
remove barriers to participation and reduce paperwork to make CACFP work better. The Work
Group’s recommendations encompass modification, as well as encouragement to fully utilize
existing authorities. The Work Group urges Congress to:
1. Extend area eligibility to child care centers in CACFP
Allow child care centers to establish eligibility based on their location in areas served
by schools where at least 50 percent of enrolled children are eligible for free or
reduced-price meals, or on their location in areas where census data show that at least
50 percent of resident children are members of households whose income meet the
income eligibility guidelines for free or reduced-price meals. Centers that are not
area-eligible should be allowed to update eligibility at any time during the year when
there are changes reported in school or census data. Under current law, only child
care homes and at-risk afterschool care centers may use location in eligible areas to
determine CACFP eligibility.
2. Extend community eligibility and other certification approaches to CACFP
Extend USDA’s authority to support community eligibility and other certification
approaches, which are currently available in the National School Lunch Program, to
facilitate a child’s participation in CACFP. Community eligibility approaches use
information from the Supplemental Nutrition Assistance Program (SNAP) and other
means-tested programs, instead of traditional paper applications, to allow schools that
predominantly serve low-income children to offer free school meals to all students.
“Provision 2” schools establish claiming percentages and can then serve free school
meals to all students for a 4-year period without obtaining additional applications. In
CACFP, “Provision 2” child care centers would use the existing blended-rate formula
to establish claiming percentages in the first year. They would agree to operate as
“non-pricing” programs, where there are no charges for meals, and serve all children
enrolled in child care. A “Provision 2” option for CACFP would reduce application
burdens and simplify meal counting and claiming procedures.
3. Continue to engage a representative work group to guide CACFP paperwork
reduction efforts
Authorize a representative work group to continue to guide paperwork reduction
efforts in CACFP. This work group, with insight into determining how Program
requirements may continue to be streamlined and improved, would be a resource to
assist USDA in evaluating potential solutions for effectively reducing paperwork.
Members of this work group would include CACFP and child care professionals,
advocates, and industry stakeholders.
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Recommendations to USDA
The feedback from the Work Group’s consultation with CACFP stakeholders serves as the basis
for the recommendations that are at the heart of this report. The Work Group has compiled a set
of recommendations and proposed practical solutions to overcome administrative challenges and
barriers to participation.
The Work Group urges USDA to:
1. Work with State agencies to implement existing flexibilities to reduce
paperwork;
2. Make a child’s eligibility for CACFP benefits easier to document and improve
access through direct certification;
3. Align monitoring requirements to streamline reviews of child care homes and
centers;
4. Establish a single, blended-rate method of payment, which is determined
annually for centers;
5. Simplify the documentation of food service records required by the State
agency;
6. Establish annual eligibility determinations for for-profit centers;
7. Simplify verification of the nonprofit food service status of sponsored centers;
8. Eliminate budget requirements that are counterproductive to a fiscally
responsible Program operation;
9. Streamline the CACFP renewal process for sponsoring organizations and
centers;
10. Support the sponsoring organization’s ability to mediate and fix problems
through improvements in the serious deficiency process;
11. Expand the appeals process to resolve disputes over State-specific
requirements; and
12. Embrace technology solutions to improve integrity and reduce paperwork.
The Work Group supports consistency across Child Nutrition Programs, and favors flexibility to
allow sponsoring organizations to determine the best methods for achieving compliance with
CACFP requirements. The Work Group encourages USDA to implement actions that have
effectively reduced or simplified requirements in the National School Lunch, School Breakfast,
or Summer Food Service Programs. Where action by USDA has already been taken, or is not
required, the Work Group urges USDA to encourage State agencies to fully utilize the authorities
they already have to streamline CACFP, increase acceptance and adoption of technology
solutions, and examine administrative requirements with an eye toward decreasing paperwork
burden while maintaining integrity.
Practical solutions to reduce paperwork
The purpose behind each of the Work Group’s twelve recommendations is to turn “best
practices” into standard practices that will be easy to implement, have support of CACFP
stakeholders, and be enforced consistently at all levels of administration. The recommendations
were drawn from the Work Group’s consultation with stakeholders. Work Group members
10

listened to the views of their associates, representing 95 percent of sponsoring organizations and
87 percent of State agencies that are responsible for CACFP oversight in child care homes and
centers.
To address each recommendation, this report proposes actions that are designed to improve and
streamline the Program. A comprehensive discussion of the recommendations is presented under
Appendix E, which examines existing CACFP requirements, highlights the views of stakeholders
that inspire the recommendation, and suggests policies and procedures for USDA and State
agencies to consider changing.
This report identifies actions for USDA to standardize policy and, where necessary, make
modifications. However, the majority of implementing actions emphasize policies and
procedures that State agencies have existing authority to change. Nearly all of the Work Group’s
recommendations urge State agencies to support streamlining efforts and implement flexibilities
that already exist.
1. Work with State agencies to implement existing flexibilities to reduce paperwork
Since the release of the Paperwork Reduction Work Group Final Report in 2007,
USDA’s policy and Program development efforts have centered on consolidating,
simplifying, and reducing CACFP requirements, where practicable. USDA has
issued policy guidance to encourage State agencies to improve participation and
reduce paperwork.
The Work Group urges USDA to:
•
•
•
•

Provide technical assistance to help each State agency understand how
to effectively implement existing flexibilities to reduce paperwork;
Work with State agencies and their leadership to implement changes;
Use the Management Evaluation process as an opportunity to analyze
additional State policies and promote best practices among State
agencies; and
Plan regional conference calls with State agencies to compare
implementation and best practices among States.

2. Make a child’s eligibility for CACFP benefits easier to document and improve
access through direct certification
All child care homes and most centers serve meals at no charge to children in
CACFP. In general, each child’s household must provide documentation to
establish the child’s eligibility for CACFP benefits and determine the level of
reimbursement that the child care home or center will receive. While CACFP
requires parents to complete traditional paper applications, the National School
Lunch Program allows schools to use direct certification, community eligibility,
and other approaches to provide free meals to children without another
application.
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The Work Group urges USDA to:
•
•

Explore USDA's authority to support opportunities for direct
certification, community eligibility, and other forms of certifications to
approve a child’s participation in CACFP; and
Explore opportunities for USDA to promote current best practices in
the use of direct certification in CACFP.

Sponsoring organizations must establish procedures to collect and maintain daily
CACFP records as well as records required by the State agency. USDA requires
documentation of enrollment that includes information on each child's normal
days and hours of care and the types of meals, such as breakfast and lunch, the
child is expected to receive while in care. This documentation must be updated
annually and signed by a parent. Daily attendance must be recorded separately
from meal counts, although they may be maintained on the same form. USDA
also requires the provision of information which promotes nondiscrimination,
explains CACFP to parents, and encourages access to the Special Supplemental
Nutrition Program for Women, Infants, and Children (WIC).
The Work Group urges USDA to:
•
•
•

Eliminate the collection of normal days, hours, and meals in care;
Retrain sponsoring organizations and State agencies so that meals are
not disallowed if parents make clerical errors in filling out enrollment
forms; and
Accept meal counts that are identified by the child’s name as the
attendance record.

The Work Group urges State agencies to:
•
•
•
•

Accept any documentation the child care home or center uses that
contains the required information;
Allow sponsoring organizations to pre-populate data fields in forms
with information from their electronic databases;
Allow the parent to make changes if needed and initial the document,
instead of filling out new documentation during the annual renewal
process; and
Work with sponsoring organizations to determine the best methods for
making CACFP and WIC information available to parents of children
in child care homes and centers.

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3. Align monitoring requirements to streamline reviews of child care homes and
centers
Monitoring is an important process for ensuring integrity and compliance with
CACFP requirements. Streamlining the review process would help State agencies
and sponsoring organizations manage their staff and administrative resources and
focus Program funds on monitoring activities that would be more effective at
improving CACFP integrity.
The Work Group urges USDA to:
•
•

•
•

•

•

Remove the requirement that no more than 6 months elapse between
reviews and allow sponsoring organizations to determine how to plan
and schedule unannounced reviews;
Remove the requirement that child care homes notify sponsoring
organizations on days when the provider will not be serving meals and
allow sponsoring organizations to determine how to manage child care
homes when the provider plans to be out of the home during the meal
service period;
Eliminate the requirement that sponsoring organizations conduct
household contacts;
Replace the 5-day reconciliation of meal counts and attendance with a
method that compares the number of children served a particular meal
type on the day of the review with the number of children served the
same meal type over the previous 5-day period;
Define required data points to be collected, provide a sample form, and
allow sponsoring organizations to develop their own method of
documenting a review, whether by paper or electronically via
computers, mobile devices, or other technology; and
Ensure that problems of noncompliance are addressed consistently
across all States.

The Work Group urges State agencies to:
•
•

•

Allow sponsoring organizations to conduct the review of a multipurpose child care center on the same day, at the same time, and on the
same form;
Work with sponsoring organizations to determine the best methods
for:
o Verifying the accuracy of meal counts, enrollment,
meal production, nonprofit status, and attendance; and
o Verifying that child care homes and centers have
corrected errors; and
Eliminate requirements that sponsoring organizations and their child
care homes and centers keep duplicate sets of records.

13

4. Establish a single, blended-rate method of payment, which is determined
annually for centers
USDA requires State agencies to assign rates of reimbursement, not less
frequently than annually, based on family size and income information reported
by each child care center. Assigned rates of reimbursement may be changed more
frequently than annually if changes in family size and income are warranted.
The Work Group urges State agencies to:
•
•
•

Implement a single blended-rate method of payment for centers based
on an individual center’s enrollment;
Base payments to centers on each center’s blended-rate instead of
averaging the rates of all centers under the same sponsoring
organization; and
Allow centers the option of amending the rate more frequently than
annually.

5. Simplify the documentation of food service records required by the State agency
Sponsoring organizations and centers that participate directly under the State
agency must establish procedures to collect and maintain records, including
copies of menus and any other food service records required by the State agency.
The Work Group urges State agencies to:
•

•

•

•

Work with sponsoring organizations to determine the best methods for
verifying food production costs, including onsite reviews of food
service records, electronic trackers of food costs and production, or
portion menus, instead of meal production records;
Eliminate State mandates that require:
o Meal production records for sponsored centers;
o Meal disallowances when meal production records
reveal errors; and
o Head Start centers to document infant formula choices.
Allow:
o Recording of infants’ meal counts throughout the day;
o Posted prototype menus to serve as infant meal records;
o Child care homes and centers to record all creditable
meals served; and
o Sponsoring organizations to determine which
combination of meals served will provide the maximum
reimbursement to the child care home or center; and
Support the continued use of simplified menu records in child care
homes.

14

6. Establish annual eligibility determinations for for-profit centers
For-profit child care centers and outside school hours care centers submit claims
for reimbursement only for calendar months during which at least 25 percent of
the children in care are eligible for free and reduced-price meals or receive
benefits under title XX of the Social Security Act.
The Work Group urges:
•
•

USDA to establish annual eligibility determinations for for-profit
centers serving high numbers of low-income children; and
State agencies to eliminate requirements to submit monthly backup
documentation of attendance, income eligibility forms, or title XX
participation.

7. Simplify verification of the nonprofit food service status of sponsored centers
Centers and sponsoring organizations of affiliated centers must keep
documentation of nonprofit food service to demonstrate that all CACFP
reimbursement funds are used solely for the operation or improvement of a food
service that is conducted principally for the benefit of children. The State agency
must have a system in place for monitoring and reviewing this documentation.
The Work Group urges State agencies to:
•
•
•

Eliminate requirements for monthly verification of nonprofit food
service status;
Work with sponsoring organizations to determine the best methods for
monitoring nonprofit status, including the frequency of review and the
types of documents that would be reviewed; and
Allow sponsored centers to maintain nonprofit food service records
onsite for review, instead of requiring them to submit backup
documentation to the sponsoring organization.

8. Eliminate budget requirements that are counterproductive to a fiscally responsible
Program operation
Sponsoring organizations and centers that apply directly to the State agency
undergo a rigorous application process to determine their eligibility to participate
in CACFP. State agencies must establish procedures that require sponsoring
organizations and centers to demonstrate and document that they are financially
viable, are administratively capable, and have effective internal controls to ensure
accountability with Program requirements. This documentation includes budgets,
accounting records, approved budget amendments, and, for sponsoring
organizations, management plans and appropriate records on child care homes
and centers.
15

The Work Group urges USDA to:
•
•
•

Simplify cost allocation of administrative funding among child care
homes and centers that operate CACFP;
Reduce the number of items that need prior written approval and allow
carryover of line items that can be adjusted without prior written
approval in the end-of-year budget; and
Standardize a checklist of budget renewal requirements across all
States.

The Work Group urges State agencies to:
•
•
•
•

Collect annual budgets only from sponsoring organizations, not from
the individual centers they sponsor;
Allow sponsoring organizations to revise their budgets to capture
allowable end-of-year budget changes 30 days after the end of the
year;
Adopt Federal small purchase procedures that allow informal
procurement methods for services and supplies under $150,000; and
Allow sponsoring organizations of centers to:
o Retain reimbursement of administrative expenses on an
annual, not monthly, basis; and
o Carryover unspent administrative funds after the end of
the fiscal year.

9. Streamline the CACFP renewal process for sponsoring organizations and
centers
The Healthy, Hunger-Free Kids Act requires permanent agreements and
eliminates annual renewal applications from sponsoring organizations and child
care centers to the State agency.
The Work Group urges USDA to:
•
•
•

Evaluate the documentation, which State agencies collect as part of the
renewal process, to ensure that it aligns with USDA guidance;
Require resubmission of information, such as job descriptions and
policies, only when changes are made; and
Allow licenses to be submitted either as they are renewed or, in States
where licenses are permanent, when changes are made.

16

10. Support the sponsoring organization’s ability to mediate and fix problems
through improvements in the serious deficiency process
USDA has established a process that applies uniform standards to correct serious
problems and, when that effort fails, protect CACFP from abuse. The serious
deficiency process is a tool for sponsoring organizations to correct problems and
provide due process for child care homes. If child care homes are unwilling or
incapable of correcting serious problems, the serious deficiency process protects
Program integrity by terminating and disqualifying providers who are not in
compliance with the regulations. Sponsoring organizations, centers participating
under the State agency, and child care homes have the right to appeal actions by
the State agency, which can deny participation, disallow claims for
reimbursement, or propose termination for cause.
The Work Group urges USDA to:
•
•
•
•

Define standards to measure severity of problems and distinguish
between human error and systemic or serious noncompliance;
Extend the deadline for day care homes to complete corrective action
from 30 to 90 days;
Shorten the 7-year timeframe for disqualification from CACFP; and
Establish a standard practice with specific steps for requesting
reinstatement.

11. Expand the appeals process to resolve disputes over State-specific requirements
USDA has established a process that applies uniform standards to appeal adverse
actions that have direct financial impact on CACFP, such as denial of a claim for
reimbursement or demand for overpayment. However, this process does not
address actions resulting from State-specific requirements.
The Work Group urges USDA to:
•
•
•
•

Expand the list of appealable actions to include corrective action steps,
interpretation of CACFP regulation and policy, and additional State
agency requirements that conflict with USDA regulation or guidance;
Suggest best practices for State agencies to resolve differences in
interpretation and implementation of requirements;
Create a process for elevating and mediating disputes through USDA;
and
Explore alternative dispute resolution approaches.

17

12. Embrace technology solutions to improve integrity and reduce paperwork
USDA encourages State agencies and sponsoring organizations to establish
internet or electronic-based systems for reporting and recordkeeping.
The Work Group urges State agencies to:
•
•
•
•
•

Accept and provide training to staff and sponsoring organizations in
using electronic and digitized signatures;
Allow all data from required forms to be collected electronically and
made available to reviewers in a usable format;
Accept electronic records and storage in place of paper copying and
filing systems;
Allow electronic monitoring to confirm corrective action and perform
followup reviews; and
Encourage technology solutions that would:
o Reduce the incidence of errors in the daily records that
child care homes and centers must maintain; and
o Overcome administrative challenges and barriers to
participation of child care homes and centers in rural
communities.

18

In Closing
All of the recommendations for improvement are intended to streamline paperwork, without
compromising the integrity of CACFP. Action by Congress, USDA and State agencies to
implement these recommendations would make CACFP a stronger, better-managed, and easierto-administer nutrition and wellness program for America’s children.
Members of this Work Group see the value of CACFP in child care homes and centers each day.
The examination of CACFP paperwork requirements has strengthened the commitment of this
Work Group to a long-term, sustained effort, working closely with USDA and Program partners.
However, the Work Group is also very much aware that CACFP’s nutrition benefits are out of
reach for millions of young children in child care. Across the Nation, over half of the child care
homes operate without CACFP support for healthy meals. Although Program participation
among child care centers has increased, the number of non-participating centers, located in areas
where the median household income is below the Federal poverty level, remains high.
There is strong consensus among Work Group members that efforts to improve and simplify
CACFP must also address participation, particularly among lower income families and
providers. An essential goal of each recommendation, moving forward, is to remove barriers to
participation so that children in various forms of early childhood education and care have access
to the benefits of this important nutrition program. While this report focuses on paperwork
requirements in traditional child care settings, many of these recommendations will have broader
impact to help improve participation and make CACFP less burdensome and more cost-effective
to administer in at-risk afterschool care centers, emergency shelters, and adult day care centers.
This report outlines recommendations that would promote local flexibility to tailor policies to
particular needs, support innovative ways to expand participation, provide incentives for State
agencies to improve Program performance, and encourage consistency with other Child Nutrition
Programs. The report identifies specific actions for USDA to standardize policy, work in
partnership with State agencies to support the States’ implementation of streamlining efforts, and
where necessary, make modifications that would improve CACFP participation and performance.
USDA has expressed to the Work Group the importance of doing more to enable the States to
succeed – for their success in embracing flexibilities and finding efficiencies will make CACFP
paperwork reduction efforts a success. USDA is also mindful that CACFP’s mission cannot be
accomplished without a strong and sustained effort to ensure that integrity is always a priority in
Program administration.
USDA is analyzing the recommendations with the immediate goal to complete actions, which are
already in progress, to consolidate and simplify Program requirements through policy guidance.
FNS is considering strategies, such as utilizing Federal oversight processes and publicizing best
practices among States, which would ensure State agencies are supporting CACFP streamlining
efforts already in place. FNS is also determining how each of these solutions will help inform
future policy decisions and effect changes that will improve CACFP without compromising the
measures taken over the past several years to protect Program integrity.
19

APPENDIX A

Healthy, Hunger-Free Kids Act of 2010
Public Law 111–296
SECTION 336:
REDUCING PAPERWORK AND IMPROVING PROGRAM ADMINISTRATION.
(a) DEFINITION OF PROGRAM.—In this section, the term ‘‘program’’ means the child and
adult care food program established under section 17 of the Richard B. Russell National School
Lunch Act (42 U.S.C. 1766).
(b) ESTABLISHMENT.—The Secretary, in conjunction with States and participating institutions,
shall continue to examine the feasibility of reducing unnecessary or duplicative paperwork resulting
from regulations and recordkeeping requirements for State agencies, institutions, family and group
day care homes, and sponsored centers participating in the program.
(c) DUTIES.—At a minimum, the examination shall include—
(1) review and evaluation of the recommendations, guidance, and regulatory priorities
developed and issued to comply with section 119(i) of the Child Nutrition and WIC
Reauthorization Act of 2004 (42 U.S.C. 1766 note; Public Law 108–265); and
(2) examination of additional paperwork and administrative requirements that have been
established since February 23, 2007, that could be reduced or simplified.
(d) ADDITIONAL DUTIES.—The Secretary, in conjunction with States and institutions
participating in the program, may also examine any aspect of administration of the program.
(e) REPORT.—Not later than 4 years after the date of enactment of this Act, the Secretary shall
submit to Congress a report that describes the actions that have been taken to carry out this section,
including—
(1) actions taken to address administrative and paperwork burdens identified as a result of
compliance with section 119(i) of the Child Nutrition and WIC Reauthorization Act of 2004
(42 U.S.C. 1766 note; Public Law 108–265);
(2) administrative and paperwork burdens identified as a result of compliance with section
119(i) of that Act for which no regulatory action or policy guidance has been taken;
(3) additional steps that the Secretary is taking or plans to take to address any administrative
and paperwork burdens identified under subsection (c)(2) and paragraph (2), including—
(A) new or updated regulations, policy, guidance, or technical assistance; and
(B) a timeframe for the completion of those steps; and
(4) recommendations to Congress for modifications to existing statutory authorities needed to
address identified administrative and paperwork burdens.

20

APPENDIX B

CACFP Paperwork Reduction Work Group Members
NATALIE CLARK
Chief Operating Officer
Minute Menu Systems, LLC
1702 North Collins Boulevard, Suite 260
Richardson, Texas 75080
[email protected]

PAULA JAMES
Director
Child Health and Nutrition Program
Contra Costa Child Care Council
1035 Detroit Avenue, Suite 200
Concord, California 94518
[email protected]

STEPHANIE CLARKE
Child Health and Nutrition Manager
4C's of Alameda County
22351 City Center Drive
Hayward, California 94541
[email protected]

JODI KUHN
Director
Subsidy Food Program
Knowledge Universe Education
650 NE Holladay Street, Suite 1400
Portland, Oregon 97232
[email protected]

ELLEN FARRELL
Training and Special Projects Manager
Bureau of Child Care Food Programs
Florida Department of Health
4052 Bald Cypress Way Bin #A-17
Tallahassee, Florida 32399-1727
[email protected]

LINDA LEINDECKER
Executive Director
Horizons Unlimited
Post Office Box 10384
Green Bay, Wisconsin 54307
[email protected]

CHERYL FLAATTEN
Family Child Care Director
Community Action of Southeast Iowa
2850 Mt Pleasant, Suite 108
Burlington, Iowa 52601
[email protected]

VICKI LIPSCOMB
President and Executive Director
Child Nutrition Program, Inc.
741 Kenilworth Avenue, Suite 102
Charlotte, North Carolina 28204
[email protected]

LOIS HAZELTON
Director, Centers Administration Unit
New York State Department of Health CACFP
150 Broadway, 6th Floor West
Albany, New York 12204
[email protected]

BENEDICT ONYE
Education Consultant
Bureau of Health, Nutrition, Family Services
and Adult Education
Connecticut Department of Education
25 Industrial Park Road
Middletown, Connecticut 06457
[email protected]

GERI HENCHY
Director of Nutrition Policy and Early Childhood
Nutrition
Food Research and Action Center
1200 18th Street NW, Suite 400
Washington, DC 20036
[email protected]

BRETT PARMENTER
CDI Head Start CACFP Coordinator
Community Development Institute
10065 East Harvard Avenue, Suite 700
Denver, Colorado 80231
[email protected]

DIANE HOGAN
Nutrition Programs Professional
Office of Child Nutrition and School Health
Nevada Department of Education
9890 South Maryland Parkway
Las Vegas, Nevada 89183-7168
[email protected]

LYNNE REINOSO
Manager
Community Nutrition Programs
Oregon Department of Education
255 Capitol Street NE
Salem, Oregon 97310
[email protected]

21

APPENDIX C

USDA POLICY GUIDANCE
Memoranda Issued in 2013 – 2014 to Address Recommendations
Proposed by the Paperwork Reduction Work Group
Date

Title

Purpose

March 29, 2013

CACFP 09-2013
Additional State
Requirements in the
CACFP

Addresses paperwork requirements that State
agencies impose above and beyond the Federal
requirements, which represent a large majority of
paperwork burden complaints reported by
sponsoring organizations.

May 17, 2013

CACFP 11-2013
Questions and Answers
Regarding the
Participation of Head
Start Programs in Child
Nutrition Programs

Consolidates guidance on documentation of
categorical eligibility, enrollment, and infant
formula that affects Head Start programs.

July 26, 2013

CACFP 13-2013
Health and Safety in
CACFP

Provides guidance to help sponsoring
organizations detect and report the types of
problems that rise to the level of an imminent
threat to the health or safety of participating
children or to the public.

July 26, 2013

CACFP 14-2013
Monitoring of
Licensing
Requirements

Clarifies that, while use of CACFP monitors to
review licensing requirements is permitted and
may be beneficial, it may not be required by State
agencies and is not an allowable use of CACFP
funds.

July 26, 2013

CACFP 15-2013
Existing Flexibilities

Highlights existing flexibilities at the State level to
simplify and improve operational provisions
related to enrollment documentation, payments,
training, single agreements, applications, infant
meals, meal production records, media releases,
procurement methods, sign-in sign-out records,
and additional State requirements.

November 12,
2013

CACFP 03-2014
Available Flexibilities
for CACFP At-risk
Sponsors and Centers
Transitioning to
Summer Food Service
Program

Highlights existing flexibilities at the State level to
streamline operational provisions related to
applications, agreements, site eligibility, health and
safety inspection, training, monitoring, and
financial management requirements, and
encourage participation of CACFP centers in
summer meal programs.
22

APPENDIX D

USDA POLICY GUIDANCE
Memoranda Issued in 2007 – 2008 to Address
Recommendations from the 2007 Paperwork Reduction
Work Group Final Report
Date

Title

Purpose

February 23,
2007

CACFP 02-2007
Paperwork Reduction
in the CACFP

Addresses specific recommendations for policy
and regulatory changes that may reduce paperwork
and USDA’s response to the recommendations.

May 1, 2007

CACFP 07-2007
Update on Electronic
Transactions in the
Child Nutrition
Programs

Updates guidance on electronic transfer of
information.

May 9, 2007

CACFP 05-2007
Additional State
Agency Requirements

Provides guidance to ensure that approved Statespecific requirements are consistent with CACFP
regulations and do not deny Program access.

June 15, 2007

CACFP 09-2007
Electronic Record and
Reporting Systems

Encourages State agencies and sponsoring
organizations to establish electronic-based systems
with alternatives to ensure Program access.

July 3, 2007

CACFP 11-2007
Accommodations for
Non-Traditional
Program Operators

Encourages State agencies to take the least
restrictive approach in applying CACFP
regulations to the day-to-day operations of
emergency shelters and other non-traditional child
care centers.

November 15,
2007

CACFP 01-2008
Facility Applications
and Agreements in the
CACFP

Describes the flexibilities available to State
agencies in implementing facility application and
agreement requirements.

February 15,
2008

CACFP 05-2008
Sharing Income
Eligibility Information
Between Child
Nutrition Programs

Highlights existing guidance on the disclosure of
children’s eligibility information to persons
directly connected to the administration of a Child
Nutrition Program.

23

APPENDIX E

RECOMMENDATIONS AND ACTIONS
Proposed by the Paperwork Reduction Work Group
1. Work with State agencies to implement existing flexibilities to reduce paperwork
Since release of the Paperwork Reduction Report of 2007, USDA’s policy and Program
development efforts have centered on consolidating, simplifying, and reducing CACFP
requirements, where practicable. USDA has issued policy guidance to encourage State agencies
to streamline participation and reduce paperwork. This set of guidance addresses a broad range
of CACFP topics, including:
• Additional State requirements;
• Participation of Head Start programs;
• Health and safety in child care homes and centers;
• Monitoring of licensing requirements;
• Examples of streamlined operational practices for sponsoring organizations,
traditional child care homes and centers, and non-traditional centers;
• Electronic transactions and recordkeeping; and
• Information-sharing.
Listening to Stakeholders
Concerns that flexibilities at the State level are not being fully realized generated comments from
CACFP participants and State agencies, including the following:
• “[It is] clear to us that USDA issuing memos is not providing enough to give State
agencies permission to make the changes.”
• “Flexibilities are not mandates.”
• “State agencies fear that USDA will cite them for not following the regulations.”
• “State agencies lack the resources to get training done.”
• “CACFP needs consistency across States and regions.”
Implementing the Recommendation
The Work Group urges USDA to:
• Provide technical assistance to help each State agency understand how to effectively
implement existing flexibilities to reduce paperwork;
• Work with State agencies and their leadership to implement changes;
• Use the Management Evaluation process as an opportunity to analyze additional State
policies and promote best practices among State agencies; and
• Plan regional conference calls with State agencies to compare implementation and
best practices among States.

24

APPENDIX E

2. Make a child’s eligibility for CACFP benefits easier to document and improve access
through direct certification
All child care homes and most centers serve meals at no charge to children in CACFP. In
general, each child’s household must provide documentation to establish the child’s eligibility
for CACFP benefits and determine the level of reimbursement that the child care home or center
will receive. While CACFP requires parents to complete traditional paper applications, the
National School Lunch Program allows schools to use direct certification, community eligibility,
and other approaches to provide free meals to children without another application.
USDA requires documentation of enrollment that includes information on each child's normal
days and hours of care and the types of meals, such as breakfast and lunch, the child is expected
to receive while in care. This documentation must be updated annually and signed by a parent.
The requirement to collect this data is waived if the State CACFP or licensing agency requires
the use of a sign-in and sign-out attendance sheet for each child, which is signed by the parent.
Child care homes and centers are required to keep accurate records supporting daily attendance
that shows when a child is actually present in the day care. Daily attendance must be recorded
separately from meal counts, although they may be maintained on the same form. Sponsoring
organizations must establish procedures to collect and maintain daily CACFP records as well as
records required by the State agency.
USDA also requires the provision of information which promotes nondiscrimination, explains
CACFP to parents, and encourages access to the Special Supplemental Nutrition Program for
Women, Infants, and Children (WIC). Child care homes, centers, and parents of enrolled
children must receive this information from either the sponsoring organization or the State
agency.
Listening to CACFP Stakeholders
Participants and State agencies provided strong feedback about enrollment forms, income
eligibility forms, attendance, and CACFP and WIC information, including the following:
• Though USDA does not require a specific format, 68 percent of sponsoring
organizations must use a State prescribed enrollment form, which creates a
duplication of effort for centers that capture the required information for each child
on other types of forms, such as the Head Start enrollment document.
• 62 percent of sponsoring organizations are not allowed to prepopulate information on
enrollment or income eligibility forms.
• 61 percent of State agencies agree that requiring the collection of a child’s normal
days, hours, and meals in care has not improved CACFP integrity in their States.
• 55 percent of sponsoring organizations must collect a child’s normal days, hours, and
meals on the enrollment form even though their State licensing agencies require daily
attendance sheets signed by parents.
• 49 percent of State agencies require parents to sign consent forms if the child care
home provider returns the income eligibility forms on their behalf.

25

APPENDIX E

•

•

“Direct certification for children receiving benefits through the Supplemental
Nutrition Assistance Program, Temporary Assistance to Needy Families, Head Start,
and Child Care Development Funds would reduce red tape for parents, reduce
potential errors for child care homes and centers, and ease access for eligible
children.”
“Sponsoring organizations are constrained in how they may make information about
CACFP and WIC available to parents.”

Implementing this Recommendation
The Work Group urges USDA to:
• Eliminate the collection of normal days, hours, and meals in care;
• Retrain sponsoring organizations and State agencies so that meals are not disallowed
if parents make clerical errors in filling out enrollment forms;
• Accept meal counts that are identified by the child’s name as the attendance record;
• Explore USDA's authority to support opportunities for direct certification, community
eligibility, and other forms of certification to approve a child’s participation in
CACFP; and
• Explore opportunities for USDA to promote current best practices in the use of direct
certification in CACFP.
The Work Group urges State agencies to:
• Accept any documentation the child care home or center uses, whether paper or
electronic, that contains the required information, such as Head Start enrollment
documentation, a single form that combines enrollment and income eligibility
information, or a combination of forms already used in the child care setting;
• Allow sponsoring organizations to prepopulate data fields in forms with information
from their electronic databases;
• Allow the parent to make changes if needed and initial the document, instead of
filling out new documentation during the annual renewal process; and
• Work with sponsoring organizations to determine the best methods for making
CACFP and WIC information available to parents of children in child care homes and
centers.
3. Align monitoring requirements to streamline reviews of child care homes and centers
Monitoring is an important process for ensuring integrity and compliance with CACFP
requirements. Streamlining the review process would help State agencies and sponsoring
organizations manage their staff and administrative resources and focus Program funds on
monitoring activities that would be more effective at improving CACFP integrity.
Before applications are approved, sponsoring organizations are required to visit new child care
homes and centers to discuss Program benefits and affirm their ability to meet Program

26

APPENDIX E

requirements. After the agreements are signed, sponsoring organizations must conduct reviews
of all child care homes and centers three times a year:
• At least two reviews must be unannounced;
• One unannounced review must include observation of a meal service;
• No more than 6 months may elapse between reviews; and
• The timing of reviews must be unpredictable to child care homes and centers.
Frequently, CACFP reporting and recordkeeping requirements do not distinguish between the
center that participates directly under the State agency and the center that elects to participate
through a sponsoring organization. When centers choose to be sponsored, they are agreeing to
daily monitoring of menus, meal counts, and attendance, as well as three onsite reviews of all
areas of compliance each year. While the State agency is required to conduct onsite reviews at
least once every 3 years, a sponsoring organization will have conducted a minimum of nine
reviews of each of its sponsored centers during the same period.
USDA has established minimum review elements for State agencies and sponsoring
organizations to conduct reviews, including reconciliation of meal counts, enrollment,
attendance, and meal claims for all meals and all children for a 5-day period. The goal of the
reconciliation of records is to determine whether the meal counts are accurate by comparing
them to the daily attendance for all meal types for the selected meal service period.
As part of the review process, USDA requires State agencies and sponsoring organizations to
contact households to verify enrollment and attendance of children in child care homes and
centers when there is cause. State agencies are required to establish criteria and procedures for
the State agency and sponsoring organization to use in making household contacts. State
agencies must also monitor that the sponsoring organization is correctly implementing these
requirements.
USDA also requires child care homes to notify sponsoring organizations on days when the
provider will not be serving meals. The sponsoring organization’s agreement with the child care
home must state that, if this procedure is not followed and an unannounced review is conducted
when the children are not present in the child care home, claims for meals that would have been
served during the unannounced review will be disallowed.
Listening to CACFP Stakeholders
Questions about monitoring requirements also elicited significant feedback from CACFP
participants, including the following:
• 80 percent of sponsoring organizations must use State agency review forms.
• 72 percent of sponsoring organizations may not conduct followup reviews
electronically.
• 61 percent of sponsoring organizations must print records for State agency review
although electronic records are available.
• 75 percent of sponsoring organizations of multipurpose child care centers must keep
separate records for each component of CACFP.

27

APPENDIX E

•
•
•
•
•
•

54 percent of sponsoring organizations of multi-purpose child care centers may not
document reviews on a single form and often must make multiple visits on different
days to complete separate reviews.
50 percent of sponsoring organizations are required to conduct a household contact
whenever there is an inconsistency in a claim, although parents are often reluctant to
answer.
“Oversight requirements, such as timing of reviews, notification by child care home
providers, and household contacts, are not improving CACFP integrity and divert
Program funds from more effective monitoring activities.”
“There should be less paperwork for the center that receives frequent monitoring from
a sponsoring organization, than for the center that participates directly through the
State agency.”
“Requiring child care homes to provide notification when they are not serving meals
creates more paperwork and administrative expense than savings for sponsoring
organizations.”
“Conducting household contacts is not a cost-effective method for verifying meal
counts.”

Implementing this Recommendation
The Work Group urges USDA to:
• Remove the requirement that no more than 6 months elapse between reviews and
allow sponsoring organizations to determine how to plan and schedule unannounced
reviews;
• Remove the requirement that child care homes notify sponsoring organizations on
days when the provider will not be serving meals and allow sponsoring organizations
to determine how to manage child care homes when the provider plans to be out of
the home during the meal service period;
• Eliminate the requirement that sponsoring organizations conduct household contacts;
• Replace the 5-day reconciliation of meal counts and attendance with a method that
compares the number of children served a particular meal type on the day of the
review with the number of children served the same meal type over the previous
5-day period;
• Define required data points to be collected, provide a sample form, and allow
sponsoring organizations to develop their own method of documenting a review,
whether by paper or electronically via computers, mobile devices, or other
technology; and
• Ensure that problems of noncompliance are addressed consistently across all States.
The Work Group urges State agencies to:
• Allow sponsoring organizations to conduct the review of a multiple-purpose child
care center on the same day, at the same time, and on the same form;
• Work with sponsoring organizations to determine the best methods for:
o Verifying the accuracy of meal counts, enrollment, meal production,
nonprofit status, and attendance; and
o Verifying that child care homes and centers have corrected errors; and
28

APPENDIX E

•

Eliminate requirements that sponsoring organizations and their child care homes and
centers keep duplicate sets of records.

4. Establish a single, blended-rate method of payment, which is determined annually for
centers
USDA requires State agencies to assign rates of reimbursement, not less frequently than
annually, based on family size and income information reported by each child care center.
Assigned rates of reimbursement may be changed more frequently than annually if changes in
family size and income are warranted.
State agencies are required to assign rates for centers through one of three methods:
1. Actuals – 44 percent of State agencies require sponsoring organizations and
independent centers to submit each month's claim for reimbursement based on the
actual number of meals served free, at a reduced-price, or at the paid rate;
2. Percentages – 36 percent of State agencies establish claiming percentages based on
the number of enrolled children eligible for free, reduced-price, and paid meals; and
3. Blended – 20 percent of State agencies determine a blended per-meal rate based on a
formula that multiplies national average payment rates by claiming percentages for
free, reduced-price, and paid meals.
Listening to CACFP Stakeholders
Determining the methods of payments for centers encouraged feedback from participants and
State agencies, including the following:
• 63 percent of State agencies that assign percentages or blended-rates establish the
rates monthly.
• “Methods of payments based on actuals and percentages generate confusion and
unnecessary paperwork.”
• “Requiring child care centers to re-evaluate the payment rate each month generates
unnecessary paperwork.”
• “Child care centers are not properly paid when their rates are blended with the rates
of other sponsored centers.”
• “Child care centers should receive payments based on each center’s blend of free,
reduced-price, and paid meals.”
Implementing this Recommendation
The Work Group urges State agencies to:
• Implement a single blended-rate method of payment for centers based on an
individual center’s enrollment;
• Base payments to centers on each center’s blended-rate, instead of averaging the rates
of all centers under the same sponsoring organization; and
• Allow centers the option of amending the rate more frequently than annually.

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APPENDIX E

5. Simplify the documentation of food service records required by the State agency
Sponsoring organizations and centers that participate directly under the State agency must
establish procedures to collect and maintain records, including copies of menus and any other
food service records required by the State agency.
Listening to CACFP Stakeholders
Questions about menus, meal production records, and meal services for infants also elicited
significant feedback from participants and State agencies, including the following:
• 53 percent of State agencies require centers to complete meal production records,
although sponsoring organizations and State agencies report that they are complicated
and unreliable.
• 50 percent of sponsoring organizations of centers must keep end-of-month inventories
to document actual food costs.
• 64 percent of State agencies require centers to record daily the types and amounts of
foods served to infants.
• 61 percent of sponsoring organizations of centers must use the State agency’s infant
meal production record.
• 54 percent of State agencies require child care homes to record daily the types and
amounts of foods served to infants.
• “On demand feeding makes maintaining point of service records of each meal
component served to each infant difficult.”
• “Documentation of an infant’s acceptance of formula and other preferences do not
apply to Head Start centers which must always purchase the same types of formula
and foods parents serve their infants.”
• “Reviewing a center’s documentation of daily menus, recipes, and costs during an
unannounced review is a better indicator of meal pattern compliance than production
records.”
• “Child care homes and sponsored centers may not be receiving the maximum
allowable reimbursement when they are required to ‘self-select’ which meals are
eligible for reimbursement.”
Implementing this Recommendation
The Work Group urges State agencies to:
• Work with sponsoring organizations to determine the best methods for verifying food
production costs, including onsite reviews of food service records, electronic trackers
of food costs and production, or portion menus, instead of meal production records;
• Eliminate State mandates that require:
o Meal production records for sponsored centers;
o Meal disallowances when meal production records reveal errors; and
o Head Start centers to document infant formula choices;
• Allow:
o Recording of infants’ meal counts throughout the day;
o Posted prototype menus to serve as infant meal records;
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APPENDIX E

•

o Child care homes and centers to record all creditable meals served; and
o Sponsoring organizations to determine which combination of meals served
will provide the maximum reimbursement to the child care home or
center; and
Support the continued use of simplified menu records in child care homes.

6. Establish annual eligibility determinations for for-profit centers
For-profit child care centers and outside school hours care centers submit claims for
reimbursement only for calendar months during which at least 25 percent of the children in care
are eligible for free and reduced-price meals or receive benefits under title XX of the Social
Security Act.
Listening to CACFP Stakeholders
Questions about determining eligibility of for-profit centers encouraged feedback from
participants and State agencies, including:
• 18 percent of State agencies require for-profit centers to report attendance, income
eligibility forms, or title XX documentation each month to verify the center’s
eligibility to submit claims for reimbursement.
• “Child care centers do not experience large variability in the percentage of enrollment
or licensed capacity.”
• “Submitting monthly documentation results in a disproportional amount of work for
any center that serves a high number of low income children.”
Implementing this Recommendation
The Work Group urges:
• USDA to establish annual eligibility determinations for for-profit centers serving high
numbers of low-income children; and
• State agencies to eliminate requirements to submit monthly backup documentation of
attendance, income eligibility forms, or title XX participation.
7. Simplify verification of the nonprofit food service status of sponsored centers
Centers and sponsoring organizations of affiliated centers must keep documentation of nonprofit
food service to demonstrate that all CACFP reimbursement funds are used solely for the
operation or improvement of a food service that is conducted principally for the benefit of
children. The State agency must have a system in place for monitoring and reviewing this
documentation.

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APPENDIX E

Listening to CACFP Stakeholders
State agencies’ responses to questions about the documentation of meal service costs disclosed
that:
• 52 percent of State agencies require that food, paper goods, payroll, and other
allowable meal service costs be broken down into subcategories each month.
• 22 percent of State agencies require unaffiliated centers to copy and submit receipts
and other expense records to the sponsoring organization each month.
Implementing this Recommendation
The Work Group urges State agencies to:
• Eliminate requirements for monthly verification of nonprofit food service status;
• Work with sponsoring organizations to determine the best methods for monitoring
nonprofit status, including the frequency of review and the types of documents that
would be reviewed; and
• Allow sponsored centers to maintain nonprofit food service records onsite for review,
instead of requiring them to submit backup documentation to the sponsoring
organization.
8. Eliminate budget requirements that are counterproductive to a fiscally responsible
Program operation
Sponsoring organizations and centers that apply directly to the State agency undergo a rigorous
application process to determine their eligibility to participate in CACFP. State agencies must
establish procedures that require sponsoring organizations and centers to demonstrate and
document that they are financially viable, are administratively capable, and have effective
internal controls to ensure accountability with Program requirements. This documentation
includes budgets, accounting records, approved budget amendments and, for sponsoring
organizations, management plans and appropriate records on child care homes and centers.
A budget is an essential tool for sound business planning and operation that must reflect the
anticipated needs and financial resources to participate in CACFP. Every sponsoring
organization and center that participates directly under the State agency must submit a budget in
its initial application and the State agency must review and approve this.
All CACFP costs must be necessary and reasonable. All expenses require prior approval, either
through the initial budget or an amendment to the budget. Additional levels of written approval
may be required for routine expenses, such as smoke detectors, copiers, computers, and payroll
processing.
Sponsoring organizations of multiple components of CACFP must allocate costs among the child
care homes and centers they operate. For example, administrative funds for child care homes
may not be used to cover administrative expenses in sponsored centers.

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APPENDIX E

The administrative budget of a sponsoring organization of centers must include all administrative
costs, whether incurred by the sponsoring organization or by the sponsored centers. 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.
USDA requires sponsoring organizations to continue to submit budgets for each upcoming year.
Centers must submit budgets as frequently as required by the State agency.
Listening to CACFP Stakeholders
Participants and State agencies provided significant feedback to questions about budgets,
including the following:
• 42 percent of State agencies require budgets from sponsoring organizations of child
care homes that exceed 10 pages, while 55 percent of sponsoring organizations of
centers and 63 percent of independent centers submit budgets that are less than
4 pages.
• “Many recurring expenses are for commonplace equipment and services that should
no longer require specific prior written approval.”
• “When sponsoring organizations determine that they need to repair or replace
equipment unexpectedly, the process for submitting new budgets and waiting up to
30 days for approval has the potential to derail Program operations and impact
compliance.”
• “There needs to be a method to capture end of the year changes that occur after the
budget year is closed out.”
• “CACFP funds should be treated as a single funding source.”
• “Sponsoring organizations budget expenses on an annual, not monthly, basis.”
Implementing this Recommendation
The Work Group urges USDA to:
• Simplify cost allocation of administrative funding among child care homes and
centers that operate CACFP;
• Reduce the number of items that need prior written approval and allow carryover of
line items that can be adjusted without prior written approval in the end-of-year
budget; and
• Standardize a checklist of budget renewal requirements across all States.
The Work Group urges State agencies to:
• Collect annual budgets only from sponsoring organizations, not from the individual
centers they sponsor;
• Allow sponsoring organizations to revise their budgets to capture allowable end-ofyear budget changes 30 days after the end of the year;
• Adopt Federal small purchase procedures that allow informal procurement methods
for services and supplies under $150,000; and

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APPENDIX E

•

Allow sponsoring organizations of centers to:
o Retain reimbursement of administrative expenses on an annual, not
monthly, basis; and
o Carryover unspent administrative funds after the end of the fiscal year.

9. Streamline the CACFP renewal process for sponsoring organizations and centers
The Healthy, Hunger-Free Kids Act requires permanent agreements and eliminates annual
renewal applications from sponsoring organizations and child care centers to the State agency.
USDA requires annual collection of:
• Updated licensing information for child care homes and centers, either directly from
the State licensing agency or from the sponsoring organization or center;
• Updated information on approved child care homes and centers;
• A single certification that all CACFP requirements have been met and changes have
been submitted to the State agency; and
• The sponsoring organization’s budget for the upcoming year.
Listening to CACFP Stakeholders
Questions about the renewal process also encouraged feedback from participants and State
agencies, including the following:
• 57 percent of sponsoring organizations must submit full renewal applications with
supporting documents to the State agency each year.
• 48 percent of State agencies require sponsoring organizations of child care homes,
and 40 percent of State agencies require sponsoring organizations of centers to submit
annual management plans.
• 23 percent of sponsoring organizations are required to submit backup paper
documentation to support the electronic submission.
• “The renewal process should be standardized, limited to USDA requirements, across
all States.”
Implementing the Recommendation
The Work Group urges USDA to:
• Evaluate the documentation, which State agencies collect as part of the renewal
process, to ensure that it aligns with USDA guidance;
• Require resubmission of information, such as job descriptions and policies, only
when changes are made; and
• Allow licenses to be submitted either as they are renewed or, in States where licenses
are permanent, when changes are made.

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APPENDIX E

10. Support the sponsoring organization’s ability to mediate and fix problems through
improvements in the serious deficiency process
USDA has established a process that applies uniform standards to correct serious problems and,
when that effort fails, protect CACFP from abuse. The serious deficiency process is a tool for
sponsoring organizations to correct problems and provide due process for child care homes. If
child care homes are unwilling or incapable of correcting serious problems, the serious
deficiency process protects Program integrity by terminating and disqualifying providers who are
not in compliance with the regulations. Sponsoring organizations, centers participating under the
State agency, and child care homes have the right to appeal actions by the State agency, which
can deny participation, disallow claims for reimbursement, or propose termination for cause.
Listening to CACFP Stakeholders
Participants and State agencies provided comments about the serious deficiency process,
including the following:
• “[There are] wide differences in how State agencies and sponsoring organizations
implement the serious deficiency process.”
• “Current requirements fail to distinguish between human error and intentional
noncompliance, which has led to termination of child care home providers from
CACFP and, subsequently, other child care benefit programs, for reasons unrelated to
serious and deliberate violation of Program requirements.”
• “Deadline of 30 days is too short to provide training and technical assistance to
correct problems.”
• “Child care home providers with limited English proficiencies, learning abilities, or
education are more likely to make repeated paperwork errors, which may unfairly
lead to severe actions, such as termination and disqualification.”
• “Penalty of 7-year disqualification from CACFP participation is arbitrary, fails to
weigh the severity of the problem, and overlooks a standard set of procedures for
requesting removal of the disqualification and reinstatement.”
Implementing this Recommendation
The Work Group urges USDA to:
• Define standards to measure severity of problems and distinguish between human
error and systemic or serious noncompliance;
• Extend the deadline for day care homes to complete corrective action from 30 to
90 days;
• Shorten the 7-year timeframe for disqualification from CACFP; and
• Establish a standard practice with specific steps for requesting reinstatement.

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APPENDIX E

11. Expand the appeals process to resolve disputes over State-specific requirements
USDA has established a process that applies uniform standards to appeal adverse actions that
have direct financial impact on CACFP, such as denial of a claim for reimbursement or demand
for overpayment. However, this process does not address actions resulting from State-specific
requirements. Although they may not have a direct financial impact, implementation of Statespecific requirements may increase paperwork and conflict with USDA Program guidance. The
added administrative cost associated with the required actions may create an indirect financial or
paperwork burden to the Program, which would discourage participation.
Listening to CACFP Stakeholders
Participants and State agencies also provided comments about State-specific requirements,
including the following:
• “Wide differences exist in how State agencies and sponsoring organizations
implement CACFP requirements.”
• “No formal process exists to mediate disputes over additional State agency
requirements.”
• “No formal process exists for State agencies to mediate disputes over USDA
Regional Office interpretation of CACFP requirements.”
• “There is a fear of retribution if concerns are elevated above the normal chains of
communication and oversight.”
Implementing this Recommendation
The Work Group urges USDA to:
• Expand the list of appealable actions to include corrective action steps, interpretation
of CACFP regulation and policy, and additional State agency requirements that
conflict with USDA regulation or guidance;
• Suggest best practices for State agencies to resolve differences in interpretation and
implementation of requirements;
• Create a process for elevating and mediating disputes through USDA; and
• Explore alternative dispute resolution approaches.
12. Embrace technology solutions to improve integrity and reduce paperwork
USDA encourages State agencies and sponsoring organizations to establish internet or
electronic-based systems for reporting and recordkeeping. Implementation of these systems
must include a means to ensure that child care homes, centers, and families have full access to
CACFP benefits if they do not have use of computers.
Electronic records should be complete, uniform, easily understood and easily accessible.
Electronic records and reporting processes must be legally binding and comply with Federal and
State laws, which may specify which form and format is to be used for certain electronic
processes.

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APPENDIX E

Listening to CACFP Stakeholders
Questions about electronic records and other technology solutions elicited significant feedback
from participants and State agencies, including the following:
• 80 percent of State agencies allow sponsoring organizations to maintain all records
electronically; however, 36 percent also require paper copies, and 50 percent require
printed copies for reviews.
• 64 percent of State agencies accept electronic review forms and 77 percent of them
accept electronic signatures on the review forms; however, 64 percent of sponsoring
organizations do not know the State agency policy.
• 45 percent of sponsoring organizations may provide electronic records for review;
however, 48 percent of them must also submit them in paper.
• “Web-based data collection systems and electronic forms can check for math errors
and catch clerical mistakes that may get overlooked on paper.”
• “Supplying electronic recordkeeping systems to child care home providers would
allow sponsoring organizations to analyze meal count and attendance records
remotely.”
• “Maintaining duplicate records is redundant where automation is available.”
• “Electronic tools help streamline a variety of administrative tasks, such as making the
schedule of reviews as random as possible, tracking food costs and production, and
maximizing reimbursement while disregarding any meals served over the upper
limit.”
• “Remote methods of monitoring, training, and technical assistance would help
sponsoring organizations create access to CACFP for rural child care homes and
centers.”
Implementing this Recommendation
The Work Group urges State agencies to:
• Accept and provide training to staff and sponsoring organizations in using electronic
and digitized signatures;
• Allow all data from required forms to be collected electronically and made available
to reviewers in a usable format;
• Accept electronic records and storage in place of paper copying and filing systems;
• Allow electronic monitoring to confirm corrective action and perform followup
reviews; and
• Encourage technology solutions that would:
o Reduce the incidence of errors in the daily records that child care homes
and centers must maintain; and
o Overcome administrative challenges and barriers to participation of child
care homes and centers in rural communities.

37