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Previously Issued Q&As Relating to Operation of the Child Nutrition Programs: Updated for School Year 2021-2022 




FNS has released questions and answers intended to provide clarification to State agencies and Program operators as they operate the Child Nutrition Programs during school year (SY) 2021-2022. These questions and answers were previously issued in calendar year 2020 and have been updated for application to SY 2021-2022. 

The following is a summary of questions and answers relating to CACFP. Q&A FULL TEXT.


1. What is the maximum number of Program meals and snacks that can be claimed for Federal reimbursement each day during school year (SY) 2021-2022?

CACFP Child and Adult Care: Up to two meals and one snack, or two snacks and one meal, per child or adult participant per day;

  • CACFP At-Risk Afterschool Meals Component: Up to one meal and one snack, per child per day; or
  • CACFP Emergency Shelters: Up to three meals, per resident 18 years and younger, per day.¹

¹Section 1107 of the American Rescue Plan of 2021 authorizes reimbursement for meals and snacks that emergency shelters serve to individuals under the age of 25, from the date of enactment until the date the COVID-19 public health emergency is lifted. See: Reimbursement for Meals and Snacks Served to Young Adults in the CACFP - Q&As.

2. Can Child Nutrition Program (CNP) operators that have received a loan through the Paycheck Protection Program (PPP), made available through the Small Business Administration and qualified lending partners, use CNP Program funds received from the State (CNP Federal funds) to pay back a PPP loan?

Some sponsors have used PPP funds to pay for CNP labor expenses. Under certain circumstances, a PPP loan may be forgiven.

  • If the PPP loan is forgiven: Any CNP expenses paid for using those forgiven PPP funds may not be claimed using CNP funds since they have already been paid with another source of Federal funding.
  • If the PPP loan is not forgiven: CNP funds may only be used to repay that portion of the loan which was used to cover allowable CNP expenses.

School Meal Programs

5. Can residential child care institutions (RCCIs) operate SSO under the Nationwide Waiver to Allow the Seamless Summer Option through School Year 2021-2022?

Yes. In order to safely serve nutritious meals during COVID-19, SFAs that use the Nationwide Waiver to Allow the Seamless Summer Option through School Year 2020- 2021 are permitted to operate the SSO at RCCIs.

Child and Adult Care Food Program

24. Can the at-risk afterschool meals component of the CACFP operate simultaneously with SSO?

Yes. CACFP At-Risk, which operates during the regular school year, may operate simultaneously with the SSO during implementation of Child Nutrition Response #85.

25. What does the meal times waiver allow specific to suspension of CACFP meal service times during the public health emergency?

Child Nutrition Response #88 allows State agencies to suspend the meal service times established by the Program operator.

26. Which components under CACFP does the non-congregate waiver apply to?

Child Nutrition Response #87 applies to all CACFP components—child care centers, adult day care centers, outside-school-hours care centers, at-risk afterschool care programs, family day care homes, and emergency shelters.

27. Can CACFP sites that are open implement the non-congregate and meal time nationwide waivers?

Yes, however, FNS expects CACFP sites to use the non-congregate and meal time waivers only for the duration and extent they are needed.

28. Can a child care center that operates CACFP and is closed due to COVID-19 provide non-congregate meals to enrolled children?

Child Nutrition Response #87 provides CACFP institutions and facilities the ability to provide meals through a variety of methods, including pick-up schedules with designated times for distribution, as long as these are approved by the State agency prior to implementation.

29. Are child care centers required to serve non-congregate meals to enrolled children who are not physically in care on some, or all, days of the week the center is operating? For example, some children may be receiving virtual instruction due to an increased risk of severe illness and/or special healthcare needs, while others are being cared for onsite.

Child care centers participating in CACFP are subject to the congregate feeding requirement that restricts meal service to receiving care onsite. However, a State may elect to use the waivers allowing non-congregate and parent-pick up, and these waivers can help program operators to continue safely serving meals to children as they work toward reopening.

30. Under the non-congregate waiver, can CACFP operators deliver meals directly to children or adult participants’ homes?

Yes. If the CACFP operator determines there is a need and it is logistically feasible to deliver meals directly to homes, it may do so with State agency approval and adherence to all Federal confidentiality requirements.

31. What are the requirements for initiating CACFP home meal delivery for a household?

CACFP operators must first obtain written consent from households of enrolled children (this could include email or other electronic means) that the household wants to receive delivered meals. In addition, CACFP operators should confirm the household’s current contact information to ensure meals are delivered to the correct location.
Once the CACFP operator receives written consent from the parent or guardian to release contact information, the information may be shared with other organizations involved with meal delivery.

32. Do CACFP home-delivered meals need to be shelf stable?

No. The type of meal offered will depend on the resources and capacity of the Program operator.

33. Does the child or adult participant need to be present for CACFP home meal delivery?

No. As long as the CACFP operator has obtained the household’s written consent to deliver meals and has verified the current address, the child or adult participant does not need to be present at the time of delivery.

34. Can CACFP State agencies and sponsoring organizations add new centers and facilities during the 34. COVID-19 emergency?

Yes, State agencies and sponsoring organizations can add new centers and day care homes that are providing care during the coronavirus pandemic.

35. Are State agencies and sponsoring organizations required to conduct pre- approval reviews for new CACFP centers and day care homes during the coronavirus pandemic?

Yes, to ensure program integrity during the emergency response, State agencies and sponsoring organizations are still required to conduct pre-approval reviews for new institutions and facilities.

36. During COVID-19 how may we offer the enrichment activity if we are operating in a non-congregate setting for social distancing and safety?

Under the non-congregate and parent pick-up waivers, these activities may be conducted virtually or in other non-congregate ways. Program operators may consider offering online homework assistance, activity packets, electronic games and books, or other e-learning activities for the children to partake in at home.

37. May CACFP At-Risk sites/sponsors that did not serve weekend meals prior to COVID-19 expand to provide weekend meals with a non-congregate enrichment activity?

Yes. Federal regulations at 7 CFR 226.17a(b) state that CACFP at-risk centers that provide care for children on weekends during the regular school year may claim meals served on weekends.

38. For CACFP at-risk afterschool care programs that are providing on-site care to children attending school virtually due to COVID-19, what meals may be served?

Per Federal regulations at 7 CFR 226.17a(m), when school is in session, a CACFP at- risk meal and/or snack must be served after the child’s school day. Schools that are operating virtually for some of their students are considered to be in session; therefore, the afterschool program would need to plan their meal service around the time of the virtual school day. Only a meal and/or snack served after the virtual school day is over would be reimbursable.

39. May CACFP at-risk afterschool programs that are not caring for children on- site provide meals through alternate meal service options?

Yes. FNS recognizes that program operators need additional support and flexibility to continue safely serving meals to children as they work toward reopening. Under the nationwide non-congregate feeding and parent pick-up waivers, at- risk programs may provide meal deliveries and grab-and-go meals.

40. May a child care center or day care home claim reimbursement for CACFP meals that children take home to consume on weekend days when they are not in care?

CACFP centers and day care homes that are approved for non-congregate feeding and meal service time flexibility may provide meals for a child to consume on weekends, as long as the facility is approved to serve meals on weekends and the child is enrolled for weekend care.

41. How can CACFP at-risk centers track attendance to claim reimbursement for meals and snacks served to children participating virtually?

At-risk centers approved to participate under the COVID-19 waivers continue to maintain attendance records. This includes daily attendance rosters, sign-in sheets, or with State agency approval, other methods that result in accurate recording of daily attendance. When children participate virtually, flexibility in using other methods may be needed. For example, if it would result in accurate recording of daily attendance, the State agency may approve documentation of meal pick-up or meal delivery as a record of a child’s attendance. The State agency should work with at-risk centers and sponsors to develop appropriate methods to document attendance and conform with the program’s COVID-19 safety policies.

42. For afterschool programs, if the educational or enrichment activity is electronic and a child does not have access to the required electronic device, is the activity still considered available to all?

As Program operators plan enrichment activities for participating children, FNS encourages them to consider the ability of children to access various activities. It may be appropriate to offer some activities that children could participate in without internet access or electronic devices, such as books, activity packets, or coloring sheets. Although children are not required to participate in or complete an activity in order to receive an afterschool meal or snack, whatever activities are offered should include options that are accessible to all participating children.

43. May CACFP at-risk centers providing extended care during the day (both school hours and afterschool hours) claim reimbursement for a breakfast and/or lunch served in addition to the one meal and one snack allowed for at-risk?

No. Centers that are only approved to operate under the CACFP at-risk component may not claim reimbursement for meals that exceed their program meal limitation of one meal and one snack per child, per day.

44. As child care centers continue to open, they may have limited schedules and hours of operation. Can centers provide a combination of congregate and non- congregate meals?

Yes. Under the nationwide waivers, child care centers that remain open can provide congregate meal services to children in attendance and arrange for non-congregate meal service pick-up or delivery for the children who are not in attendance.

Multi-Program Sponsors

45. Can an SFA that participates in both SSO and CACFP At-Risk provide meals and snacks through SSO and CACFP At-Risk to each participant? Do the Programs have to be operated at the same site or different sites? Can participants pick up multiple meals at once?

An SFA, if approved to operate both Programs, may locate them at the same or at different sites. The SFA may allow children to pick up multiple meals from each Program at one time. However, the maximum number of meals that may be offered to each child may not exceed the number of meals allowed by each Program.

46. May school-age children who are attending school virtually and who also are enrolled and attending child care during the day receive meals through both CACFP and school meal programs?

Yes. Students enrolled in both school and child care may receive meals through multiple Child Nutrition Programs.

Civil Rights

47. Is the Nondiscrimination Statement required on informational materials and websites?

States are not relieved of their obligation to include the required Nondiscrimination Statement (NDS) on all printed and electronic program materials made available to applicants, participants, and potentially eligible persons for public information, public education, or public distribution. This includes, but is not limited to, information pertaining to eligibility, benefits, services, the location of local facilities or service delivery points, and hours of service.

48. Will meal pattern waivers affect a program operator’s responsibility to make meal modifications for participants with disabilities?

During this public health emergency, States and program operators are not relieved of their obligation to provide meal modifications for participants with disabilities.