Skip to content

April Policy Update

April 5, 2024

Policy Update Interior

Since our last policy updated, there has been new legislation introduced, a proposed rule for serious deficiency released, as well as federal and state recognition of the CACFP. There have also been multiple pieces of USDA guidance and FRAC research published regarding the CACFP. Check out the recent policy updates below! 



In March, Senator Casey introduced the Early Childhood Nutrition improvement act to partner the bill in the House of Representatives. The bill, endorsed by NCA, would allow providers open for more than 8 hours a day to be reimbursed for an additional meal, make reimbursement more equitable, and work to streamline the CACFP. To learn more, read our summary blog. 

Visit our Action Center to urge your elected officials to support this legislation! 

Proposed Rule: Serious Deficiency Process in the CACFP and SFSP 

This proposed rule was released by USDA in February with suggested updates to the serious deficiency process for CACFP, as well as the extension of the process to the Summer Food Service Program (SFSP). The serious deficiency process was created to help protect the integrity of child nutrition programs. However, current regulations for serious deficiency leave program operators without the opportunity to remove serious deficiency determination, even when they have successfully implemented a corrective action plan. Instead, program operators can only have serious deficiency determinations temporarily deferred, so any recurring issue immediately leads to termination and disqualification. Updates proposed in this rulemaking would adjust the serious deficiency process so that program operators can fully correct any serious management problems and return to good standing. FNS is also proposing multiple updates to improve the clarity and understanding of the serious deficiency process. 


National CACFP Week Recognized at State and Federal Levels 

This year, National CACFP Week was formally recognized at federal and state levels. A congressional resolution for National CACFP Week was introduced in both the House of Representatives and the Senate. The resolution was introduced in the House by Representatives Suzanne Bonamici and Marc Molinaro. The Senate resolution was introduced by Senators Amy Klobuchar and John Boozman and passed by unanimous consent. In addition, 17 Governors signed proclamations declaring March 10-16, 2024, as CACFP Week in their States. 


USDA Guidance 

Updated Instructions for the SAE Recovery Process and SAE Financial Status Report 

On August 23, 2023, the Food and Nutrition Service (FNS) published the Child Nutrition Program Integrity Final Rule, which establishes changes to the SAE recovery process in Fiscal Year (FY) 2023 and going forward. The changes and clarifications outlined below impact SAE reallocation funds received beginning in FY 2023. CACFP sponsor administrative funds are reported on the same form as SAE funds. As a result of the changes to how SAE funds are tracked and reported on the SAE Financial Status Report, FNS provides guidance for reporting sponsor administrative funds and carryover.  

FY 2024 Reallocation of SAE Funds in Child Nutrition Programs 

This memorandum provides the information needed to conduct the FY 2024 reallocation of State Administrative Expense (SAE) funds in the child nutrition programs (CNPs). Reallocation is a formal process by which state agencies can request additional SAE funds above their initial authorized funding level. State agencies are reminded that several updates to the carryover and reallocation of SAE funding went into effect in fiscal year (FY) 2020.   

State Agency Review Requirements  

This memorandum provides additional information regarding the provisions related to the frequency and number of reviews for State Agencies monitoring the CACFP, that were codified in the Child Nutrition Program Integrity Final Rule. These provisions have a compliance date of August 23, 2024, and are consistent with the statutory mandate of the NSLA. FNS codified regulations to increase the frequency of reviews for some institutions operating the CACFP.  


CACFP Research 

FRAC’s report Leveraging CACFP for Farm to Early Care and Education: Growing Wins Across Early Childhood and Food System Sectorsaims to support child care providers to access CACFP and utilize it for eligible Farm to ECE activities by highlighting the mutually beneficial synergy between these initiatives. When combined, the CACFP and Farm to Early Care Education (Farm to ECE) activities can have an extraordinary impact on children, child care providers, and local communities. The report also provides recommendations for stakeholders to boost participation in these vital programs.   


For more information contact