Off-site Monitoring in FY26
January 26, 2026
USDA has the authority to waive statutory or regulatory program requirements for Child Nutrition Programs. State Agencies can submit a 12(l) waiver application to USDA in order to allow for flexibilities, including off-site monitoring, in their state.
Beginning in Fiscal Year 2024, USDA began processing annual waivers from State agencies to allow sponsoring organizations to use off-site monitoring for a certain number of site visits. In FY25, State agencies submitted a variety of waivers that were approved by USDA, allowing up to two site visits to be conducted off-site if certain parameters were met. Almost every FY25 waiver was limited to monitoring family day care homes, however Texas had a waiver approved to conduct off-site visits for homes and centers.
While last year, State agencies submitted their waiver requests in accordance with USDA Guidance CACFP 12-2018 (Child Nutrition Program Waiver Request Guidance and Protocol- Revised) and using the USDA’s Child Nutrition Program State Waiver Request Template included with that guidance, this year USDA sent out a specific CACFP State Waiver Request Template for Sponsoring Organizations to Conduct Offsite Monitoring of Day Care Homes. The waiver template only applies to the monitoring of family day care homes and permits only one off-site visit for the fiscal year.
Why It Matters
Offsite monitoring waivers provide much-needed flexibility to sponsoring organizations. Sponsors who have implemented an off-site monitoring waiver report that it saves money, allows more time for technical assistance and training, maintains program integrity and increases access to providers in remote, hard-to-reach and high-crime areas.
FY26 Offsite Monitoring Waivers
At least 20 States have submitted their waiver request using the USDA template:
- Alaska
- Arkansas
- California
- Colorado
- Illinois
- Iowa
- Kansas
- Massachusetts
- Michigan
- Missouri
- New Hampshire
- New York
- Ohio (family day care homes must be more than 30 miles from the sponsors office)
- Oregon
- Pennsylvania
- Texas
- Washington
- West Virginia
- Wisconsin
- Wyoming (family day care homes must be more than 50 miles from the sponsors office)
Two States have submitted additional offsite monitoring waiver requests to USDA:
- Alaska has submitted a waiver to allow a second offsite monitoring visit for all family day care homes in the State. The Alaska Department of Education and Early Development used the Child Nutrition Program State Waiver Request Template for this request.
- Texas has submitted two additional waivers to USDA.
- The first would extend the ability to conduct one offsite visit to sponsors of child care centers and adult day care centers.
- The second would allow CACFP sponsors already approved for one offsite monitoring visit to conduct a second review of sites that are 100 miles or 2 hours' travel time away from the nearest sponsor field office.
USDA Waiver Authority
Under Section 12(l) of the Richard B. Russell National School Lunch Act (NSLA), the Secretary of Agriculture is given the authority to waive any requirements within the NSLA for a State or eligible service provider that requests a waiver if:
- the Secretary determines that the waiver of the requirement would facilitate the ability of the State or eligible service provider to carry out the purpose of the program;
- the State or eligible service provider has provided notice and information to the public regarding the proposed waiver; and
- the State or eligible service provider demonstrates to the satisfaction of the Secretary that the waiver will not increase the overall cost of the program to the Federal Government, and, if the waiver does increase the overall cost to the Federal Government, the cost will be paid from non-Federal funds.