Regulations & Guidance


Published CACFP Policy Memo Summaries

June 28, 2019 

Delayed Implementation of Grains Ounce Equivalents in the Child and Adult Care Food Program

Published on July 1, 2019

Full Text 

On July 1, 2019, FNS published a proposed rule, Delayed Implementation of Grains Ounce Equivalents in the Child and Adult Care Food Program (CACFP), to delay, until October 1, 2021, implementation of the requirement for crediting grains served in CACFP using ounce equivalents.

The new implementation date would allow more time for FNS to develop additional technical assistance materials and for State agencies and sponsoring organizations to provide training and technical assistance to make compliance easier for day care homes and centers nationwide.

The two-year extension would also apply to crediting grains in infant and preschool meals in the National School Lunch and School Breakfast Programs.

FNS has opened a 30-day window for comments on this proposed rule.  It is very important that we comment! 

The deadline is July 31, 2019.  Your comments may be submitted in writing by one of the following methods:

Federal eRulemaking Portal: go to Follow the online instructions for submitting comments.

Mail:      Community Meals Branch

Policy and Program Development Division

USDA Food and Nutrition Service

3101 Park Center Drive

Alexandria Virginia 22302

Please submit your comments as every comment is read by FNS.  NCA will have a model comment available the week of July 8, 2019.

CACFP-04-2019 January 8, 2019 

Update on Funds Available for the Department of Agriculture’s Food and Nutrition Service, Child Nutrition Programs

FNS has provided State Agencies with additional available appropriated funding. These funds, along with those previously provided, can support program operations at normal levels well into the month of March.

Full Text

CACFP02-2019 December 13, 2018 

Update of Food Crediting in the Child Nutrition Programs

Effective Date: Immediately Full Text

Last December, USDA’s Food and Nutrition Services (FNS) requested comments on food crediting in Child Nutrition Programs (CNPs) through a Request for Information (RFI). Many stakeholders spoke and FNS listened. Listed below are the changes to food crediting.

Per USDA SP 08-2019, CACFP 02-2019, SFSP 02-2019, Update of Food Crediting in the Child Nutrition Programs, dated 12/4/2018:

  • Shelf-stable, dried and semidried meat, poultry, and seafood snacks are now reimbursable as part of a meal or snack.
    • Not limited to meals and snacks served off-site.
    • Coconut, hominy, popcorn, surimi seafood, and tempeh are now creditable as well.
    • As a reminder, turkey bacon is creditable.

Be on the lookout for new memos to be published soon to provide additional clarification on how these new creditable items can be used to fulfill food components as well as crediting vegetables disguised as other food components, including noodles or pastas made from vegetables, including legumes.

Why It Matters
The changes in food crediting remind us that our voices matter. We have the incredible opportunity to work towards providing the healthiest start possible for those in our care. Let us take these changes and build even stronger programs to reach every child in need.

CACFP01-2019 October 18, 2018

Guidance for FY19: Updated CACFP Meal Patterns and Updated NSLP and SBP Infant and Preschool Meal Patterns

Effective Date: October 1, 2018 (FY 2019)

Full Text

Understanding that new meal pattern implementation has been difficult for many State Agencies and Sponsoring Organizations, USDA FNS has issued a memo strongly encouraging continued corrective action over fiscal action where appropriate. However, if a meal misses an entire required food component, the meal must still be disallowed.

Please refer to the full-text memo for a list of technical assistance resources. Also, please remember that the Institute of Child Nutrition (ICN) will continue to offer meal pattern trainings per request through their website as well as other valuable resources to assist in implementing the new meal patterns.

Why It Matters
Times of transition can be difficult. We are all here to feed children the healthiest meals possible and sometimes need extra technical assistance to ensure we are operating the program with the highest level of integrity and nutrition possible. By continuing to support one another through technical assistance, we can ensure our efforts feed every child in need.

CACFP 09-2018 April 13, 2018


Grain Requirement in the CACFP; Q&A

Effective Date: Currently in effect

 Full Text

Whole grain-rich can be a confusing term. This memo outlines and provides additional clarification to the grains component of the new meal pattern as well as provides an extensive and updated Q&A. Please note that this memo introduces ingredients you can disregard when determining if a product is whole grain-rich.This includes cornstarch.

This memo supersedes CACFP 01-2018.


  • All grains served must be made with enriched or whole grain or flour or bran or germ.
  • Grain is a required component at breakfast, lunch, and supper meals, with an option at snack.
  • One serving of grains a day must be whole grain-rich.
  • Ounce equivalents (oz eq) are not required until October 1, 2019 while the rest of the new meal pattern have already gone into effect as of October 1, 2017 (currently in transition period).

Enriched Grains and Fortified Breakfast Cereal

Creditable criteria (must meet at least one):

  1. Labeled as enriched.
  2. An enriched grain is the first ingredient listed (or second after water).
  3. A cereal is listed as fortified or includes the vitamins and minerals that have been added to the product. Does not need to be enriched.

Whole Grain-Rich

  • One serving a day.
  • Applies only to children and adults, not infants.
  • Contains at least 50% whole grains and the remaining grains are enriched, or 100% whole grain.

Creditable Criteria (must meet at least one):

1. Product is listed on a State Agency’s WIC-approve whole grain food list.

2. Labeled as “Whole wheat” and has a Standard of Identity issued by the FDA.

  • Please reference full-text for a comprehensive list of approved Standard of Identity terms for whole grain-rich breads and pastas.
  • Any other product must be evaluated based on one of the other methods listed in this memo.

3. Includes one of the following health claims (for CACFP only):

  • Diets rich in whole grain foods and other plant foods and low in total fat, saturated fat, and cholesterol may reduce the risk of heart disease and some cancers.
  • Diets rich in whole grain foods and other plant foods, and low in saturated fat and cholesterol, may help reduce the risk of heart disease.

4. Meets the whole grain-rich criteria under the National School Lunch Program (NSLP).

  • One exception are grain-based desserts.

5. Meets FNS’ Rule of Three:

  • First ingredient must be whole grain and the next two grain ingredients (if any) must be whole grains, enriched grains, bran, or germ.
  • Any grain derivatives (by-products of grains) may be disregarded.
  • Any non-creditable grains (not enriched or whole flours) that are labeled as 2% or less may be disregarded as well.
  • Mixed dishes (pizza crust, burritos, etc): the first grain ingredient must be whole grain and the second two grains (if any) must be whole grains, enriched grains, bran, or germ.
  • Ready-to-eat Breakfast Cereals: if the first ingredient is a whole grain and the cereal is fortified, it’s creditable.
  • Please reference full-text for a comprehensive list of approved whole grains, brans and germs, enriched grains, disregarded ingredients, and non-creditable grains or flours).

6. Proper documentation from a manufacturer or a standardized recipe that demonstrates whole grains are the primary grain ingredient by weight.

Grain-Based Desserts

  • No changes. Please refer to the full-text memo under superscript 3 or 4 in Exhibit A (Attachment 2) for a full list.

Breakfast Cereals

  • Must contain no more than 6 grams of sugar per dry ounce (21.2 grams of sugar per 100 grams of dry cereal) and be made from enriched or whole grain meal or flour, or be fortified, to be creditable.
  • Reminder: infant cereals and ready-to-eat cereals must be iron-fortified.
  • To determine if a cereal meets the sugar limit:
    • Utilize any State Agency’s WIC approved breakfast cereal list.
    • Use USDA’s Team Nutrition training worksheet.
    • Calculate using either Standard Method or Round Method. Only one method is needed to prove the cereal is within the sugar limits.
    • Standard Method: Find serving size in grams, divide by total sugars, if the answer is equal or less than 0.212, then it’s creditable.
    • Rounding Method: Find serving size in grams, multiply the serving size by 0.212. If the answer ends in 0.5 or more, round the number up to the nearest whole number. Find the sugars listed on the Nutrition Facts label. If that number is equal to or less than the number you came up with after rounding, the cereal meets the sugar limit.


  • State Agencies should not impose additional paperwork burdens to prove compliance. Instead, they are encouraged to update forms if needed. An example would be to write WW or WGR in front of a food item to signify compliance. Another way to update a form could be a simple checked box.
  • State Agencies and Sponsoring Organizations must verify the creditability of food served during on-site reviews.
  • During the current transition period (until September 30, 2018), State Agencies and Sponsoring Organizations must provide technical assistance instead of fiscal action.

Please reference the entire memo along with the extensive Q&A included in the full-text memo for further clarification. This summary is not intended to replace the USDA memo.

Why It Matters
Sometimes transitions are difficult; the move to whole grains have been no exception. Many asked for additional guidance and this clarification proved that your voice is heard. Your voice matters. We must continue to advocate for the children in our care, provide the healthiest meals possible, and work together to ensure the highest level of participation and integrity possible.

CACFP10-2018 April 4, 2018

Conducting Five-Day Reconciliation in the CACFP; Q&A

Effective Date: Immediately Full Text

The Food and Nutrition Service (FNS) released a new memo to clarify the procedure and purpose in conducting five-day reconciliations in the Child and Adult Care Food Program (CACFP) during monitoring visits. This memo contains revised guidance to eliminate disparities and reduce duplication in the review process by acknowledging state flexibilities and local choices as well as recognize the role of technology in streamlining data.

  • Designed to be simple. Consistency of enrollment, attendance, and meal count for a five-day period (except in outside-school-hours care centers, At-Risk Afterschool, and Emergency Shelters where enrollment forms are not required).
  • Process for centers and homes the same.
  • Use aggregate data, not individual data.
  • No need to cite licensed capacity because it is already included in onsite reviews.
  • Meals should not be disallowed if there is a reasonable explanation for inconsistency.
  • Not designed for daily comparison or verifications.
  • Recognize the role electronic resources can play. No need to verify both electronically and in a 5-day reconciliation.
  • Recognize overlap. If your State Agency already requires evaluation of enrollment, attendance, and meal counts for the entire claim period, there is no need for another check via reconciliation.
  • Recommends States create written procedures to both streamline and ensure consistency.

Please reference the extensive Q&A included in the full-text memo for further clarification.

Why It Matters
We must always strive to balance program integrity and reduce paperwork burdens to build the best program possible for the children we serve and those who care for them daily. By recognizing overlap, clarifying the reconciliation process, and continuing to exchange ideas and collaborate, we can increase the effectiveness and reach of our programs. Together, we can take another step towards eradicating food insecurity for every child.


CACFP05-2018 January 19, 2018

Providing Child Nutrition Program Benefits to Disaster Survivor Evacuees

Effective Date: Immediately Full Text

In light of recent natural disasters such as floods and wildfires, USDA FNS has released a memo outlining the current options available to reach the children who count on our programs daily. This is not a new policy memo but guidelines for providing quick services while still abiding by program requirements. Additionally, FNS provided administrative flexibilities during recent disasters. The best strategy to serve disaster survivors is to already have a plan in place if at all possible.

Children Identified as Homeless

  • Defined as “a child identified as lacking a fixed, regular and adequate nighttime residence.”
  • Automatically eligible for free meals in NSLP and SBP as well as CACFP.
  • The families of children who are evacuated during disasters need to be informed by Program officials and school staff that they are eligible for free meals.
  • Determination of homelessness can be made by an LEA homeless liaison, an organization assisting evacuees, or a homeless shelter representative.
    • An adult living with a child or a school official can also fill out the form.
    • Meals and snacks served to children in day care homes designated as homeless can be claimed at the Tier I rate. In day care centers, providers can claim the free rate.

Eligibility for D-SNAP and NAP Recipients

  • Disaster Supplemental Nutrition Assistance benefits were temporarily available for individuals touched by the recent wildfires and hurricanes in several states. These benefits have primarily expired.
  • Eligible households from Puerto Rico who received Nutrition Assistance Program benefits may still be receiving those.
  • Contact your SNAP agency to determine your free meal eligibility for those receiving D-SNAP or SNAP benefits.

Other Considerations

  • If eligibility status cannot be obtained due to a school closure or another event, school officials can submit an application on behalf of the student with their best available economic knowledge of their situation.
  • Children who are eligible for free meal benefits will continue to receive them for the entire school year as well as 30 days into the next school year. CACFP free meal recipients will receive them for 12 months.

Why It Matters
The aftermath of a natural disaster can be incredibly hard to address without the proper plan and resources in place. By utilizing the information outlined in this memo, we can reach those most in need as efficiently as possible. Collaboration between sponsoring organizations, State Agencies, school officials, and community groups can not only ensure that children who have survived disasters can receive regular, nutritious meals but also provide a bit of normalcy in an extraordinarily stressful time


CACFP04-2018 January 18, 2018

Market Basket Analysis when Procuring Program Goods and Modifying Contracted-For Product Lists; Q&A

Effective Date: Immediately Full Text

Many program operators utilize a practice called “market basket” analysis to choose contracts for program goods. Market Basket Analysis is evaluating the lowest price a vendor can offer for a representative sample of goods (recommended 75% of total estimated cost). Keep in mind that this method of procurement cannot be used for awarding equipment for service contracts (such as pest control). While not a new concept, this memo seeks to clarify the process to ensure compliance with Federal procurement standards.

The preferred method of awarding a contract is based on evaluating the price of all goods as an aggregate or by line. However, program operators can utilize a simplified analysis by totaling the bottom line costs of major items in a contract to determine the lowest price between bidders. Three key factors must be kept in mind when awarding a contract:

  • Responsive and responsible contractor
  • Price must be the primary factor in evaluating contracts
  • Contracts must be awarded to the lowest bid or most advantageous to the program.

Market Basket Analysis can also be utilized in procuring goods through the Net-Off-Invoice (NOI) value pass through system. Additionally, all additional items needed must be included, along with their price, on the final contract. The pricing and quantities must be reasonably accurate and contain descriptions.

If a program operator wishes to add a specific item to an existing contract, they must do so through another avenue (micro purchasing, small purchase procedures, sealed bids, or competitive proposal). If the item is needed on an ongoing basis, it must meet these conditions to be added:

  • The option to add a good must be included on original contract.
  • The total value of all goods (including add-ons) cannot exceed original limit stated on contract.
  • If the contract has a renewal option, upon renewal the additional items must be included in an amendment.
  • Each year a contract is renewed there must be determined a new basis for contract value. This includes the previous years expenditures as well as add-ons.
  • Add-on goods records must be kept.

Please refer to the extensive Q&A in the full text of this memo for additional clarification.

Why It Matters
We operate our programs to feed as many children experiencing food insecurity as possible. An important step in keeping our programs efficient, effective, and promoting integrity is accurate record-keeping regarding goods procurement. By utilizing each method as needed, we can best serve our providers and the children in their care.

FD-107 November 21, 2017

Donated Food Storage, Distribution, and Product Dating (Revised)

Effective Date: Immediately Full Text

Product and expiration dates on foods are not federally regulated. Manufacturers choose the type of labeling for their product. As participants in child nutrition programs (CNPs) the varied dates can make it difficult to know which donated products to serve first. This memo seeks to clarify this confusion.

  • Utilize a first-in-first-out (FIFO) system of inventory management to ensure no donated items expire.
  • Remember to order only what you need to avoid waste, manage your inventory closely with accurate records, and ensure proper storage practices for food safety.
  • Remember that you must use the product within 6 months for CNPs (or 3 months in the Commodity Supplemental Food Program and Food Distribution Program on Indian Reservations).
  • Products marked with the earliest end date (best-if-used-before, etc.) should be used first.
  • If a product does not have a best-by date, refer to your records to note when the item was received.

Product Dating

  • Best-if-used-by, best-if-used-before, sell-by, and use-by date can all be utilized as quality indicators. If you do not notice a change in food integrity (smell, color, texture), you may use the product up to the six-month mark.
  • Do not receive donated food that is already past the aforementioned labeled dates.
  • Products that have pack code, date of pack, or manufacturing date cannot be used to judge nutritional value or expiration. Instead, utilize your inventory records to ensure freshness.
  • Out-of-condition foods should not be served. Dispose of them in compliance with your State and local requirements. If a food does not appear to have anything defective but you question if you should serve it, contact your State Health Department to conduct an inspection of the food.
  • Food that requires special handling, such as dried fruits, grain products, and string cheese, need to be stored in a cool and dry place at refrigerator or freezer temperatures.

Why It Matters
Donated foods can be key in menu planning for many across the country. It is our responsibility to maintain program integrity by serving the safest food possible. By utilizing these revised instructions, we can ensure program integrity and use all resources available to provide the healthiest start to the children in our care.

CACFP02-2018 October 19, 2017

Feeding Infants and Meal Pattern Requirements in the CACFP; Q&As

Effective Date: Immediately Full Text

Infant feeding can be a challenge. This memo seeks to clarify the new meal patterns as related to infant feeding, including breastmilk/formula and the introduction of solid foods. It also includes an extensive Question & Answers section in the second half of the memo to assist in providing the best nutritional start possible for the youngest in our care. Remember, infants do not eat on a set meal schedule, so you must not disallow infant meals for not following the typical meal schedule. Further clarification is below:

Creditable Infant Formulas                                 

  • Must be iron-fortified. To ensure that the formula is creditable, follow these guidelines:
    • Double-check that the formula is not on the FDA Exempt Infant Formula list.
    • Look on label for “Infant Formula with Iron” or a similar statement.
    • Use the Nutrition Facts label to ensure that the formula has at least 1 mg of iron per 100 calories.
    • A medical statement is necessary for the creditable use of an FDA Exempt Infant formula.

Provided breastmilk or formula

  • Parents may decline the provider’s formula and bring their own creditable formula or expressed breastmilk.
  • Breastmilk is creditable when provided as expressed milk or breastfed on site.
  • Both formula and breastmilk are creditable even when it is the sole meal component.
  • While you must document that breastmilk or formula were received, you do not have to specify whether on-site or expressed.
  • Providers are responsible for making sure the other food components are offered when they begin solid foods.

Expressed breastmilk storage

  • May be stored up to 72 hours after being expressed in a refrigerator at 40F or below.

Solid Foods (Complementary Foods)

  • Two infant age groups: 0-5 months and 6-11 months.
  • Delay the introduction of solids until 6 months or developmental readiness (typically 6 to 8 months)
  • Meals must not be disallowed as infants begin to try new foods. Meal offerings must follow the infant’s feeding patterns. Do not disallow a meal because one day you offered a food and the next you didn’t.
  • Be sure to offer foods that are appropriate for the age of the infant in texture and consistency.
  • As a best practice, centers and homes should ask the parent or guardian to approve in writing when they should begin serving solid foods to their infant. The American Academy of Pediatrics (AAP) recommends these signs:
    • When an infant has good head control and can sit in a high chair or seat.
    • When an infant opens their mouth for food, watches others eat with interest, and/or seem excited to participate in the meal.
    • When an infant has less of a gag reflex and can move food from spoon to mouth.
    • When the infant has doubled their birth weight and weighs 13 pounds or more.

Vegetables and Fruits

  • Juice is no longer allowed for infants.
  • Vegetables and/or fruits are already required at breakfast, lunch, and supper for infants who are developmentally ready. Additionally, fruits and vegetables are now required at snack for the same developmentally ready infants.


  • Ready-to-eat cereals allowed for developmentally ready infants.
    • Must meet sugar limits (no more than 6 grams per dry ounce).

Meat and Meat Alternates

  • Older infants may have yogurt as a meat alternate as long as it contains no more than 23 grams of sugar per 6 ounces.
  • Whole eggs allowed as a meat alternate as well.
  • No cheese spread or cheese food products are reimbursable. Regular cheese is still allowed.

DHA enriched foods

  • DHA-containing credible infant food items are now reimbursable.


  • Must keep records of menus.
  • State Agencies are allowed to request other forms of documentation. However, State Agencies are encouraged not to impose additional paperwork burdens.

Please be sure to refer to the extensive Question and Answer portion of the full text memo.

Why It Matters
Taking care of infants is a joy for many providers across the nation. However, sometimes feeding them can be challenging and confusing. The new meal patterns may seem overwhelming at first, but broken down into food components can help us understand the most recent nutritional science when crafting our menus and introducing foods to those who are ready. The increased flexibility for breastfeeding mothers (both expressed milk and feeding on-site) supports both mothers and strengthens our program. We know the first years of life are vitally important to a lifetime of positive health and these changes help us support healthier infants as they grow into children.

CACFP18-2017 September 20, 2017

Clarifications: Funding Levels for FY 2018 Child and Adult Care Food Program Audit Fund Allocation

Effective Date: Immediately Full Text 

State Agencies can now request up 2% of the allocated funds available per their State legislative body for auditing in FY 2019. Stage Agencies may request up to the maximum 2% at the beginning of FY 2018 and again at the end of the 2nd quarter of FY 2018. They may not exceed the cumulative amount of 2% of the funds available for their use in any fiscal year.


  • October 13, 2017 – Deadline for funding level request to your Regional Office. No additional information is needed.
  • October 20, 2017 – FNS Regional Offices should send funding level requests to the National Office at Please be sure the subject line states “FY 2018 CACFP Audit Funds Request – [add Region and State(s) Name].
  • State Agencies must report on a Quarterly Basis.
  • All State Agencies will automatically receive 1.5% CACFP Audit funds for FY 2018.
  • Additional funding will be added once all requests are processed. Regional Offices will notify each State Agency requesting additional funding.
  • Another notice will be issued in March for those who have not requested additional funds by the end of the 2nd quarter of FY 2018.

Why It Matters
To best serve the children in our care, we must utilize the tools available to uphold program integrity and increase program participation and effectiveness. By utilizing the audit funds available, State Agencies can best accomplish their fiscal year requirements and serve those in their programs. We must work together at all levels to provide the best care and nutrition to those we serve.

CACFP16-2017 June 30, 2017

Grain-Based Desserts in the CACFP

Effective Date: October 1, 2017 Full Text

One important revision to the meal pattern standards is the disallowance of grain-based desserts. Realizing the significant burden placed on providers if they had to calculate sugar, satured fats, and other nutritional components of each grain item they served to conclude if the item was allowable or not, USDA instead created categories to define grain-based desserts.

When the final meal pattern revision was published, sweet crackers (including graham and animal crackers), remained consistent with the School Meal Programs designation and were included under grain-based desserts. After the final ruling was published, numerous stakeholders expressed the challenge of disallowing sweet crackers due to their shelf-stable nature, appetizing, and low-cost characteristics. They were frequently served in both rural areas and At-Risk Afterschool sites due to those characteristics.

Because of the aforementioned characteristics and the lack of opportunity to provide feedback before the final rule was published, flexibility is needed. Sweet crackers (including graham and animal crackers) have been excluded from the grain-based dessert category in the new meal patterns. Graham and animal crackers are allowable components in the new meal pattern. However, you are encouraged to serve these on a limited basis due to their higher sugar content than other grain-based products.

Please keep in mind that program operators are allowed to serve grain-based desserts as an additional, non-reimbursable item. As a best practice, providers are encouraged to save both non-reimbursable grain-based desserts and sweet crackers for special occasions and celebrations.

Why It Matters
Ask any young child if they like animal and graham crackers and their response will certainly be an enthusiastic yes. Many providers in rural areas as well as those participating in the Afterschool component of the CACFP serve them as shelf-stable snacks with a reasonably low sugar content that the children in their care will enjoy.

As this memo clarified, your voice matters. We must always advocate for the children in our programs, strive to provide them the most nutritious meals within our means, and work alongside all levels of program administration to operate our programs with the greatest integrity possible.

CACFP17-2017 June 30, 2017

Documenting Meals in the Child and Adult Care Food Program

Effective Date: October 1, 2017 Full Text

Day care centers and homes must demonstrate that they are meeting the meal pattern requirements by keeping records of menus. State Agencies may determine other types of acceptable recordkeeping documents required to prove compliance with the new meal patterns. State Agencies are recommended not to impose additional paperwork burdens as much as possible. Instead, FNS encourages State Agencies to maintain the current requirements or to update existing forms to streamline paperwork.

Please refer to the full text summary to locate the specific documents FNS will be updating to reflect this memo. They will offer best practice recommendations for staying within compliance of the new meal patterns.

Why It Matters
The new meal pattern transition has started and we all wish to provide the very best to the children in our care. One of the difficult areas for many program operators is paperwork requirements. By utilizing these memos that outline and clarify existing regulations, we can promote program integrity and uphold the highest nutritional standards possible. By working together, at all levels, we can transition as effortlessly as possible into the new meal patterns.

CACFP14-2017 June 22, 2017

Policy Memorandum on Modifications to Accommodate Disabilities in the CACFP and SFSP

Effective Date: Currently in effect Full Text

The Americans with Disabilities Act (ADA) of 2008 made key changes to the meaning and interpretation of the word “disability.” The term is meant to be broad and inclusive. For our programs, disability is defined as “any person who has a physical or mental impairment which substantially limits one or more ‘major life activities.’” Since the definition is so broad, as sponsors we should be concerned with equal access to the program and not legal standards for disabilities.

As sponsors, we are tasked with providing reasonable accommodation for those requiring dietary changes due to a disability at no extra charge. Often, this simply means a different meal than everyone else. However, a written statement from a licensed healthcare professional must be provided before substituting portions of a meal due to a dietary restriction related to a disability.

Prior legislation through Section 504 of the Rehabilitation Act of 1973, Title III of the Americans with Disabilities Act of 1990, and the Individuals with Disabilities Act (IDEA), solidifies our duty to provide appropriate specialized meals and substitutions when required by anyone we serve who is disabled.

Meal substitutions can often stay within the meal pattern requirements. If a substitution cannot, a written statement from a licensed medical professional is needed for the meal to remain reimbursable. The medical statement must contain a description of the disability as well as what accommodation must be made.

Reasonable accommodation does not extend to substitutions or changes in your program that could put a severe financial strain on your provider. If that would occur, you are urged to speak with the participant and the participant’s parent or guardian to discuss alternative accommodations. Keep in mind that exclusion from the typical, integrated environment does not meet a reasonable accommodation standard. While someone with an allergy may need to be separated, they should still be kept in the same room or environment as everyone else.

Other accommodations may be additional aides or adaptive feeding equipment. Please note that these are allowable costs and supplement funding may be available through special education funds. At minimum, a written final statement should be included with each participant who claims a disability. Those who employ 15 or more individuals also need a compliance coordinator (Section 504 Coordinator). For those who operate smaller organizations, it is recommended to have someone to provide technical assistance for modification compliance. A team-based approach is highly recommended to provide the best care possible to everyone we serve.

Why It Matters
Every child deserves the healthiest start in life. We are given the wonderful opportunity to be a key component and building block in their childhood journey by providing adequate and nutritious food to some of our nation’s most marginalized children and adults in care. Those with disabilities provide a unique challenge to our programs. By recognizing their specific needs and placing the modifications necessary to meet those needs, we uphold the integrity of the CACFP and continue our mission to make our children the healthiest they can possibly be, no matter their economic, physical, or mental background. 

CACFP13-2017 May 10, 2017

Transition Period for the Updated Child and Adult Care Food Program Meal Patterns and the Updated National School Lunch Program and School Breakfast Program Infant and Preschool Meal Patterns

Effective Date: October 1, 2017- September 30, 2018

Full Text

The new meal patterns strengthen the nutrition providers can offer by addressing the dietary needs of all individuals as well as serving increasingly diverse and culturally appropriate foods. USDA FNS understands that major transitions can be difficult for everyone involved and have shown a fierce commitment to providing ample time to train everyone on proper implementation of the new regulations. We appreciate the attentiveness FNS has shown to State Agencies, sponsoring organizations, and providers in acknowledging the difficulties some may have in implementation of the new meal patterns.

To counter the difficulties anyone may have, technical assistance must be offered during the first year of meal pattern implementation instead of punitive action. Meals cannot be disallowed as long as providers are acting in good faith. However, as currently required, fiscal action will be taken if a meal is missing one or more required food components.

Technical assistance is also urged during the transition period for recordkeeping. State Agencies are reminded not to increase the burden of recordkeeping for providers to the fullest extent possible.

Ultimately, we hope to work together during this transition to serve as many children in our program the most nutritious meals possible.

Why It Matters
As program operators, our primary goal has always been the health of our nation’s children. The passage of the revised meal patterns for the CACFP arm providers with the very best nutrition science and consequently, the best for the children we serve. Change can be difficult, but with the opportunity to correct human error as we transition, lighten the burdensome trend of increased paperwork, and provide technical assistance where needed, we will become a stronger program and community.

CACFP10-2017 April 6, 2017

Taking Food Components Offsite in the At-Risk Afterschool Component of the CACFP

Effective Date: Currently in effect Full Text

Generally, meals are not allowed offsite in the CACFP because of the requirement for congregate feeding. Field trips are allowable exceptions with proper notification to the provider’s State Agency. However, the At-Risk Afterschool component is more similar to the Summer Food Service Program (SFSP) and the National School Lunch Program (NSLP). Because of program design, children are allowed to take one vegetable, fruit, or grain item offsite to eat at a later date in the At-Risk Afterschool program. The item must be the child’s or an item left on a share table. Additionally, please remember to ensure compliance with local and State health and safety codes. If your site is deemed out of compliance, it is not an appealable decision.

Why It Matters
Flexibility and choice are not always granted to food insecure children. By allowing children to take an item off-site to eat at a later date if they so choose, we are providing the best atmosphere for the most nutrition to be consumed by the child as well as mitigating food waste. This is an important tool in combatting food insecurity and a welcome addition to the Afterschool component of the CACFP. 

CACFP09-2017 March, 23, 2017

Vegetable and Fruit Requirements in the CACFP; Q&As

Effective Date: October 1, 2017 Full Text

The updated meal pattern requirements regarding fruits and vegetables are outlined below. Keep in mind that while these new rules may be difficult at first, they are based on the most recent nutrition science and by making this transition, we are providing the very best for the children in our care.

Infant Meal Patterns

Vegetables and Fruit

  • Infants that are between 6 and 11 months (and developmentally ready) must be served a fruit or vegetable at all meals, including snack.
  • Adding a variety of nutritious foods before the age of two has shown to greatly impact nutrition choices later in the child’s life.


  • Juice is not a reimbursable meal component for infants of any age.

Child and Adult Meal Patterns

Separate Fruit and Vegetable Components

  • Both vegetables and fruits must be served at lunch and supper.
  • You may serve two vegetables at lunch and supper instead of a fruit and vegetable. The second vegetable must be served at the same serving size as the fruit component at minimum.
  • If two vegetables are served, they cannot be the same food item, but may be from the same subgroup (i.e. dark greens, beans and peas, etc.).
  • You cannot serve two fruit components in place of the vegetable component.
  • Vegetables and fruits are a combined component at breakfast. You may continue to serve vegetables, fruit, or a combination at breakfast.
  • You may now serve a fruit and a vegetable as the two required components at snack.


  • Juice may only be used to meet a dietary requirement once per day.

Please remember to check out the Q&A at the end of the memo for helpful tips and clarifications.

Why It Matters
Feeding infants and small children is no easy feat. While the changing dietary guidelines may seem challenging at first, establishing healthy food habits at any early age can completely change the food patterns of children as they age. We have a responsibility to provide the healthiest options we can, and these guidelines help make that goal a reality. 

CACFP08-2017 March 10, 2017

Questions and Answers on the Updated Meal Pattern Requirements for the CACFP

Effective Date: October 1, 2017 Full Text

The USDA FNS compiled a memo addressing the numerous questions submitted regarding the changes in the meal patterns for the CACFP. Many Q&A’s can be found in memos regarding individual components of the updated meal patterns, but this particular memo includes numerous components from the infant meal pattern changes to milk requirements to meat-alternate substitutions and more.

The primary changes are outlined below as refreshers:

Infant Meal Patterns


CACFP General Meal Patterns


Why It Matters
The updated meal patterns were crafted with the most recent nutritional science in mind. While the changes may prove a little cumbersome at first, sponsors are encouraged to assist their providers with the transition by utilizing the memos provided, especially the Q&As. Ultimately, these new meal patterns will create healthier children. 

CACFP06-2017 January 17, 2017

Feeding Infants and Meal Pattern Requirements in the CACFP; Q&As

Effective Date: October 1, 2017 (with earlier implementation encouraged) Full text

Infant feeding patterns have seen significant changes in the last several decades. The revised meal pattern requirements that go into effect this Fall acknowledge the most recent and relevant nutrition science as well as the recommendations of the American Academy of Pediatrics (AAP). This memo explains the new policies concerning creditable infant formula, breastfeeding (both expressed and on-site), and complimentary (solid) food introduction. Please be reminded that infant feeding is not required to be on an established schedule. Additionally, any infant in the care of a center or home operating the CACFP are considered enrolled and subject to this revised meal patterns.

Creditable Infant Formula

  • All center or home formula must include iron-fortification, which is defined as containing “1 or more milligram of iron in a quantity of product that supplies 100 kilocalories when prepared in accordance with label directions for infant consumption.”

  • No list will exist for approved formulas. Instead, use this criteria:

    • Ensure the formula is not FDA-exempt.
    • Look for “Infant Formula with Iron” on the label. It must be included.
    • Use the Nutrition Facts label to verify the formula has 1 or more milligrams of iron.
    • Infant formulas not regulated by the FDA are not reimbursable.
    • Exempt infant formulas accompanied by a medical statement signed by a licensed physician or a State recognized medical authority are allowed for disabled infants.

Parent or Guardian provided Formula or Breastmilk

  • A parent or guardian may decline the infant formula provided at the center or home.

  • Creditable infant formula or expressed breastmilk provided by the parent or guardian is reimbursable.

  • Breastfeeding an infant on-site is also reimbursable.

    • State Agencies can make breastfeeding on-site reimbursable before the full implementation date of the revised meal patterns.
    • No documentation is required for an amount a mother breastfeeds her infant on-site.
    • Once the infant begins consuming solid foods, the center or home must provide the necessary components (outlined below) for the meal to be reimbursable.

Expressed Breastmilk Storage

  • Expressed breastmilk may be stored for up to 72 hours in a refrigerator at 40F (4.4C). This has changed from the previous 48 hour standard.

Solid Foods (Complementary Foods)

  • The revised meal patterns have two infant age groups:

    • Birth through 5 months.
    • 6 months to 11 months.
    • Introduction of solid foods have been given increased flexibility and should be given around 6 months, but ideally at 6 to 8 months.
    • Around 7 to 8 months, infants should be consuming solid foods from all major food categories.
    • As a best practice, centers and homes should obtain in writing from a parent or guardian when an infant is developmentally ready to be introduced to solid foods.
    • The following guidelines should be observed when speaking with parents about solid food introduction:
      • The infant has good head control in a high chair.
      • The infant opens his or her mouth when food is within sight or when others are fed. Other signs may be observed such as reaching for food and enthusiasm during mealtimes.
      • The infant can move food from a spoon to his or her throat.
      • The infant has doubled his or her weight and weighs 13 pounds or more.

Solid Food Components for Infants – Revisions

Vegetables and Fruits

  • Infants are already required at breakfast, lunch, and supper meals for those developmentally ready (around 6 months).

  • Additionally, fruits and vegetables must be served as a snack to developmentally ready infants.

  • Juice is no longer creditable for infants.


  • Ready-to-eat cereals may be served as a snack to developmentally ready infants.

  • Align with cereal requirements for children and adults meaning no more than 6 grams of sugar per dry ounce.

Meat and Meat Alternatives

  • Yogurt is reimbursable for older infants as a meat alternative.

    • Must contain no more than 23 grams of sugar per 6 ounces.
    • Cheese food or cheese spread is no longer reimbursable as meat alternatives.
    • Whole eggs (not just egg yolks) are reimbursable as a meat alternative.

DHA Enriched Infant Foods

  • Reimbursable in single-component infant foods as long as they meet all other crediting requirements.

A summary of implementation dates can be found below:


Please be sure to read the extensive Question & Answers section provided in the full-text memo for further clarification of infant feeding in the revised meal patterns.

Why It Matters
Infant feeding is both complex and some of the most vital work we do as facilitators of the CACFP. The revised meal patterns reflect the very best and most recent nutrition research we are able to provide for the youngest and most vulnerable in our care. Many of these regulations are reimbursable before the implementation date. We encourage you to adopt them as soon as you are able for the smoothest transition, to correct any errors you may find along the way, and to continue to provide the very best start to a lifetime of healthy eating habits. 

CACFP05-2017 December 9, 2016

Offer Versus Serve and Family Style Meals in the Child and Adult Care Food Program; Q&As

Effective Date: October 1, 2017 (with earlier implementation encouraged) Full Text

One component of the revised meal patterns are the extensions of Offer Versus Serve (OVS) into the adult day care and At-Risk Afterschool settings of the CACFP and Family Style Meals in the entire CACFP. The Food and Nutrition Service (FNS) issued this memo to clarify the differences between OVS and Family Style as well as provided an extensive Q&A at the end to expand on practical utilization of these two options to reduce food waste and increase program efficiency.

Offer Versus Serve


  • It is an optional component of the new meal patterns.
  • Must notify your State Agency of implementation.
  • Available only at adult day care and At-Risk Afterschool settings.
    • Does not apply for younger children because they are still forming their palate and need exposure to new foods.
    • Applies only to breakfast, lunch, and supper. Not snack.
    • May offer more than the minimum choices.
    • If you offer more than one food item for a food component, appropriate instructions or signs must be made available to assist the child or adult in choosing a reimbursable meal.
    • Ultimately will result in cost savings through reduced food waste.

Terms to Know

  • Food component – include grains, vegetables, fruits, meat/meat alternates, and milk. Must include all these food components in at least minimum amounts to qualify as a reimbursable meal.
  • Food item – a specific food within the food component.
  • Combination food – contains more than one food item from different food components that cannot be separated.

CACFP Requirements

OVS at Breakfast

  • A typical breakfast must include three food components: milk, fruits and vegetables (combined component at breakfast), and grains.
  • An OVS breakfast must include at least four food items in at least minimum serving size: milk, fruit and vegetable component, grains, and a meat/meat alternate component or an additional food item from the fruit and vegetable or grain components.
  • All food items must be different from one another (i.e. cannot serve two types of cereal in one meal).
  • Must take three out of the four food items offered.
  • If two food items make up a single component, both items must be taken to be a reimbursable component of the meal.

OVS at Lunch or Supper

  • At least one food item from each of the five food components in the required minimum serving size must be offered.
  • Remember, milk is optional for those in an adult day care setting during lunch or supper.
  • All food items must be different from one another (i.e. cannot offer both applesauce and apples)
  • Must take three food components rather than three items.
  • Those three food components are up to the child or adult.

Family Style Meals


  • Optional but available in all settings of the CACFP.
  • Consists of a shared platter of food that is passed around among participants in the program.
  • Flexibility in portions that are served.
  • Encourages a pleasant eating environment, promotes mealtime learning, and educational activities centered around food.
  • Even if the entire meal cannot be served family style, one or two components could be beneficial.


  • A minimum, sufficient amount of food must be made available.
  • Children and Adults must serve themselves with the exception of fluids.
  • May not claim second meals for reimbursements.

Key Differences in OVS and Family Style

  • Family style are self-serve and OVS are pre-portioned by provider.
  • Children and adults must be offered a minimum required serving size of each required meal component in both, in family style there is not a minimum requirement to receive reimbursement.
  • Family style meal service can be utilized in all settings within the CACFP and OVS may only be used in adult day care and At-Risk Afterschool settings.

Why It Matters
The new meal patterns offer us an opportunity to improve our programs through increased flexibility, efficiency, and nutritional effectiveness. Armed with updated nutritional knowledge and standards, the expansion of Offer Versus Serve and Family Style Meals into our CACFP programs can only strengthen our commitment to those we serve.

FD-104 December 2, 2016

Value of USDA Donated Foods for Audits (Revised)

Effective Date: Currently implemented Full text

Auditing procedures can prove tricky for many program operators in child nutrition programs. This memo sought to clarify how the value of USDA Donated Food Commodities were calculated in determining the need for an audit as well as where a program fits in the various child nutrition programs. The recipient of USDA donated foods would then be evaluated based on programmatic compliance under that specific program by auditors. Currently, “any agency of State, local, or Tribal governments and nonprofit organizations that expend $750,000 or more in Federal awards in a given school or fiscal year must obtain an audit for that year.”

To fully determine your yearly expenditures, USDA Donated Foods must be included. To determine their value, follow these two steps:

  1. Determine their quantity.

    1. CSFP, TEFAP, or FDPIR distributing or recipient agencies must include all USDA donated foods distributed or used in a fiscal year as expended.

    2. NSLP, CACFP, or SFSP (or a charitable institution) recipient agencies must include all USDA donated foods receive in a fiscal year as expended.

  1. Assign value.

    1. Fair-market value (FMV) of USDA donated foods at the time of their receipt; the FMV must exclude non-food items.

    2. 1 of 3 donated food valuation methods [included in 7 CFR 250.58(e)]

      1. Cost-per-pound posted annually by USDA. Found here:

      2. Most recently published cost-per-pound price in the USDA donated foods catalog. Found in the Web-Based Supply Chain Management (WBSCM).                                                

      3. Rolling average of the USDA prices (avg. cost per pound) based on each State distributing agency's USDA donated food sales orders in WBSCM.

Remember, once you choose a method for attributing value to your USDA Donated Foods, you must remain consistent throughout the fiscal year.

Why It Matters 
Keeping proper records, including financial expenditures, are a vital part of staying within compliance and promoting program integrity as a program operator in all child nutrition programs. Our children deserve the highest standard of nutrition available, and by utilizing these auditing procedures, we can help secure the healthiest future for those we serve.

CACFP04-2017 December 1, 2016

Area Eligibility in Child Nutrition Programs

Effective Date: Currently implemented Full Text 

The Food and Nutrition Service (FNS) released a new memo clarifying the increased streamlining of the Community Eligibility Provision (CEP) for the Child and Adult Care Food Program (CACFP), the At-Risk component of the CACFP, the Summer Food Service Program (SFSP), and the Seamless Summer Option (SSO) of the National School Lunch Program (NSLP). The new streamlining has removed the requirement that FNS Regional Offices approve weighted average calculations. Instead, an average of up to three Census Block Groups (CBGs) may be used. A reminder of current procedures for determining CEP are summarized below as well as the new procedure for utilizing CBGs.

Types of Data

  • The two types of eligibility are generally school data and census data.
  • The CEP provides an alternative method for determining eligibility in schools that have a high percentage of low-income children that can receive free meals through the NSLP.
  • Eligibility with CEP will stay effective for five years except in the case of CACFP At-Risk Afterschool meals where eligibility must be based on school data, additional paperwork showing census as well as school data must be provided.

School data

  • May be used to establish area eligibility in CACFP, SFSP, and SSO (excluding camps).
  • 50% of the student body must be eligible for free or reduced meals.
  • For the CACFP: State Agencies must coordinate with the State’s NSLP administering agency to obtain the data from a designated month (typically October) by February 15th.
  • SFSP does not require a specific month, but FNS recommends utilizing the CACFP data for the designated month.

Community Eligibility Provision

  • An individual’s school must use the identified student percentage (ISP) multiplied by a factor of 1.6. If the resulting percentage is at least 50, meal sites within the school’s attendance area are eligible.
  • Each school must utilize their own data to determine if they are eligible. If they are part of a group or districting claiming with a shared ISP, their ISP must be at least 31.25 (which equates to the 50%).
  • Other data collection information by the school may not be used to determine eligibility.
  • More information:

Census Data

  • CACFP day care homes and SFSP and SSO sites must be the most recent census data provided by the American Community Survey (ACS) annually. ACS provides estimates on annual household income levels based on sampling.
  • Sponsoring organizations in the CACFP may either use ACS census data or school data to determine area eligibility.
  • Day care homes in Tier II reimbursement may utilize annual census data to reconfirm or change their Tier, if appropriate. Once reclassified to Tier I, the change is good for 5 years. No retroactive reimbursement will be available.

Replacement of FNS Regional Office Approval with CBGs

  • CACFP day care homes and SFSP and SSO sites located in a Census Block Group (CBG) or Census Tract with 50% or more of children qualifying for the free or reduced price school meals are considered area eligible for five years. They can qualify under CACFP or SFSP.
  • If a site is adjacent to a CBG, a weighted average may be utilized with State agency approval for up to three adjacent CBGs. How it works:
    • 40% of children must be eligible for free or reduced price meals in all CBGs averaged.
    • The average of the CBG with the site as well as up to two adjacent CBGs must equal at least 50% qualifying for free or reduced price meals.
    • Census Tracts may not be combined.
    • Calculations must use the same age groups (i.e., 0-12 or 0-18 year olds) across CBGs.

Note on Other Methods to Determine SFSP Eligibility

  • May use other approved sources to determine 50% area eligibility such as:
    • Departments of Welfare
    • Zoning Commissions
    • USDA’s Rural Development Housing Authorities
    • Housing and Urban Development (HUD) Housing Authorities
    • Local Housing Authorities

Note on sites serving to children of migrant workers

  • Sponsors must submit information obtained from a “migrant organization that certifies that the site serves the children of migrant workers.”
  • Even if non-migrant children are served, the sponsor must certify that the predominant children served are from migrant working families.
  • Must be annually re-determined.
  • More information can be found here:

Note on SFSP or SSO sites serving American Indian or Alaska Native Children

  • Area eligibility may also be determined by “submitting documentation from a Tribal authority which certifies that the proposed site is located on a Tribal reservation, on trust land, or in an Alaska Native village where 50 percent or more of the children in the defined area are eligible for free or reduced price meals.”

Accessing the data

Why It Matters
The community eligibility provision (CEP) is a powerful tool we can utilize to serve as many children as possible. With increased streamlining, our abilities to effectively administer the program, increase participation, and maintain program integrity are enhanced. The summer food gap can only be closed by our combined efforts to utilize all available tools to reach our children in need. By arming ourselves with increased knowledge on data collection and procedures, we can accurately and effectively implement these programs, assist our fellow sponsors, and watch our numbers of children served grow across all programs.

CACFP03-2017 October 19, 2016

Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services

Effective Date: Currently in effect

Full Text

Procurement of goods and services can be tricky. The Food and Nutrition Service (FNS) have released a new memo with two general reminders outlining the types of procurement program operators are able to use as well as how to utilize each group in compliance with Federal regulations. This is an update on a 2012 publication (SP 35-2012, Procuring Services of Purchasing Cooperatives, Group Purchasing Organizations, Group Buying Organizations, etc.)The two reminders are below. Be sure to read the extensive Q&A for additional guidance.

1. "Costs paid from the nonprofit food service account are necessary, reasonable, allocable, and otherwise allowable per 2 CFR 200.403 and the applicable cost principles in 2 CFR 200, subpart E."

2. "Procurements are conducted in a manner maximizing full and open competition consistent with Federal procurement standards in 2 CFR 200.318-.326 and in applicable Program regulations. "

Why It Matters
As sponsors, we wish to uphold the highest of program integrity and standards for the children we serve. A large part of this effort revolves around our providers attaining proper procurement of goods and services. Ultimately, we must grow our programs with both greater economy and greater access in mind for all the children in need.

CACFP02-2017 October 14, 2016

Grain Requirements in the Child and Adult Care Food Program; Q&As

Effective Date: October 1, 2017 (with additional compliance date of October 1, 2019 for ounce equivalent implementation)

Full Text

The new meal patterns strengthen the nutrition providers can offer by incorporating the most recent dietary and nutritional research available. The updated grain requirements outline information and guidance on what constitutes whole grain-rich foods and grain-based desserts. Additionally, the new breakfast cereal sugar limit is provided.

Whole grain-rich foods are foods that contain 100% whole grains, or that contain the minimum 50% whole grain with the remaining grains being enriched. A checklist is provided in the full memo outlining the methods to ensure an item is whole grain-rich. These include checking the label to ensure whole grain is listed as the first ingredient (or second after water) or calculating by weight. Calculating by weight will only be possible if a manufacturer provides this information, or a recipe is provided and documented.

 A third method including one of two FDA statements may be used to ensure the product is whole grain-rich. These statements are as follows: “Diets rich in whole grain foods and other plant foods and low in total fat, saturated fat, and cholesterol may reduce the risk of heart disease and some cancers.” OR “Diets rich in whole grain foods and other plant foods, and low in saturated fat and cholesterol, may help reduce the risk of heart disease.” Remember, to ensure compliance you must document “whole grain-rich” on your paperwork.

Please remember that no grain-based desserts can be creditable for reimbursement under the new meal patterns. The full-text provide a comprehensive list of foods classified as grain-based dessert. FNS reminds all program operators that you may still serve these grain based desserts on some occasions as an additional food item that is not reimbursable.

Breakfast cereals must contain no more than 6 grams of sugar per dry ounce (21.2 grams of sugar per 100 grams of dry cereal). Sponsors may utilize the WIC approved breakfast cereal list or complete a 3-step calculation if the cereal is not part of the listing. Step one is to find the serving size in grams at the top of the label and the sugars listed in the middle. Step Two is to divide the total sugars by the serving size in grams. Step Three is to look at the number you come up with and if it is equal to or less than 0.212 than the cereal is within the required sugar limit and may be creditable.

Why It Matters
The new meal patterns ensure we are serving those in our facilities with the most up-to-date nutrition while also providing the tools necessary for our centers and homes to implement these provisions as accurately as possible. Gradual implementation will not only make our children healthier but make us strengthen our programs as we work to catch common errors before implementation and ultimately learn what these new meal patterns will look like for our communities and the children we serve.

CACFP01-2017  October 6, 2016

Updated Fiscal Year Reporting Timeline and Reporting Table

Effective Date: October 1, 2016 (current)  

Full Text

Reporting Timeline

Reporting Table

The Food and Nutrition Service (FNS) released a new memo updating both the reporting timeline and table for this fiscal year. The updated documents are linked below and all changes from December 2015 are italicized. The updates are a result of feedback as well as new reporting regulations.

Why It Matters
As program operators, we work together to provide the highest level of nutrition possible for those in our care. Effective, efficient, and accurate paperwork submissions throughout the year are a vital part of ensuring program integrity, growing our programs, and reaching all food insecure children in our communities.

CACFP25-2016 September 9, 2016

Vegetable and Fruit Requirements in the Child and Adult Care Food Program; Q&As

Effective Date: October 1, 2017 (with earlier implementation encouraged)

 Full Text

The Food and Nutrition Service (FNS) has published a new memo to clarify the new meal pattern requirements regarding fruits and vegetables for infants as well as children and adults within the CACFP. Infants who are 6 months to 11 months are already given the option of fruits and vegetables at mealtimes, along with formula or breastmilk. The new meal pattern adds an additional fruit or vegetable requirement at snack and disallows juice for infants to encourage healthy eating habits.

To align with updated nutrition science and recommendations, children and adults in the CACFP must now be served a vegetable and a fruit component at both lunch and dinner. Two vegetables may also be served instead of a fruit and vegetable at lunch or dinner in an effort to increase flexibility in menu planning. Keep in mind that two fruits cannot be served at lunch or dinner. Breakfast meals will remain consistent with the School Breakfast Program and combine the fruit and vegetable component.  Additionally, a snack which includes a vegetable and fruit component in the “appropriate minimum serving size” will also be reimbursable. The chart below provides an example of menu planning for lunch and dinner with flexibility in regards to substituting fruit with two different vegetables:

Juice may only be served once a day to meet one component of a fruit or vegetable requirement. Because juice lacks dietary fiber, other forms of fruit intake are preferred (including fresh, frozen, canned, or dried).

Please be sure to check out the Q&As at the end of the memo. They are a great resource for common questions such as how to classify a tomato to how to credit food items not in the Food Buying Guide.

Why It Matters 
Increasing nutrition in those we serve is one of our primary goals as sponsors and providers in the CACFP, Utilizing the most recent and sound science to give the infants and children we serve the very best is made easier with the new meal patterns, and we should take advantage of those as quickly as we can. Implementation in small steps will yield increasingly positive nutritional results for those in our care.

CACFP24-2016 September 7, 2016

Conducting Five-Day Reconciliation in the Child and Adult Care Food Program; Q&As

Effective Date: Currently implemented

 Full Text

The Food and Nutrition Service (FNS) released a new memo to clarify the procedure and purpose in conducting five-day reconciliations in the Child and Adult Care Food Program (CACFP) during monitoring visits. Reconciliations are vital to safeguarding program integrity, but a recent recommendation by the report Reducing Paperwork in the Child and Adult Care Food Program has identified state-by-state variation regarding the overall goal of the process and how to conduct a reconciliation.

To clarify, during a review of a day care home or center, the monitor must “reconcile and ensure consistency of three critical elements - enrollment, attendance, and meal counts - for a five-day period.” The reconciliation process is meant to guard against potential errors in the claiming process that can lead to more serious concerns and potential corrective action while not placing an undue burden on providers to produce multiple sets of paperwork. Additionally, State Agencies utilize five-day reconciliations as part of their monitoring review of sponsoring organizations. Please refer to the Q&As in the full-text memo for a detailed discussion of compliance and procedures for both State Agencies and sponsoring organizations.

Why It Matters 
Serving our children within the CACFP by ensuring program integrity in day care centers and homes is vital to the continual operation of the program. By refreshing our understanding of policy and procedures relating to program operation, we can work together to make the CACFP the best it can be at all levels.

CACFP23-2016 August 31, 2016

Feeding Infants and Meal Pattern Requirements in the Child and Adult Care Food Program; Q&As

Effective Date: October 1, 2017 (with earlier implementation encouraged)

 Full Text

The Food and Nutrition Service (FNS) has published this new memo to clarify the new meal pattern requirements for day care centers and homes who feed infants. Because infants do not eat on a preset schedule as the typical older child, meals cannot be disallowed based on meal times. FNS provides a guide within the memo on this issue. Below is a summary of the current meal pattern rules and the new requirements for infants.

It is important to note that iron-fortified formula must still be provided but there will not be a USDA provided list. To ensure the formula is reimbursable, check on the FDA Exempt Formula List first, then look for the phrase “Infant Formula with Iron,” and lastly, use the nutrition label to make sure the level of iron is at 1mg of iron or more per 100 calories. If a mother chooses to send expressed breastmilk with the infant, the acceptable refrigeration time has changed from 48 hours to 72 hours. The Q&A at the end of the memo answers many questions providers may have about the changes.

Why It Matters
Infant care is some of the most complex work we may do in our day care centers and homes. With these new meal pattern guidelines, we are now better able to care for our littlest children with the most up-to-date nutrition research available. By implementing these changes gradually, we can not only be best prepared for the official change in ruling come next year, but we can best serve those in our care now. 

CACFP22-2016 August 10, 2016 

Taking Food Components Offsite in the At-Risk Afterschool Component of the Child and Adult Care Food Program

Effective Date: Date of Issuance (August 10, 2016)

 Full Text

The Food and Nutrition Service (FNS) realizes that while food is designed to be
eaten onsite in the CACFP, children may benefit from being allowed to take one vegetable,
fruit, or grain item offsite to eat at some other time. Similar to the rules governing the Summer Food Service Program (SFSP) and the National School Lunch Program (NSLP), the AtRisk Afterschool component of the CACFP does not need to seek prior approval by State agencies but must stay in compliance with local and State health and safety codes.

Why It Matters
Our goal is to reach every child in need with nutritious food. This provision in the At-Risk Afterschool portion of the CACFP strengthens our capabilities and provides a fantastic opportunity to meet the need of a particularly vulnerable population.

CACFP21-2016 August 8, 2016 

Crediting Tofu and Soy Yogurt Products in the School Meal Programs and the CACFP

Effective Date: October 1, 2017 (with earlier implementation strongly encouraged)

 Full Text

Beginning October 1, 2017, child care centers and homes will be able to credit commercially prepared tofu and soy yogurt products as a meat/meat alternate component. 2.2 ounces (1/4 cup) of commercially prepared tofu, containing at least 5 grams of protein, is creditable as 1.0 ounce equivalent meat alternate. Soy yogurt products measure ½ cup (4.0 fluid ounces) as creditable to 1.0 ounce equivalent meat alternate. It is important to differentiate types of tofu for crediting. Firm, or extra firm tofu, found in many dishes from stirfrys to omelets, count. Soft or silken tofu varieties, commonly added to smoothies and baked desserts, will not count.

Why It Matters
With the inclusion of meat alternatives to the CACFP, we are able to diversify our menus, increasingly offer culturally appropriate and traditional meals, and ultimately bolster the nutritional offerings for countless children we serve.

CACFP20-2016 August 5, 2016

Water Availability in the Child and Adult Care Food Program

Effective Date: October 1, 2017 (with earlier implementation encouraged).

 Full Text

FNS passed the final rule Child and Adult Care Food Program: Meal Pattern Revisions Related to the Healthy, Hunger-Free Kids Act to update the meal pattern regarding water availability in daycare centers and homes. Previously, centers and homes must have water available to children throughout the day. This rule expanded that provision to include offering water to children throughout the day. Child care centers and homes are not required to provide a water selfservice station, but must ask the children throughout the day if they would like some water. For especially young children that CACFP often serves, visual cues may be necessary. Remember, water must be made available at mealtimes but it is not reimbursable and should not be used in place of fluid milk.

Why It Matters
Adequate water intake is important to the health of all children. This rule makes hydration easier to achieve and ultimately makes our children healthier. It also has the possibility of cutting down on sugared beverages if water is offered after physical activities, hot summer days, and cold winter days when the air is drier.

CACFP18-2016 July 20, 2016

Resources for Making Potable Water Available in Schools and Child Care Facilities

Effective date: October 1, 2017 (with earlier implementation encouraged).

 Full Text

Safe drinking water for children in care is of utmost importance. The vast majority of institutions incur zero to little cost to provide potable water. For those that need to have their water tested, contact your local health department agency or public water provider to locate a certified lab to test for contaminants. In that case, providers may have “allowable use of nonprofit food service account funds if the costs are determined to be reasonable, necessary, and allowable to the Federal meal programs.” Remember, nonprofit food service account funds may not be used to improve plumbing because it would add permanent value to the building and that cost should be paid for by the school district or child care facility’s general fund. Filtering systems may be allowed but primarily on a case by case basis.

Additional information
Attached to this memo are links to resources Program operators can access to learn more about safe drinking water and testing for lead and other contaminants, and to obtain additional technical assistance.

Why It Matters
Adequate water intake is important to the health of all children. This rule makes hydration easier to provide for child care centers and homes and outlines the financial steps to secure safe drinking water in all facilities.

CACFP17-2016 July 14, 2016

Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the CACFP, Q&As

Effective Date: October 1, 2017, with earlier implementation strongly encouraged.

 Full Text

The new requirements for fluid milk and fluid milk substitutions reflect the Dietary Guidelines for Americans and the most relevant nutrition science available. These requirements acknowledge the various dietary needs amongst children as they move from infancy to toddlerhood to childhood as well as special dietary accommodations that require flexible, nondairy options. To ensure compliance, documentation of fat content and flavored/unflavored designations must be made on their menu. The guidelines are listed below:

Fluid Milk

  • One year old children:
    Unflavored whole milk only. Breastmilk is an allowable milk substitute at any age.
  • Two years old and older children and adults:
    Low-fat or fat-free milk, low-fat or fat-free lactose reduced milk, low-fat or fat-free lactose free milk, low-fat or fat-free buttermilk, or low-fat and fat-free acidified milk. 
  • All milk must be pasteurized fluid milk that meets State and local standards.

Flavored Milk

  • Children 1 through 5 years old cannot claim any flavored milk or flavored non-dairy beverages.
  • Children 6 years and older and adults Flavored milk and flavored non-dairy beverages may be served but they must be fat-free.

Fluid milk substitutes

  • Must be nutritionally equivalent to fluid milk.
  • Parent, guardian, adult participant, or person on behalf of an adult participant must provide a written request for a non-dairy substitute.
  • No medical statement required for equivalent non-dairy substitute.
  • A medical statement for a disability is required for a non-equivalent non-dairy substitute that does not meet the nutritional standards of fluid milk. Children 1 to 5 must be unflavored dairy or non-dairy substitute.


  • Adults only 6 oz. by weight or ¾ cup by volume may meet the fluid milk requirement once per day.

Why It Matters
Milk and non-dairy milk substitutes are a vital and common food component that assist in ensuring children and adults are gaining the most nutrition they can in any given day. The updated guidelines ensure we are serving those in our facilities with the most up-to-date nutrition while also providing the tools necessary for our centers and homes to implement these provisions as accurately as possible.

CACFP15-2016 June 30, 2016

Optional Best Practices to Further Improve Nutrition in the Child and Adult Care Food Program Meal Pattern

Effective Date: Optional

 Full Text

The best practices outlined below are optional and while highly encouraged,many of the recommendations are from the Dietary Guidelines and the National Academy of Medicine and not the Food and Nutrition Services (FNS). Noncompliance with these practices will not result in meal dis-allowances or a serious deficiency finding. FNS applauds any and all centers and homes that go above and beyond in implementing these best practices.


A list of resources are provided at the end of the policy to assist daycare center and homes in implementing these best practices into their everyday meal service. FNS is also in the process of creating additional resources to aid in implementation of these practices.

Why It Matters
Providing access to healthy foods while in our care is a huge reason we are all
a part of the CACFP. The suggestions outlined in this policy memo may not be mandatory, but small, incremental steps towards implementation will only make our children healthier. With these best practices, we can learn from one another and increasingly provide the most nutritious foods possible to countless children across the nation every day.

CACFP14-2016 June 24, 2016

Early Implementation of the Updated CACFP Meal Pattern Requirements and the NSLP and SBP Infant and Preschool Meal Patterns

Effective Date: October 1, 2017 for full implementation  

 Full Text

The new meal patterns strengthen the nutrition providers can offer by addressing the dietary needs of all individuals as well as serving increasingly diverse and culturally appropriate foods. Additionally, the second biggest benefit after an increase in nutrition is the opportunity to slowly phase in the new meal patterns by starting before the implementation date. This memo outlines not only the allowances that will be under this new meal pattern that were not allowed before, but FNS has also provided guidance for early implementation below. 

Option 1: Specific Allowances

Incremental change on individual meal pattern changes, including:

  • Reimbursing infant meals when the mother breastfeeds onsite;
  • Allowing yogurt, whole eggs, and ready-to-eat cereals under the infant meal pattern;
  • Serving meat and meat alternates in place of the entire grains component at breakfast no more than three times per week;
  • Counting tofu and soy yogurts as a meat alternate; and
  • Allowing yogurt to be used to fulfill the fluid milk requirement for adults once per day

Keep in mind, the following allowances in the updated meal patterns cannot be implemented singly without implementing the entire meal patterns (see Option 2):

  • Allowing juice to fulfill the entire vegetable component or fruit component;
  • Permitting parents and guardians to provide one meal component for participants with nondisability medical or special dietary needs; and Extending offer versus serve to atrisk afterschool programs.

Option 2: Entire Meal Patterns

State Agencies may approve a provider to implement an entire meal pattern prior to the effective date.

Implementation Steps

A State Agency must inform their Regional Office in writing prior to implementation of
Option 1 or 2. The Food and Nutrition Service (FNS) are currently creating training materials for State Agencies and will be providing a training in Fall 2016. FNS reminds State Agencies that they cannot disallow meals that are not compliant until October 1, 2017. State Agencies should also avoid creating additional administrative paperwork burdens for Child Nutrition Program (CNP) operators.

Why It Matters
The new meal patterns greatly enhance child nutrition by providing the tools to
attend to dietary needs, serve culturally appropriate and diverse foods, and generally increase the nutritional knowledge of all CNP operators. By gradually implementing the meal patterns, CNP operators can correct any errors during implementation, ask questions along the way, and figure out how implementation will look for their institution.

CACFP13-2016 June 22, 2016

The Use of Share Tables in Child Nutrition Programs

Effective Date: Currently in effect

 Full Text

The idea of share tables to reduce food waste and improve nutrition is being
extended to the At-risk Afterschool component of the CACFP. “Share tables” are tables or stations where children can return unwanted food and beverage items in compliance with local and State health codes. These items are then available for other children. It is important to note for Child Nutrition Program (CNP) operators to claim the reimbursable meal at the point of service, even if they put one or more of their meal components onto the share table. FNS stresses the need to sit down with your local and state health agencies to ensure food safety compliance. 

Why It Matters
Share tables are tools to assist us in providing the highest level of nutrition to some of our most vulnerable children in the atrisk afterschool component of the CACFP. By working together with our local and State Agencies, we can minimize food waste and maximize nutrition.

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