Record keeping reminders
Record keeping reminders: strive for integrity at your center
The following are several reminders as you continue to strive for Program Integrity in the CACFP in your organization.
Change in responsible individual or principal requires new signature on file
Are you a new center director or responsible individual? If so, our office must have on file a current “Certificate of Authority” with the signature of the person(s) who will be signing claims. Claims submitted by anyone other than the person whose signature is on file will not be paid. Remember that responsible individuals or principals may be personally liable for overclaims assessed against centers or sponsoring organizations.
Also, remember that we cannot accept FAXed signatures on the certificate of authority. We must have an original signature on file.
Contact our office any time during the year when you have a change in responsible individual or principal.
Need Help? Call Us!
Does your center have a new director? A new record keeper? A new cook? If so, and this person needs training on the Child and Adult Care Food Program, please contact the Nutrition Services office. Our staff conducts monthly training sessions alternating between the Lincoln area and Omaha for new centers and new staff. Training is held on-site for centers in western Nebraska.
Call Nutrition Services toll free at 800-731-2233 (or 471-2488 in Lincoln) to register for training sessions. Pre-registration is required.
IEFs Should Be Determined Within 10 Working Days
To claim meals for participants eligible in the Free and Reduced categories, it is important that Income Eligibility Forms (IEFs) be determined by center officials in a timely manner.
Nutrition Services is recommending that IEFs be determined, signed and dated by center officials within 10 working days after receiving a completed IEF from a household and no later than the last day of the month when the IEF is received. This will help assure that meals are claimed in the correct eligibility category as soon as possible.
REMINDER: Title XIX or Title XX status does NOT automatically qualify a participant in the Free category. An IEF MUST be on file and completed correctly before meals served to a participant may be claimed in either the Free or Reduced categories.
Point of Service Meal Count Required
A “point of service” meal count is required in the CACFP, according to a USDA instruction. USDA states “Daily records of the reimbursable meals served to participants, taken at the point of service, must be maintained for each meal service. Attendance data, by itself, is not enough.”
More centers are converting to commercial software packages or developing their own spreadsheets to track meals served to participants. This is acceptable with prior approval from Nutrition Services. Remember that worksheets or rosters you are using to mark the point of service meal count sheets must be kept on file as part of your CACFP records. These worksheets serve as a back-up and as documentation that point of service meal counts were made. The Nutrition Services staff and auditors may compare these records with your computer printouts during reviews or audits.
Sponsors of Centers Must Conduct and Document Site Reviews
Sponsors of multiple centers are required to monitor food service operations at each site under their administration. Regular sites must be reviewed at least three times annually. One review must be done during the first four weeks of CACFP operations. Other reviews cannot be more than six months apart.
These reviews must be documented in writing in your files. A sample review form is available from Nutrition Services for sponsors of centers. You may use this form or something similar. A written narrative report is also acceptable.
Medical Statements Must Be on File
If you plan to claim meals that do not meet meal pattern requirements for any participant who may not have certain foods for medical reasons, you must have on file a written statement from a “recognized medical authority” that the participant may not have the food(s) and what food(s) may be substituted.
If such a written statement is not on file, you may not claim meals that do not meet the CACFP meal pattern requirement.
Centers Must Document Nonprofit Food Service Operation
Each center participating in the Child and Adult Care Food Program must be able to document that it operates a nonprofit food service operation. In other words, your food program expenses must be equal to or greater than the amount of CACFP reimbursement that you receive.
Most centers easily document this nonprofit food service operation through grocery receipts and invoices alone. However, this is more difficult for those centers that have a high percentage of participants for whom meals are claimed in the Free category.
Centers may use salaries for any employees assigned to CACFP activities to document a nonprofit food service operation. Generally, 100 per cent of the cook’s salary may be allocated to CACFP expenses. If any employee spends only a portion of their day on CACFP activities (Example: 1 hour for record keeping; 1/2 hour for serving and cleaning up; etc.), a portion of these salaries may be allocated to the CACFP but ONLY if those personnel document on a daily basis the amount of time spent specifically on CACFP activities. This time log will be reviewed during compliance reviews and audits. Time certification worksheets are available from Nutrition Services.
Occasional expenses such as stoves, freezers, etc., that are for use in the CACFP may be used to document nonprofit food service operation. In rare instances, some centers have had to prorate a portion of rent and utilities (based on square footage of the food preparation and serving area) in order to document a nonprofit food service operation. This requires an indirect cost rate.
Please call Nutrition Services if you have any questions regarding how to document a nonprofit food service operation or what allowable CACFP expenditures may be.
CACFP Records Must Be On Site
During compliance reviews and audits, we have found that many centers are not maintaining records for the CACFP on site, but rather at the director’s or owner’s residence. The agreement that you have signed with the Nebraska Department of Education states, in part,
“. . .that Nebraska Department of Education Officials and USDA Officials may verify information and shall have unlimited access to applicable records; that all such records shall be securely kept and maintained on site. . .”
As contractors with the Nebraska Department of Education, this statement also means that these records are to be made available on site for auditors.
All Meal Components Should Be Served At Approximately the Same Time
During meal observations at several child care centers, we have noted that quite often, all components of a meal are not served at the same time. Some caregivers are in the practice of withholding milk until a child has eaten the majority of his or her meal or that fruit is saved and presented as dessert.
This practice presents a concept that some foods are more “special” than others. When only three components are served at lunch, a child may either fill up on these three and then be too full by the time the milk and the fruit are served. Or the child may not like one or more of the foods served initially, and play with it or an undue pressure to eat these foods may be perceived by the child. When all components are served at the same time, the child has the ability to decide what and how much he or she wants to eat.
Nutrition Services Staff Make Unannounced Visits at Centers
From time to time, Nutrition Services receives telephone calls from concerned parents, employees or licensing officials regarding questionable practices about the CACFP in some centers. Also, a significant increase in a center’s claim from one month to the next may be a cause for follow-up by Nutrition Services.
When these situations arise, a member of the Nutrition Services staff will very likely make an unannounced visit to the center in question to investigate the situation reported. This could be for the purpose of documenting the number of participants in attendance for a meal service, record keeping, or quantities of food being prepared, as examples. This is another reason why centers should assure that all CACFP records are available on site and made available to Nutrition Services staff during the hours of the center’s operation. Meals cannot be claimed if daily records are not completed for each meal service or if meals are served outside the approved meal times.
CACFP regulations require that all institutions participating in the program document training in which staff participate. This may be documented by certificates of attendance or by keeping a master training log which shows the date and topic of training, the location, the presenter and the number of hours of training awarded.
There are additional requirements for training required by the Nebraska Department of Education. These requirements are specified in Part II of each institution’s agreement with Nutrition Services (NS-407-G)
New Institutions (New Agreement Numbers)
Institutions that are new to the CACFP must complete formal NDE training on the CACFP prior to the approval of the institution’s application. This training must have occurred within
the previous 6 calendar months prior to the submission of the application to NDE. This training shall consist of training on CACFP record keeping and meal requirements and production records. At a minimum, at least one of the institution’s CACFP responsible individuals or principals must complete this training prior to CACFP approval. It is recommended that the CACFP contact person and the person(s) responsible for the food service operation also complete this training. New institutions may not begin claiming prior to the date when training was completed. At least one of the responsible individuals or principals from institutions providing care for infants under one year of age must complete infant training provided by NDE. Training can be completed in a one-day workshop which is provided by NDE.
New Responsible Individuals/Principals/Contact Persons
At least one of two responsible individuals or principals must have completed the NDE training. When an institution has a change in the responsible individual or principal and neither of the responsible individuals or principals has attended training, at least one of the responsible individuals or principals must complete formal NDE training on the CACFP within 4 months of becoming responsible individual or principal. This training shall consist of training on CACFP record keeping and meal requirements and production records. If the institution provides care for infants under one year of age, the new responsible individual or principal must complete infant training provided by NDE.
Currently Participating Institutions
Currently participating institutions are to receive ongoing training in CACFP requirements as changes occur in State and Federal policies, rules and regulations. Representatives of the
institution must receive this training at least annually. Failure to complete annual training may result in the delay or denial of an institution’s application to participate in the CACFP.
Institutions which have been found by NDE to have deficiencies in their operation of the CACFP, either through reviews, audits or other means, may be required to complete CACFP formal training as part of a corrective action plan. Failure to comply with corrective action could result in the withholding of the institution’s CACFP reimbursement until training is completed.