For NAP SACC Trainers
Nutrition and Physical Activity Self-Assesment for Child Care (NAP SACC)
NAP SACC Continuing Education Workshops
- Introduction to Childhood Obesity
- Child Nutrition
- Infant & Child Physical Activity
- Personal Health & Wellness
- Working with Families
NAP SACC Continuing Education Workshop Resources
NAP SACC Self-Assessments:
NAP SACC Best Practices
- NAP SACC Nutrition Best Practice Recommendations for Child Care Facilities
- NAP SACC Physical Activity Best Practice Recommendations for Child Care Facilities
NAP SACC Recruitment Tools
NAP SACC Trainer Helps
What is NAP SACC?
Nutrition and Physical Activity Self-Assessment for Child Care (NAP SACC)
What is NAP SACC?
The goal of NAP SACC is to assist child care facilities in improving their nutrition and physical activity environments, including policies and practices, for the prevention of obesity in children ages 0-5. This is done through the use of a child care nutrition and physical activity self-assessment, goal setting, educational tools, and technical support from NAP SACC Trainers, which are local health professionals.
Frequently Asked Question about Feeding Infants on the CACFP
Feeding infants – frequently asked questions
Do you have a question regarding feeding infants on the CACFP? Email us. Answers to your questions will be posted on this page.
Q: What do we do if a parent mixes cereal with infant formula and brings that to the center in a bottle? Can/should we serve this?
If a parent brings their own formula mixed with cereal, the center should request a medical statement in order for that formula to meet meal pattern requirements.
If there is no medical reason for the cereal to be added to the formula, the center could request that the parent bring the formula and cereal separately and then feed the infant the cereal from a spoon.
Q: If the child’s formula is not on the approved list of formulas and it is brought to the center by the parent, is a medical statement needed to claim the child’s meals for reimbursement?
According to page 23 of Feeding Infants “Iron-fortified infant formula is required to meet the meal pattern.” If the parents furnish a formula that is not on the approved list, the parents must also furnish a medical statement for the formula they choose.
Q: A parent has accepted the formula provided by the center. The center provides the formula to the infant for three reimbursable meals. Can the parent provide the formula for non-reimbursed meals at the center? This could occur if the child has five meals at the center.
A: The center needs to provide the formula for meals which will be claimed for reimbursement. The parents would be responsible for providing the formula for the non-reimbursable meals. Centers may choose to provide formula for the non-CACFP meals if they want to.
USDA has issued the following answers to these questions regarding feeding infants on the CACFP
Source: U.S. Department of Agriculture, January 7, 2000
Q: When an infant is transitioning from breast milk to formula, it is common to provide the infant with both foods, to gradually ease the infant into consuming formula in place of breast milk. During this transition period, when an infant is receiving both breast milk and formula, is the meal reimbursable?
A: Yes. From birth through 7 months, any one meal which contains some quantity of breast milk is reimbursable. Similarly, meals containing only infant formula are also reimbursable.
Q: If the mother comes into the day care home or center where her child is in care and breastfeeds her infant, is the meal reimbursable?
A: No. While we support all efforts for mothers to breastfeed their infants, it is our intention that the provider must provide some type of “service” in order to be reimbursed for a meal. The interim rule authorizes meals as reimbursable if the provider bottle feeds an infant breast milk that has been previously expressed by the mother, as it takes effort to prepare the bottle and feed the baby.
Q: Is the meal reimbursable if a provider breastfeeds her own infant?
A: Yes, as long as the infant is otherwise eligible to receive reimbursement (i.e., the provider is income eligible).
More answers from USDA
Source: U.S. Department of Agriculture, April 20, 2000
Q: When an infant receives both breast milk and formula, is the meal eligible for reimbursement?
A: Yes, a meal served to an infant under 12 months of age and under which contains some amount of breast milk (and some amount of formula ) is reimbursable as long as the total number of ounces offered to the infant meets, or exceeds, the minimum amount for the milk component as specified in the CACFP infant meal pattern.
Q: Are meals served to children, 12 months and older, reimbursable if they contain infant formula?
A: Yes, for a period of one month, when a child is weaning from infant formula to whole cow’s milk (i.e., transitioning), meals that contain infant formula may be reimbursable. When a child is weaned from formula (or breast milk) to cow’s milk, it is a common practice to provide the infant with both foods at the same meal service, to gradually ease the infant to accept some of the new food. However, unlike breast milk, infant formula is not an alternative type of milk which can be substituted to meet the fluid milk requirement for the CACFP meal pattern for children over the age of one year. (See FNS Instruction 783-7, rev. 1, Milk Requirement—Child Nutrition Programs.) Thus, for a child 13 months of age and older who is not in this transitional stage, a statement from a recognized medical authority is needed for a meal containing infant formula to be eligible for reimbursement (See FNS Instruction 783-2, rev 2, Meal Substitutions for Medical or Other Special Dietary Reasons).
Q: If a physician prescribes whole cow’s milk as a substitute for breast milk for an infant under 12 months of age, is the meal reimbursable?
A: Yes, a meal or snack containing whole fluid cow’s milk and served to an infant under 12 months of age is eligible for reimbursement if the substitution is authorized, in writing, by a recognized medical authority. Similarly, if a recognized medical authority prescribes a formula such as low-iron formula, which is not currently listed as a formula for CACFP, the meal is eligible for reimbursement.
We have always recognized the unique dietary needs of infants and that decisions concerning diet, during this first year of life, are for the infant’s health care provider and parents or guardians to make together. Therefore, to support the request, a medical statement which explains the food substitution or modification is needed. The statement must be submitted and kept on file by the facility or institution.
Q: A mother would like her 5-month old infant to receive breast milk which she provides and solid foods, which are listed as options in the meal pattern. Because the infant is developmentally ready for solid foods, whose responsibility is it to provide them?
A: If an infant is developmentally ready for one or more solid food items and the parent or guardian requests that the infant be served solid foods, the center or provider is responsible for purchasing and serving them to the infant.
The CACFP infant meal pattern takes into consideration that infants develop at different paces. Some food items such as fruit and cereal are listed as options in the infant meal pattern to account for an infant’s “readiness” to accept these foods (i.e., some infants are developmentally ready for solid foods earlier than others). This occurs in the breakfast and lunch/supper meal service for infants 4-7 months of age, and for the snack meal service for infants 8-11 months of age. A child care center or provider must serve a complete meal to every infant or child enrolled in the meal service. Therefore, if a child is developmentally ready for these solid foods, and the parent or guardian requests that the infant is served solid foods, the components are no longer considered as options and should be served to the infant to provide her with the optimal nutrition she needs to develop and grow.
Q: Is a meal reimbursable if the parent or guardian provides the majority of the meal components for infants older than three months?
In addition to medical or special dietary needs, parents may choose to provide one or several of the meal components under the CACFP infant meal pattern for infants older than three months, as long as this is in compliance with local health codes. Because we recognize that parents or guardians are often most in touch with their child’s individual dietary preferences, we believe the CACFP infant meal pattern can accommodate these preferences. In such a case, the center or provider would still be required to provide at least one of the components in at least the minimum quantities specified in the meal pattern in order for the meal to be reimbursable. Centers and sponsoring organizations also need to ensure that the parent or guardian is truly choosing to provide the preferred component(s), and that the center or provider has not solicited (requested or required) the parent or guardian to provide the components in order to complete the meal and reduce cost to the center or provider.
Q: If a mother comes to the day care home or center to nurse her infant, is the meal reimbursable?
No. Although we strongly support all efforts for mothers to breastfeed their infants, we believe that the caregiver must provide some type of service in order to be reimbursed for a meal. CACFP reimburses child care facilities for the cost of preparing and serving nutritious meals and snacks to infants and children receiving day care. In the case of breastfed infants, CACFP reimburses the facility for the cost of preparing the bottle and feeding the infant. When a parent nurses her own child, the services for which the center or the provider would receive reimbursement are not being performed.
However, the meal would be reimbursable for infants over 3 months of age who are developmentally ready for solid foods, if at least one other component is furnished by the center or provider. For example, if a mother comes to the day care home for lunch meal service to breastfeed her 5 month old infant and the provider supplies a serving of vegetables (listed as options in infant meal pattern for lunch for infants aged 4-7 months), the meal is reimbursable.
Q: If a day care home provider breastfeeds her own infant, is the meal eligible for reimbursement?
Yes, a day care provider who nurses her own infant may claim reimbursement for the meal as long as she is eligible to claim reimbursement for meals and snacks served to her own child. In this case, the meal is reimbursable because the mother (provider) is actively engaged with the child. Thus, unlike a mother who comes into a center or home to breastfeed an infant, the provider is being reimbursed for her services – the time and effort she expends breastfeeding her own infant.
Q: Cottage cheese is a meat alternate in the lunch and supper meal pattern for infants aged 8 through 11 months. How much cottage cheese must be offered to fulfill the meat/meat alternate meal pattern requirement?
Cottage cheese, cheese food, and cheese spread are acceptable meat alternates in the CACFP infant meal pattern. An error in the meal pattern tables in sections 210.10(m)(2)(iii)(C), 210.10a(h)(3), and 226.20(b)(4) incorrectly measures the amount of cheese in tablespoons. The correct amount which may be offered as a meat alternate to infants, aged 8 through 11 months, is 1 to 4 ounces.
Q: Is yogurt an allowable meat alternate in the infant meal pattern?
The Office of Analysis, Nutrition and Evaluation plans to issue a memorandum on the use of yogurt in the CACFP infant meal pattern in the future.
eligible snacks available for at risk youth
Area eligible snacks available for “at risk” youth
A new federal law (Public Law 105-336) authorizes CACFP reimbursement for meal supplements (snacks) provided to children through the age of 18 years in certain after school programs. The following guidelines have been provided by USDA:Center Eligibility:
“At Risk After School Snacks” are available to public or private nonprofit organizations. The center must be licensed to care for school age children.
Centers may participate only as “at risk” centers. “At risk” centers are located within a school site boundary in which 50 per cent or more of the school site enrollment is approved free/reduced. A complete list of eligible school sites is available from Nutrition Services at the Nebraska Department of Education.
To be eligible for reimbursement for “At Risk After School Snacks,” each center must:
Provide children with regularly scheduled activities in an organized, structured and supervised environment; and
Include educational or enrichment activities.
“At Risk After School Snacks” may not be claimed for reimbursement during summer vacation.
Each “At Risk After School Snack” will consist of two of the following four components in the amounts indicated:
Fluid Milk (1 cup)
Juice or Fruit or Vegetable (3/4 cup – juice may not be served when milk is the only other component.)
Meat or Meat Alternate (1 ounce) or Yogurt (1/2 cup – yogurt cannot be served when milk is the only other component.)
Grains/Breads (1 slice bread or an equivalent serving of an acceptable grain/bread)
“At Risk After School Snacks” are reimbursed at the free rate for all school age children.
The “At Risk After School Snack” must operate as a non-pricing program (no separate charge for snacks).
The “At Risk After School Snacks” meal count must be taken at the point of service by counting the number of students receiving a reimbursable snack.
Reimbursement is limited to one “At Risk After School Snack” per child per day.
Reimbursement may be claimed for “At Risk After School Snacks” served to school age children through the age of 18 in eligible after school care programs. Reimbursement may also be claimed for those children who turn age 19 during the school year.
“At Risk After School Snack” may be claimed only for those children for whom attendance is documented. A sign-in sheet or roster may be used to document attendance.
The following records must be maintained:
Daily meal counts (number of “At Risk After School Snacks”).
Documentation for each day of a child’s attendance (roster or sign-in sheet).
Documentation of compliance with meal pattern requirements.
Nebraska sponsors work together
Nebraska sponsors work together
by Jeany Morton
Motivated by tiering and integrity issues as well as ongoing recruitment disputes, the Nebraska CACFP sponsors have spent the past year working together to turn the USDA Management Improvement Guidance into Management Standards.
The Nebraska Department of Education, Nutrition Services, supported this effort by supplying outside facilitators, satellite links and phone links, insights from state agency perspective and a compilation of agreed upon standards in readable form.
Nebraska has eight sponsoring organizations. All sponsors but one have overlapping service areas. This is a competitive group but also a group of sponsors who are on the whole dedicated to serving child care providers in order to facilitate the best care and feeding of children.
The group started this effort by:
1) Developing a mission statement: “To promote quality nutrition and child care through financial and educational support in family child care homes while maintaining Child and Adult Care Food Program integrity.”
2) Agreeing on the following definitions:
Quality child care: Child care provided in an environment which promotes learning and growth. This includes a safe, nurturing, caring/loving environment, developmentally appropriate practices and promotes healthy eating and good nutrition.”
Program Integrity: Ability to provide quality services to the customer while adhering to the group values and governing regulations.
3) Defining a workable set of values:
Genuine love for children
Conscientious adherence to CACFP regulations
Commitment to nutrition
The group openly shared individual sponsors’ strengths as well as weaknesses. They strived to set standards that are reachable, measurable and focus strongly on program integrity. By sharing ideas, strategies, policies and procedures, the Nebraska sponsors have created a basis of standards which will serve to assist in developing a statewide quality assurance plan.
The process involved monthly meetings over a 10-month period. Each sponsor was represented by only one or two staff with the same staff attending whenever possible. The toughest issue, recruitment, was tackled first. This gave the group experience in agreeing to disagree, and in consensus building. After several months, the state recruitment policy was established. The group then moved on to other standards, such as monitoring (including the development of standard forms to be used on home visits), fiscal responsibility, governing board, training and application. Part I of our agreement was revamped. Other standards were reviewed by the group. Some of these standards were altered slightly or left as they were originally written.
Nebraska sponsors intend to meet quarterly as a peer review team with Quality Assurance as the goal. Working together, one standard at a time, the group intends to share knowledge to improve integrity, training and program quality overall. The children and their nutritional needs must remain the true motivation for sponsoring this program, with the realistic understanding that abuse of federal funds will cause the elimination of the program. With team work, the sponsors can assist one another in learning ways to detect and respond to problems promptly.
The Nebraska quarterly sponsors meetings can also become a forum for grievances should this become necessary. Sponsors must first show honest effort to discuss problems with the sponsor in question. If resolution is not possible between individual sponsors, a grievance procedure will be implemented.
Nebraska sponsors are proud of the effort given to this process. The experience has been both fulfilling and educational. The ongoing process promises to lead to the CACFP serving children in the best way possible in Nebraska.
Nebraska Family Day Care Home Sponsors Recruitment Policy
The CACFP integrity initiative in Nebraska:
Nebraska family day care home sponsors recruitment policy
The Nebraska sponsor’s recruitment policy was adopted by all eight of Nebraska’s family day care home sponsors March 1, 1999. It was amended and accepted on May 23, 2006.
Recruitment Policy – Adobe pdf file
Program Improvement Expected From Integrity Initiative
Program improvement expected from integrity initiative
Fraud. Embezzlement. Money laundering. Those are the kind of things you might expect to find in a crime novel or television show – certainly not in a child care setting. But that is exactly what has been found in nationwide audits of the Child and Adult Care Food Program (CACFP) over the last few years.
The USDA Office of Inspector General (OIG) has conducted audits of the CACFP in 20 states since 1996 and found abuses such as filing false claims, money laundering, forged signatures, improper use of food program funds and fraud.
In a nationwide sweep referred to as “Operation Kiddie Care” in 1998, the OIG first reported on significant weaknesses in program delivery. When the report was released, Inspector General Roger C. Viadero stated, “For this $1.6 billion-a-year program that feeds an estimated 2.4 million children annually, the temptation to cheat was too great and the controls to prevent cheating were too weak.” The OIG spotted several “warning signs that some agencies were acting more out of their own self-interests than the interests of the children they claimed to be feeding.”
In a March 1999 news release, USDA reported that 15 individuals had been indicted for program fraud. Of the 15, nine have pled guilty.
“This type of fraud which takes food out of the mouths of children will not be tolerated,” Viadero said. “The Office of Inspector General will continue to investigate and vigorously pursue prosecution of the criminals who defraud these programs.”
In April 1999, Tennessee Sen. Fred Thompson called on USDA Secretary Dan Glickman to take immediate action to halt the abuses that have plagued the CACFP. The nationwide abuse in the program has also been reported in the national news media. The attention is not likely to end until changes are made.
The OIG audits have focused on operations in family day care home sponsoring organizations and individual family day care homes. However, the impact of the findings has a far-reaching effect that also influences the operation of the CACFP in child and adult care centers.
These audit findings damage the entire CACFP and hurt the majority of caregivers who do a great job administering their programs. Sadly, the criminals are the ones who are posing a threat to all of the centers and family day care homes that operate honest programs, and offer quality, nutritious meals.
Nebraska Not Included in OIG Audits
So far, Nebraska child and adult care centers and family day care home sponsors have not been audited by the OIG. That doesn’t mean that it may not happen in the future. However, recognizing that such problems exist in other parts of the country has caused the Nutrition Services office of the Nebraska Department of Education (NDE) to take a pro-active approach to assure that similar results would not be found here.
As Integrity started becoming the new buzz word in the CACFP, the Nebraska Nutrition Services staff started to re-examine some practices and procedures that would strengthen the program, and hopefully, help prevent fraud and abuse in our state. Even though NDE’s vision emphasizes its role as a service agency, its role as a regulatory and enforcing agency cannot be ignored.
Education and Training
In July 1998, Nutrition Services implemented the first wave of changes designed to strengthen the management of center-based programs. We have long held the opinion that proper training and education are important factors for a successful child care feeding program. When NDE began the administration of the CACFP in Nebraska in 1986, annual training was held for child care centers. Technical assistance training was provided on-site with new centers. In the late 1980s, more frequent training was offered. Program growth became so significant that, in the mid-1990s, monthly training workshops were instituted.
Initially designed for new centers joining the CACFP, the monthly workshops not only include new centers, but new directors and new responsible individuals and principals. The workshops also serve as a resource for centers needing corrective action or refresher training. Alternating between Lincoln and Omaha, the workshops attract an average audience of 25 people each month. Workshops are also held each year in other locations such as Norfolk, North Platte, Kearney, Grand Island, South Sioux City and Scottsbluff.
With the beginning of the 1999 fiscal year, personnel from all new centers must complete the training workshop prior to the approval of the program agreement. The workshop includes three hours on record keeping, three hours on meal production records, nutrition and creditable foods. Centers claiming meals served to infants must also complete one-half hour training. At a minimum, the institution’s CACFP responsible individual/principal and/or contact person and the person(s) responsible for food service must complete this training prior to program approval. New responsible individuals/principals must attend training within four months of becoming the responsible individual/principal.
Meal Service Times
For Child and Adult Care Centers
Another change that went into effect in July 1998 was the establishment of meal service times in child and adult centers. Until that time, the federal regulations for the CACFP only provided guidelines for meal service times in outside-school-hours care centers. Since there had been no other guidance for meal service time, there were some centers offering a supper as early as 3:30 p.m. The Nutrition Services staff agreed that such an early serving time for this meal was a potential warning sign for abuse. After reviewing regulatory language that applies to other Child Nutrition programs, the following meal service times were established for center-based programs: 1) breakfast service must be completed by 10:00 a.m., 2) lunch service may be between 10:00 a.m. and 2:00 p.m., 3) supper service may be no earlier than 5:00 p.m., and 4) a minimum of three hours must elapse between the beginning of breakfast and the beginning of lunch.
Elimination of “Shift Care”
in Child and Adult Care Centers
Another potential area for abuse could occur when a center provides multiple shifts, such as the case of a 24-hour care facility. While our computer claims processing system is able to detect several errors in claims, allowing for shift care could permit the payment of potentially fraudulent claims without raising a “red flag.” The Nutrition Services staff spent several work sessions with the NDE Financial Services staff to develop a workable solution. We did not want to penalize centers that were claiming appropriate meals. Yet, we wanted to be able to monitor those claims with potential for overclaimed meals. Our claims processing system now filters out all claims in which average daily attendance exceeds licensed capacity. Each of these claims is manually reviewed with the figures the center reported in its agreement as the expected number of meals to be served at each meal service. Should this occur, these centers are required to maintain time-in and time-out records that document that the center did not exceed licensed capacity at any given time.
Responsible individuals and principals
Greater emphasis has been placed on the fiscal responsibility of the responsible individual and principal. This is the person (or persons) who signs the legal agreement between the institution and NDE. This is also the person who is allowed to sign claims for reimbursement. The responsible individual and principals are the people who are legally responsible for the receipt of all funds received from the CACFP.
In recent years, Nutrition Services and Financial Services have worked together to refine the system that assures that claims are paid only when authorized signatures appear on claims for reimbursement. The web based claims system provides each institution with a user ID and password so that those persons who have signed an agreement with NDE are authorized “signers” via the web based system.
The CACFP agreement now stipulates that institutions must notify NDE within 10 days of any change in responsible individual or principal or corporate structure and submit a new Certificate of Authority to Nutrition Services. Within the terms of the agreement, responsible individuals or principals and the owner and corporate official of the institution or sponsoring organization are agreeing to be held administratively and financially responsible for program operations. This is especially important when errors result in an overclaim.
CACFP Agreement Strengthened
The narrative agreement between institutions and NDE is a legally binding contract. The language in this agreement has been strengthened to spell out what is expected of participating institutions to comply with federal regulations. The revision of this agreement was a cooperative effort between Nutrition Services and the office of the NDE Legal Counsel.
Audits and Reviews
As a state agency, NDE Nutrition Services is required to do a minimum number of full-scale reviews of participating institutions each year. To meet this quota, all centers are on a three-year review cycle. This means your center will be reviewed by a member of the Nutrition Services staff once every three fiscal years. In some situations, reviews may occur more frequently.
In addition, for profit “Title XX” centers that receive more than $25,000 annually in CACFP funds are audited each year. Through a competitive bid process, NDE contracts with private auditing firms to conduct these audits.
If review and audit findings indicate areas needing improvement, the institution may be required to complete some type of corrective action. Types of corrective action may include attending CACFP training workshops, submitting records to document each month’s claim or on-site technical assistance may be provided by Nutrition Services to the institution.
Nutrition Services has also established an effective relationship with the Nebraska Health and Human Services System (HHSS). The two agencies have a reciprocal agreement to exchange information regarding CACFP and licensing violations. Food-related complaints in institutions participating on the CACFP are investigated by the Nutrition Services staff. In turn, Nutrition Services reports any observed licensing violations to HHSS.
Complaints are generally investigated by means of unannounced visits at an institution. In some cases, the complaints may not be legitimate. In those situations, our staff is always glad to be able to find that centers are in compliance with program regulations. If the complaints appear valid, additional unannounced visits or other means of corrective action may be warranted.
In the most severe cases, when an overclaim is assessed and the institution fails to repay the funds, the institution is declared “seriously deficient.” This means that the institution and the authorized representatives and, in some cases, other employees of the organization, are prohibited from participating in the CACFP anywhere in the U.S.
NDE has also received approval from USDA to hire a collection agency to attempt to reclaim funds that were overclaimed. Management Standards for Home Sponsoring Organizations
While strengthening the enforcement of CACFP regulations within centers in recent years, the operations in family day care homes and sponsoring organizations have also been examined.In 1997, USDA issued a Management Improvement Guidance for program improvement within family day care home sponsoring organizations. NDE took the challenge seriously and initiated a process for Nebraska’s eight family day care home sponsoring organizations to work together for program improvement. This process is described in an article by Jeany Morton of Family Service of Omaha. Nebraska is one of the smaller states, with only eight sponsors of family day care homes. Over the years, a relationship has been developed between the state agency and the eight sponsors which provides a spirit of cooperation. While some of these sponsors may be in competition with one another, over the past year, these individuals have worked together to develop a set of common management standards to which all sponsors can aspire.
Commitment to Service
This information is not intended to scare or threaten any participants in the CACFP. Our main goal is to continue to do what is best for children. Providing wholesome, nutritious meals is good for kids. The CACFP was originally created to provide meals for children from low-income households. The intent of the program is not in question. As a state agency, we want to assure that the CACFP funds continue to be used for the intended purpose – feeding children and, since 1987, adult care participants.We recognize that the majority of institutions and day care providers in Nebraska are operating within the guidelines established for the program. Our staff is committed to providing service to participants in the program. It has been our experience that overclaims are generally assessed based upon clerical and mathematical errors, rather than intentional fraud, cheating or other illegal practices. This is why our staff is dedicated to providing on-going training and technical assistance – through our monthly workshops, our toll-free telephone number and our web site. We want to make sure that all participants on the program receive the training and support necessary to operate a successful food program.While that remains a primary goal, our staff will also not shirk the responsibility of fully investigating potential fraud and abuse. CACFP has provided a valuable service for many years and we don’t want to see the entire program jeopardized because of the actions of a few.
What Lies Ahead?
It’s safe to say that Integrity will continue to be a focus of the CACFP well into the next century. As its commitment to program improvement, the USDA is spearheading a series of training sessions for state agency personnel across the country. The Mountain-Plains region of the USDA will host a two-day training session for personnel from 10 states at a conference in Omaha in October 1999. It’s expected that this training will be the impetus for ongoing improvements in the management and administration of the CACFP. You can be sure that NDE Nutrition Services will continue to work to provide a statewide program of quality meals for children and adults served by the CACFP.
Maintaining Program Integrity and Avoiding Overclaims
Maintaining program integrity and avoiding overclaims
by Susan Petersen, Consultant, Nutrition Services
from the Spring 1997 issue of Child Caring; updated 2002
Participation in the Child and Adult Care Food Program (CACFP) provides many benefits to child and adult care centers, child care home providers and day care home sponsoring organizations. These benefits are primarily in the form of money that is distributed to centers and homes as reimbursement for nutritious meals served to eligible participants.
Even though Nebraska is one of the smaller states in terms of the amount of funds distributed nationally, the total dollar figures are still somewhat overwhelming.
In fiscal year 1996, the Nebraska Department of Education (NDE) distributed approximately $4.8 million in reimbursement to child and adult care centers. The amount distributed to child care home providers through sponsoring organizations was approximately $16.9 million. Nebraska’s eight sponsors of family day care homes received approximately $2 million in administrative funds for training and monitoring purposes.
|Read more about the CACFP Integrity Initiative in Nebraska|
It’s All Tax Money
Where does this money come from? It comes from every taxpaying U.S. citizen – meaning you and me. And since this is tax money, every recipient of these dollars has to be accountable for how those funds are used and accounted for.
In recent years, Congress has been examining ways to cut back on a variety of expenses in all aspects of government. Some of those cutbacks have already affected the CACFP in an attempt to reduce government expenditures.
As part of the Welfare Reform Act, child care centers are no longer eligible to claim a “fourth meal” under the CACFP. This change went into effect immediately upon the signature of the President in August 1996.
In July 1997 we saw many changes in the way child care home providers receive reimbursement under the CACFP, as an effort by the federal government to cut $2.2 billion in the CACFP over a five year period. This change was to a two-tiered system of reimbursement from the flat-rate reimbursement that had been in effect.
Since many of the CACFP dollars are distributed to private for-profit businesses and individuals operating family child care homes, this opens up the CACFP to closer scrutiny to account for how these funds are used. Every tax-paying citizen should have the assurance that the government is spending their hard-earned tax dollars appropriately.
Audits & Reviews Conducted
Among the methods to assure that these CACFP tax dollars are used as the government intended are compliance reviews conducted by Nutrition Services staff and audits of private for-profit centers by contracted auditors. Federal regulations require the NDE Nutrition Services office to monitor the CACFP in all centers on a regular basis. Nutrition Services reviews at least one-third of all institutions each fiscal year.
An institution is each organization that has an approved agreement with NDE Nutrition Services. In addition, Nutrition Services provides monthly training for new centers and new personnel, on-site technical assistance to new centers or sponsors and a review of records of new centers to assure that program requirements are being met. In addition, Nutrition Services follows up on complaints received from other agencies or members of the public regarding questions of impropriety in the operation of the CACFP.
Audits have become an annual event for many private for-profit (“Title XX”) centers participating in the CACFP. Centers that receive $25,000 or more in CACFP funds during a fiscal year are audited for that time period.
Audits and compliance reviews are conducted with the intent to assure that program integrity is maintained. This means that reviewers and auditors are reviewing local programs for compliance with CACFP regulations and that fraud is not taking place. In some situations, over claims are the result of “honest mistakes,” but the result is the same – funds that were accepted in error must be repaid to the government.
Over claims are generally due to errors on Income Eligibility Forms, errors in claiming meals, failure to meet the 25% Title XX eligibility requirement and mathematical errors. In the majority of cases, centers have made arrangements to repay these funds to the state. In other situations, centers have ceased operations while still owing the state a significant amount of money. When necessary, these cases are turned over to a collection agency.
If the results of audits or compliance reviews indicate that CACFP funds are being used improperly, whether it be intentional or due to the center’s inability to comply with regulations, the result can be the same: the center can be declared seriously deficient and terminated from the CACFP. Being determined as seriously deficient prohibits the center or any of its officers or employees from participating in the CACFP not only in Nebraska, but nationwide. Termination is a last resort, only after an institution to failed to correct deficiencies.
According to federal regulations, serious deficiencies include, but are not limited to:
noncompliance with the applicable bid procedures and contract requirements of federal child nutrition program regulations
the submission of false information to the state agency
failure to return to the state agency any advance payments which exceeded the amount earned for serving eligible meals, or failure to return disallowed start-up payments
failure to maintain adequate records
failure to adjust meal orders to conform to variations in the number of participants
the claiming of program payments for meals not served to participants
service of a significant number of meals which did not include required quantities of all meal components
continued use of food service management companies that are in violation of health codes
failure of a sponsoring organization to disburse payments to its facilities in accordance with its management plan.
a history of administrative of financial mismanagement in any federal child nutrition program and
the claiming of program payment for meals served by a proprietary Title XIX or Title XX center during a calendar month in which less than 25 per cent of enrolled participants were Title XIX or Title XX beneficiaries.
Have Questions? Call Us!
There really is no excuse for any organization participating in the CACFP to incur large over claims as long as they are following the regulations and terms of the agreement signed with the Nebraska Department of Education. Remember that when you sign that agreement, you are responsible for complying with federal regulations and assuring that funds are properly accounted for and that all records required by the program are maintained.
The CACFP is a complex program which requires knowledge and training. If you are responsible for the CACFP, you owe it to yourself, your organization and the taxpayers to administer the program correctly.
Nutrition Services requires that every director or authorized representative be trained by Nutrition Services in program compliance. Workshops are held monthly.
If you have questions regarding the CACFP or if you or a member of your staff needs training, call our office toll-free at (800) 731-2233 or at (402) 471-2488. This is your only assurance that you will receive accurate and up-to-date information regarding the program. Don’t rely on the information that your day care colleague across town may tell you. Remember that you are ultimately responsible for the administration of the CACFP in your center.
Offutt AFB Child Development Center
Family day care home sponsors
Offutt AFB Child Development Center
106 Peacekeeper Drive, Suite 231
Offutt AFB, NE 68113
Contact: Yong Alati
Family day care home sponsors
Family day care home sponsors
The following organizations are approved sponsors of family day care homes in Nebraska.
Find out which sponsors serve your county.