In this section, we will be discussing the record keeping and reporting requirements associated with the At-risk Afterschool Meal Program. Each day sites must document the number of children that attended that Afterschool program. This should not reflect the number of children that attended the meal but rather the afterschool programs as a whole. Attendance counts must be separate from meal counts. This can be done through various methods, but typically accomplished through daily attendance rosters completed by staff or sign in sheets completed by participants. Staff must also record the number of snacks and or meals planned and prepared.
Number of snacks and or meals actually served. Remember that if a sponsor is approved to claim both first and second meals, the number of first meals must be tracked separately from second meals as these will be reported separately on the claim for reimbursement. If adults performing labor for the meal service are going to be provided a meal, the planned number of adult meals and actual number of adult meals served must also be documented. Remember that adult meals cannot be included in your claim for reimbursement even though meals served to program adults are considered an allowable cost to the program. Menus that include a detailed description of the food item served, which component it is associated with, and the portion size. For more information on this and determining credibility, please review the appropriate meal pattern training on Canvas.
Many sponsor of other Child Nutrition Programs are familiar with production record requirements. Production records are meal service documentation records that have detailed information on the amount of each individual food item planned and prepared. Calculations found on the production records help ensure enough food is prepared to produce the required number of meals planned. Our office has sample production records and recommend sponsors use production records as a menu planning and preparation tool as a best practice. That being said, production records for the At-risk program are not required for those sponsors using the CACFP meal pattern. Our office requires what we refer to as detailed menu records. The information that must be contained on the detailed menu records was described on a previous slide. More information about detailed menu records is discussed in the CACFP meal pattern training. School sponsors that elect to use the NSLP meal pattern are still required to complete daily production records.
Many of the documents completed during the application process will become apart of the sponsor’s permanent record packet. We will ask to see these records whenever we come to conduct a program review. Permanent records include: your program agreement signed by our office, non-pricing policy statement, outside employment policy, procurement or purchasing policy, and procurement codes of conduct; as well as your civil rights complaint procedure. Your site eligibility document, as well as any vendor or Food Service Management Company contracts, must be kept for as long as they are active, which may be longer than the standard record retention requirements.
Sponsors and sites must also keep track of all expense records, to include: invoices, receipts, and labor documentation where program funds were used to pay for these costs. Sponsors must also have menu crediting documentation to ensure the meals planned and provided meet the selected meal pattern. These records include CN labels and product formulation statements for food items served that meet more than one component and that was not made or assembled by the sponsor or contracted vendor. An example of a product that would require a CN label or product formulation statement would be a chicken nugget. For more information on this topic, our office has an in-depth stand alone training on CN labels and product formulation statements.
When our office comes out to do a review, we will need to verify that you’re operating a non-profit food service and that program funds are used only to pay for allowable program costs. This basically means that you are not getting reimbursement that you are not spending or spending program funds on things that are not allowable program costs. When purchasing program items, keep all of the receipts from any food and non-food items—such as paper goods used in meal service—that you purchase. If you plan on paying for administrative or operational staff salaries from program funds, assuming you have funding left over after paying for food and non-food meal service items, you would need to show payroll documentation indicating the wages and amount of time staff worked on CACFP duties.
When purchasing, you’ll need to separate out your food program purchases from other purchases. For example, let’s say you’re at the store and you’re picking up the groceries for the week, paper plates, cups, and some replacement books for your center. You would purchase the food, paper plates, and cups in the same transaction, but you would purchase the books in a separate transaction. If for some reason, an item that is not related to the food program is purchased with food program items, simply cross that item off when you get back to your center. We would not use that item’s cost in determining your non-profit food service. If we notice that you are regularly purchasing food program items along with items that are not allowable as food program costs, it may result in a finding of program non-compliance. If you have questions about allowable costs, contact our office for assistance.
One item to note, if you are using the CACFP meal pattern, is that non-creditable foods—with the exception of condiments—are not allowable program costs. Therefore, you cannot use program funds to purchase non-allowable foods. Examples would be granola bars, or other grain based desserts such as cookies or brownies. In addition to keeping receipts of food purchases, to show a non-profit food service, you’ll also need to keep receipts to show that you purchased a sufficient amount of food to meet the meal pattern. Keep track of your receipts! You'll want to think of them as cash. If we come out on a review and find that you didn’t purchase enough food to meet the meal pattern, whether you really didn’t purchase enough food or you just lost a receipt, we may have to deny a portion or all of your meal reimbursement request. It’s also easiest for review purposes if you separate your receipts by month. You’re welcome to make copies of the receipts for record keeping, but make sure that you copy the entire receipt. We must be able to see the date, time, and all of the items that were purchased on the receipt.
Because the funding you receive is part of a federal grant award, the rules regarding how federal funds may be spent on goods and services apply. There is an overarching code of federal regulations governing procurement standards. The standards deal with competition, methods of procurement to be used, contract cost and price, and more. 2 CFR 220 covers everything from very small organizations to very large organizations. Because they are so broad, the USDA interprets them. As they decide on the interpretation, they pass the information on to each state and from there we pass it on to you. CACFP regulations also have specific sections governing procurement. You can either google the CACFP regulations or link to them from our website.
Procurement standards include: having documented procurement procedures that conform to federal, state, and local laws and regulations; maintaining oversight to ensure that contractors perform in accordance with the terms and conditions of their contracts or purchase orders; and maintaining written standards of conduct covering conflicts of interest and governing the performance of its employees engaged in the procurement process. *Procurement rules for CACFP are a new focus for the USDA.
One of the required documents that you must maintain permanently, is the written code of conduct for employees engaged in procurement. We often refer to this as the code of conduct. This policy spells out the ethics concerning purchasing. We have a sample code of conduct that you’re welcome to adopt, or you might have your own already. If you already have one of your own, you wouldn’t need to adopt our code of conduct as long as yours is at least as restrictive as our sample code of conduct. The code of conduct prohibits real or apparent conflicts of interest. An example of a conflict of interest would be if you were purchasing your groceries exclusively from a store owned by your spouse. You need to allow free and open competition among the vendors in your area.
Also, the individual doing the purchasing of the food can’t accept gratuities, favors, or anything of monetary value in return for their business. This means that if a company is trying to get you to have them deliver all of your groceries, you couldn’t accept a trip to Hawaii that they offer you to try to get your business. You are able to accept nominal gifts (not in the form of money) with a value up to $10, with a maximum of $50 annually. Reward cards or gas discounts that many stores offer would NOT fall into this category. Whoever is involved with purchasing your food and anything else with food program reimbursement money needs to be aware of the code of conduct.
A second policy that you must keep permanently is the procurement policy. If you’re a large organization—for example, you’re associated with a university—you might already have a procurement policy. As with the code of conduct, we developed a procurement policy that you’re welcome to adopt. You may use ours or yours, but you need to submit it to our office to be approved if you haven’t already. The procurement policy outlines that you will spend the reimbursement money in compliance with applicable state, federal, and local laws. It needs to outline that you’ll make sure that expenses are reasonable and necessary, as well as define purchase thresholds and outline purchase procedures.
If you have been on the CACFP program for a while and used the state agency procurement policy template, you’ll notice that the amounts on this slide have increased. In FY2019 the federal government raised the micro-purchase and small purchase thresholds. You can keep the amounts the same and follow your policy as written or increase them to these amounts. In the template policy there is a decision tree, where it goes through what to do if your purchases are under or over a certain amount. This is a graphical representation of this. These numbers that we’re going over are what is required if you are utilizing the most current federal procurement thresholds. If you have different procurement thresholds, it’s fine as long as they're at least as restrictive as these thresholds. Remember that certain organizations such as public schools must follow state and local procurement rules and thresholds, which are more restrictive than the federal standards.
Micro purchasing is the method that requires the least documentation. In fact, it doesn’t require any documentation at all apart from the receipts from your purchases. You would be able to use the micro-purchasing process if your purchase is under $10,000 at a time, and you’re not spending more than $250,000 over the course of a year at a single vendor or store. You would also need to equally distribute your shopping among all of the qualified suppliers in your area. Because of lack of more clear instructions, our office is allowing “all qualified suppliers” to translate to at least 3 stores in the immediate area. You must be equitably making purchases at each store in order to satisfy the micro-purchasing rule. This does not necessarily apply to the cost, but to items. Buy bread at one store this week or month, and a different store the next week or month, etc.
Often times, even though a center might fit in the micro purchasing threshold (no purchases over $10,000 and less than $250,000 in a year at one store), they have a favorite store that they go to and don’t want to shop around, as required with micro purchasing. You are able to continue to do the majority of your shopping at one store, but you’ll need to show that you’re getting the best bang for your buck at that store. You’ll be getting quotes from at least three stores and showing that you’re choosing the least expensive one. You would also go through this process if you’ll be spending over $10,000 in one purchase at a store, but less than $250,000 over the course of the year at that same store. Keep in mind that you can’t artificially separate purchases to get them under a certain amount threshold and deliberately circumvent these requirements.
After doing your market research and developing your specification, you decide your organization would be best served by choosing a prime vendor for an item (or if you exceed the micro-purchase threshold). For this you will need to conduct informal procurement. Remember to document each step including your specification. To complete the quote process, you’ll need to get at least three quotes for the items that you purchase and will need to go through this process at least annually. You don’t need to wander around the different stores to get the current prices, you may look on-line, through their advertisements, or call or e-mail the vendors. When communicating with the vendors, it is important to share the same questions with each vendor and be sure that the process is equitable. It is not appropriate to share price information obtained from one vendor with another vendor and ask them to beat that price. You will instead just ask each vendor to give their best price and then select that vendor.
Our office has created a spreadsheet that can help you to document quotes for multiple items to be purchased from the same vendor. This spreadsheet will also allow you to take other factors into consideration when determining best price, such as, membership costs, fuel rewards, travel or shopping time, or other relevant factors. This spreadsheet can be downloaded from the resources section. If you would like additional training on how to use it, please contact our office.
Part of your record keeping and reporting requirements will involve ensuring your program operates in a non-discriminatory manner. You will accomplish this by ensuring: No child or family is denied access to the Food Program and it’s benefits due to race, color, national origin, age, sex or disability. Remember that discrimination is defined as different treatment, either intentionally or unintentionally. Display “And Justice for All…” posters, which include information on the protected classes and how to file a complaint of discrimination. Include the appropriate non-discrimination statement on any CACFP-related material being distributed to the public. Draft and follow your civil rights complaint procedures, which must include reporting any received complaints to our office immediately upon receiving complaints.
Sponsors are also required to collect ethnic and racial information from their program participants. Each participant will fall into an ethnic and racial category. These categories are those required by the USDA. Sponsors will enter this information into C.N.P. web each year. The ethnic categories are based on culture and those used are Hispanic or non-Hispanic. The racial categories are biological and those used are Asian, White, Black, American Indian, and Pacific Islander.
There are three items that must be posted at each site. The first we just spoke about, the “And Justice for All poster.” It must be posted in a location easily seen by those who enter both the sponsor office and at each of the meal service locations. The poster should be the original poster as received from our office. You cannot alter the size of the poster. Sites must post a copy of their current child care license or the notice required by Child Care Licensing indicating that this site is a license exempt facility. The license exempt notice is a separate notice from the letter you receiving confirming your license exempt status. The third item you must display, is a copy of your daily menu at the sites. Parents or caregivers must be able to see what the planned menu is for the day. We recommend posting a weekly menu so students and parents can plan ahead. The ability to do this is especially important for parents and students accommodating for special dietary needs.
Next, we will go over the training requirements. New organization owners and directors must complete State Agency training. New employees at your center must be trained when they’re first hired. In-person training may be arranged or staff may complete the on-line At-risk Meal training. You’re welcome to use our training videos to fulfill these requirements. Staff must be trained based on what their responsibilities to the food program are before being given those responsibilities. All employees involved in any way with the food program at your center must be trained on the food program, at least annually. For administrative staff, there are 6 CACFP required key topics that relate to the operation of the food program and two additional required topics on policies.
The six key topics that must be trained on are: Meal Pattern and serving sizes, Meal counting, Record Keeping requirements, Reimbursement system, Claim submission, Review procedures. The two additional required topics are: Outside Employment Policy and Civil Rights. The civil rights training requirements will be discussed in more detail in the civil rights training.
Not all staff have to be trained on every topic. Staff must be trained based on what their responsibilities to the food program are before being given those responsibilities. Since civil rights is everyone’s responsibility, all food program staff must complete Civil rights training annually. If civil rights training has already been completed under a different federal nutrition program, there is no need to repeat the training. Just be sure to have documentation. Sponsors may use the state agency’s training to meet this requirement. Any staff member that is trained to complete site monitoring must be trained on all of the key topics to include monitoring requirements.
As with everything else on the food program, if you didn’t write it down, it didn’t happen. You’ll need to document that you’ve completed the training that you given to your staff. You will need to show that you trained new staff upon hire and for the annual training, you’ll need to keep a dated agenda, the list of topics trained on, and an attendance sheet for those who attended. Our office has a template form for documenting training. Feel free to use these forms to document the training that you give. Sponsors may also find it helpful not to document individual training sessions, but to have a consolidated training tracker or spreadsheet that details the training type and dates for all employees. This helps to see that all employees have completed the necessary training at a glance and that any make up training has been completed as necessary. Training trackers are also especially useful during a review to easily demonstrate compliance.
Next, let's discuss how long sponsors must keep program records. To do this, let's look at a couple of different types of records. Permanent Records—as the name implies, these records are permanent and should be kept for as long as you are participant of the program. We will discuss these more in depth in a moment. Most other records are going to fall into the general program documents category. These are things like menu records, meal counts, training and monitoring documentation, etc. You must keep these records for three years prior, plus the current year. Site Eligibility Records will also be three years plus the current year as well or as long as they are being used for eligibility. Remember, site eligibility is good for up to 5 years. There are exceptions to the time frames above for those sponsors involved in an ongoing investigation or have unresolved audit findings. In these cases, sponsors must retain documentation until the investigations or audits are closed.
Records may be kept electronic or hard copy. This refers to all paperwork. Training documentation, receipts, meal counts, menu records, everything. At any time, our office could request any record from within the record retention time frame. There are generally five or six documents that must be kept permanently depending on your situation: Your agreement with our office when you initially come onto the food program, Non-pricing policy statement, The outside employment policy, The civil rights complaint procedure policy, Written code of conduct for employees engaged in procurement, and Purchasing policy.
We’ll ask to see these records when we come and do reviews. If you’re already on the program, take a moment to make sure that you have these documents and can locate them. If you can’t find them, contact your specialist and they’ll be able to send you a copy for your records. When deciding which records to keep, it is important to understand that our office has to be able to review the information where it was first recorded, prior to being transferred or consolidated. The original place it was recorded is referred to as the source document. For example, if teachers keep a classroom attendance sheet on a clipboard and fill that out each day and then these are turned in and consolidated onto an attendance spreadsheet, we would still need to be able to review the original attendance sheet. It is okay if this is a scanned copy of the original, but we must be able to validate that there were no transfer errors that occurred when transferring information from the paper sheet to the electronic workbook.
In addition to reporting the total number of meals and snacks served to eligible children based on daily attendance rosters or sign-in sheets when submitting claims to our office, sponsors are at times requested to provide program information as part of an approved program study or data request from the USDA’s Food and Nutrition Service. By accepting the grant funds and signing a program agreement, you have agreed to participate in these research activities. Do not worry too much about this, as studies are infrequent and typically only involve a small sample of sponsors across the state.