Conducting a Five-day Reconciliation in the CACFP

Reference: Title 7, Code of Federal Regulations, sections 226.6(m)(4), 226.10(c), and 226.16(d)(4)(ii); California Department of Education Management Bulletin USDA-CACFP-11-2013; U.S. Department of Agriculture Policy Memorandum CACFP 10-2018

Supersedes: California Department of Education Management Bulletin CACFP-10-2016

Subject: Conducting a Five-day Reconciliation in the Child and Adult Care Food Program

This management bulletin provides updated guidance on the five-day reconciliation process for sponsors of centers and day care homes. This management bulletin supersedes Management Bulletin CACFP-10-2016: Conducting Five-day Reconciliation in the Child and Adult Care Food Program (CACFP) with Questions and Answers.

Background

The five-day reconciliation is a vital tool for ensuring program integrity. Per Title 7, Code of Federal Regulations (7 CFR), sections 226.6(m)(4) and 226.16(d)(4)(ii), all CACFP Sponsors must complete a five-day reconciliation. Each sponsor appoints monitors who must reconcile three key elements—enrollment, attendance, and meal counts—for a five-day period, in order to ensure the agency correctly reports the daily number of meals.

If the data is not consistent, the sponsor’s monitor must determine the reasons for the discrepancies and require corrective action. The monitor must also determine whether any meals should be disallowed or whether the agency submitted an overclaim.

The U.S. Department of Agriculture (USDA) recently issued Policy Memorandum CACFP 10-2018: Conducting Five-day Reconciliation in the CACFP with Questions and Answers, which is on the USDA CACFP Policy Web page. The purpose of this policy memo, which includes a comprehensive list of questions and answers, is to make the five-day reconciliation process more efficient and consistent for sponsors. The revised guidance establishes a single set of procedures meant to eliminate disparities that sponsors encounter in conducting reconciliations. The revised guidance also addresses possible acceptable alternatives to the five-day reconciliation—namely, automated data systems and edit checks that reconcile the required documents.

Automated Data Systems

All agencies participating in the CACFP through the California Department of Social Services (CDSS) must submit their monthly claims for reimbursement in the Child Nutrition Information and Payment System (CNIPS). The CNIPS claims module does not reconcile enrollment, attendance, and meal counts, and submitting a claim for reimbursement does not meet the five-day reconciliation requirement.

Agencies with automated data systems that check all critical elements—enrollment, attendance, and meal counts—may be exempt from meeting the requirement if they can verify their systems have the capability to:

• Collect enrollment, attendance, and meal count data

• Separate attendance or sign-in/sign-out sheets from meal counts

• Perform comparisons of enrollment, attendance, and meal counts that would detect potential problems in the claiming process

In reviewing a sponsor’s operation of the CACFP, a CDE reviewer or Auditor will verify that the sponsor’s edit checks are working as intended and that the automated data system meets the five-day reconciliation requirement.

Edit Checks

Sponsors must complete and document a monthly edit check in accordance with 7 CFR, Section 226.10(c). This edit check, however, does not replace the five-day reconciliation requirement. The intent of the edit check calculation is to ensure that sponsors do not claim more than the maximum number of meals or snacks for the month. For more information regarding edit checks, refer to CDE Management Bulletin USDA-CACFP-11-2013: Clarification Regarding Required Meal Claim Edit Checks and Block Claims on the CACFP Management Bulletin Web page.