Enrollment Records and Block Claiming

This Management Bulletin revises the previously issued guidance on the Child and Adult Care Food Program (CACFP) Second Interim Rule contained in Management Bulletins (MB) 05-205 and 05-211.

To participate in the CACFP, a child must be enrolled for care in a child care center or family day care home. MB 05-205 informed independent child care centers, child care center sponsors, and family day care home sponsors that the Second Interim Rule required that they annually update each child’s enrollment document, have it signed by a parent or guardian, and ensure that it contains information regarding a child’s normal days and hours of child care and the expected meals to be served to the child. 

Subsequently, the United States Department of Agriculture (USDA) broadened how centers may comply with the new requirement for days and hours of child care and expected meals. As a result, centers may either include this information on their enrollment documents, as stated in MB 05-205, or use sign-in and sign-out sheets in lieu of collecting this information. In California, Community Care Licensing requires centers to maintain sign-in and sign-out sheets, whereby parents or guardians sign children in and out of child care. Since the sign-in and sign-out sheets are required by an appropriate state agency, the USDA regards their use as an acceptable alternative to the collection of information regarding child care hours and meals. 

Centers still must annually update each child’s enrollment document and ensure the document is signed by a parent or guardian.

Day care homes, on the other hand, do not have the alternative of sign-in and sign-out sheets, as homes are not required to maintain them. Consequently, homes may only include the information regarding days and hours of child care and expected meals on their enrollment forms. Like centers, they also must annually update each child’s enrollment document and ensure the document is signed by a parent or guardian.

MB 05-211 informed sponsoring organizations of child care centers, adult day care centers, family day care homes, or any combination thereof, of the Second Interim Rule’s new edit check requirements for the monthly meal reimbursement claims. Note: Facility is the general term in the CACFP regulations for sponsored centers and homes and will be used to refer to both centers and homes.

Before filing a reimbursement claim, a sponsor must conduct an edit check of each sponsored facility’s meal claim. The edit check must:

• Verify the facility is approved to serve the meals that are claimed;
• Determine the accuracy of the facility’s claim by comparing the number of enrolled participants multiplied by the number of operating days to the meals claimed; and
• Detect block claiming by the facility. A block claim is defined as a claim in which the number of meals claimed at a facility for one or more meal types is the same for 15 consecutive operational days during a claiming period.   

The California Department of Social Services (CDSS) preapproves a facility to serve and claim all meal types. As a result, a sponsor does not have to verify that a facility is approved to serve the meals that are claimed. However, a sponsor must ensure that each of its facilities meets the meal claiming limitation of two meals and one snack or two snacks and one meal per child per day.

If a sponsor detects block claiming, the sponsor must conduct an unannounced review of the facility’s operation within 60 days (90 days with the permission of the CDSS) to determine if the block claiming is legitimate or the result of claiming errors. The CDSS advises sponsors to begin the 60-day review timeframe upon receipt of the block claim. For example, if a sponsor receives a block claim from a facility on November 15, the sponsor would have 60 days from that date to complete its unannounced review.

The USDA makes an exception to this required follow-up. If, during an unannounced review, a sponsor discovers a block claim prior to its submission and is able to document a valid reason for it, then the sponsor will be exempt from conducting a follow-up review of the facility when that claim is received by the sponsor.

Sponsors must carefully document the reasons why block claims are legitimate and avoid a checklist approach to validating such claims. For example, a sponsor should not merely check or note that a facility accepts sick children as the reason for a block claim. Rather, the sponsor should also state that the facility has a written policy for accepting sick children and that sick children have been routinely observed during monitoring.

This institution is an equal opportunity provider.
Esta institución es un proveedor que ofrece igualdad de oportunidades.