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CACFP Administrative Manual Section 16.2

Table of Contents
Terms, Definitions, and Acronyms

Section 16: Administrative Review Process for Compliance with the CACFP Meal Patterns

16.2 Analyzing Meals Served on the Day of the Onsite Meal Observation

Outlined below is the preliminary review process; however, an expanded review may occur if the reviewer considers it necessary.


The CACFP Operator must provide the reviewer with the posted, dated menu for the day so the reviewer can ensure the meal observed reflects the menu and that all components are included and creditable toward the meal pattern requirements. This menu must also include the serving sizes provided to each age group unless the CACFP agencies operate only an at-risk afterschool program or emergency shelter. These agencies are not required to document serving sizes for each age group.

Nutrition Facts Labels or Ingredients Lists

The reviewer will check the Nutrition Facts labels or Ingredients lists from packaged foods and for foods used as ingredients in standardized recipes for the food items or components in a reimbursable meal to ensure that the meal pattern requirements for meals served that day were met.

CACFP Operators are required to retain the Nutrition Facts labels and Ingredient lists from packaged foods until the end of the day during the year of their program review in case of an unannounced meal observation by program reviewers. If the Nutrition Facts labels and Ingredient lists are not available during the day of the onsite meal observation because meals were not prepared onsite or for another justifiable reason, the CACFP Operator has five business days to provide the reviewer with a copy of these documents.

The reviewer will look at the Nutrition Facts labels or Ingredients lists to determine the following:

  • For infants only: Infant formula served (including infant formula brought from home) contained at least 1 milligram of iron per 100 calories and is regulated by the Food and Drug Administration (unless supported by a signed medical statement).

  • For infants only: All infant cereal served at meals and snacks were made from dry, iron-fortified infant cereal. Ready-to-eat cereals (only allowable for infants at snacks) were either fortified or made from enriched or whole grain meal or flour, and contained no more than 6 grams (g) of sugar per dry ounce (oz).

  • Fluid milk served to children and adults did not exceed the fat content allowable for the age of the participant and flavored milk was not served to participants five years of age and younger. Reminder: In California, the Healthy Beverages in Child Care Act does not allow licensed child care centers and day care home providers to serve flavored beverages to children of any age.

  • Nondairy fluid milk substitutes served to participants (without a medical statement) met the federal fluid milk substitution nutrient requirements (Title 7, Code of Federal Regulations [7 CFR ], Section 226.20 [g][3]). Note: Simply providing the nondairy milk substitute’s name and brand is not considered sufficient documentation. Reviewers will request to see the Nutrition Facts label.

  • Grains were made from enriched or whole grain meal or flour, bran, or germ.

  • WGR food items met the criteria for WGR listed in the USDA Policy Memorandum CACFP 09–2018, Grain Requirements in the CACFP, Questions and Answers (Q&A). Documentation required to demonstrate the food item met the criteria for WGR will depend upon which method listed in the USDA policy memo was used.

  • Breakfast cereals contained no more than 6 g of sugar per dry oz, and were fortified; the first ingredient was a whole grain, enriched grain, bran, or germ; or, the name and brand of breakfast cereal is listed in the California Department of Public Health Women, Infants, and Children(WIC)Authorized Food List Shopping Guide External link opens in new window or tab. (or any other state agency’s WIC Shopping Guide External link opens in new window or tab. ), in which case a Nutrition Facts label is not required. Tip: When breakfast cereal is removed from the original package and stored in containers, attach the package label with the Nutrition Facts Label and Ingredients list to the container, or provide other documentation to demonstrate that the food item is creditable.

  • Tofu was commercially prepared, easily recognizable as a meat substitute (e.g., sausage link, tofu chunks in a stir fry), and contained at least 5 g of protein per 2.2 oz (equivalent to ¼ cup).

  • Yogurt contains no more than 23 g of sugar per 6 oz.

  • Standardized recipes (which are kept on file) for all foods prepared from scratch show that the contribution from each ingredient required to meet the meal pattern was correct.

All other food items must be included in the USDA FBG External link opens in new window or tab. , the USDA Crediting Handbook for the CACFP External link opens in new window or tab. , or have a CN label or PFS on file which shows that the contribution to the meal pattern was correct, i.e., meat/meat alternates or combination foods.

Additional Meal-related Documentation

The reviewer will request the following meal-related documents (which must be kept on file) to substantiate that the CACFP meal requirements were met on the day of the onsite meal observation:

  • Medical statements or documentation related to requests for medical statements, if applicable.

  • Written requests from a child’s parent or guardian, or household member of an adult participant, for nondairy milk substitutes when medical statements are not on file and that the substitute follows the Management Bulletin (MB) CACFP-02-2020, if applicable.

  • Documentation for all meal or snack modifications for participants without a disability, if applicable.

  • Written notification to parents that an iron-fortified infant formula is provided,or a signed written statement from a parent or guardian who denies the formula provided by the CACFP Operator and instead chooses to provide an alternate infant formula, if infants are served.

  • For infants only: Containers of expressed breast milk are labeled with the infant’s name and date, and not offered more than 72 hours after expressed or thawed.

References: CACFP Regulations,7 CFR sections 226.15 and 226.20; CACFP 17–2016, Revised Child Nutrition Authorization 2010: Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the CACFP, (Q&A); SP 53–2016, CACFP 21–2016, Crediting Tofu and Soy Yogurt Products in the School Meal Programs and the CACFP; CACFP 08–2017, Q&A on the Updated Meal Pattern Requirements for the CACFP; CACFP 09–2017, Vegetable and Fruit Requirements in the CACFP, Q&A; CACFP 14–2017, SFSP 10–2017, Policy Memorandum on Modifications to Accommodate Disabilities in the CACFP and the Summer Food Service Program (SFSP) Policy Memorandum; CACFP 02–2018, Feeding Infants and Meal Pattern Requirements in the CACFP, Q&A; CACFP 09–2018, Grain Requirements in the CACFP, Q&A; MB CACFP–08–2017; SFSP–02–2017, Modifications to Accommodate Disabilities in the CACFP and the SFSP on the CDE CACFP Modifications to Accommodate Disabilities web page; MB CACFP–01–2020, Documentation Requirements for the CACFP Meal Patterns; and MB CACFP–02–2020, Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the CACFP

Questions:  Kayla Christensen | | 916-324-6153

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