Transition Period for Updated CACFP, Infant, Preschool Meal Patterns
|DATE:||May 10, 2017|
|POLICY MEMO:||SP 30-2017, CACFP 13-2017|
|SUBJECT:||Transition Period for the Updated Child and Adult Care Food Program Meal Patterns and the Updated National School Lunch Program and School Breakfast Program Infant and Preschool Meal Patterns|
This memorandum outlines a transition period for the updated Child and Adult Care Food Program (CACFP) meal patterns and the updated infant and preschool meal patterns in the National School Lunch Program and School Breakfast Program (school meal programs). In recognition of the challenges associated with conforming to the updated requirements, the transition period outlined in this guidance will allow CACFP institutions and facilities and school food authorities (child nutrition program (CNP) operators) to adjust to the updated requirements in the first year of implementation without having fiscal actions imposed or being found seriously deficient.
FNS recognizes implementation of the updated requirements will be a significant change for many CNP operators. FNS is committed to helping state agencies learn and understand the updated meal patterns and to ensure they are able to train their CNP operators to be fully equipped to comply with the updated requirements as soon as possible. Based on FNS’ experience during the past year with early implementation of the updated meal patterns by some program operators (SP 42-2016, CACFP 14-2016 “Early Implementation of the Updated Child and Adult Care Food Program Meal Pattern Requirements and the National School Lunch and School Breakfast Programs’ Infant and Preschool Meal Patterns” (http://www.fns.usda.gov/sites/default/files/cn/SP42_CACFP14_2016os.pdf), FNS anticipates that most issues of non-compliance will result from CNP operators’ efforts to adhere to the updated requirements. Therefore, FNS concluded that the most appropriate initial remedy to non-compliance is technical assistance and training.
Accordingly, similar to when the school meal programs’ updated K through 12 meal patterns were first implemented in 2012, FNS is providing a transition period for CNP operators implementing the updated CACFP meal patterns and the updated school meal programs’ infant and preschool meal patterns. The transition period will allow an opportunity to focus on providing technical assistance to CNP operators related to the updated meal patterns. Therefore, during Fiscal Year 2018 (October 1, 2017- September 30, 2018), state agencies and sponsoring organizations must provide technical assistance in lieu of fiscal action when they observe violations related to the updated meal pattern requirements. As long as CNP operators are making a good faith effort to comply with the updated requirements, meals cannot be disallowed and CNP operators cannot be found seriously deficient when meals fall short of the updated CACFP meal patterns and the updated school meal programs’ infant and preschool meal pattern requirements during this transition period. State agencies and sponsoring organizations should work with CNP operators who are not meeting the updated meal pattern requirements to identify actions necessary in order to do so.
As currently required, state agencies and sponsoring organizations must continue to take immediate fiscal action if a meal is completely missing one or more of the required food components (see 7 CFR 226.2, definition of “meal”, and 226.20(a)). FNS will closely monitor any challenges related to the implementation of the updated CACFP meal patterns and the updated school meal programs’ infant and preschool meal patterns. FNS strongly encourages state agencies and CNP operators to provide feedback on implementation of the updated meal patterns. FNS will assess this information to determine if additional guidance is needed.
FNS expects state agencies to work closely with their CNP operators and provide technical assistance on an ongoing basis to support CNP operators during this important time of transition. FNS applauds the efforts of CNP operators to achieve and maintain compliance with the updated meal pattern requirements, including those who are already partially or fully implementing the updated requirements.
State agencies are reminded to distribute this information to program operators immediately. Program operators should direct any questions regarding this memorandum to the appropriate state agency. State agency contact information for the school meal programs and CACFP is available at http://www.fns.usda.gov/cnd/Contacts/StateDirectory.htm. State agencies should direct questions to the appropriate FNS regional office.
Policy and Program Development
Child Nutrition Programs
Program Monitoring and OP Support
Child Nutrition Programs
The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.