COVID-19 Attendance Requirements for Child and Adult Care Food Program At-risk Afterschool Meals

This morning, the California Department of Education (CDE) circulated information regarding attendance requirements for CACFP At-Risk Afterschool Meals. See below:


The U.S. Department of Agriculture (USDA) Policy Memorandum SP 05-2021, CACFP 04-2021, SFSP 04-2021: Questions and Answers relating to the Nationwide Waiver to Allow Summer Food Service Program and Seamless Summer Option Operations during School Year 2020–2021 was issued January 5, 2021. Question Number 2 addresses flexibilities during the pandemic to the federal requirements for maintaining attendance records for At-risk Centers in accordance with Title 7, Code of Federal Regulations, Section 226.17a(o)(1). In discussions with the USDA, the following minimum procedures will meet with the expectations of the COVID-19 flexibilities:

  1. Closed Enrolled Sites Serving CACFP At-risk Meals:

  2. Can use a tally system and/or meal count forms with the daily attendance rosters and/or enrollment documents to meet the attendance record requirement.

  3. Use their tally system to record the number of meals served as parents or legal guardians pick up meals.

  4. Will need to record the number of leftover meals that will be served the following day.

  5. Include daily tally documents as part of the end of day procedures, which should be compared with attendance rosters and/or enrollment documents to ensure meal counts are correct. Daily tally documents should be kept with attendance rosters and/or enrollment documents for record keeping purposes.

  6. Provide the tally system documents and/or meal count forms, which includes leftover meals, with the daily attendance rosters and/or enrollment documents to support the meals claimed as part of the Administrative Review (AR).

  7. Update and maintain a written integrity plan to reflect the above attendance and meal counting and claiming procedures.


  1. Open Sites Serving CACFP At-risk Meals:

  2. Can use a tally system and/or meal count forms with enrollment rosters or the serving site and the neighboring schools that the site is serving to meet the attendance record requirement.

  3. Use their tally system to record the number of meals served as parents or legal guardians pick up meals.

  4. Will need to record the number of leftover meals that will be served the following day.

  5. Include daily tally documents as part of the end of day procedures, which should be compared with attendance rosters and/or enrollment documents and transport records to ensure meal counts are correct. Daily tally documents should be kept with attendance rosters and/or enrollment documents and transport records for record keeping purposes.

  6. Provide the tally system documents and/or meal count forms, which includes leftover meals, with the daily attendance rosters and/or enrollment documents to support the meals claimed as part of the AR.

  7. Update and maintain a written integrity plan to reflect the above attendance and meal counting and claiming procedures.

The above minimum solutions are in line with flexibilities extended during COVID-19 operations to assist in providing safety measures to protect the well-being of the staff, parents, and students, as well as maintaining program integrity during meal service. Based on the guidance from the USDA, the California Department of Education (CDE) has updated the Frequently Asked Questions (FAQ) section of the CDE COVID-19 Guidance in the Child Nutrition Programs (CNP) web page to provide further guidance.

Contact Information If you have any questions regarding this subject, please contact your CACFP County Specialist. The County Specialist list for the CACFP is available in the Child Nutrition Information and Payment System (CNIPS) Download Forms section, Form ID CACFP 01.

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