2018 CACFP Childcare Annual Training
Good afternoon and welcome to the annual training for child care centers that are participating in the Child and Adult Care Food Program (CACFP). I’m Adele Roberts, and I’m the supervisor for the CACFP. Here’s our agenda for today. The full agenda item you’ll notice at the end says it’s for sponsors of multiple sites. I know that all of you are not necessarily sponsoring multiple sites but because of our need for you to certify at the end of the total webinar that you have participated in this, it’s going to be important that all of you stay on the webinar until we completely finish and then at that point there will be a link provided where you fill in some basic information that will generate a report for us so that we know that you have watched this webinar. OSPI Child Nutrition Services, we provide two different types of trainings for the CACFP. One is the annual training that we’re doing today and the other type of training are technical assistance workshops. Sometimes there’s some confusion about what those are so we want to cover that here. The CACFP regulations require all institutions to attend annual training. Participating in this webinar fulfills that requirement for this year. It is intended for current staff and sponsors and is a way for us to provide you with updates and assure that the CACFP regulations are understood and followed. We also want to remind everyone that we provide training for new institutions throughout the state multiple times each year. We mentioned this as a part of this training because this strongly advised that a new staff person that has administrative duties for the CACFP attend one of these workshops. Many program reviews go poorly when a new staff person has not been thoroughly trained. There is information about these workshops on our website. Our training today is targeted for participants who are already familiar with the program requirements. I want to introduce to you two new staff members that we have. The first one is Jessica Condron and she is providing services for centers in King County, Chelan, and Douglas counties. Jeanette Green has also joined our staff. She’s here in the Olympia office and provides services for centers in Thurston, Mason, Grays Harbor, Clallam, Jefferson, Kitsap, and Kin- and a small number in King County. King County is so large, not one person can handle all of the centers that are in King County. Jeanette is taking over Arianne McConchie’s position, and Arianne continues with us here in the Olympia office doing additional administrative duties. Before we move on with our other agenda topics there just a few items that I want to touch on. First of all is renewal. The majority of the renewal will be completed in WINS. WINS was opened yesterday for renewal for CACFP. The renewable (?) for child care centers has been posted on the OSPI website and a CNS update went out to make sure that you are aware of that. We want to be sure that you understand that the deadline for submission is October 1st. It’s always fine to be submitting things sooner than that, but by getting things in by October 1st, we can be sure that we can get your application approved in a timely manner. The bulletin will provide you with information about additional items that you may need to be providing beyond just the WINS agreement. Also associated with the new fiscal year but a different activity from renewal is the completion of a study month. By the time the October 2018 claim has filed all institutions that have to complete a study month will need to have gathered income eligibility application forms from their families, evaluate them, and complete a roster of all children in attendance during the study months along with the eligibility categories that they’ve assigned to each child. The results of your study month must be entered into WINS before you are able to file your October 2018 claim. There are some institutions that are not required to do study months and those include emergency shelters and at risk only programs. If you’re from a new institution that started sometime this past year, please remember that you also need to do a new study month for the start of the new fiscal year. Then you will be on the same cycle as everybody else. It is almost the end of August so if you haven’t already started this process or aren’t in the midst of it, you certainly should have plans in place and are getting underway. The CNS update was distributed on June 29th regarding enrollment and income eligibility information and the newest income guidelines and EIEAs are available on our website on the study month page. We want to be sure that you are aware that there is an updated enrollment income eligibility application. We made changes based on the latest USDA prototype. The biggest difference you will notice is in the section where the household income is to be reported. There are now boxes that can be checked and make it clear how often the income is received. You can see that section there on- on the screen. We are hoping that this new way of reporting this helps you getting the accurate information you need to correctly evaluate the family’s income. If you have already distributed EIEAs and have used the old form, it is not necessary to give out forms again, but start using this new form as soon as possible because it may be more helpful for you and your families. One topic that is sure to come up more often in the future is procurement. You may be aware that in the last several years, USDA has issued memos about procurement. A webinar was provided for CACFP institutions in May that was recorded, and a link is provided on our CACFP training webpage. It’s about 15 minutes long. If you did not participate in the webinar in May, we would suggest that you view this introductory training. There will be more to come later that will build on this first training. So most of our topics today that are going to be addressed as a part of this webinar came from USDA through guidance with memorandums. Once the memorandum is issued we write a short summary for a CNS update that is sent out by email. These notifications also include a link to the full memorandum and we recommend that you always read the complete memo. It is important that we have current contact information, including accurate email addresses for all institutions so that everyone is receiving these updates. All of our updates regarding policies are found on the CACFP webpage under correspondence and updates. And that’s what you see there on your screen. Memos that we’ll be speaking to today include Child Nutrition flexibilities for school year 2018-19, whole grain-rich requirements in CACFP, and conducting five-day reconciliations for the CACFP. The memorandum about flexibilities for the school year 2018-19 primarily addressed some meal requirements for the National School Lunch Program. The only part of the memo that applied to CACFP had to do with flavored milk. As you may recall in the updated meal pattern, flavored milk may only be served to children six years of age and older. The regulation also stated that the flavored milk had to be non fat. With this flexibility, 1% flavored milk may also be served. There were no changes in terms of the age restrictions for the use of flavored milk. So now I’m going to turn this over to Molly who’s going to provide information about whole grain-rich products. Hello everybody. I’m gonna spend some time during this webinar not talking only about the revised meal pattern requirements, but very specifically on whole grains and whole grain-rich requirements. So we’re going to be discussing the updated grains memo from April, ways to verify whole grain-rich foods, documentation that’s required for whole-grain rich foods, and go through some scenarios. USDA issued a revised memo about serving grains under the revised meal pattern requirements. This new memo supersedes the prior version that was CACFP 01-2018. The new memo explains the new grain requirements, clarifies how to determine if a grain meets the whole grain-rich criteria, and also includes an updated question and answer section. So let’s talk a little about the grain requirements in general for the CACFP. All grains must be made with enriched or whole grain meal or flour or bran or germ in order to be creditable, meaning that it counts towards meeting the meal pattern requirements. This is not a new requirement from the revised meal pattern. All grains served should have been meeting this requirement. What is new is that the updated meal pattern requires at least one serving of grains per day must be whole grain-rich, and we’re going to spend some time discussing how to determine if a grain item is considered whole grain-rich. When it comes to cereals, the previous and still current requirement for cereals is that if they were not already whole-grain then they would have needed to have been fortified. So we’ve used the terms enriched and fortified. So what does this really mean? Enriched grains start as a refined grain, a grain that has been processed to remove the outer bran covering and the germ. Then they are enriched, which means they have added back what the refinement has removed. So thiamin, riboflavin, folic acid, iron, those are added after the processing. Foods from refined grains must meet one of the following criteria: they could be labeled as enriched in the product name, such as enriched long grain rice. So this is your typical white rice. Enriched grain is listed as the first ingredient, or second after water. So the label might read enriched wheat flour or even yellow corn flour and then a sub listing of nutrients added which is iron, folic acid, riboflavin, niacin, and thiamin. So this is describing what I talked about in the very beginning, but if a grain item was not made from a whole grain already, it must be enriched. Similarly foods that are fortified like breakfast cereal start from a refined grain and then have vitamins and minerals added during or after processing including some that weren’t there before when the food was refined. This increases the nutritional quality For breakfast cereals, the product is labeled as fortified or ingredients list names the vitamins and minerals that have been added. If breakfast cereal is fortified it does not need to be enriched. Here’s an example of a fortified breakfast cereal. So the ingredients are wheat flour, sugar, and then it contains 2% or less of salt, baking soda, caramel color, and then the vitamins and minerals are added at the end. So vitamin C and niacin, vitamin B6, iron. You can see the list of them on the ingredient label. So, in this example the vitamins and minerals are added at the end of the production of the cereal instead of using an ingredient that was already enriched or fortified. So in this example we have, this is a non fortified breakfast cereal and you can see that the ingredients show rice flour, corn flour, evaporated cane juice, and sea salt. This cereal would not be creditable as a grain. It is not made from whole or enriched grains and is not fortified. So let’s now talk about whole grain-rich. What is it, what does it mean for you? Whole grains have not had the nutrient-rich germ and bran removed and thus do not need enrichment. Foods that meet the whole grain-rich criteria contain at least 50% whole grains and the remaining grains are enriched or are already 100% whole grain. The new memo gave us six different ways to determine a food as whole grain-rich. Only one of the six options need to be met. New reference sheets are available for you to use around this topic. You might want to pull them out, there are handouts available, and follow along as we go through the slides. Thee first way is to have a product that’s found on the WIC approved whole grain food list. Any grain product found on a state agency’s WIC approved whole grain food list meets the CACFP whole grain-rich criteria. The link to this list for the state of Washington is on the screen. Whole grain choices from the WIC whole grain food list include bulgur, oatmeal, breakfast cereals, and soft tortillas. There is also a shopping guide you can download from the website that you can take with you to the store with descriptions of these items. One specific food we’d like to highlight from the WIC whole grain food list are the tortilla choices. The other methods for determining whole grain-rich items will prove challenging for most tortillas. Both corn and corn masa soft tortillas, along with whole wheat soft tortillas, are on the WIC approved whole grain food lists. When you’re purchasing those items you must buy only the brands on the approved list, which the green arrow is pointing towards. There are some specific types of tortillas that are not WIC approved and would not be allowable for the whole grain-rich items. Examples are tortillas with mixed grains, like both corn and wheat, flavored tortillas and wraps, reduced fat or light tortillas, as well as any store made tortillas that would not be allowed to count as a whole grain-rich item. There is a list of cereals that meet CACFP requirements. Those are cereals on the WIC approved breakfast cereal list, meaning they meet both the sugar limit and they are a creditable grain. However only cereals marked with the bold W meet the whole grain-rich requirements. There are more cereals that will also be whole grain-rich and meet the sugar limit that are not on this list. You would need to review the label. So there are two lists of cereals on the WIC list. There’s approved cereals for WIC, and then there are also those designated with the bold W that are considered to be whole grain cereals. The second way is to have a product that’s labeled as whole wheat and has a standard of identity issued by the US Food and Drug Administration or the FDA. An FDA standard of identity is a set of rules for certain products, like whole wheat bread for example, that must contain or may contain to legally be labeled with that product name. FDA provides standards of identity for certain whole wheat bread products and certain whole wheat pasta products. Breads with these exact product names conform to an FDA standard of identity and can be considered whole grain-rich using this method. Specifically, whole wheat bread, entire wheat bread, graham bread, whole wheat rolls, entire wheat rolls, graham rolls, whole wheat buns, entire wheat buns, and graham buns. Pastas with these exact product names conform to an FDA standard of identity and can be considered whole grain-rich using this method. Whole-wheat macaroni product, whole wheat macaroni, whole wheat spaghetti, and whole wheat vermicelli. Please be aware that manufacturers may label their products with terms that are similar to but slightly different from FDA standards of identity. Terms defined above. Crackers, tortillas, bagels, and biscuits do not have a standard of identity for processing. Some frequently encountered terms include whole grain, made with whole grains, made with whole wheat, or contains whole grains. These terms do not indicate an FDA standard of identity for whole wheat products. Foods labeled with these terms must be evaluated for whole grain-rich credibility for CACFP using one of the other methods on this list. So, here we have an example. Sandwich thins. Do you think that these meet the whole grain-rich standard of identity requirements? You have to look closely but this product would be whole grain-rich as it is labeled a whole wheat roll. Other grain products labeled as whole wheat that do not have an FDA standard of identity such as crackers, tortillas, bagels, and biscuits must be evaluated for whole grain-rich credibility for CACFP using one of the other methods The third way to determine whole grain-rich is to have a product that includes one of the following Food and Drug Administration approved whole grain health claims on its packaging exactly as written. The exact wording is in the memo but you can find it also on the grain requirements reference sheet in the handouts. And remember, it must be word-for-word exactly as written. So you can see the first one there, diets rich in whole grain foods and other plant foods and low in total fat, saturated fat, and cholesterol may reduce the risk of heart disease and some cancers. The fourth method is to have a food that meets the whole grain-rich criteria under the National School Lunch Program. So this may apply to those of you who get your meals from local school districts. The fifth way is called the rule of three. FNS developed the rule of three in recognition that CACFP operators purchase food differently than school meal program operators. In CACFP operators often shop in retail environments, and may not have access to manufacturers’ product formulation statements or child nutrition labels. We’ve also developed a new reference sheet available for you to use all about the rule of three. So if you have this handout in front of you go ahead and pull it out and we can follow along together. To meet the rule of three as a whole grain-rich product the first ingredient or the second ingredient after water must be whole grain. And the next two grain ingredients, if there are any, must be whole grains, enriched grains, bran, or germ. Remember that for the rule of three you’re looking at the grain products ingredient list and ingredients are listed in order by weight so the first one listed is the ingredient in the largest quantity in the item. Other items to consider are any grain derivatives which are byproducts of grains may be disregarded. Any non creditable grains such as flours that are not enriched or whole, that are labeled as 2% or less of the product weight are considered insignificant and may also be disregarded. And we do have a list of those ingredients on your reference sheet. And we’ll discuss those a little bit more in the future slides. When applying the rule of three to grain products of mixed dishes such as pizza crusts and tortillas for burritos, and the first grain ingredient must be whole grain and the next two grain ingredients if there are any must be whole grains, enriched grains, bran, or germ. So you may have to scan past other non grain ingredients like the cheese and the beans to find just those grain ingredients When applying the rule of three for ready to eat breakfast cereals: if the first grain ingredient is a whole grain and the cereal is fortified, the product then in this situation we’re ready to eat meets the whole grain-rich criteria. So breakfast cereals the second and third ingredients if any do not need to be considered. So breakfast cereals are kind of their own special group. And remember, if they’re on that WIC list and have that bolded W, you don’t need to use this method for cereals. So a reference sheet has been created that details all of the various grains pertaining to the rule of three. So this one’s separate from the rule of three, it’s just giving more detail about grains and whole grains. So pull this one out also. So as you can see this reference sheet includes a comprehensive list of whole grains, brands, germs, and rich grains disregarded ingredients the ones that are due to small amounts non creditable grains or flours that cannot be the first three grain ingredients. This is going to be a really handy worksheet for you as you navigate through your whole grain-rich items. So let’s try out an example, You have an English muffin and the ingredients are whole wheat flour, water, enriched wheat flour, wheat starch, yeast, sugar, and salt. Do you think this meets the rule of three requirements? So you’re going to be asking yourself these questions. Is the first ingredient a whole grain? Yes, the first ingredient is it’s whole wheat flour and that’s a whole grain. Is the second ingredient a whole grain or an enriched grain bran or germ? Yes, it is the second ingredient is enriched wheat flour which is an enriched grain. And finally, we have the third grain ingredient Is the third grain ingredient whole grain or an enriched grain bran or germ? The third ingredient is wheat starch. And when you look at your reference sheet you can see that wheat starch is a grain derivative. And what did we say about grain derivatives? That they can be ignored, they do not count as a grain ingredient. So does this English muffin meet the rule of three to be considered a whole-grain rich item? Yes, it does the first two ingredients met the rules and the third grain ingredient which was a grain derivative can be ignored. Let’s look at another example, So here we have corn chips made from whole corn, vegetable oil, salt, cheddar cheese maltodextrin, wheat flour, romano cheese, whey protein concentrate. So what are we going to look for Is the first ingredient a whole grain? Yes it is it’s whole corn. What about the second grain ingredient is it a whole grain or enriched bran or germ? No it’s not the next screen ingredient is an unenriched wheat flour and it is not whole-grain or enriched grain bran or germ. So that second grain is not meeting the requirements. So do we know if this corn chip meets the rule of three? And you’re right the answer is no, this product is not creditable as a whole-grain rich product for the CACFP using the rule of three. Because although the first grain ingredient is a whole grain it was whole corn. The next grain ingredient is unenriched wheat flour. However, this items is still creditable as a grain it’s just not being served as the whole-grain rich item because the first item is a whole grain it is creditable. So here we have another example we have a store made tortilla. Do you think this item is going to need the rule of three? Let’s take a look So when we look at this ingredient list we see that the first grain ingredient is, Organic whole wheat flour. So is that a whole grain? Yes it is and it doesn’t really matter for whole grain-rich whether it’s organic or not. That’s just so happens to be this product that we’re looking at. What about the second ingredient is that a whole-grain or an enriched grain, bran or germ? Organic wheat flour No- it’s not it’s not whole-grain it’s not enriched so again this product is not creditable as a whole-grain rich product for CACFP using the rule of three because although the first ingredient is a whole grain it was whole wheat, The next great ingredient is an unenriched wheat flour. But again like the prior example this item is creditable as a regular grain that’s not being served as a whole-grain rich item because the first green ingredient is whole corn. So you can serve the tortilla but you could not designate it on your menu as your whole-grain rich item for the day. Okay, let’s move on to one more method that is number six. So in this last method number six, This method allows you to determine a whole grain rich item with proper documentation from a manufacturer or a standardized recipe that demonstrates that whole grains are the primary grain ingredient. Documentation from a manufacturer or a standardized recipe is particularly helpful when determining whole grain rich credibility from grain products that do not have a whole grain as the first ingredient then for other mixed dishes. When a grain product such as bread has the first ingredient that is not whole grain the primary ingredient by weight may still be whole-grain if there are multiple whole-grain ingredients and the combined weight of those ingredients that are whole grain is more than the weight of the other grain ingredients. So we have an example here with some bread, again it has multiple grain ingredients and when they combine those whole grains it ends up being heavier than the other grain ingredients that are not whole grains. And again it could be something like a beef enchilada that’s a mixed product. When the grain portion of a mixed product is not entirely whole-grain it also may be whole-grain rich depending upon the proportion of whole grains to the other grain ingredients. So for something like an enchilada you would need to get documentation from the manufacturer like a product formulation statement. A formulation statement might indicate something similar to this example of a bagel where the manufacturer states that the product has enriched wheat flour which is 40 percent of the grain weight. Whole-wheat flour which is 30 percent of the grain weight and whole oats which is 30 percent of the grain weight. So the manufacturer gave you this information, What are you going to do to determine if you have a whole grain rich bagel? So you know that you have enriched wheat flour which is 40 percent and whole wheat flour which is 30 percent and whole oats which is 30 percent. So when we add those together we now have 60 percent whole grain ingredients and we have 40 percent enriched ingredients. So the 60 percent whole grain is greater than a forty percent that is not whole grain. Another example could be something a little more simple like a recipe for homemade bread. The recipe states that you have 2 cups of whole wheat flour and 2 cups of enriched flour. Does this meet the whole grain-rich requirements? So are at least half of the grains whole? Yes they are because you have two cups of whole wheat flour and 2 cups of enriched flour. So this would also be a whole-grain rich bread according to this recipe. So we’ve just reviewed 6 different ways that you can choose to use when you’re determining a whole-grain rich item and some items will qualify using more than one method but I will remind you that the item only needs to meet one of the six methods, not all six. And different food types make lend themselves to qualify using different methods. So if you’ve qualified the item one way, you should just stop there and not try to qualify it as whole-grain rich using a second or third method. There is also another way that you can verify that you have a whole-grain rich item and this is not specifically listed as one of the six methods. It would be having an item that has a child nutrition or CN label. Some of you may already be using products with child nutrition labels that list grains in ounce equivalents. And even though we’re not implementing the ounce equivalents for CACFP until October 1st 2019. Centers may use the ounce equivalent information on a CN label product to meet the whole grain-rich requirements for CACFP. an ounce of whole grains is slightly more than the current serving size requirement for CACFP. Therefore, the ounce equivalent of whole-grains meets the minimum quantity for the CACFP grain component. Here’s an example of a CN label that provides a grain contribution for the meal pattern. So you can see on here it’s a fully cooked country fried breaded beef patty and it has two ounces of meat alternate. And it provides one ounce equivalent of grains for child nutrition meal pattern requirements. Schools are required to serve only whole-grain rich grades. And while CACFP only requires one serving per day, you can still use this label as documentation to show that you have a whole- grain rich item served. There were also some questions and answers included in the memo so we’re going to spend a few minutes and review some of those throughout the rest of this section. First one can centers use the whole grain stamps from the Whole Grain Council to determine if a grain product meets the whole grain rich criteria? And the answer to that is no. While the whole grain stamp provides useful information on the amount of whole grains a product contains. They are not sufficient documentation to determine if a food is whole-grain rich. And this is because the products that display a whole grain stamp may also contain high amounts of non creditable grains such as a non enriched refined flour. And as you know, to better align the CACFP meal patterns with the Dietary Guidelines, grain-based desserts cannot count towards the grain requirement at any meal or snack. Therefore, grain-based desserts are those items that have a superscript 3 or 4 and Exhibit A of this memo. It is important to note that cookies do not have an FDA standard of identity. So manufacturers may come up with fanciful names that could mislead the menu planners into serving a product that may not be allowed. When determining whether a food is a grain based dessert, the menu planner should consider whether the food is commonly thought of as a dessert or a treat. So cookie is, sweet pie crusts, donuts cereal bars, breakfast bars, granola bars sweet rolls, toaster pastries, cakes and brownies are all considered grain-based desserts. Menu planners should also be aware that even if a product is not labeled as a traditional dessert item, it may contain higher levels of added sugars or saturated fats. So many planners need to use their discretion when serving these foods and don’t hesitate to ask your program specialist if you are unsure whether a product should be considered a grain based dessert. Centers may want to occasionally serve grain-based desserts such as for celebrations or other special occasions. And as a reminder centers continue to have the flexibility to serve grain-based desserts as an additional food item that does not contribute toward the meal component required for reimbursement. However non creditable food items are not allowable costs and must be purchased using non program funds. So our homemade granola bars or other homemade grain-based desserts allowed? What do you think? No. homemade and commercially prepared grain-based desserts cannot count towards the grain component in CACFP and that was starting October 1st of 2017. Granola bars are noted with a superscript 4 in Exhibit A so they qualify as a grain base dessert. And based on feedback the food nutrition services from USDA decided using categories to define grain-based desserts was the best approach versus establishing nutrient standards or preparation requirements. So what about quick breads? Are they aloud? And the answer is yes, quick breads are breads that are leavened with ingredients such as baking powder and baking soda instead of yeast. Some examples of quick breads would be banana bread, pumpkin bread, zucchini bread, and they’re credited in the same group as muffins under Group D in Exhibit A and continue to be a part of a reimbursable meal. What about scones and grain puddings? Are they considered grain-based desserts? It kind of depends. Sweet scones, sweet bread puddings and sweet rice puddings are considered grain based desserts and cannot count towards the grain requirement. Savory scones, such as one made with cheese and herbs, credit like a biscuit, and are not considered grain-based desserts. However, sweet scones, such as those made with fruit and icing, are more like a cookie and are considered grain-based desserts. Bread puddings could also be sweet or savory. Sweet bread puddings, such as ones made with chocolate chips, are considered a grain-based dessert. However, savory bread puddings, such as one made with spinach and mushrooms, are not considered grain-based desserts. Menu planners should consider the common perception of the food item and whether it is thought of as a dessert or a treat when deciding to serve it. So how do you document that you’re serving these whole-grain rich items? So if you were serving in brown rice or oatmeal or quinoa, what would you do? You would make a notation on your menu for each of those whole-grain rich items you serve. What about if you were serving white rice? Would that have a whole-grain rich notation? No, it wouldn’t, because white rice is not whole-grain rich. So it’s kind of up to you how you want to designate your menu items that are whole-grain rich, but make sure that you clearly indicate which items you’re counting for the whole grain-rich item of the day. You could put WGR next to the food item, or you could put an asterisk or other symbol next to the item. I would just recommend avoid putting WW or Whole Wheat next to any whole grain-rich item as if it is not wheat based than it should not say Whole Wheat. It could be corn or rice or another grain How do you document that you’re serving these whole grains and that you purchase these whole grains? We are going to keep documentation on file, and I would recommend that you cut or copy, somehow save the product labels of the items that you are purchasing. The Food Nutrition Services of USDA understood that implementation of the updated CACFP meal pattern would be a significant change for some centers. And in recognition of that, they established a transition period for the updated CACFP meal patterns over this past fiscal year of 2018. So that started October 1st of 2017, through the end of September of this year, 2018. During the transition period, if a State agency or a sponsoring organization observed a meal pattern violation related to the updated meal patterns, like, for example, not serving a whole grain-rich item each day, they were to provide technical assistant instead of fiscal action. And those of you that sponsored multiple sites, when you’re out visiting those sites, and you should be looking for the product labels, you would also be providing technical assistance and not disallowing at this time. But September 30th is just around the corner, so our grace period is almost up. Each site, or sponsor if all the centers use the exact same items, should have a collection of product labels that support the items noted on their menu as being whole grain-rich. You only need one copy of each product type, so if you buy the same bread all the time just save or copy one label. Over the past year, we’ve reviewed many collections of labels. Some of the labels that we see are whole grain-rich and some are not, so I would recommend that, as you’re keeping your labels, that you make a note on the label that the item is either whole-grain rich or it’s not whole-grain rich, and keep them separately in a binder or in a box or a bag. Have one section for the whole-grain rich items and one for non whole-grain rich items. Okay, a couple test your knowledge questions. A school-age center serves a grain with a breakfast and a p.m. snack, so they don’t do lunch at this center, just breakfast and p.m. snack. Neither of the grains are whole-grain rich. Which meal would be disallowed? So which meal would not be eligible for reimbursement? So again, starting October 1st, we’re going to need to disallow when a whole-grain rich item is not served at some point during the day. And in this example, the snack would be disallowed and that’s because the snack is the meal with the lowest reimbursement rate and it also contained a grain. What if a grain was not served at snack, and the breakfast grain was not whole-grain rich? So because the grain was not served at snack, and the grain of breakfast is not whole-grain rich, the breakfast meal would need to be disallowed and that means that it’s not eligible to be claimed for reimbursement. In that situation, the breakfast meal is the lowest reimbursed meal that contained a grain. What about a center that serves breakfast and lunch and plans the whole-grain rich item for lunch. However, the center is forced to close early due to severe weather that’s coming. Will meals be disallowed? The answer to this one is no. If a center is unable to serve a meal with the whole-grain rich grain due to extenuating circumstances, no meals need to be disallowed on the basis that the whole grain-rich requirement was not met. So this would be a time when there was a whole-grain rich item planned, but it was very unexpected that they did not serve that meal. What if the center only serves one meal per day? Does the grain have to be a whole-grain rich grain? And the answer to this one is yes. If a center serves only one meal per day, so that would be a breakfast, a lunch, or supper, then the grain served at that meal must be whole-grain rich to meet the whole-grain rich requirements. When a meat or meat alternative is served in place of the grain component of breakfast, which is allowed a maximum of three times per week, and the center serves only that one meal per day, a whole-grain rich item does not need to be served. And also, another example would be, if your center only serves lunch on a Saturday, but during the week they serve breakfast, lunch, and snack, on that one Saturday, that lunch needs to be planned to have a whole-grain and that whole-grain needs to be served. Your Saturday lunches aren’t extenuating circumstances. And let’s not forget about the other updated meal pattern requirements. Both cereal and yogurt have sugar limits, so we don’t want to forget to pay attention to those products as well. We do have a reference guide for you to use when you’re making your selections of cereals and yogurts, and you can find this guide, along with the other updated meal pattern requirements on our website. I know this has been extremely helpful for a specialist as we’re out doing our reviews. You can look at your labels and we can just verify the serving size and the sugar limit for both the cereal and the yogurt. And as I mentioned, just like the whole-grain rich foods, you need to be keeping your product labels from the yogurts, and the cereals, that you’re purchasing, so you can document that you are meeting those sugar requirements for those two types of foods. Don’t forget, you have those old versions of those meal pattern charts hanging in your classrooms. You probably should take those ones down, because they’re not quite accurate anymore. Some other tips, so we’ve seen actually quite a few instances where centers have printed out product information from the internet, and when we look at that documentation, there’s been quite a few times where it does not meet the whole-grain rich requirements or the sugar limit if it was a cereal or yogurt. But in talking with the cook or the director, they swear that when they went shopping they double checked and that it did meet the requirements. So, kind of doing a little investigating, we look in their pantry, in their fridge, and we see that the product labels that they found online don’t match what they actually have on the product they have on hand. And that’s even for products that have the exact same name, so make sure you save or make a copy of the actual item, the box, the the container. And make sure you save the right part of the label, the part that’s showing that it’s meeting whatever is specific to the meal pattern requirements. So if it’s a whole grain-rich item, we might need the ingredient list, we might need a picture or a copy of the front of the package if it’s one of the items with the standard of identity, like that 100% whole wheat bread. If it’s yogurt or cereal, we would need the nutrition facts label that shows how much sugar is in each serving, and that would also include things that have child nutrition labels. You need to be cutting or photocopying the child nutrition label from the actual product package. CN labels that are printed off a website are not good enough. Do you purchase your meals from a vendor? Remember that the vendor works for you. OSPI does not approve vendors or the food or products that the vendor provides to you. So what is your responsibility to ensure that the foods you are serving meet the revised meal pattern requirements? Do you want to just take their word for it or do you want to see the product labels for yourself? We definitely recommend that you take the time to review the supporting documents for the meals the vendor is providing. During CACFP administrative reviews, documentation is going to be requested to show revised meal pattern compliance if it is found that meals do not meet the requirements, and meals need to be disallowed, you as the Sponsor will be paying back the money for those disallowed meals and not your vendor. Also during administrative reviews, we will we will be reviewing your receipts and invoices to not only confirm that you have a non-profit food service, but also to verify that the items that you note on your menu, as whole grain-rich, have been purchased and do also meet the whole grain-rich requirements. Remember that starting October 1st, it is expected that your meals and snacks served will be in full compliance with the revised meal pattern requirements. If they are not, meals are not eligible for reimbursement and they will be disallowed, and this could be very costly to your program. So make sure that you are saving the documentation that you need product labels, child nutrition labels, product formulation statements, recipes, or or package labels that show a FDA health claim. And we will share any additional guidance on the revised meal pattern as it is available, and hopefully we’ll have a revised USDA crediting handbook sometime here soon. We’ve been waiting patiently. So in the meantime, keep all of your product labels. Thanks so much for listening and I’m going to turn it back over to Adelle for some Civil Rights Training. Thanks Molly. Welcome to the Civil Rights training for Federal Child Nutrition Programs. Child nutrition regulations require that we provide Civil Rights training every year to all our institutions. You in turn are required to provide Civil Rights training to all of your staff at all of your centers if you have multiple centers. Civil Rights Regulations are intended to assure that benefits of Child Nutrition Programs are made available to all eligible people in a non-discriminatory manner. All child nutrition program sponsors receiving Federal dollars must implement Civil Rights requirements to be eligible for the program. Discrimination is the different treatment which makes a distinction of one person, or a group of persons, from others either intentionally by neglect, or by the actions, or lack of actions based on the protected classes. The FNS protected classes are race, color, national origin, sex, disability, age, and reprisal or retaliation for prior civil rights activities. The regulation for Civil Rights is listed in the FNS 113 instruction and states specific areas that are required to be included in Civil Rights training. These will be the areas that we will cover today in our training. First, is the collection of data. Local agencies must have a system to collect the racial and ethnic identities of the populations that they serve. This data will be used to determine how effectively the Child Nutrition Programs are reaching a potential eligible persons. Self-identification is the preferred method. Our E/IEAs have an optional section for participants to record racial and ethnic data. If racial and ethnic data is not provided by meal program participants on the EIEAs, or EIEAs are not collected from participating children, such as in emergency shelters or at-risk programs, sponsors must still make their best visual determination of participating children’s racial and ethnic identity using their own judgment. This data is collected annually at renewal on the site application. Notification systems – they’re intended to inform applicants, participants, and potentially eligible persons of the program availability, program rights, and responsibilities, the policy of non-discrimination, and the procedure for filing a complaint. Include the full USDA non-discrimination statement on any materials that share information about Child Nutrition Program benefits- including websites. The non-discrimination statement needs to be included on letters, center parent handbooks, menus, special holiday promotion flyers, brochures, and on the webpage. All non-discrimination statements should be in print size no smaller than the text of the document. It is important to use the most current non-discrimination statement. This statement was last updated in 2015. It’s also important to know that there are different statements for different USDA programs- all our Child Nutrition Programs use the same non-discrimination statement. What we’re showing on the slide right now is the beginning of the current non-discrimination statement. It also concludes at the end about how to file a complaint. There’s also a short statement that is simply- “This institution is an equal opportunity provider”. USDA allows limited use of this short statement if you can’t realistically display the entire statement without changing the nature of the material. For example this shorter statement could be used on meal program menus. The And Justice For All poster must be posted anywhere program benefits are available. This includes anywhere children participating in federal child nutrition programs receive their meals. The poster should also be posted in the administrative offices for child nutrition program sponsors. This poster should be posted where meal program participants, and their parents, can see it. Next is complaint procedures. What is a civil rights complaint? A civil rights complaint is a complaint alleging that discrimination has occurred in violation of one of the protected classes. Every institution must have a civil rights complaint procedure. If you have multiple sites, each site should have a copy of the procedure, and a form to use. If your organization has its own procedure, you may use that. Most importantly, all employees must be aware of and understand the complaint procedure. When taking a complaint, make sure to include language about – informing people about your complaint procedure. Excuse me- make sure to include language about your procedure, where parents might need to find it- such as in handbooks or on your webpages, and anywhere a parent might need to find the information. Always make sure to maintain and manage a complaint log, even if it is a blank tab on an Excel spreadsheet, or a piece of paper. A person can allege that discrimination has occurred and file a discrimination complaint because they feel they were- delayed in receiving benefits or services that others receive, denied benefits or services that others receive, treated differently than others to their disadvantage, or given disparate treatment something- that doesn’t seem discriminatory but has a discriminatory impact in practice. A complaint does not need to be written by the person alleging that discrimination has occurred. If the complaint is verbal, the sponsor needs to record the complaint for the person. Ideally during a verbal complaint the following information will be collected- and this is one of the reasons why we have a sample form, because it makes sure you collect everything you need- this would include contact information of the complaintant, the location and name of the entity delivering the service or benefit ,the nature of the incident or action that led the complaint to feel that discrimination was a factor, the basis on which the complaint and feels discrimination exists- such as the race, color, national origin, etc. The names, titles, and business addresses of persons who may have knowledge of the discriminatory action, and the dates during which the alleged discriminatory actions occurred. Or if continuing- the duration of such actions. Let’s take a look at a scenario. A parent has recently read a lot about gluten, and has decided that the family will be gluten-free the center has told her that they will not provide special gluten-free products, and the parent contacts OSPI to complain. Is this a civil rights complaint? No, it is not a civil rights violation. There is no medical need for the child to have this substitution. Potential civil rights complaints may start with phone call, letter, email, fax, or any form of communication where someone feels they, or someone they know has received unequal treatment in any area of the operation of the child nutrition program. It is a basic right for a person to file a civil rights complaint, however there is a time limit for filing the complaint. It’s very important to document all conversations and information that might be pertinent to a possible civil rights complaint. Because a person who wishes to file a civil rights complaint may report as late as a hundred and eighty days after the date of the alleged occurrence. I would encourage you to use the civil rights complaint form on our OSPI website. As I mentioned, it helps you collect all of the information needed for a civil rights complaint. It also includes instructions for completing and submitting. To find our complaint form, you go to the OSPI CACFP webpages, and the address is there on your screen. Maintaining complete documentation of civil rights complaints is important for all agencies involved in civil rights complaint resolution. Maintaining a complaint log is required by child nutrition program sponsors and the state agency to be in compliance with child nutrition program regulations. Remember, somebody can report a complaint as late as 180 days after the date of the alleged occurrence, so sponsors and the state agency should maintain thorough documentation of all events that could potentially result in a civil rights complaint. OSPI Child Nutrition Services has responsibilities regarding the reporting process. All complaints received by the Office of Civil Rights are acknowledged and investigated. OSPI Child Nutrition webpages have some great resources like our Civil Rights reference sheet that outlines the information that we’re reviewing here. Fourth item we need to mention is compliance review. Assuring compliance with civil rights requirements is a state agency responsibility and is included in the administrative review process. For sponsors with multiple sites- it is important to review civil rights compliance at each of the sites on an ongoing basis. Non-compliance resolution- during compliance reviews, if an area of non-compliance is determined it needs to be resolved. Written notice should be provided describing the non-compliance and the action required to correct the situation. When the corrective action has not been completed within 60 days, OSPI will forward the information to USDA which begins a process to resolve the non-compliance findings. Accommodation of persons with disabilities. There are requirements for reasonable accommodation of persons with disabilities. When a program participant has a diagnosed disability that restricts their diet, the sponsor must provide the prescribed food substitutions or modifications at no charge. For a sponsor to accommodate a dietary need based on a diagnosed disability, a medical note from a recognized medical authority is required. We’ll cover this in more detail a little bit later in this webinar. There are requirements for language assistance. Institutions are expected to take reasonable steps to assure meaningful access. Smaller organizations with smaller budgets, are not expected to provide the same level of language services as larger recipients, with larger budgets. Recipients should carefully explore the most cost effective means of delivering competent, and accurate language services before limiting services due to resource concerns. USDA provides the income eligibility forms in various languages, and we have had centers contact us in the past and use some of the forms that USDA provides. Here’s a map of Washington that shows the percent of persons who speak a language other than English and speak English less than very well. The darker the shading in a county, the higher the percentage that speak English less than very well. Here you can see a breakdown of the languages spoken by people in Washington who speak a language other than English, and speak speak English less than very well. Spanish speakers make up nearly half of this population. Again, the factors to consider for providing language assistance includes what experience you have with people who speak this language, what services they’re needing, the community agencies or religious organizations that can help identify populations who can assist you with this. The more frequent the contact with a specific language group, the more likely that enhanced language services are needed, and steps need to be taken to make sure that you can accommodate their needs. The Civil Rights Division covers many USDA programs and often has different resources available that you may find that you can use. Small institutions may have more limited resources for language assistance than larger ones. It’s important to use the resources we have available. If an institution translates information into a language not available by USDA, we’d love to share it with the rest of the state so let us know about that. Conflict resolution. When people are upset or angry and it is not handled well, there is the potential for people to believe that they have been discriminated against. It is important to work with your staff to be sure they know how to work with parents, so that problems can get resolved rather than escalating. Be sure to address these types of problems with staff during training. Let’s go back to the parent that wanted her child to have a gluten-free diet. How might you respond to this parent? The updated meal pattern regulations now allows the family to provide one item for their child and the center can still claim the meal. You could suggest to the parent that when there is a substitution needed, she could provide a gluten-free option. We will talk about parent provided foods later in the webinar. Customer service and civil rightsit is important to remember that good customer service decreases the likelihood of all complaints. So be sure your staff know how to provide good customer service and who they should refer parents to when difficulties arise. And last, civil rights training. It is the responsibility of the sponsor to document that all staff receives civil rights training each year. Documentation includes a training agenda- including the date of the training and a sign-in sheet of the attendees. Training is important because sponsors need to be prepared to handle a civil rights complaint if one occurs. In addition to training, the sponsor must have a policy in place that describes how the situation will be handled, and who the contact person is for help with handling or documenting the complaint. The policy must list what to do if there is a complaint and who to contact. The Child Nutrition webpages have some resources for you to help you out with this around our Civil Rights requirements and with training your staff. Do you have questions about civil rights and child nutrition programs? If so, visit our webpages or contact your program specialist. Now we’re going to take a moment to change speakers. This is Arianne, and I’m going to be talking about meal modification parent provided foods and requirements specific to sponsoring organizations. What our meal modifications? It’s when a plan to menu item is replaced by another food. A planned menu item can be replaced by another food from the same food component category without medical documentation. Examples of this would be replacing cottage cheese or hamburger or peaches for citrus fruit. These substitutions are permitted to meet a child’s food preference, food allergies, or other health concerns when a menu item is not available. Substitutions must be documented on the menu when the provider decides to make the substitution. Federal law and USDA regulation require nutrition programs to make reasonable modifications to accommodate children with special dietary needs. An impairment which substantially limits a major life activity or bodily function which include allergies and digestive conditions, but do not include personal diet preference, requires a statement by a state recognized medical authority for meal modifications that do not meet the meal pattern. Conditions that require special dietary needs are those that affect physical or mental impairment which substantially limits one or more major life activities. Examples of major life activities include but are not limited to, breathing walking, lifting, eating, communicating, digestive or respiratory function. They do not need to be considered life-threatening in order to constitute a special dietary need. Requirements for meal modifications are written are having a written statement that supports the need for the substitution and provides recommended alternate foods. Those written statements must be signed by a state recognized medical authority, and the center must provide the remaining required meal components in order to claim the meal. The special dietary needs reference sheet can be found at the link on the screen and details requirements for accommodating diets with special needs. We do have a form on our website that you’re welcome to use for special dietary accommodations. This form is available in English and in Spanish. Our form does not need to be used as long as a note from a state authorized medical authority provides the same information. Namely to include a description of how the impairment affects the child, explanation of what must be done to accommodate the child’s diet, and a list of foods and or beverages to be substituted, provided or modified. In the past you’ve asked that the medical disability be stated, and this is no longer a requirement. A state recognized medical authority is defined as a licensed healthcare professional authorized to write medical prescription in the state of Washington. This would include a medical doctor, doctor of Osteopathy, physician’s assistant with prescriptive authority, naturopathic physician, or advanced registered nurse practitioner. Parents have the option to provide food substitutions that modify the meal pattern. And there may be substitutions when a substitution is required or provided for reasons other than a medical need or disability. Examples may include personal preference for example when the parent may prefer that their child have organic food only, moral conviction, and this may include vegan or vegetarian diets, or religious reasons. Since none of these examples are for medical need, and the center has the option to provide a substitution but is not required by law but the parent can provide a substitution for their child. If a parent or guardian provides a substitution and only one component can be provided in order for a meal to be reimbursable- as long as the parent provided food meets the meal pattern requirements AND the center provides the remaining components. There is one exception to this requirement, if a substitution is provided due to a special medical need, then the parent can provide one additional item. As stated earlier in the presentation, substitutions that do not meet the meal pattern are not eligible for reimbursement unless they are supported by a medical statement that is signed by recognized medical authority. Again, the statement needs to outline the need for the substitution and provide recommendations for alternate foods. For fluid milk substitutions, if a parent or center wishes to provide one of the CACFP-approved non-dairy beverages, then the center must obtain a fluid milk substitution form from the parent. This form, along with the list of approved non-dairy beverages, can be found on our website. If the parent chooses to provide a substitution that is not approved, then they need to follow the same procedures outlined earlier and obtain a written medical statement. Please note, lactose free milk meets the meal pattern and does not require a milk substitution form or a signed medical note. Now I’ll ask a few true or false questions to test your knowledge. Providers must make reasonable modifications to accommodate children with special dietary needs including personal diet preference. Is this true or false? This statement is false. The provider does need to make reasonable dietary modifications to accommodate children with special dietary needs, but this does not include personal diet preference. Only one component can be provided by parent or guardian, and a center must provide remaining components for a reimbursable meal. Is this statement true or false? And this is true. A state recognized medical authority only needs to list the foods a child should avoid in the doctors note. Is a statement true or false? And this is false, the doctor’s note needs to describe how the impairment affects the child, explain what must be done to accommodate the child’s diet, and list the foods and or beverages to be substituted, provided or modified. An approved non-dairy beverage requires a written medical statement that is signed by state recognized medical authority. Is this true or false? And this is false. Approved non-dairy beverages do not need a signed written medical statement, but they do require a fluid milk substitution form. We’ll now talk about a requirement specific to sponsors of multiple sites. Sponsoring organizations or a sponsor of more than one site has some special requirements that single-site organizations do not have. In the sponsor application in WINS, sponsoring organizations must answer yes to the question- “Are you participating as a sponsoring organization?” Once you do this, the management plan will show up. You are also required to complete the site reviews for all of your sites. How many site reviews must be done each fiscal year? There are three site reviews per year that must be completed, unless you are doing review averaging, which must be planned ahead of time with your program specialist. How much time can lapse between reviews ? There must be no more than six months between site reviews. Who can complete the site reviews? A trained employee of your organization, a site director cannot review their own site. Also, all sites must be reviewed within the first four weeks of opening, reviews cannot be contracted to be done outside of your organization, and the form used to conduct the site reviews is located on our k-12 website. When doing your site review, you want to make sure to complete the entire form and indicate if the review is an unannounced or a follow-up review. The reviewer must check prior site reviews to see if corrective action is in place and permanently corrected. Note that two of the three site reviews must be unannounced. Once the site review is completed, always discuss the site review with the person in charge at the site, and be sure that you both sign and date the form. We’re finding many organizations are not correctly completing their site review form and there are errors in several sections of the review form. You may not be physically able to observe the complete meal in every classroom, but you do need to observe as much as you can and look at meal counts and attendance for each room. Don’t forget to check the box on the review form noting the type of meal service, whether it’s pre-portion or family-style and record all meal components served – including the type of milk. You’ll also want to note the time you began and ended the meal observation. Be sure to check in WINS to make sure that the site calendar is the same time that the meal was observed. If there is a discrepancy, you’ll have to make sure to change this in WINS. During your site review, you’ll have to complete a five-day meal count reconciliation. Record the meal count and attendance for the last five serving days for the entire site- not just one classroom. Do not include holidays or date of review as part of the five days. After you’re done with the meal count reconciliation, you’ll want to compare the number of meals that you observed with the attendance. The meal count cannot be higher than the attendance. If you notice, that on the day of review, there are more children in attendance and more meals served, or less meals served or children in attendance, you’ll want to note why there is a discrepancy. This is a snapshot of review form just showing you that it’s easy to miss boxes. The boxes that are not completed here are the total daily attendance. Please make sure that you fill this form out completely. Another part of the site review is completing the enrollment form verification. This is not applicable for at-risk, emergency, or outside school hours centers. During the enrollment form verification you’ll want to list names of 10% of the children attending in the past five days. Check to see if enrollment forms are on file for those children. If an enrollment form is missing, it needs to be noted in the corrective action section of the form and obtained. A variety of meals must be observed. You may not always observe lunch because it is easier to observe than other meals. Indicate if corrective action is required. Indicate if prior review findings were corrected. Monitor and Site Director must sign and date the form. Again site directors can review each other sites but not their own site. The next few slides are showing you what a completed form looks like- please note that all the boxes have been checked. Please note on this page- the meal counts and meal reconciliation has been done completely and filled out thoroughly. This is the last page of a correctly completed site review form. Note that it is signed and dated by both the monitor and the site representative. Just a reminder that all centers, including single site sponsors, must provide training on the topics listed here. To include CACFP meal pattern, civil rights, record-keeping, claim submission, meal counts, and the reimbursement process. The documentation must include the date, sign-in sheet, agenda, and the handouts that were used. This concludes our annual training for child care centers. Please remember to certify your attendance in today’s training at the link found on the website where you are viewing this training. If you have specific questions to the training that you viewed today, please contact your specialist directly.