PolicyBrief
H.R. 2818
119th CongressApr 10th 2025
Early Childhood Nutrition Improvement Act
IN COMMITTEE

This Act improves early childhood nutrition programs by revising eligibility certification for proprietary centers, streamlining serious deficiency reviews, adjusting meal reimbursement limits, updating inflation calculations, and establishing an advisory committee to reduce paperwork burdens.

Suzanne Bonamici
D

Suzanne Bonamici

Representative

OR-1

LEGISLATION

Child Care Food Bill Mandates Paperwork Reduction Committee, Shifts Inflation Tracking for Meal Reimbursements

The Early Childhood Nutrition Improvement Act is essentially a major system upgrade for the Child and Adult Care Food Program (CACFP), which is the federal program that helps pay for meals served in daycares and after-school programs. This bill isn't about radically increasing funding; it’s about modernizing the bureaucracy and making sure the money that already exists is delivered more efficiently and fairly. Key changes include streamlining how for-profit centers qualify, completely overhauling the process for finding serious deficiencies, and launching an all-out war on paperwork.

The War on Paperwork: Digital Docs and Advisory Committees

If you run a small family daycare or a large child care center, Section 6 is your new best friend. It requires the Secretary of Agriculture to establish an advisory committee within 180 days solely focused on cutting the massive administrative burden associated with CACFP. This committee must include representatives from every corner of the program—from small family homes to large centers and state agencies—to figure out how to ditch unnecessary forms and streamline recordkeeping.

The bill specifically mandates that new guidance must allow states to accept digital forms, electronic signatures, and electronic records as valid documentation. Think about that for a second: no more hunting down paper forms or needing wet signatures just because a state agency hasn't caught up with 2024 technology. The goal here is to make applications simpler and monitoring less invasive, which frees up providers to spend more time with kids and less time wrestling with a filing cabinet.

Clearing Up 'Serious Deficiencies' and Impartial Appeals

Section 3 tackles one of the most stressful parts of running a federally funded food program: the “serious deficiency” finding. Right now, if a state agency finds a serious problem, it can result in disqualification. This bill recognizes that the rules are often confusing, especially when states add their own requirements on top of federal law.

To fix this, the bill requires the Secretary to review and revise the entire process. Crucially, it demands that the new rules must distinguish between a simple, honest mistake—a “reasonable margin of human error”—and intentional or systemic problems. Furthermore, the Secretary cannot use a state’s own specific rules (those that go beyond federal law) when deciding if a program is seriously deficient. For providers, this means the federal hammer can only fall based on federal rules, offering a clearer, more predictable standard.

It also mandates a formal appeals process run by a trained, impartial official who has zero connection to the agency that made the original finding. If you’re a small daycare owner, this is huge: it ensures you get a fair shake and aren't appealing a ruling to the same people who made it.

Who Pays for Lunch? Tracking Costs and Setting Limits

Section 4 clarifies reimbursement limits, a necessary step for program integrity. Daycare providers can generally be reimbursed for up to two meals and one snack, or one meal and two snacks, per child per day. However, the bill adds a clear exception: if the care schedule spans eight or more hours, providers can claim reimbursement for a third meal or an extra snack. This directly supports working parents who need full-day care and ensures their children get adequate nutrition during long shifts.

Section 5 makes a subtle but significant change to how meal costs are adjusted for inflation. Currently, these adjustments are based on the Consumer Price Index for food at home (grocery prices). The bill shifts this to the Consumer Price Index for food away from home (restaurant/takeout prices). Since child care centers are essentially buying and preparing food in a commercial setting, this change aims to track their actual operating costs more accurately. If restaurant costs rise faster than grocery costs, this change benefits providers by increasing their reimbursement rate slightly more, helping them keep up with inflation.