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Certification Regarding Principals, Board Members

Nutrition Services Division Management Bulletin

To: Child and Adult Care Food Program Sponsors

Number: 04-201

Attention: Food Program Director

Date: February 2004

Subject: Certification Regarding Principals and Board Members

Reference: United States Department of Agriculture CACFP Policy Memo 03-11

This Management Bulletin provides guidance from the United States Department of Agriculture (USDA) regarding the requirement that Child and Adult Care Food Program (CACFP) agencies certify that none of their principals (program managers and board members) have been convicted of misdemeanor or felony business related offenses within the past seven years.

The CACFP Interim Rule to Strengthen Program Integrity, 7 Code of Federal Regulations 226.15(b)(8), requires an agency to certify that “neither the institution nor any of its principals have been convicted of any activity that occurred during the past seven years and that indicated a lack of business integrity.” A lack of business integrity includes fraud, embezzlement, theft, receipt of stolen property, and making false claims.

The USDA guidance (attached) suggests the most effective means by which an agency principal can attest to the lack of a criminal background is to ask each principal to complete a form attesting to their business integrity. We suggest that institutions collect the certifications from their principals on an annual basis and maintain them on file for review and audit purposes. We are attaching a sample form that can be used to collect this certification.


USDA CACFP Policy Memo 03-11 at
Certification of Principals - Sample Form at

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Thursday, July 24, 2014

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