Prior Approval for CACFP Allowable Costs
Nutrition Services Division Management Bulletin
Purpose: Policy, Beneficial Information
To: Child and Adult Care Food Program Agencies
Attention: Program Operators
Date: February 2017
Reference: Title 2, Code of Federal Regulations, sections 200.33 and 200.439; Management Bulletin CACFP-06-2014: Streamlining Child and Adult Care Food Program (CACFP) At-risk Afterschool Meal Participation for School Food Authorities; U.S. Department of Agriculture (USDA) Food and Nutrition Service Instruction 796-2, Revision 4; USDA Guidance for Management Plans and Budgets: A CACFP Handbook, December 2013; and USDA Policy Memorandum CACFP 11-2016: State Agency Prior Approval Process for School Food Authority Equipment Purchases
Subject: Prior Approval for Child and Adult Care Food Program Allowable Costs
This management bulletin (MB) provides clarification on the required prior approval of allowable costs in the Child and Adult Care Food Program (CACFP). The U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS) Instruction 796-2, Revision 4, establishes guidelines for the financial management of CACFP funds. These guidelines include, but are not limited to, information on CACFP allowable costs, and the level of approval required for such costs. As a reminder, all costs, including food, require prior approval before the cost is incurred. Some expenses require specific prior written approval by the California Department of Education (CDE) or the FNS, depending on the nature of the cost. An agency’s failure to obtain prior approval, or specific prior written approval, for any CACFP cost will result in findings during the administrative review and audit processes. As with all findings, significant noncompliance may result in declaring an agency seriously deficient.
For expenses that require prior approval, the cost must be approved on the appropriate budget line in the Child Nutrition Information and Payment System (CNIPS). CDE approved budgets, therefore, must be based on real CACFP costs. In the CNIPS, agencies must submit budget revisions and obtain CDE approval prior to exceeding a budget line in the original approved annual budget.
Because the CDE considers a school food authority’s (SFA) successful operation of the National School Lunch Program as sufficient evidence of administrative capability and financial viability, SFAs are not required to submit budgets for the At-risk Afterschool Meals Component of the CACFP. This exemption, however, only applies to costs that require prior approval, and not to costs that require specific prior written approval. For more information, see MB CACFP-06-2014, Streamlining CACFP At-risk Afterschool Meal Participation for SFAs located on the CDE CACFP Web page at http://www.cde.ca.gov/ls/nu/cc/mbsn212014cacfp062014.asp.
Specific Prior Written Approval
CACFP allowable costs that require specific prior written approval must be approved in writing by the CDE or the FNS. Effective February 23, 2017, for SFAs on the CACFP, specific prior written approval is not required for equipment ($5,000 or more per unit) detailed on the USDA Capital Expenditure Approved List. You can find this list on the CDE Capital Expenditure Approved List Web page at http://www.cde.ca.gov/ls/nu/sn/capexpapprovedlist.asp.
However, if any SFA, including an SFA on the At-risk Afterschool Meals Component of the CACFP, would like to purchase equipment included in this list, the agency must include the cost of this equipment on the appropriate CNIPS budget line and obtain prior approval from the CDE. [Note: The previous sentence was originally included in error. SFAs are not required to submit budgets if they solely participate in the At-risk component of the CACFP, and, if they participate in the regular child care portion of the CACFP, do not have to submit a charge for the pre-approved equipment on their required CACFP budget. Reference: The Healthy, Hunger-Free Kids Act of 2010, Public Law 111-296; U.S. Department of Agriculture Policy Memo CACFP 08-2012; California Department of Education Management Bulletins USDA-CACFP-01-2011 and USDA-CACFP-02-2011.]
If you have any questions regarding this subject, please contact your CACFP specialist. A contact list of CACFP specialists is available in the Download Forms section of the CNIPS, Form ID CACFP 01. You can also contact Nancy Charpentier, CACFP Office Technician (OT), by phone at 916-327-2991 or by e-mail at email@example.com, or Leslie Schar, Community Nutrition Programs Administration OT, by phone at 916-324-6153 or by e-mail at firstname.lastname@example.org, to be directed to your CACFP specialist.