CACFP Manual for Emergency Shelters


Overview of CACFP

CACFP serves nutritious meals and snacks to eligible children and persons with disabilities, as defined under 7 CFR 226.2, who reside in participating emergency shelters. Emergency shelters participating in CACFP must follow program regulations.

Training Objectives

  • Understand the staff and director's responsibilities for the emergency shelters or sponsoring organization’s (SO) participation in the Child and Adult Care Food Program (CACFP).
  • Understand the responsibilities of the Department of Health and Senior Services Community Food and Nutrition Assistance (DHSS-CFNA) in administering the CACFP.
  • Understand how sponsors meet and comply with CACFP performance standards.
  • Understand the importance of accurate recordkeeping and its role in verifying the shelter’s claims for reimbursement.
  • Identify the records that must be maintained by shelter staff to meet regulatory requirements. Explain the procedures for completing each record.
  • Understand Civil Rights compliance requirements.
  • Use the meal pattern requirements and menu planning process to create nutritious and creditable meals.
  • Explain how to use the United States Department of Agriculture Food Buying Guide (FBG) for Child Nutrition Programs and the Crediting Handbook for the CACFP to assist with menu planning.
  • Explain the importance of good nutrition in the emergency shelter setting.

Benefits of the Child and Adult Care Food Program

The Child and Adult Care Food Program (CACFP) can be an important resource to emergency shelters that provide residential and food services to children and persons with disabilities who are experiencing homelessness.

The CACFP is a federal program that provides reimbursements for nutritious meals and snacks to children ages birth to 18 years of age and persons with disabilities as defined under 7 CFR 226.2 who reside in participating emergency shelters. CACFP contributes to the wellness, healthy growth, and development of young children in the United States.

CACFP plays a vital role in improving the quality of the meals served in the emergency shelters, making it more affordable for the organization. Benefits include:

  • Shelters may be approved to claim up to three meals or two meals and one snack for each resident participant per day.
  • Training and technical assistance are available on nutrition, food service operations, program management, nutrition education, and recordkeeping.
  • Improved health and well-being of infants and children through age 18 and persons with disabilities by providing nutritious, well-balanced meals.
  • Development of healthy eating habits in children that will last through their lifetime.

Key points To Remember About CACFP

  • Providing nutritious meals and snacks is the primary goal. The mission of the Food and Nutrition Service (FNS) is to provide children and families better access to food and a more healthful diet through its food assistance programs, such as CACFP, and nutrition education efforts in compliance with 7 CFR 226.
  • CACFP is a supplementary program, not an entitlement program, which requires accurate recordkeeping and program compliance.
  • United States Department of Agriculture’s (USDA) FNS administers the CACFP at the national level, and the Department of Health and Senior Services-Community Food and Nutrition Assistance (DHSS-CFNA) is the State Agency (SA) that administers the program in Missouri.
  • The DHSS-CFNA is regulated by Congress and the USDA.
  • The DHSS-CFNA will conduct CACFP monitoring reviews at all participating emergency shelters and sponsoring organizations pursuant to 7 CFR 226.

Performance Standards

Financial Viability, Administrative Capability, Program Accountability

The executive director and the board chair or owner of the child care facility or sponsoring organization (SO) and those named as a responsible individual and food program contact must, due to their position in the facility, accept final administrative and financial responsibility for the Child and Adult Care Food Program (CACFP) and ensure that the CACFP is operated with program integrity.

Each new independent facility, SO of two or more facilities, or renewing facility must submit information sufficient to document that it is financially viable, is administratively capable of operating the program in accordance with CACFP regulations, and has internal controls in place to ensure accountability. To document this, any new sponsor, which may include an independent facility or an SO of two or more facilities, must demonstrate in its application that it is capable of operating in conformance with the CACFP performance standards.

The Department of Health and Senior Services-Community Food and Assistance (DHSS-CFNA) must only approve the applications of those new sponsors that meet these performance standards and deny the applications of those new sponsors that do not meet the standards. In ensuring compliance with these performance standards, the DHSS-CFNA establishes rules and procedures and makes decisions based on information from internal controls at the federal and state level that includes information obtained during the application process, information from audits and complaints, results of edit checks, claim reviews, monitoring reviews; and notice of civil and criminal action.

Each new independent facility, SO of two or more facilities, or renewing facility must submit information sufficient to document that they are operating in accordance with the CACFP Performance Standards – Viability, Capability, and Accountability (VCA) outlined in 7 CFR 226.6(b)(1):

  1. The organization must be Financially Viable. The facility must have a budget and demonstrate it has adequate financial resources to operate the CACFP on a daily basis, has adequate sources of funds to continue to pay employees and suppliers during periods of temporary interruptions in CACFP payments and/or to pay debts when fiscal claims have been assessed against the sponsor, and can document financial viability through audits or financial statements. Sponsors must ensure that CACFP funds are expended and accounted for in accordance with CACFP regulations, 2 CFR 400, and the requirements in FNS Instruction 796-2, rev. 4.

    The organization should expect that DHSS-CFNA will review the SO’s financial records at least annually.
  2. The organization must be Administratively Capable. The facility must have appropriate and effective management practices in place to provide program benefits to all participants and an adequate number and type of qualified staff to operate the CACFP. An SO of two or more facilities must document in its management plan that it employs staff sufficient to meet the ratio of monitors to facilities, taking into account the factors that DHSS-CFNA will consider in determining an SO’s staffing needs, as set forth in CACFP regulations. An SO must have written program policies and procedures that assign program responsibilities and duties. An SO’s policies and procedures must also ensure compliance with civil rights requirements.
  3. The organization’s program must be Accountable. The facility must have internal controls and other management systems in effect to ensure fiscal accountability and ensure that the CACFP will operate in accordance with requirements. To demonstrate program accountability, the sponsor must document that it meets the following criteria:
    • Board of Directors – have adequate oversight of the program by an independent governing board of directors.
    • Fiscal Accountability – have a financial system with management controls specified in writing. These written operational policies must ensure the following:
      • Fiscal integrity and accountability for all funds and property received, held, and disbursed.
      • The integrity and accountability of all expenses incurred.
      • Claims will be processed accurately and in a timely manner.
      • Funds and property are properly safeguarded and used.
      • Expenses incurred are for authorized program purposes.
      • A system of safeguards and controls is in place to prevent and detect improper financial activities by employees.
    • Recordkeeping - maintains appropriate records to document compliance with CACFP requirements, including budgets, accounting records, approved budget amendments, management plans, and appropriate records on facility operations. There must be documentation in the management plan that the organization will provide adequate and regular training of its staff and sponsored facilities.
    • Documents that prove compliance with CACFP regulations, including, but not limited to, menus, production records, delivery receipts, income eligibility forms, meal count records, and attendance records, shall not be altered. If additions/corrections are required, they must be made using ink. The incorrect information must be crossed out using one line so that the original information can still be read. Changes using pencils or white out shall be prohibited. All changes must be initialed and dated by the person making the correction.
    • SO operations - documentation in the management plan that the SO will perform monitoring to ensure the sponsored facilities accountably and appropriately operate the program, and have a system in place to ensure that administrative costs do not exceed the regulatory 15 percent limitation.
    • Meal Service and other operational requirements - follow the practices that result in the operation of the program in accordance with the meal service, recordkeeping, and other operational requirements of the federal regulations. These practices must be documented and must demonstrate that the independent facility or sponsored facilities will:
      • Provide meals that meet meal pattern requirements.
      • Comply with licensure or approved requirements.
      • Have food service that complies with applicable state and local health and sanitation requirements.
      • Comply with civil rights requirements.
      • Maintain complete and appropriate records on file.
      • Submit claim reimbursement only for eligible meals.

Program Integrity

CACFP regulations define Seriously Deficient (SD) as the status of an independent facility or SO of two or more facilities that has been determined to be non-compliant in one or more aspects of its operation of the program. If a sponsor is unwilling or incapable of correcting serious problems, the SD process protects program integrity by removing the institution from the program.

The chairman of the Board of Directors, the executive director, or owner, as well as other person(s) responsible for the Child and Adult Care Food Program (CACFP) operation, such as the responsible individual and the food program contact, noted on the Center and/or Sponsor Info Sheets on the Application/Claims database are considered the “responsible individual(s)” or “responsible principal(s)” of the organization. By virtue of the management position as a “responsible principal,” you have administrative and financial responsibility for the oversight, management, and integrity of the CACFP and compliance with applicable regulations.

Should a sponsor ever be classified as SD and terminated due to mismanagement of the CACFP, the name(s) of the “responsible principal(s)” and “responsible individual(s)” will be placed on the United States Department of Agriculture’s (USDA) National Disqualified List (NDL). Once on the NDL, the responsible parties named would not be able to work in another organization that participates in the CACFP or any other Child Nutrition Program for up to seven years.

Financial Review

In August of 2023, the USDA-FNS published a final rule on program integrity to ensure that child nutrition programs are properly operated and managed to protect federal taxpayer dollars. As part of this final rule, the state agency is required to review your financial records at least annually. The following records must be made available upon request:

  • At least one month of all bank account activity associated with CACFP will be reviewed against other associated records to verify that the financial transactions meet program requirements.
  • The actual expenditures of CACFP funds and the amount of reimbursement funds retained from unaffiliated centers to support the sponsoring organization’s administrative costs will be reviewed.
  • The reported expenditures will be reconciled with program payments to ensure that funds are accounted for fully.

Management Tools and Resources

CACFP sponsors enter into a contract with the Department of Health and Senior Services Community Food and Nutrition Assistance (DHSS-CFNA) to participate in the CACFP. The following management tools and resources are available on the Missouri CACFP website. [NEEDS LINK]

  • CACFP Income Eligibility Guidance for Child Care Centers
  • United States Department of Agriculture Food Buying Guide for Child Nutrition Programs
  • Crediting Handbook for the Child and Adult Care Food Program
  • Child & Adult Care Food Program Manual for Child Care Centers
  • “And Justice For All” poster
  • Building for the Future flyer and pamphlet
  • Missouri WIC outreach poster

Single Audit Compliance

Under 2 CFR 200.501—Audit Requirements, SFSP Sponsors are required to submit a Single Audit within nine months of the close of your fiscal year for any fiscal year in which you expend $1,00,000.00 or more in federal funds.

A Single Audit is when a professional auditor goes over a grantee’s financial management processes, including its financial management system and its compliance with all of its federal grant requirements. It is called a Single Audit because it combines one audit covering all of a grantee’s federal grants. The purpose is to ensure that grantees receiving federal grant funds use the funds in compliance with the government’s requirements. It was created to promote sound financial management, promote uniform guidelines for audits and deploy audit resources efficiently.

Failure to comply will result in a declaration of Serious Deficiency by the state and possible program termination.

Discovering Problems

The following is a management assessment tool that describes some of the more common indicators of program mismanagement identified through federal and state-level internal controls.

Child and Adult Care Food Program Institutions Indicators of Potential or Existing Problems (Red Flags!)

Budget/Claim for Reimbursement
  • Year-to-date claims do not reflect the approved budget.
  • Questionable or potentially fraudulent meal-claiming practice (e.g., meals claimed when the facility is closed).
  • Expenditures charged to the nonprofit food service that are not listed on the budget approved by the state agency.
Operational Oversight
  • No qualified accountant or adequate accounting information system.
  • Lack of internal controls (e.g. inadequate separation of duties, position held by family member limits internal control).
  • Related party transactions (e.g., when the director or family member is the owner of the catering company used for contracted meals or the owner of the rented property housing the CACFP facility).
  • Absentee management.
  • Substantial difference between the number of participants observed at meal time during the monitoring review and the Average Daily Participation (ADP) for the same meal for the review month.
Audits
  • Required audits or monitoring reviews are not performed by SOs.
  • The Management/Board of Directors does not follow up on corrective action taken.
Other
  • Health and safety concerns reported from any source.

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