Allowable Costs Related to Physical Activity

This Management Bulletin (MB) provides guidance on the use of the Child and Adult Care Food Program (CACFP) funds for training and technical assistance (TA) related to the promotion of physical activity and limiting the use of electronic media. This guidance applies to the use of administrative funds, nonprofit food service account funds, and State Administrative Expense (SAE) funds. For questions and answers pertaining to costs related to physical activity and limiting the use of electronic media in the CACFP, see the U.S. Department of Agriculture (USDA) Policy Memo CACFP 15-2015 Allowable Costs Related to Physical Activity and Limiting the Use of Electronic Media in the CACFP at the USDA web page.

The Healthy, Hunger-Free Kids Act of 2010 (HHFKA) amended the Richard B. Russell National School Lunch Act to expand the purpose of the CACFP to provide aid to child and adult care institutions and family or group day care homes for the provision of nutritious foods that contribute to the wellness, healthy growth, and development of young children, and the health and wellness of older adults and chronically impaired disabled persons (Title 42, U. S. Code [42 USC ], Section 1766[a][1][A][ii]). The HHFKA also directed the USDA to encourage child care centers and day care homes to provide opportunities for physical activity/active play and to limit the use of electronic media (42 USC 1766[u]).

Promotion of physical activity and limiting the use of electronic media is not required under CACFP regulations; however, the Food and Nutrition Service (FNS) encourages state agencies (SA) and CACFP facilities to adopt best practices to promote the health and wellness of CACFP participants. The FNS recognizes that many SAs and CACFP facilities have already incorporated wellness information into their ongoing CACFP training materials. This memorandum states that developing such training may be an allowable use of the CACFP funds as described below.

Allowable Costs for Child and Adult Care Food Program Institutions and Facilities

Any costs associated with training and/or the development or distribution of materials must be reasonable, necessary, and allocable (i.e. the program has derived benefit from the cost and therefore the portion attributable to the program may be allowed). On February 25, 2015, the FNS released CACFP 08-2015, Assessing Costs in the CACFP, along with a tip sheet that provides guidance on the process SAs and sponsors should use when considering proposed uses of the nonprofit food service account funds for CACFP-related costs. CACFP 08-2015 is available on the USDA Policy web page.

The FNS Instruction 796-2 allows CACFP funds to be used for wellness efforts under certain circumstances and includes questions and answers relating to the use of program funds for the cost of training, materials, and supplies that encourage physical activity and limiting the use of electronic media (FNS Instruction 796-2, Rev. 4, Section VII, A 3).

Sponsoring organizations may use administrative funds, independent and unaffiliated centers may use their nonprofit food service account funds, and day care home providers may use CACFP reimbursement for wellness efforts, including promoting physical activity and limiting the use of electronic media. However, the use of funds may not jeopardize the quality of meals served or compliance with any other program requirements. Additionally, costs incurred by facilities related to training that promotes physical activity or limiting electronic media are treated as other allowable meeting and conference costs (FNS Instruction 796-2, Rev. 4, Section VIII, I, 28).

Free Resources

The following USDA resources are free to program participants and available to download at no cost:

• USDA Team Nutrition resource library

• USDA MyPlate.gov website

Additional resources for increasing physical activity and limiting the use of electronic media can be found on the Healthy Kids, Healthy Future website.

The FNS encourages SAs and CACFP participants to use these materials first. Within the parameters described above, CACFP administrative funds and reimbursements may be used to print, distribute, and use USDA publications and guidance materials and other free training materials that support physical activity and limiting electronic media use.

When these free resources are not sufficient and with prior SA approval , institutions may develop and distribute new materials as long as:

• materials (e.g., training curricula, toolkits, newsletters, pamphlets, etc.) emphasize the link between nutritious meals and physical activity and/or limiting the use of electronic media.
  
  
• cost for these materials are reasonable, necessary, and allocable as it relates to CACFP requirements.

Expenditures for publications, printing and reproduction, training program costs, and materials/supplies require prior approval (FNS Instruction 796-2, Rev. 4, Section VIII, I, 27, 30, and 33). Requests for approval must clearly demonstrate how and why existing resources are inadequate.

When reviewing these expenditures, SAs are expected to carefully consider whether the use of program funds for wellness activities constitutes a reasonable and necessary expense. As part of this review, SAs should consider whether existing training programs and other materials are available before allowing the use of program funds to pay for or develop new materials. The following questions may be used to help determine if costs are allowable:

• What product or service is being considered for acquisition?
  
  
• How does this product or service directly benefit the operation and/or improvement of the program and its priorities?
  
  
• What is the estimated cost of the product or service?
  
  
• Is the product or service currently available, or would the purchase of the product or service be duplicative and not cost effective?
  
  
• What alternate free or low-cost options to address the need have been considered?
  
  
• Would the proposed cost divert nonprofit food service account funds from supporting food costs or food service operation staff time and effort, and thus impair or diminish the delivery of the meal service?

Allowable Costs for State Agencies

SAs may use SAE funds for wellness activities within the guidelines outlined above and with prior FNS Regional Office approval. However, SAE funds are made available only for state-level costs and may be used for training and TA related to wellness activities only if the costs meet all criteria for an allowable cost (i.e., necessary, reasonable, and allocable).

Alternative Funding Opportunities

All SAs and CACFP institutions and facilities are encouraged to seek alternate funding and/or grant opportunities, when available, to promote physical activity and limit the use of electronic media in child care settings. Many local health departments (LHD) receive USDA Supplemental Nutrition Assistance Program Education (SNAP-Ed) funds to implement comprehensive community obesity prevention and nutrition promotion programs. A list and contact information for the LHDs receiving SNAP-Ed funding can be found on the California Department of Social Services CalFresh Healthy Living (SNAP-Ed) web page.

Questions

If you have any questions regarding this subject, please contact your county’s CACFP Specialist. A list of CACFP Specialists is available in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS), Form ID CACFP 01. You can also contact the CACFP Unit Office Technician by phone at 916-651-54001 or by email at CACFPinfo@dss.ca.gov to be directed to your CACFP Specialist.

This institution is an equal opportunity provider.

Esta institución es un proveedor que ofrece igualdad de oportunidades.