Special Considerations for a CACFP Sponsor Board of Directors

ARAM, CACFP, SFSP
My Food Program Working With a Board of Directors Blog Post
A practical guide to board oversight
Serving on the board of a Child and Adult Care Food Program (CACFP) sponsor involves more than attending meetings. Sponsors manage federal funds and oversee Program rules at multiple facilities or providers.
 
Board members must understand these duties, ask questions, and keep records of their decisions. Active oversight helps protect Program funds and keeps the organization on track.

The Board Must Be Independent

Under 7 CFR § 226.2, an independent board meets regularly and has the power to hire and dismiss the executive director. This power must be real, not just written in the bylaws. Members should be able to review management’s work fairly and act when needed. A board made up mainly of employees, relatives, or people with financial ties to the sponsor may struggle to act independently. Choose members carefully and set clear rules for conflicts of interest.

Board Members Need CACFP Training

Members do not need to know every rule. They do need enough training to spot risks and ask useful questions. Training should cover:
  • Sponsor duties to facilities and providers
  • Meal patterns and who can participate
  • Monitoring visits and steps to correct problems
  • Claim review and submission
  • Allowed costs and purchasing rules
  • Civil rights and recordkeeping
  • The serious-deficiency process and consequences of poor management
Keep a record of board training. Provide updates when rules, state policies, or key staff duties change.

Financial Oversight Goes Beyond the Bank Balance

The board must ensure that written controls protect CACFP funds and limit spending to allowed Program costs. Financial reports should show:
  • CACFP funds received and provider payments made
  • Office and management costs compared with the budget
  • Business dealings with people connected to the sponsor
  • Credit card charges and expense repayments
  • Debts and other amounts owed
  • Audit findings and plans to correct problems
Under 7 CFR § 226.6, sponsors must show that they have sound finances, can manage the Program, and have systems to ensure accountability. Divide financial tasks when possible. One person should not approve a purchase, pay for it, record it, and check the bank records.

Identify and Manage Conflicts of Interest

Staff or board members may have personal or financial ties to vendors, landlords, or others doing business with the sponsor. These ties are not always banned, but they need careful review. A written policy should require members to:
  • Report actual or possible conflicts before the board discusses a deal
  • Step out of discussions and votes when appropriate
  • Record the decision and why it serves the organization’s interests
Meeting minutes should explain the conflict, who stepped out, and why the board approved or rejected the deal.

Report and Follow Up on Compliance Problems

Management should promptly tell the board about major problems and provide a written plan to fix them. The board should follow up until each problem is resolved. Reports should include:
  • State agency findings
  • Proposed claim denials or repayment demands
  • Major audit findings
  • Staff misconduct affecting CACFP
  • Serious data-security or recordkeeping problems
  • Ending sponsorship of a major facility or provider
For each issue, the board should know who is responsible, when action is due, and how staff will confirm that the fix worked.

Keep Clear Records of Board Actions

Meeting minutes should show what the board reviewed, discussed, and decided. They do not need to record every word. Include:
  • Who attended
  • Financial and CACFP reports reviewed
  • Conflicts of interest and who stepped out
  • Contracts and major purchases approved
  • Plans to correct problems and follow-up results
  • Executive director reviews
  • Formal votes and decisions
These records help show that members considered risks and made informed choices.

Plan for Key Staff Changes

The sponsor should be able to keep operating if a key employee leaves or becomes unavailable. Too much knowledge or control in one person creates risk. A backup plan should cover:
  • Secure access to banking, accounting, and CACFP systems
  • Claim submissions and monitoring schedules
  • Contact with the state agency
  • Payroll and provider payments
  • Access to contracts, policies, and Program records
  • Who takes over key duties and decisions
Train backup staff and write down essential steps. Store instructions and access details securely so authorized staff can use them when needed.
A Practical Board Checklist

Review these questions regularly.

  • Do we meet regularly and record our decisions?

  • Do members understand the sponsor’s CACFP duties?

  • Are financial reports clear, complete, and on time?

  • Are Program funds spent only on allowed costs?

  • Are conflicts of interest reported and managed?

  • Are required monitoring visits completed?

  • Are problems fixed on time, and do the fixes work?

  • Do we have enough staff and resources?

  • Are we told about major findings and concerns?

  • Could we keep operating if a key employee left tomorrow?

Federal References

7 CFR § 226.2
Definition of an independent governing board of directors

7 CFR § 226.6
State agency duties and CACFP performance standards
Sample Board Meeting Agenda

Sending agendas and packets ahead of time allows meetings to focus on discussion instead of catching up. Click the image below to download a sample Board Meeting Agenda.

My Food Program Board Meeting Sample Agenda