Policy Memo 168

DOH-CACFP: Number 168 (8/13), Supersedes Number 163 (12/11)

TO: All EWPHCCS Grantees

FROM: Sandra Rhoades, Director, Homes Administration Unit and Obesity Prevention and Outreach Unit, Child and Adult Care Food Program

SUBJECT: Eat Well Play Hard in Child Care Settings (EWPHCCS) Fiscal Record Requirements and Use of Incentives

I. Purpose and Scope

Fiscal audits of EWPHCCS grantees are conducted by State, Federal and/or independent auditors to verify that SNAP-Ed funds are used in accordance with applicable regulations. Complete and accurate records are required to support all expenses. This memo provides EWPHCCS grantee organizations with guidelines from the SNAP-Ed Plan Guidance regarding fiscal record keeping and nutrition education reinforcement materials.

II. Background Information

1. Fiscal Record Keeping refers to the process used to document costs charged to the EWPHCCS project grant. Grantees must account for all costs of operation through the consistent use of generally accepted accounting principles (GAAP). All costs must be properly documented and be necessary, reasonable and allowable under SNAP-Ed guidance found at (http://snap.nal.usda.gov). Costs may only be charged in the Federal Fiscal Year in which they are encumbered or obligated. The following three costs commonly lacking adequate documentation.
   1. Food Receipts: Food receipts must be retained for EWPHCCS related activities, preferably separate from other food costs. Write the name of items purchased when the receipt abbreviates or does not itemize the foods. The following information must be attached to food receipts:
      1. the name of the recipe being prepared;
      2. the date of the EWPHCCS lesson; and
      3. the name and location of the center where the lesson will take place.
   2. Mileage or Public Transportation Costs: Record the address of the starting and ending location of each trip. This will be the supporting documentation for mileage costs of using personal vehicles or the fees for public transportation charged to EWPHCCS. See attached sample mileage/public transportation form.
   3. Time and Attendance Records: Time and attendance records must be available for all staff working on EWPHCCS activities. Payroll records are acceptable for staff working 100% of the time on EWPHCCS. Staff that work less than 100% of their time on EWPHCCS must record the number of hours worked each day on EWPHCCS. Organizations may develop their own forms to record the hours or use the attached sample time and effort documentation form.
2. Nutrition Education Reinforcement Materials, (also known as incentives) are items that are given to SNAP eligibles or persons closely associated with the SNAP (such as staff), and contain nutrition and physical activity messages. Incentives cannot be used to encourage participation in a SNAP-Ed event or series of events.
   1. In accordance with the SNAP-Ed Plan Guidance, incentives should:
      • Be targeted to SNAP participants and eligible participants;
      • Have a direct relationship to program objectives, SNAP-Ed lessons and goals and the expected behavior change;
      • Be of nominal value and cost no more than $4.00 per item;
      • Contain or convey an educational message or have a use that directly reinforces a relevant nutrition and/or a physical activity message;
      • Have value as nutrition education and obesity prevention aides;
      • Be specific to only one event, session or lesson; and
      • Not be used solely for staff morale boosters.
   2. Due to current fiscal constraints, incentives should only be offered after assessing the cost-effectiveness of the item. Aprons and water bottles are discouraged as they are not directly relevant to nutrition lessons. Examples of allowable incentives for parents include: vegetable peelers, apple corers or cutting boards. Examples of incentives for child care staff include: child-sized serving utensils, child-size pitchers, and children's books that promote good nutrition and/or physical activity practices.

   If an organization chooses to print their name on incentives EWPHCCS must also be credited on the incentives.

   Any new or reproduced material used for EWPHCCS must be reviewed and approved by central office.

III. Summary of Changes

SNAP-Ed grantees must maintain fiscal records that clearly identify and support EWPHCCS activities. This memo outlines record keeping requirements for program expenses such as food receipts, travel expenses and time and attendance records. This memo also serves to remind grantees that incentives should only be used to perpetuate good nutrition and physical activity practices. Incentives must be of nominal value ($4.00 or less per item) and must comply with the guidelines set forth above. Newly developed and reprinted material must be reviewed and approved prior to use and include the appropriate credits.

Enclosures:
Sample Time and Effort Documentation Form
Sample Mileage/Public Transportation Form