CACFP Claims Validation Project Report

We conducted 811 off-site and 179 on-site claims validation reviews of CACFP institutions across ten states: California, Colorado, Florida, Illinois, Minnesota, Missouri, New Jersey, New York, Ohio, and Washington. The ten states were determined through a retrospective review of available reporting, data, and other open-source information to assess potential fraudulent activities and showcase states that have best practices.

Review activities involved validating facility- level claims documentation, assessing operations and meal counting practices, and meeting with state agencies to discuss oversight responsibilities.

Using detailed facility-level claims data, USDA identified risk indicators - including block , attendance-based claiming, and other anomalies to select a targeted sample of sites for further documentation review or onsite validation.

The project identified several systematic challenges and integrity concerns that state agencies and program operators should prioritize in their oversight and corrective action work.

Data-Driven Integrity Risks

Potentially improper or suspicious claiming patterns were found in nearly every participating state. While these cases were limited in number, they were concentrated among specific institutions, suggesting that targeted, data-driven monitoring is essential for detecting irregularities early.

Common Review Concerns

• Meal count variance: Reliance on attendance or estimates instead of point-of-service counts significantly increases the risk of inflated or inaccurate claims.
• Recordkeeping deficiencies: Missing, incomplete, or inconsistent documentation limits the ability to verify claims and creates opportunities for misuse.
  meal pattern and service noncompliance: Missing components, improper quantities, and meals served outside approved times signal both compliance issues and heightened fraud risk.
• Integrity warning signs: Prefilled records, identical counts across days or meal types, and meal counts exceeding attendance are red flags that warrant immediate follow-up.
• Operational and oversight gaps: Insufficient staff training, weak internal controls, and lack of understanding of CACFP rules increase vulnerability to both intentional and unintentional noncompliance.

Two cases-one in Ohio and one in New Jersey-raised significant concerns about the validity of program participation. In both instances, reviewers were unable to confirm operations due to the absence of staff/participants or refusal of entry. These cases highlight the ongoing risk of fraudulent participation and reinforce the need for vigilant oversight and swift state-level follow-up when sites cannot be validated.

Best Practices Observed

Many institutions demonstrated practices that support high integrity and strong operational performance. State agencies and sponsors may consider promoting these strategies as models:

• Accessible, well-organized documentation systems, including electronic records for attendance and meal counts.
• Consistent point of service counting procedures aligned with CACFP requirements.
• High-quality, transparent meal service practices, including family style meals and scratch preparation.
• Clean, sanitary, and well-maintained kitchens and food service areas.
• Engaged leadership and staff who demonstrate understanding of CACFP requirements and a commitment to accurate reporting.

We will use the results of this project to strengthen guidance, clarify policy expectations, and inform rulemaking aimed at improving program integrity. State agencies will receive additional communication regarding recommended corrective actions for noncompliance issues identified during the reviews.

Moving forward, state agencies and operators should prioritize:

• Strengthening internal controls to prevent improper claims.
• Using data analytics and available systems to detect anomalies in real time.
• Ensuring staff at all levels receive consistent, ongoing training in CACFP requirements.
• Following up promptly and decisively when operational questions or integrity concerns arise.
• Applying corrective action and enforcement measures when required to address noncompliance.

Protecting CACFP from fraud, waste, and abuse is a shared responsibility and a critical component of ensuring the program remains reliable, credible, and capable of serving children and adults who depend on it. We look forward to continued partnership with state agencies and program operators in building strong, accountable, and integrity-driven program operations nationwide.