Specific Prior Written Approval (SPWA) Overview

" December 1, 2021 - SPWA is required for all costs that fall outside of the normal operational requirements of the CACFP. However, CEs frequently forget to request SPWA or to amend their budgets, resulting in findings and monies having to be returned to the Program.
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December 1, 2021 - CACFP CEs are required to account for costs that are necessary to run a non-profit food service accurately and to maintain documentation that demonstrates costs were paid, allowable, and comply with the requirements of the program’s rules and regulations, inclusive of the United States Department of Agriculture (USDA) Food and Nutrition Service’s (FNS) Instruction 796-2, Rev.4.   FNS Instruction 796-2, Rev 4 requires that all allowable expenses be approved by TDA (and in some cases the USDA) before being included in a budget and before the CE incurs the cost.  

There are three levels of approval for program costs: (1) prior approval, (2) Specific Prior Written Approval (SPWA), and (3) approval by USDA’s Food and Nutrition Service Regional Office (FNSRO), depending on the amount and the category of the expense.  

All program costs must have Prior Approval from TDA.  Budget review and approval is part of the application process.  Prior approval is requested each time a budget is submitted for approval to TDA via TXUNPS, and prior approval is granted once TDA approves the submitted budget in TXUNPS.  Costs must be identified by item when a budget is submitted to TDA.  However, including a projected cost as a part of a larger entry on a line item in a submitted budget may not be sufficient disclosure for prior approval designation.  
In these instances, Specific Prior Written Approval (SPWA) may be needed.  SPWA is required for costs which are not typically incurred in the routine operation of the CACFP (examples include, but are not all inclusive of, less-than-arms-length transactions or membership fees), but may be necessary and reasonable for proper and effective program operations (please refer to FNS Instruction 796-2, Rev. 4).  TDA will inform CEs of the necessity for obtaining SPWA as part of their budget review and based on the information submitted, if needed.   Requests for SPWA must be submitted via the SPWA module in TX UNPS, prior to these costs being incurred.

In some instances, FNSRO review and approval is needed.  TDA is responsible for engaging the FNSRO for budget review and approval as necessary. Reminder: Approval of a budget line item does not constitute SPWA and/or FNSRO approval for these costs.

As part of an Administrative Review, TDA reviews the approved budget and costs incurred.  Should it be noted that if a CE failed to obtain SPWA for a particular cost, TDA is required to issue a finding and the incurred cost will be denied, resulting in the CE being responsible for repayment of those funds back to the CACFP program. 


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In accordance with federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, this institution is prohibited from discriminating on the basis of race, color, national origin, sex (including gender identity and sexual orientation), disability, age, or reprisal or retaliation for prior civil rights activity.

Program information may be made available in languages other than English. Persons with disabilities who require alternative means of communication to obtain program information (e.g., Braille, large print, audiotape, American Sign Language), should contact the responsible state or local agency that administers the program or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339.

To file a program discrimination complaint, a Complainant should complete a Form AD-3027, USDA Program Discrimination Complaint Form which can be obtained online at: https://www.usda.gov/sites/default/files/documents/USDA-OASCR%20P-Complaint-Form-0508-0002-508-11-28-17Fax2Mail.pdf, from any USDA office, by calling (866) 632-9992, or by writing a letter addressed to USDA. The letter must contain the complainant’s name, address, telephone number, and a written description of the alleged discriminatory action in sufficient detail to inform the Assistant Secretary for Civil Rights (ASCR) about the nature and date of an alleged civil rights violation. The completed AD-3027 form or letter must be submitted to USDA by:

1. Mail:
U.S. Department of Agriculture
Office of the Assistant Secretary for Civil Rights
1400 Independence Avenue, SW
Washington, D.C. 20250-9410; or
2. Fax: (833) 256-1665 or (202) 690-7442; or
 
This institution is an equal opportunity provider.
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