The participation of providers in CACFP is supervised by a sponsor, in this case Community Action of Eastern Iowa ["Community Action"]. To participate in CACFP in Iowa, the provider must possess a certification of registration from the Iowa Department of Human Services, and must sign an agreement that provides for the terms and conditions of program participation. This agreement provides for announced and unannounced visits to the provider's daycare site by the sponsor. When the sponsor notes the absence of claimed children during a visit, the sponsor is expected to contact parents/guardians to ensure that reimbursement is not sent to the provider for meals/snacks not actually served to a child. As a result of a parent audit conducted by the sponsor, the sponsor determined that the provider was making false claims. The evidence supported this determination.

The evidence supports a finding that the submission of false claims is systemic and was not a one-time human error. Community Action has shown that Ms. Bailey has not permanently and completely corrected the seriously deficient practice of submission of false claims. The termination of Rebecca Bailey from the Child and Adult Care Food Program is hereby ordered.