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CSFP Section 4

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CSFP Procedures Manual Section 4: Eligibility Criteria

4.1 Eligibility Criteria for Lead Agencies

  1. Lead Agency Eligibility Criteria.
    1. Lead Agencies must meet the criteria of 7 CFR Part 247 and 7 CFR Part 250 as an eligible recipient agency and those criteria of Food Assistance (FA).
    2. "Eligible recipient agencies" means an organization that:
      1. Is a public agency or federally recognized tribe; or
      2. Is private, possessing tax-exempt 501(c)(3) status under the Internal Revenue Code (IRC), or has applied for tax-exempt status with the Internal Revenue Service (IRS) and be moving toward such status; or
        1. Is automatically tax-exempt and organized or operated exclusively for religious purposes under the IRC; and
        2. Is not a penal institution; and
        3. Provides food assistance by meeting all the requirements of the Agreement and applicable regulations in 7 CFR Parts 247 and 250 with the designated State agency pursuant to 7 CFR §247.4(2) prior to the receipt of USDA Foods or administrative funds; and 
      3. Falls into one of the following categories:
        1. Emergency feeding organizations (including community action agencies, food banks, and food pantries); or
        2. Charitable institutions (including hospitals and retirement homes); or
          1. Nutrition projects operating under the Older Americans Act of 1965 (Nutrition Program for the Elderly), including projects that operate congregate Nutrition sites and projects that provide home-delivered meals; and
          2. Meets additional criteria, as required by FA, which may include being an existing Lead Agency or Sub Agency for other FA programs; and
          3. Is registered as a nonprofit corporation with the Washington Secretary of State Office; and
          4. Is registered in the System for Award Management (SAM) and continues to maintain an active SAM registration with current information at all times during which it receives federal funding; and
          5. Is not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded in any Federal or State department or agency from participating in transactions.
  2. Lead Agency Capabilities.
    1. Lead Agencies shall:
      1. Have management capabilities to administer the Agreement with Food Assistance (FA). These management capabilities include the following (see Sections 5-9 of this manual for more details):
        1. Executing and managing program Sub Agency Agreements; and 
        2. Developing Sub Agency management policies and procedures; and
        3. Have sufficient dry, cold, and frozen storage and transportation capacity for USDA Foods; and
        4. Have financial capabilities, internal controls, and fund accounting procedures to ensure the proper disbursement of, and accounting for, all funds; and
        5. Secure adequate insurance (additional information can be found in FD-139 Clarification on Inventory Protection Requirements).
  3. Civil Rights and Nondiscrimination Responsibilities.
    1. All Lead Agencies shall practice nondiscrimination in services and employment and ensure compliance with all federal, state, and local laws concerning civil rights and nondiscrimination. All have the right to be free from discrimination because of race, color, national origin, sex (including gender identity and sexual orientation), disability, age, or reprisal or retaliation for prior civil rights activity. 
    2. Compliance also includes:
      1. Lead Agencies must practice nondiscrimination in the employment of individuals and the delivery of services in any program or activity conducted or funded by USDA.
      2. Operating in accordance with federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex (including gender identity and sexual orientation), disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA.
      3. The Civil Rights Act of 1964 prohibits employment discrimination based on religion but exempts religious entities from this prohibition. 7 CFR §16.3(c) expressly provides that religious organizations participating in USDA assistance programs do not waive this exemption. Consistent with this legal authority, religious employers may preferentially hire persons whose beliefs and conduct are consistent with the employers’ religious precepts and not be at risk of losing USDA federal assistance funding.
      4. The full USDA Nondiscrimination Statement in English can be found on the FA website.

4.2 Lead Agency Program Responsibilities

  1. Adhere to CSFP Requirements and Responsibilities.
    1. The Lead Agency shall comply fully with, and ensure any Sub Agency complies fully with, the following CSFP requirements and responsibilities:
      1. All provisions of the Food Assistance (FA) Agreement and future amendments.
      2. 7 CFR Part 247.
      3. 7 CFR Part 250, unless they are inconsistent with the provisions of 7 CFR Part 247.
      4. All applicable federal and state laws, regulations and policies.
      5. CSFP Procedures Manual and CSFP State Plan.
      6. USDA and FA instructions.
      7. Requirements relating to food safety and food recalls.
      8. Review FNS Policies quarterly.
    2. Not all Lead Agency responsibilities are noted in this Section; additional responsibilities are highlighted throughout this manual.
  2. Audits.
    1. Participating agencies will meet the following audit requirements and submit the required documents from this section to the agency with which they hold a program Agreement. The reporting schedule is as follows:
      1. Initial submittal: Within 30 days of execution of the Agreement (unless already submitted).
      2. Subsequent submittal: Annual or biennial submittal (as applicable) – due within 9 months of the end of the organization’s fiscal year.
    2. For organizations with fiscal years beginning on or after October 1, 2024, the Uniform Guidance Single Audit threshold increased from $750,000 to $1,000,000. This means the Single Audit threshold of expenditures increase would not be available for audit periods prior to October 1, 2024. Agencies should check with their Auditor for additional guidance.
    3. The value of USDA Foods (non-cash federal awards) received through CSFP should be included within both the Lead Agency and Sub Agency audits under the appropriate Assistance Listing Number (10.565). For guidance on the valuation of USDA Foods, see USDA Policy Memo FD-104.
    4. Note: Additional details are available in the current, signed Agreement.
    5. Types of Audits:
      1. Federal Funding of $1,000,000 or more.
        1. If the Lead Agency expends $1,000,000 or more from all federal sources during the Lead Agency's fiscal year, as determined under 2 CFR §200.501 of the Federal Award Uniform Guidance, the Lead Agency will obtain an annual Single Audit conducted in compliance with Federal Award Uniform Guidance and the requirements of the Agreement. The $1,000,000 includes the value of food received from federal food programs. If also receiving State food assistance funding, a Schedule of State Assistance must be included within the audit.
      2. Federal Funding of $999,999.99 or less and State Funding of $100,000 or more.
        1. If the Lead Agency is not required to complete a Single Audit and expends $100,000 or more in total state funds in a fiscal year, the Lead Agency must have a financial audit at least every two (2) years that covers the previous two (2) years as defined by Government Auditing Standards (The Revised Yellow Book) and according to Generally Accepted Auditing Standards (GAAS).
      3. The Lead Agency will submit the Single Audit Exemption Form (AGR-2207) signed by an independent Certified Public Accountant or an appropriate financial officer who provides financial services to the Lead Agency and submit annual audits to FA if the Lead Agency obtains annual audits for its own purposes. If also receiving State food assistance funding, a Schedule of State Assistance must be included within the audit.
    6. Additional Requirements:
      1. Federal Funding of $999,999.99 or less and State Funding of $99,999.99 or less.
        1. If the Lead Agency is not required to complete a Single Audit or a financial audit, the Lead Agency will submit an Accounting System Verification Form (AGR-2206) and a Single Audit Exemption Form (AGR-2207) signed by an independent Certified Public Accountant or an appropriate financial officer who provides financial services to the Lead Agency, annually.
      2. Additional submittals (as applicable):
        1. Lead Agencies that receive less than $100,000 in state funding, less than $1,000,000 in federal funding, and do not receive an audit must submit an Accounting System Verification Form (AGR-2206) within 30 days of Agreement execution, and annually within 30 days of the end of the Lead Agency’s fiscal year.
        2. Lead Agencies that do not receive a Single Audit must submit the Single Audit Exemption Form (AGR-2207) within 30 days of Agreement execution, and annually within 30 days of the end of the Agency’s fiscal year.
      3. Lead Agencies must submit a copy of its most recent audit or financial statements, regardless of type, to FA, including any management letters with documentation showing how any problems (questioned costs, management findings, or inadequate internal controls) were resolved.
      4. Lead Agencies must ensure that all their Sub Agencies are compliant with all audit requirements listed in Section 3.1.B, Sub Agency Agreement and in Section 4.4, Sub Agency Responsibilities.
        1. A Lead Agency Schedule of Submittals can also be found in Section 9, Compliance Management.
    7. Additional Resources:
      1. OMB Uniform Guidance Audit Requirements – Subpart F.
      2. USDA Policy FD-037.
      3. For additional guidance in determining the value of USDA Foods for Audits refer to USDA Policy FD-104.
  3. Contracting.
    1. Prior to receiving USDA Foods or administrative funds the Lead Agency must:
      1. Meet all eligibility requirements as outlined in the approved Lead Agency Agreement.
        1. Meet all requirements of the Agreement and applicable regulations in 7 CFR Parts 247 and 250 with the designated state agency pursuant to 7 CFR §247.4(a)(2), as applicable, prior to the receipt of USDA Foods or administrative funds.
      2. Have a fully executed Lead Agency Agreement.
        1. The Lead Agency must enter into an Agreement with the designated state agency pursuant to 7 CFR §247.4(a)(2) for the receipt of USDA Foods or administrative funds.
    2. Lead Agencies Must Have the Ability to Enter into Sub Agency Agreements.
      1. Prior to passing through USDA Foods or administrative funds, the Lead Agency must first have an executed Agreement with the designated state agency pursuant to 7 CFR §247 before it can enter into Sub Agency Agreements with an eligible recipient Sub Agency.
      2. Prior to passing through USDA Foods or administrative funds the Lead Agency must fully execute Sub Agency Agreements with organizations that:
        1. Meet all eligibility requirements as outlined in the approved Sub Agency Agreement.
          1. Meet all requirements of the Sub Agency Agreement and applicable regulations in 7 CFR Parts 247 and 250 prior to the receipt of USDA Foods or administrative funds.
          2. The Lead Agency should ensure that the organization and its distribution facilities meet Agreement requirements prior to execution of Sub Agreement.
        2. Have an executed Sub Agency Agreement.
          1. The Sub Agency must enter into an Agreement with the Lead Agency for the receipt of USDA Foods or administrative funds.
    3. Approved Agreements must be consistent with the FA provided CSFP Sub Agency Agreement (AGR-2320) template as required by FA. Prior FA approval of any proposed changes is required, using Request for Alternate Language Approval (AGR-2325). The Lead Agency must maintain on file all required documentation.
    4. If Sub Agencies perform additional duties or activities (such as transportation or storage for other Sub Agencies) on behalf of the Lead Agency, this must be reflected in the Sub Agency Agreement or by amendment.
  4. Lead Agencies Shall Not Have Been Debarred.
    1. The Lead Agency shall notify FA within 30 days of any exclusion from participating in any federal or state transactions.
    2. The Lead Agency agrees to include the above requirements in all Sub Agency Agreements.
    3. Lead Agencies shall ensure their Sub Agencies are not debarred upon signature of a new Agreement and annually thereafter.
  5. Lead Agencies Must Provide Sub Agencies with Program Information.
    1. Pass through program information that affects the management of CSFP to its Sub Agencies. This includes information on new, modified, and ongoing policies and procedures.
    2. Provide Sub Agencies with a link to the CSFP Procedures Manual.
    3. Offer technical assistance to help Sub Agencies carry out their CSFP obligations.
    4. Ensure that Sub Agencies implement any policy changes.
      1. This may include notification of program changes or amendment to the Sub Agency Agreement.
  6. Food Assistance (FA) May Require a Lead Agency to Attend Meetings or Trainings.
    1. Notification of required or recommended attendance at meetings will be sent by FA. These may include meetings for:
      1. Updating the Lead Agency on policies or procedures.
      2. Providing information on changes in legislation affecting CSFP.
      3. Providing training that would result in better service for clients.
      4. Regional training meetings.
  7. Lead Agencies will ensure that all Sub Agencies have the following required documents posted in a conspicuous location at the point of client intake. 
    1. USDA “And Justice for All” poster (AD-475-A).
    2. Partnerships with Faith-Based and Neighborhood Organizations Final Rule "Written Notice of Beneficiary/Client Rights" poster (AGR-10017).
    3. Current CSFP Income Eligibility Guidelines (AGR6-2503-007).
  8. Lead Agencies Shall Conduct Compliance Reviews of Sub Agency Performance.
    1. The Lead Agency is responsible for monitoring their Sub Agencies once every two years. The Lead Agency must use an FA approved review form or the provided Sub Agency Review (AGR-2227) document on the FA website. Each year, upon request by FA, the Lead Agencies will provide a list of the sites they plan to review. Lead Agencies shall review Sub Agency activities to assure they are operating the program in accordance with the Sub Agency Agreement and applicable policies.
    2. This includes:
      1. Verifying that Sub Agency meets all criteria for CSFP Sub Agencies.
      2. Verifying all CSFP expenditures are appropriate and reported timely, and that other applicable policies are followed.
      3. Review eligibility determinations.
      4. Review client intake forms, including electronic systems.
      5. Review the monthly distribution rate.
      6. Review storage, warehousing practices, and inventory control system.
      7. Verify annual civil rights training was conducted for all volunteers and staff.
      8. Verify intake compliance in accordance with all applicable postings forms, and requirements.
  9. Lead Agencies Must Take Action to Correct Sub Agencies’ Performance.
    1. The Lead Agency shall take action to correct any Sub Agency noncompliance:
      1. Lead Agencies may give a Sub Agency a specific period of time to comply and shall follow the process for suspending or terminating a Sub Agency as outlined in the Sub Agency Agreement.
      2. If corrective action deficiencies are found during the review, the Lead Agency must send a copy of the written report or form to FA. Corrective actions are typically used when a deficiency is significant in nature, denial by Sub Agency to correct the deficiency, or historical noncompliance by the Sub Agency in addressing lower-level deficiencies.
      3. Lead Agencies shall ensure that any required follow-up or corrective action has been completed and noted in the Sub Agency’s file or review form.
  10. Adhere to other CSFP Requirements and Policies.
    1. The Lead Agency will track inventory records monthly for each Sub Agency. See Section 8, USDA Foods and Warehouse Management.
    2. The Lead Agency will maintain current records with all Sub Agency Site Lists (AGR-2387), monitoring changes in Sub Agencies contact person’s name, telephone number, mailing and/or physical address. Lead Agency will submit updated Sub Agency information to FA on an annual basis.
    3. The Lead Agency is required to notify FA within 10 days regarding changes to Sub Agency eligibility, addition of new distribution sites, and closure of distribution sites.
    4. Lead Agencies that provide direct services must register with wa211.org, the statewide health and human services information and referral system within 30 days of the start date of the Agreement.
    5. The Lead Agency shall be registered in the System for Award Management (SAM) and continue to maintain an active SAM registration with current information at all times during which it receives federal funding.
    6. Maintain Internal Revenue Code (IRC) 501(c)(3) status and Washington Secretary of State Corporation Registration, as applicable.
    7. In order to receive payment from FA the Lead Agency must first register with the Statewide Vendor/Payee Services. When registering, an agency may choose to have payments directly deposited to an agency bank or mailed as a check.
  11. Lead Agency Nutrition Education Responsibilities:
    1. In accordance with 7 CFR §247.18, Lead Agencies providing direct client services shall make nutrition education available to all participants. Program funds should be directed for nutrition education to the benefit of participants and staff members involved in nutrition education.
    2. It is the responsibility of the Lead Agency and all Sub Agencies to ensure that nutrition education in alignment with CSFP requirements is provided to all participants.
    3. The goal of providing nutrition education is to enable CSFP participants to obtain better nutritional status through increased understanding of basic nutrition principles and through effective use of USDA Foods. Participating Agencies must provide nutrition education opportunities to all participants. The following are essential to achieving that goal:
      1. Reinforcement of basic nutrition guidance.
      2. Instruction on the use of CSFP USDA Foods, including food preparation techniques, recipes, meal frequency, and food-cost savings.
      3. Recognition of the special health and nutritional problems of lower-income individuals, such as high blood pressure, sodium/potassium ratios, anemia, and obesity.
      4. Dissemination of information on preventative health care and on community programs such as food conferences, food cooperatives, and local presentations.
      5. Consumer resource information and assistance.
      6. Motivational messages on topics such as health care, physical activity, mental health, homemaking, education, employment, and cultural activities.
    4. FA supports the nutrition education of CSFP in three ways. Participating agencies should incorporate these tools into the nutrition education they provide to participants.
    5. Nutrition Education Plan:
      1. FA will provide technical assistance, basic nutrition support, general public assistance information, recipes, and other resources, as available, to support nutrition education at local agencies. FA will maintain these and other nutrition resources on its webpage. To ensure that the nutrition education provided is effective, the State will integrate materials developed through its partnership with SNAP-Ed into other programs administered by FA, including CSFP. A significant number of nutrition resources have been translated into multiple languages. Local agencies and CSFP participants will be able to access nutrition education materials online at www.agr.wa.gov/services/food-access/hunger-relief-resources/recipes-and-nutrition/nutrition-resources as well as basic nutrition information included in their distribution package.
      2. Participating agencies are required to provide clients with nutrition information materials at least once per quarter. These agencies have the flexibility to utilize the WSDA-provided resources or WSDA-approved resources from an alternate source or by the Lead Agency. A review of participating agencies’ nutrition education materials is also conducted as part of the compliance review process.
    6. Participant Survey:
      1. Agencies that provide direct client services are required to gather input from clients on the types of nutrition education that they would find beneficial; this ensures nutrition education is up to date with the needs of individual communities.
      2. FA will provide CSFP Lead Agencies with a CSFP Participant Survey (AGR-2248) for all participants to complete on an annual basis. The timing of this survey will coincide with the collection of the annual Racial/Ethnic Group Participation Form FNS-191. The survey includes an option for local agencies to add a question regarding the specific effectiveness of participating agencies’ unique nutrition education efforts. Participating Agencies are responsible for issuing the annual CSFP Participant Survey (AGR-2248) and compiling the client input, which is then sent to FA for analysis. Agencies engaging in direct client services are encouraged to incorporate the recommendations from the survey, when appropriate, into the nutrition education provided during CSFP distribution to clients in their community. Lead Agencies may funnel any additional client input received outside of the survey period to FA to help make program improvements in a timely manner.
      3. FA will work with the Department of Social and Health Services SNAP-Ed unit or similar organization to analyze the data, including working with a nutritionist or entity that provides qualified nutrition expertise to evaluate the effectiveness of the nutrition education plan and to make recommendations for improvement at both the state and local level. FA will provide the results of the evaluation to Lead Agencies and include any relevant regional data. The Lead Agency will utilize the evaluation results to adjust their nutrition education efforts to ensure effectiveness.
    7. Nutrition Education Materials:
      1. FA wants to ensure Lead Agencies have the tools needed to feed the food insecure residents of Washington State and provide them with information that supports nutrition and overall health improvements. Each CSFP applicant receives the Welcome to CSFP Resources Handout (AGR-739) during the initial certification. Participating agencies and their clients have access to a variety of nutrition education materials on the FA Nutrition Resources webpage.
      2. The FA Nutrition Resources webpage showcases a variety of tools developed for food pantry staff and volunteers to encourage the consumption of healthier food options in their pantries.
      3. The FA Senior Nutrition Resources webpage has links to various USDA nutrition resources such as USDA MyPlate for older adults, a MyPlate Cookbook, senior fitness information, and other local and cultural recipes and resources. These tools are available in English, Spanish, Russian, Simplified Chinese, Korean, Vietnamese, and Ukrainian. Additionally, copies of all Senior Nutrition Newsletters are available for distribution to participants.
  12. Food Demonstrations:
    1. In accordance with 7 CFR §247.18(d), any food demonstrations using supplemental USDA Foods shall be conducted by the state or Lead Agency solely in conjunction with nutrition education and primarily for participants under the program. Supplemental USDA Foods may not be used for outreach, refreshments for participants, or any other such purpose. CSFP USDA Foods may not be provided to any other community agency or facility for any purpose whatsoever, unless such agency has entered into a signed written agreement with the state or Lead Agency to provide nutrition education services under the program.
    2. If supplemental USDA Foods are used for demonstration purposes, the number of cans or packages used must be indicated on the monthly CSFP Lead Agency Inventory Report (AGR-2249A), under the column for “Amount Used for Nutrition Education.”
  13. Other Public Assistance Outreach Responsibilities.
    1. In accordance with 7 CFR §247.14, agencies providing direct client services must provide participants with written information on the following programs, and make referrals, as appropriate:
      1. Supplemental security income (SSI) benefits.
      2. Medical assistance provided to Medicare beneficiaries.
      3. Supplemental Nutrition Assistance Program (SNAP).
      4. Senior Farmers’ Market Nutrition Assistance Program (SFMNP).
    2. FA provides written information on these programs in the Welcome to CSFP Resources Handout (AGR-739) required handout. Additionally, FA will incorporate information on these and other program in the FA produced Senior Nutrition Newsletter, available at the FA website. This ensures that participants receive information about the program when they sign up for the program and throughout their time participating in the program.

4.3 Eligibility Criteria for Sub Agencies

  1. Sub Agency Eligibility Criteria.
    1. The Lead Agency shall determine the eligibility of any Sub Agency prior to Sub Agency Agreements being issued.
    2. Sub Agencies must meet the criteria of 7 CFR Part 247 and 7 CFR Part 250 as an eligible recipient agency (unless they are inconsistent with 7 CFR Part 247) and as required by the Sub Agency Agreement.
    3. “Eligible recipient agencies” means an organization that:
      1. Is a public agency or federally recognized tribe; or
      2. Is private, possessing 501(c)(3) tax-exempt status under the Internal Revenue Code (IRC), or has applied for tax-exempt status with the Internal Revenue Service (IRS) and be moving toward such status; or
        1. Is automatically tax exempt as organized or operated exclusively for religious purposes under the IRC; and
        2. Is not a penal institution; and
        3. Provides food assistance for home consumption by meeting all criteria for determining recipient eligibility pursuant to 7 CFR Part 247; and
        4. Meets the criteria to enter into an agreement with the designated Lead Agency pursuant to 7 CFR Part 247 prior to the receipt of USDA Foods or administrative funds; and
        5. Meets additional criteria, as required by the Lead Agency (Food Assistance (FA) prior approval is required) and falls into one of the following categories: Emergency feeding organizations (including community action agencies, food banks and food pantries).
          1. Is not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded in any Federal or State department or agency from participating in transactions.
          2. Has a Unique Entity Identification (UEI) number assigned in the System for Award Management (SAM). 
          3. Is currently registered as a nonprofit corporation with the Secretary of State Office in Washington (as applicable).
          4. Is prepared to complete the Alternate 501(c)(3) Church Verification Form (AGR-2241) verifying that, as organization without 501(c)(3) status with the IRS, it is recognized in the community as a church if required by Lead Agencies.
          5. Nutrition projects operating under the Older Americans Act of 1965 (Nutrition Program for the Elderly), including projects that operate congregate nutrition sites and projects that provide home-delivered meals.
          6. Charitable institutions (including hospitals and retirement homes).
  2. Sub Agency Capabilities.
    1. Sub Agencies shall:
      1. Have management capabilities to administer the Sub Agency Agreement with the Lead Agency. These management capabilities include the following (see Sections 5-9 of this manual for more details):
        1. Executing and managing program Sub Agency Agreements.
        2. Developing Sub Agency management policies and procedures.
      2. Have sufficient dry, cold, and frozen storage and transportation capacity for USDA Foods.
      3. Have established financial capabilities, internal controls, and fund accounting procedures to ensure the proper disbursement of, and accounting for, all funds provided (if applicable).
      4. Have adequate insurance or means to provide coverage for the loss of any program foods.
      5. Lead Agencies may have additional requirements.
  3. Civil Rights and Nondiscrimination Responsibilities.
    1. All Sub Agencies shall practice nondiscrimination in services and employment and ensure compliance with all federal, state, and local laws concerning civil rights and nondiscrimination. All have the right to be free from discrimination because of race, color, national origin, sex (including gender identity and sexual orientation), disability, age, or reprisal or retaliation for prior civil rights activity. Sub Agencies must practice nondiscrimination in the employment of individuals and the delivery of services in any program or activity conducted or funded by USDA.
    2. Operate in accordance with federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex (including gender identity and sexual orientation), disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA.
    3. The Civil Rights Act of 1964 prohibits employment discrimination based on religion but exempts religious entities from this prohibition. 7 CFR §16.3(c) expressly provides that religious organizations participating in USDA assistance programs do not waive this exemption. Consistent with this legal authority, religious employers may preferentially hire persons whose beliefs and conduct are consistent with the employers’ religious precepts and not be at risk of losing USDA federal assistance funding.
    4. The full USDA Nondiscrimination Statement can be found on the FA website.

4.4 Sub Agency Responsibilities

  1. Adhere to CSFP Requirements and Responsibilities.
    1. The Sub Agency shall comply fully with the following CSFP requirements and responsibilities, including those referenced in Section 4.2, Lead Agency Program Responsibilities (as applicable):
      1. All provisions of the Sub Agency Agreement and future amendments.
      2. 7 CFR Part 247.
      3. 7 CFR Part 250, unless they are inconsistent with the provisions of 7 CFR Part 247.
      4. All applicable federal and state laws, regulations and policies, including Lead Agency policies.
      5. USDA, Food Assistance (FA), and Lead Agency instructions.
      6. CSFP Procedures Manual and CSFP State Plan.
      7. Requirements relating to food safety and food recalls.
    2. Not all Sub Agency responsibilities are noted in this Section; additional responsibilities are found in Section 3.1.B, Sub Agency Agreement and are highlighted throughout this manual.
  2. Audits.
    1. The Sub Agency shall submit all audits, regardless of type, to the Lead Agency, or if the Sub Agency obtains audits for its own purposes. If a Sub Agency receives federal funding, from any source (including the value of CSFP USDA Foods and administrative funds), then the Sub Agency must complete the Audit Requirement Form for Sub Agencies (AGR-2217). The form is to be sent to the Lead Agency annually, within 30 days after the end of the Sub Agency’s fiscal year.
    2. Sub Agencies must submit a copy of their most recent audit or financial statements, regardless of type, to their Lead Agency, including any management letters with documentation showing how any findings (questioned costs, management findings, or inadequate internal controls) were resolved.
    3. Types of Audits:
      1. Federal Funding of $1,000,000 or more.
        1. If the Sub Agency expends $1,000,000 or more from all federal sources during Sub Agency’s fiscal year, as determined under 2 CFR §200.501 of the Federal Award Uniform Guidance, the Sub Agency shall obtain an annual Single Audit conducted in compliance with Federal Award Uniform Guidance and the requirements of the Sub Agency Agreement. The $1,000,000 or more includes the value of food received from federal food programs. CSFP funding may be used to pay for the audit, proportionate to CSFP’s fair share. The value of CSFP USDA Foods and funding must be included in the audit Schedule of Expenditures of Federal Awards. Single audits must include a Schedule of State Financial Assistance/Schedule of State Awards, or equivalent.
      2. Federal Funding of $999,999.99 or less and State Funding of $100,000 or more.
        1. If the Sub Agency is not required to complete a Single Audit, as noted above, and expends $100,000 or more in total state funds (from any source) in a fiscal year, Sub Agency must have a financial audit at least every two years that covers the previous two years as defined by Government Auditing Standards (The Revised Yellow Book) and according to Generally Accepted Auditing Standards (GAAS). The $999,999 or less includes the value of food received from federal food programs. CSFP funding may be used to pay for the audit, proportionate to CSFP’s fair share.
      3. Additional Requirements:
        1. Federal Funding of $999,999.99 or less and State Funding of $99,999.99 or less.
          1. If the Sub Agency is not required to complete a Single Audit, or a financial audit, or obtains an audit for its own purpose then the Sub Agency should submit an Accounting System Verification Form (AGR-2206) signed by an independent certified public accountant or an appropriate financial officer who provides services to the Sub Agency. This form is due annually to their Lead Agency, or 45 days after the execution of the Sub Agency Agreement. The $999,999 or less includes the value of food received from federal food programs.
      4. Additional submittals (as applicable):
        1. Sub Agencies that receive less than $100,000 in state funding, less than $1,000,000 in federal funding, and do not receive an audit must submit an Accounting System Verification Form (AGR-2206) within 30 days of the Sub Agency Agreement execution, and annually within 30 days of the end of the Sub Agency’s fiscal year.
          1. Agencies that do not receive any state funding (all sources) are exempt from this requirement.
        2. Sub Agencies must submit the Audit Requirement Form for Sub Agencies (AGR-2217) within 30 days of Sub Agreement execution, and annually within 30 days of the end of the Agency’s fiscal year.
        3. Sub Agencies must submit a copy of their most recent audit or financial statements, regardless of type, to the Lead Agency, including any management letters with documentation showing how any problems (questioned costs, management findings, or inadequate internal controls) were resolved.
      5. Additional Resources:
        1. OMB Uniform Guidance Audit Requirements – Subpart F.
        2. USDA Policy FD-037.
        3. For additional guidance in determining the value of USDA Foods for Audits refer to USDA Policy FD-104.
  3. Contracting.
    1. Prior to receiving CSFP USDA Foods or administrative funds the Sub Agency must:
      1. Meet the requirements for Section 4.3, Eligibility Criteria for Sub Agencies.
      2. Have entered into a signed Agreement with the Lead Agency for the receipt of USDA Foods or administrative funds prior to releasing any USDA Foods or administrative funds under the Sub Agency Agreement.
  4. Sub Agencies Shall have the following required documents posted in a conspicuous location.
    1. USDA “And Justice for All” poster (AD-475-A).
    2. Partnerships with Faith-Based and Neighborhood Organizations Final Rule “Written Notice of Beneficiary/Client Rights” poster (AGR-10017).
    3. Current CSFP Income Eligibility Guidelines (AGR6-2503-007).
  5. Sub Agencies Shall Not Have Been Debarred.
    1. The Sub Agency shall notify the Lead Agency within 30 days of any exclusion from participating in any federal or state transactions.
  6. Sub Agencies Must Coordinate Services and Adhere to Other CSFP Policies.
    1. Sub Agencies must:
      1. Coordinate emergency food services with similar programs administered by the federal government, the state of Washington, and other community organizations.
      2. Have information available for clients about other health and nutrition resources, including public assistance programs such as job training, mental health and substance abuse counseling, emergency housing, rental assistance, cash assistance, childcare, and energy assistance.
      3. The Lead Agency may require Sub Agencies to also carry fidelity insurance.
      4. Register with wa211.org, Statewide Telephone Information and Referral System within 30 days of execution of the Sub Agency Agreement.
      5. Submit all reports on time.
      6. Maintain accurate and complete records for a period of six years from the final payment of the Sub Agency Agreement or longer if the records are related to unresolved claim actions, audits, or investigations.
      7. Attend meetings as required by the Lead Agency and/or FA.
      8. Complete all required civil rights training on an annual basis.
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CSFP Procedures Manual Table of Contents
Section 3 Section 5
Revision History
Section 4 Revision 2025-07-15