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CSFP Section 9

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CSFP Procedures Manual Section 9: Compliance Management

9.1 Administrative Due Dates

  1. Food Assistance (FA) is responsible for monitoring the operation of CSFP. This ensures the program is being administered in accordance with federal and state requirements and promotes program integrity. Participating agencies must ensure that all required reports and submittals are adhered to, in accordance with the schedule of reporting, throughout the Agreement period. FA staff will monitor Lead Agency compliance of all required submittals. Lead Agencies will monitor Sub Agency compliance of all required submittals.
  2. Note: Extenuating circumstances may exist, resulting in program non-compliance. Lead Agencies may contact FA staff and Sub Agencies may contact their Lead Agency if this occurs.
  3. Required Reports and Schedule of Submittals for Lead Agencies.
    1. Unless otherwise required by a provision in the Agreement, the Lead Agency shall adhere to the following schedule for reporting:
      1. Initial Submittals: New Lead Agencies.
Due Date CSFP Reports
30 days after Agreement execution
45 days after Agreement execution
  • Client Confidentiality Policies
  • Corrective Action for Sub Agencies
  • Dispute Resolution Process for Sub Agencies

                              b. Annual Submittals.
Due Date CSFP Reports
20th of the month following provision of services
Annually, 30 days after the end of the Lead Agency’s fiscal year
  • Single Audit Exemption Form for Lead Agencies (AGR-2207), if applicable
  • Accounting System Verification Form (AGR-2206), if applicable
Annually, 9 months after the end of the Lead Agency’s fiscal year
  • Single Audit Report, if applicable
  • Financial Audit (one- or two-year audit), if applicable
Annually, due date provided by FA
Within 30 days of change throughout the Agreement period
  • Lead Agency must keep current site lists and notify FA of any changes to Lead or Sub Agency Site Lists
Within 30 days of Agreement execution (unless previously submitted) and thereafter upon each renewal.
  • Certificate of Insurance (COI)
Within 30 days of CSFP Sub Agency Agreement execution.
  • Sub Agency Agreement Face Sheets
Upon request or as needed
  • Other reports and data as requested

                             c. Forms listed above may be downloaded from the FA CSFP forms and publications page: CSFP Forms | Washington State Department of Agriculture.
  1. Required Reports and Schedule of Submittals for Sub Agencies.
    1. Unless otherwise required by a provision in the Sub Agency Agreement or the Lead Agency, the Sub Agency shall adhere to the following schedule for reporting:
      1. Initial Submittals: New Sub Agencies.
Due Date CSFP Reports
30 days after Sub Agency Agreement execution
45 days after Agreement execution
  • Client Privacy Policy
  • Client Release of Information Form

                             b. Annual Submittals.
Due Date CSFP Reports
On the date determined by the Lead Agency of the month following provision of services
Annually, 30 days after the end of the Sub Agency’s fiscal year
Annually, 9 months after the end of the Sub Agency’s fiscal year
  • Single Audit Report, if applicable
  • Financial Audit (one- or two-year audit), if applicable
Annually, due date provided by the Lead Agency
Within 30 days of change throughout the Sub Agency Agreement period
  • Sub Agency must keep current site lists and notify Lead Agency of any updates to its Sub Agency Site List (AGR-2387)
Within 30 days of Agreement execution (unless previously submitted) and thereafter upon each renewal
  • Certificate of Insurance (COI), if required by Lead Agency
Upon request or as needed
  • Other reports and data as requested
  1. Forms listed above may be downloaded from the FA CSFP forms and publications page: CSFP Forms | Washington State Department of Agriculture.

9.2 CSFP Compliance Reviews

  1. Food Assistance (FA) is responsible for monitoring the operation of CSFP. This ensures the program is being administered in accordance with federal and state requirements and promotes program integrity. FA staff will monitor Lead Agencies in a variety of ways including, but not limited to, an evaluation of:
    1. An initial risk assessment prior to executing Agreements;
    2. Monthly submitted expenditure and inventory reports;
    3. Responses to requests; and
    4. Program compliance reviews.
    5. Additionally, FA reserves the right to visit any CSFP Sub Agencies in order to evaluate the CSFP Lead Agency’s ability to effectively administer CSFP at the local level.
  2. If a Lead Agency violates any conditions set forth in the CSFP Agreement, FA staff will investigate the violation.
  3. FA Compliance Reviews of CSFP Lead Agencies and Sub Agencies.
    1. Lead Agency Reviews.
      1. FA will review CSFP Lead Agencies that are performing at an adequate level at least once every two years. Lead Agencies with a high-risk rating from the Accounting System and Financial Capability Questionnaire (AGR-2383) or performance issues may be reviewed with greater frequency and more in-depth monitoring processes. If a Lead Agency violates any of the more critical conditions set forth in the Agreement, FA staff may conduct a site visit to investigate the violation.
    2. Sub Agency Reviews.
      1. FA will conduct an annual program compliance review of five CSFP Sub Agencies which receive CSFP USDA Foods and/or administrative funds pursuant to an Agreement with a Lead Agency. Sub Agencies are chosen for a review based on the CSFP Lead Agency review schedule and other factors. In addition, Sub Agencies may be chosen for review based on performance concerns.
      2. CSFP Lead Agencies will be notified by FA if one of their Sub Agencies is selected for review, and the Lead Agency may elect to attend the review. FA will communicate the required follow-up to the Lead Agency, and the Lead Agency will ensure that all identified findings are addressed in a timely and appropriate manner by the Sub Agency. Lead Agencies who fail to do this in a timely manner will be at risk of noncompliance in their Agreement with FA.
    3. Note: CSFP Lead Agencies are also required to conduct compliance reviews of all their CSFP Sub Agencies at least once every two years. Lead Agencies must use an approved review document.
    4. At a minimum, each compliance review will encompass when/as applicable:
      1. Eligibility determinations;
      2. Nutrition education;
      3. Distribution rate formula;
      4. Storage and warehousing practices;
      5. Fiscal and inventory control;
      6. Reporting and record keeping requirements; and
      7. Compliance with civil rights policies and training.
    5. Program compliance review forms:
      1. Lead Agency Review (AGR-2225).
      2. Sub Agency Review (AGR-2227).
    6. FA will:
      1. Notify the Sub Agency and/or Lead Agency personnel of compliance reviews in advance, if possible. Exceptions may apply. 
      2. Request documentation ahead of time for review in the office by FA staff.
      3. Obtain appropriate signatures, at the time of review, to verify the review took place.
      4. At the request of the participating agency or FA, an exit interview will be conducted.
      5. Send the final report to the agency that was reviewed and (if applicable) their respective Lead Agency. This will include results, recommendations, required follow-up or corrective action.
        1. If significant corrective action is required, then Food Assistance will also notify the USDA FNS Western Region Office.
        2. Lead Agencies are responsible for Sub Agency compliance.
      6. Retain a copy of all compliance reviews on file and monitor required follow-up or corrective action items to ensure completion.

9.3 Compliance Management

  1. Food Assistance (FA) May Recapture and Reallocate CSFP Funds.
    1. FA may recapture unclaimed funds if a Lead Agency does not submit expenditure reports in a timely manner. Also, if a Lead Agency does not spend down their full allocation, it will be reallocated for program use.
    2. FA will pursue recovery of any misused funds or foods.
  2. FA May Terminate or Suspend the Agreement in Part or in Whole.
    1. FA may suspend or terminate the CSFP Agreement – for cause or for convenience - in accordance with the process stated in the Agreement.
    2. If FA suspends the Agreement for cause, FA may provide opportunity for the Lead Agency to correct the noncompliance during the period of suspension. FA will not pay any costs associated with suspended work from the time Lead Agency receives notice of suspension until the time Lead Agency receives notice from FA to resume work. FA may terminate the Agreement at any time during a period of suspension.
    3. The Lead Agency shall refund FA for any misuse or loss of CSFP funds or USDA Foods under the Agreement, regardless of whether the Lead Agency has further distributed the funds or USDA Foods.
  3. Lead Agencies May Suspend or Terminate Sub Agency Funds.
    1. Lead Agencies may suspend or terminate funding to Sub Agencies in accordance with the Agreement and their written Sub Agreement and Corrective Action Policy, as applicable. 
    2. Note: The Lead Agency must notify FA prior to taking any corrective action or termination of a Sub Agency.

9.4 Dispute Policy

  1. For Lead Agencies.
    1. When a dispute arises between Food Assistance (FA) and the Lead Agency that cannot be resolved by direct negotiation, the Lead Agency may request a dispute hearing by WSDA’s Director, who may designate another person (designee) to hear the dispute, as described in the Agreement. The decision of the Director or the Director’s designee will be the final agency decision.
    2. Lead Agencies may appeal any substantive decision of FA to deny, award, recapture, reallocate, suspend, or terminate funds that are believed to be to be unfair, unreasonable, or have a major adverse impact on local delivery of services. The decision being appealed will stand until the dispute review process is completed and will only be modified or reversed as a result of the dispute review process.
    3. The parties must attempt to resolve the dispute in accordance with the policy described in the Agreement before filing a claim in any tribunal.
  2. For Sub Agencies.
    1. The CSFP Lead Agency must establish a written dispute resolution process for Sub Agencies prior to executing Sub Agency Agreements, and the Lead Agency shall provide a copy of that process to all CSFP Sub Agencies within 45 days of Sub Agency Agreement execution. The dispute resolution process must be approved by FA and it shall not include FA as the arbitrator.
    2. When a dispute arises between the CSFP Lead Agency and Sub Agency that cannot be resolved by direct negotiation, the Sub Agency must follow the Lead Agency’s dispute resolution process. FA may provide feedback to Lead Agencies when they are dealing with a Sub Agency dispute.
  3. Dispute Resolution Resources.
    1. Authorized by the state legislature in the 1984 Court Improvement Act, Dispute Resolution Centers (DRCs) help create solutions to resolve disagreements by offering voluntary, confidential, informal, and non-adversarial alternatives to the legal system. Each DRC is a private, nonprofit organization or a service of local government with community-based facilitators. A list of DRC’s by county may be found at: https://www.courts.wa.gov/court_dir/?fa=court_dir.dispute.
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CSFP Procedures Manual Table of Contents
Section 8  
Revision History
Section 9 Revision 2025-07-15