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EFAP Section 10

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EFAP Procedures Manual Section 10: Program and Compliance Management

All WSDA FA EFAP forms and publications listed in this section are found here.

10.1 Administrative Due Dates

  1. Food Assistance (FA) is responsible for monitoring the operation of EFAP. This ensures the program is being administered in accordance with state (and applicable federal) 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 EFAP 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
  1. Annual Submittals.
Due Date EFAP 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 10 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
  • Lead Agency must notify FA of any changes to Lead Agency Contact Information (MS Forms)
Within 30 days of Agreement execution
(unless previously submitted) and
thereafter upon each renewal.
  • Certificate of Insurance (COI)
Within 30 days of EFAP Sub Agency
Agreement execution.
  • Sub Agency Agreement Face Sheets
Upon request or as needed
  • Other reports and data as requested
  1. Forms listed above may be downloaded from the FA EFAP Forms and Publications page, or a link to the MS Form may be provided by the regional representative.
  2. 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 EFAP Reports
30 days after Sub Agency
Agreement execution
  • If providing direct client services (e.g. Food Pantry), registration in wa211.org Statewide Telephone and Referral Network system
  • Certificate of Insurance (COI) and additional insured endorsements, if required by Lead Agency
  • Sub Agency Site List (AGR-2387)
  • The Sub Agency’s most recent audit report, if applicable
  • Accounting System Verification Form (AGR-2206), if applicable
  • Audit Requirement Form for Sub Agencies (AGR-2217)
45 days after Agreement execution
  • Client Privacy Policy
  • Client Release of Information Form
  1. Annual Submittals.
Due Date EFAP Reports
On the date determined by the Lead Agency of the month following provision of services
  • EFAP Sub Agency Client Data?
Annually, 30 days after the end of the Sub Agency’s fiscal year
  • Audit Requirement Form for Sub Agencies (AGR-2217)
  • Accounting System Verification Form (AGR-2206), if applicable
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
  • Sub Agency Site List (AGR-2387)
  • Annual Equipment Inventory Report (AGR-2201), if applicable
  • Annual Capital Improvement Inventory Report (AGR-2614), if applicable
Within 10 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 EFAP Forms and Publications page.

10.2 Lead Agency Compliance Management

  1. Conduct program reviews of Sub Agencies’ performance.
    1. Lead Agencies must review Sub Agencies' activities to assure they are following EFAP policies. This includes:
      1. Verifying that the Sub Agency meets all criteria listed in the Agreement, Procedures Manual, and other required instructions.
      2. Verifying all EFAP expenditures are appropriate and reported monthly, and that other applicable policies are followed.
    2. Lead Agencies must conduct program site reviews of Sub Agencies at least once per Agreement period (once every other year).
    3. Lead Agencies must produce a written report summarizing their program review visits with any corrective action needed.
    4. Lead Agencies must follow up on any findings and make a notation in the Sub Agency’s file of any corrective action.
    5. Lead Agencies must notify Food Assistance (FA) of any significant corrective action, this does not include items listed as required general follow-up.
    6. Lead Agencies must ensure that their review document, at a minimum, meets the standards set forth in the Sub Agency Agreement.
      1. FA must approve the review document that the Lead Agency is using for their Sub Agency reviews.
  2. Lead Agencies must take action to correct Sub Agencies’ performance.
    1. The Lead Agency must take action to correct any Sub Agency noncompliance in conformance with the program requirements for each program under which the Sub Agency receives food or funds.
    2. The Lead Agency may give a Sub Agency a specific period of time to comply and must follow the process for suspending or terminating a Sub Agency as outlined in the Agreement when a Sub Agency does not comply within that given timeframe.
  3. Lead Agencies may suspend or terminate the Sub Agency Agreement in part or in whole.
    1. Lead Agencies may terminate or suspend the Agreement, with 30 days' advance notice, as outlined in the Lead Agency's corrective action policies and as the Agreement allows.
      1. Regardless of whether or not the termination is for cause or at will.
    2. Lead Agencies may elect to recapture and reallocate unclaimed funds.
  4. The Lead Agency may select a new Food Bank or Food Pantry due to closures or terminations.
    1. If a Food Bank or Food Pantry vacancy occurs during an Agreement period, the Lead Agency will have flexibility in the selection process to mitigate gaps in service. The process will be as follows:
      1. The Lead Agency will contact the Food Pantries in the county(ies) to inform them that a new Food Bank or Food Pantry (exceptions apply) will need to be selected and seek input on prospective Food Banks, Food Pantries, and/or alternate solutions.
      2. The Lead Agency will determine the selection process and make the final selection for the new Sub Agency(ies) when a vacancy is due to closure or termination.
        1. The Lead Agency may also opt to select Sub Agency(ies) based on a two-thirds majority vote of eligible agencies in the impacted county(ies).
        2. The Lead Agency may opt to provide alternate solutions in the short-term such as providing mobile Food Pantry services, working with other Food Pantries closest to the impacted area, or conducting food purchases.
      3. Exception:
        1. If this was decided on at the Biennial Meeting, then the Lead Agency is obligated to follow the agreed upon process.
      4. The Lead Agency will determine any prospective Sub Agency’s eligibility prior to selection.
      5. The Lead Agency will enter into an Agreement with the new Sub Agency and notify FA of the outcome of the meeting.
  5. May reallocate funds when a Sub Agency closes or is terminated.
    1. During the agreement period, the Lead Agency may reallocate the funds of a closed or terminated Sub Agency and notify the existing Food Pantries of the reallocation plan, using the following methods:
      1. Reallocate funding to impacted Food Pantries based on the allocation formula used during the application process without an additional vote of the remaining voting agencies.
      2. Reallocate funding to the new Food Pantry or Food Bank without an additional vote of the remaining Food Pantries.
      3. Reallocate a portion of the funds to support short-term solutions.
      4. Exception:
        1. If this was decided on at the Biennial Meeting, then the Lead Agency is obligated to follow the agreed upon process.
    2. The Lead Agency may elect to hold a meeting with the remaining Food Pantries to determine the best use of the funds. This could include such decisions as giving the funding to the Food Pantry(ies) closest to the closing/terminated Food Pantry or spending the funds on some purchase that would benefit all providers such as a group food purchase or equipment purchase.
      1. The Lead Agency must have the support of two-thirds of the participating voting agencies (Lead and Food Pantry Sub Agencies) or permission from FA when distributing the funds differently than the original allocation formula.
    3. Lead Agencies must notify FA in writing the result of the reallocation, and if applicable, provide verification that the parties involved were in agreement of reallocation.

10.4 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 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 EFAP 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 EFAP 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 EFAP Lead Agency and a 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

10.6 Food Assistance Dispute Policy

  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 review by WSDA's Director, who may designate another person (designee) to hear the dispute, as follows:
  2. Disputing an FA decision.
    1. 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.
    2. FA must provide Lead Agencies with a copy of the dispute policy prior to or with any substantive decision.
    3. Any decision of FA to deny, award, recapture, reallocate, suspend, or terminate funds 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 Lead Agency dispute review process.
    1. The request must:
      1. Be written;
      2. Identify the Lead Agency’s name, address, and Agreement number;
      3. State the disputed issue(s);
      4. State each party’s position;
      5. Be sent to the Director, with a copy to the FA Program Manager within 15 working days after the parties agree that they cannot resolve the issue.
    2. The FA Program Manager must submit a written answer to the request to both the Director or the Director’s designee and the requestor within 10 working days.
    3. The Director or Director’s designee must review the written statements and provide a decision in writing to both parties within 15 working days. At the discretion of the Director or Director’s designee, the time in which to make a decision may be extended upon notice to both parties.
    4. The decision of the Director or the Director’s designee will be the final agency decision.
    5. The parties must attempt to resolve the dispute under this policy and as in the Disputes section of the Agreement, before filing a claim in any tribunal.
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EFAP Procedures Manual Table of Contents
Section 9
Revision History
Section 10 Revision 2025-09-30