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EFAP Section 4

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EFAP Procedures Manual Section 4: Applications and Agreements

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

4.1 Biennial Applications

  1. The EFAP Biennial Application (AGR-2205) must be completed by the Lead Agency and submitted to Food Assistance (FA) by the due date listed on the checklist, along with the EFAP Biennial Meeting Minutes Tool (AGR-2396) or an alternate format that contains all of the information that is required in the Biennial Meeting Minutes Tool. Additional documentation may be required.
  2. The EFAP Biennial Application (AGR-2205) includes the following tabs:
    1. Checklist & Instructions: Instructions for completing the Biennial Application and a list of all required documents due with your application.
    2. Summary: Applicant (Lead Agency) Contact Information, Budget Roll-up, Counties Served, Certification.
    3. County 1: Participating Food Pantry(ies) and Budgets, participating Food Bank(s) and Budgets. 
    4. County 2: Participating Food Pantry(ies) and Budgets, participating Food Bank(s) and Budgets. 
    5. County 3: Participating Food Pantry(ies) and Budgets, participating Food Bank(s) and Budgets. 
    6. County 4: Participating Food Pantry(ies) and Budgets, participating Food Bank(s) and Budgets. 
    7. County 5: Participating Food Pantry(ies) and Budgets, participating Food Bank(s) and Budgets. 
  3. The Lead Agency will input the required data. The Application includes automatic roll-up features within the Excel workbook to minimize data entry by the Lead Agency.
  4. Once the EFAP Biennial Application is completed then the Lead Agency will submit it, the Biennial Meeting Minutes, signed FA Accounting System and Financial Capability Questionnaire (AGR-2383), and Biennial Meeting Ballot Tool (AGR-2397), if applicable, to their FA Regional Representative by email.

4.2 Contracting Process for Agreements Between Food Assistance and the Lead Agency

  1. The Lead Agency is the eligible organization that is voted to be, by the participating Sub Agency Food Pantries, their county’s Emergency Food Assistance Program (EFAP) Lead Agency for the upcoming two-year Agreement period.
  2. The Lead Agency will enter into an Agreement with the Washington State Department of Agriculture Food Assistance (FA) for the upcoming biennium. FA will issue the EFAP Agreement to a Lead Agency via DocuSign.
    1. EFAP Agreements will begin on the first day of the biennium, July 1, and end on the last day of the biennium, June 30.
    2. The EFAP Agreement supported with state funds is considered a Grant. See Section 2.2, Program History - EFAP Flowchart.
    3. Monthly invoice workbooks and client data reports are required. See Section 7.4, Required Invoicing and Data Reports for additional details.
  3. Once the Lead Agency Agreement has been executed, additional documents will be required to be submitted. At a minimum, the following items will be required:
    1. 10 days after Agreement execution:
      1. If applicable, the Lead Agency’s most recent audit report.
    2. 30 days after Agreement execution:
      1. If providing direct client services (Food Pantry) registration in 211 Statewide Telephone and Referral Network system.
      2. Insurance certificates and additional insured endorsements.
      3. Current Sub Agency Agreements Face Sheet, including signature page.
      4. Lead and Sub Agency Owned, Operated, and Sponsored Site Lists.
      5. The Lead Agency’s most recent audit report, if applicable (This requirement applies to Lead Agencies that did not enter into an EFAP Agreement with FA in the previous biennium).
      6. FA Accounting System Verification Form (AGR-2206), if applicable.
      7. FA Single Audit Exemption Form for Lead Agencies (AGR-2207).
    3. 45 days after Agreement execution (New Lead Agencies only):
      1. Client Confidentiality Policies.
      2. Corrective Action for Sub Agencies.
      3. Dispute Resolution Process for Sub Agencies.

4.3 Contracting Process for Sub Agreements Between Lead Agencies and Sub Agencies

  1. The Sub Agency is the organization that holds a written Agreement with the Lead Agency to implement the program at the local level. 
  2. The Lead Agency enters into Agreements with its Sub Agency Food Bank(s) and Food Pantries.
    1. The Lead Agency must execute EFAP Sub Agency Agreements with its Sub Agencies.
    2. Unless using the Food Assistance (FA) EFAP Sub Agency Agreement template without modification, the Lead Agency must first obtain approval from FA.
      1. FA’s review for approval will be limited to assuring that the Sub Agency Agreement contains the minimal substantive terms that FA considers necessary for EFAP.
      2. Lead Agencies should seek their own legal advice to determine the adequacy of the FA provided template.
      3. When updated, FA will notify Lead Agencies and post the Sub Agency Agreements on the EFAP webpage.
  3. EFAP Agreements will begin on the first day of the biennium, July 1, and end on the last day of the biennium, June 30.
  4. Once the Sub Agency Agreement has been executed, the Sub Agency Site List (AGR-2387) and additional documents will be required, including the following:
    1. 30 days after Agreement execution:
      1. The Sub Agency’s most recent audit report, if applicable.
      2. FA Accounting System Verification Form (AGR-2206), if applicable. 
        1. Sub Agencies receiving only food (no funds) are not required to complete the FA Accounting System Verification Form (AGR-2206). 
        2. Sub Agencies submit this form to their Lead Agency on an annual basis. 
      3. Registration of Food Pantry with 211.
      4. Insurance certificates and additional insured endorsements.
      5. FA Audit Requirement Form for Sub Agencies (AGR-2217).
        1. Sub Agencies submit this form to their Lead Agency on an annual basis. 
      6. Other documents as requested.

4.4 Sub Agency Agreements and Fiscal Sponsorship

  1. Fiscal Sponsorship is an arrangement between an existing 501(c)(3) nonprofit and a project, program, or even another nonprofit. The sponsor extends its tax-exempt status to the project (food pantry or meal program) so the project can receive food and/or funding. The Fiscal Sponsor provides fiduciary oversight, financial management, and other administrative services to strengthen the ability for charitable projects to succeed. The Fiscal Sponsor assumes responsibility for compliance and risk; the sponsored project gives up autonomy in exchange for borrowing the credibility of the sponsor’s 501(c)(3) status.
  2. If not in conflict with their contracting policies and procedures, Lead Agencies may sign a Sub Agency Agreement with an organization that is fiscally sponsored. Below are considerations but do not constitute legal advice.
  3. A Fiscal Sponsor must meet all Sub Agency Agreement eligibility guidelines (see Sub Agency Agreement for more details):
    1. Have the required status:
      1. 501(c)(3) federal tax-exempt status (and thus includes the activity in its annual IRS Form 990 reporting). This would include the Sponsor’s EIN, or
      2. A federally-recognized Tribe, or
      3. Be a church as defined by the IRS (Alternate 501(c)(3) Church Verification Form (AGR-2241)).
    2. Have a Unique Entity Identification (UEI) number in the System of Award Management (SAM).
    3. Have WA Secretary of State non-profit corporation status, if not a public agency or federally recognized tribe.
    4. Not be suspended or debarred from participating in any federal or state transactions.
    5. As required by the Lead Agency:
      1. Insurance coverage
  4. A Fiscal Sponsor handles all financial administration, controlling the funds and assets. A sponsored activity/program typically has no board of directors, no tax return, and no bank account, except petty cash. A fiscal sponsor provides all audit, fiscal, and other verification forms required by the Sub Agency Agreement to the Lead Agency.
  5. Note: To execute a Sub Agency Agreement, a sponsored organization/pantry may only have one sponsor. It is not appropriate to mix-and-match compliance roles, using one nonprofit’s tax-exempt status and another organization’s insurance coverage, with a few possible exceptions (such as if a food distribution site is located in a building insured by another entity). On the other hand, one sponsor can have multiple sponsored activities/sites. Fiscal Sponsors hold tremendous responsibility. They must ensure that their program and any sponsored projects comply with FA rules and requirements.
  6. When working with sponsored projects, the Lead Agency should engage the Fiscal Sponsor as the organization with which it holds the Sub Agency Agreement. The Fiscal Sponsor’s legal name, Tax ID, SAM, etc., should be listed on the Sub Agency Agreement. The Lead Agency should know who has signature permissions for the Fiscal Sponsor and whether an MOU is in place with the sponsored project (as necessary).
  7. Fiscal sponsorship situations and the level of involvement the Sponsor has chosen to provide may differ case to case. Regardless, the Lead Agency should endeavor to reduce risk to itself, the program, the participating organizations and provide a framework for success in administering EFAP. If a Lead Agency has questions about fiscal sponsorship, contact the Regional Representative assigned to your agency.
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EFAP Procedures Manual Table of Contents
Section 3 Section 5
Revision History
Section 4 Revision 2025-09-30