TEFAP Procedures Manual Section 5: Client Management
All WSDA FA TEFAP forms and publications listed in this section are found here.
5.1 Written Client Privacy Standards Requirements
- Lead Agencies and Sub Agencies Must Have Written Client Privacy Standards.
- All providers must respect the privacy of their clients and make reasonable attempts to safeguard their information. Personally identifiable information (PII) collected, used, or acquired in connection with providing emergency food services must be used only for the purpose of those programs.
- Personally identifiable information (PII): Information identifiable to any person, including, but not limited to: information that relates to a person’s name, health, finances, education, business, use or receipt of governmental services or other activities, addresses, telephone numbers, social security numbers, driver license numbers, other identifying numbers, and any financial identifiers, and “Protected Health Information” under the federal Health Insurance Portability and Accountability Act of 1996 (HIPAA) Public Law No. 104-191, § 264, 110 Stat. 1936, any financial identifiers, and other information that may be exempt from public disclosure or other unauthorized persons under state and federal statutes.
- No personal identifiers associated with this program’s data may be shared with individuals or agencies outside of your organization, this program, etc., without written consent.
- One cannot release, divulge, publish, transfer, sell or otherwise make known to unauthorized persons PII without express written consent of the client or as provided by law.
- Participating agencies with direct client contact must have written client privacy policies on file.
- Sub Agencies must have copies of their client privacy policies on file with their Lead Agency.
- Participating agencies who make referrals for clients must have a copy of the client information release form on file.
- Written consent from the client shall include what client information can be shared and to whom or to which agencies/businesses. For a sample client release form, please contact the Lead Agency.
- Participating agencies agree to implement physical, electronic, and managerial safeguards to prevent unauthorized access to PII.
- Monitoring by Food Assistance (FA) of Personal Information Collected.
- FA reserves the right to monitor, audit, or investigate the use of personal information collected, used, or acquired by the Lead Agency. Not properly maintaining clients’ private information could result in termination of a TEFAP Agreement.
- The Lead Agency shall monitor the use of personal information collected by Sub Agencies.
5.2 United States Department of Agriculture (USDA) Nondiscrimination Statement
- All organizations that receive federal food or funding from Food Assistance (FA) must share this nondiscrimination statement with all clients.
Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the state or local agency that administers the program or contact USDA through the Telecommunications Relay Service at 711 (voice and TTY). Additionally, program information may be made available in languages other than English.
To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at How to File a Program Discrimination Complaint and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by:
1. Mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Mail Stop 9410, Washington, D.C. 20250-9410;
2. Fax: (202) 690-7442; or
3. Email: program.intake@usda.gov.
USDA is an equal opportunity provider, employer, and lender.
5.3 Written Beneficiary Notice and Referral Requirements for Participating Agencies
- Partnerships with Faith-Based and Neighborhood Organizations Final Rule (89 FR 15671 and 7 CFR Part 16).
- Because TEFAP is supported in whole or in part by financial assistance from the Federal Government, participating agencies are required to provide written notice of Beneficiary/Client Rights for CSFP, TEFAP, LFPA and referral requirements for CSFP and TEFAP.
- Participating agencies with direct client services must conspicuously display the Partnerships with Faith-Based and Neighborhood Organizations Final Rule “Written Notice of Beneficiary/Client Rights” (AGR-10017) at the point of client intake.
- The Lead Agency shall provide new posters upon request.
- Referral requirements for CSFP and TEFAP include providing either the phone or text number of the USDA Hunger Hotline. See poster for details.
- Because TEFAP is supported in whole or in part by financial assistance from the Federal Government, participating agencies are required to provide written notice of Beneficiary/Client Rights for CSFP, TEFAP, LFPA and referral requirements for CSFP and TEFAP.
- Existing Beneficiary/Client Notification.
- Participating agencies providing direct client services must notify beneficiaries already enrolled in the program and a written notice must be provided directly to all beneficiaries at food distribution locations or alongside a food package delivery. Existing beneficiaries should all be notified as soon as possible.
- Explicitly Religious Activities Are Not Allowed.
- Participating agencies may not discriminate against clients on the basis of religion, a religious belief, a refusal to hold a religious belief, or a refusal to attend or participate in a religious practice.
- Participating agencies may not require clients to attend or participate in any explicitly religious activities (including activities that involve overt religious content such as worship, religious instruction, or proselytization) that are offered by the organization, and any participation by clients in such activities must be purely voluntary.
- Participating agencies must separate in time or location any privately funded explicitly religious activities (including activities that involve overt religious content such as worship, religious instruction, or proselytization) from activities supported with direct federal financial assistance.
- See 7 CFR §16.4 and USDA Policy Memo FD-142 for further clarification.
5.4 Civil Rights Policy
- The civil rights policy applies to all participating organizations.
- The policy of Food Assistance (FA) is to not discriminate against any class of persons in all services to clients. FA expects local programs to provide food to every person who seeks it, regardless of their status as a member of any class of person.
- See Section 5.2, United States Department of Agriculture (USDA) Nondiscrimination Statement, as well as state and local laws for protected class information. Regardless of what classes are protected under law, food banks, food pantries, and meal programs are more likely to avoid a discrimination claim by following FA policy to not discriminate against any class of people. The purpose of the program is not to judge a person’s status, but to feed hungry people.
- As well as not discriminating against any class of people, providers must also adhere to the following:
- Employees and volunteers meeting the same eligibility requirements for services shall be given the same opportunity to receive services and shall be treated the same as other clients.
- They must treat all clients with dignity.
- They shall not require, request, or accept payment or donations from clients for food received.
- They shall not practice evangelism or proselytize, request or require clients to participate in any kind of religious service as a condition for receiving emergency food.
- They may not put religious literature in food bags, pray in the presence of clients, or ask clients if they would like to pray before, during, or after receiving food. Food pantry activities must be separated from any religious activities.
- They may have religious literature on a table or counter that clients may voluntarily take separate from any food being distributed.
- Lead Agencies will ensure that they and their Sub Agencies have in place a notification system that includes informing applicants and clients, at the service delivery point, of their right to file or make a verbal complaint including an anonymous complaint. At a minimum, this can be accomplished by posting the USDA Title VI “And Justice for All” nondiscrimination poster displayed in a conspicuous location at all distribution sites (food pantries and meal programs). The nondiscrimination language must be on all printed program (TEFAP) brochures.
- All agencies that receive federal financial assistance, including food, must provide civil rights training to volunteers and staff involved in all levels of the administration of these programs on an annual basis. Lead Agencies are responsible for providing their staff and volunteers that interact with clients and/or who handle personal information of clients with training on civil rights annually. Lead Agencies will ensure their Sub Agencies provide training for their staff and volunteers on an annual basis.
- FA provides civil rights training tools on the FA webpage.
5.5 Civil Rights Training
- The Civil Rights training requirement applies to all participating agencies.
- Lead Agencies will ensure that they and their Sub Agencies have annual civil rights training.
- Pursuant to FNS Policy Memo FD-113, Lead Agencies are responsible for providing all applicable staff and volunteers with annual civil rights training.
- Additionally, Lead Agencies are responsible for ensuring their Sub Agencies, including staff and volunteers who interact with program applicants or clients and/or participate in program administration are provided civil rights training on an annual basis. Lead Agencies must review to ensure Sub Agencies conduct the annual civil rights training for staff and/or volunteers, as applicable.
- Food Assistance (FA) has provided additional civil rights training information that should be reviewed. Additional questions can be directed to the Lead Agency.
- FA has provided two approved civil rights training checklists on its website for participating agencies to use. Agencies should review all guidance document checklists before determining which training is best suited for its employees or volunteers based on their roles in administering the program.
- Organizations must utilize FA provided civil rights training tools as applicable. The Annual Civil Rights Training for Frontline Staff/Volunteers/Management (AGR-2198) is used for primary staff and volunteers that are directly involved in the administration of TEFAP and, the Annual Civil Rights Training for Non-Frontline Staff/Volunteers/Management (AGR-2199) is used for secondary staff and volunteers that may not directly administer TEFAP but are still required to receive the training annually. See guidance documents at the FA TEFAP Forms and Publications website for more details.
5.6 Civil Rights Complaint Process
- Lead Agencies will ensure that they and their Sub Agencies follow the civil rights complaint process.
- Federal Civil Rights Language:
- In accordance with federal civil rights law and the USDA civil rights regulations and policies, the USDA, its agencies, offices, employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident.
- Any person or representative alleging discrimination based on a protected class has the right to file a complaint within 180 days of the alleged discriminatory action. Complaints may be accepted in both written or verbal form. If the allegation is received verbally, the person to whom they are made is responsible for writing up the elements of the complaint on behalf of the complaintant.
- Filing a Federal Civil Rights Complaint: Advise people who allege discrimination based on one or more of the federally protected classes listed above on how to file a complaint using the USDA Program Discrimination Complaint Form, AD-3027 found online at https://www.usda.gov/about-usda/general-information/staff-offices/office-assistant-secretary-civil-rights/how-file-program-discrimination-complaint and at any USDA office. or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by:
- Mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Ave SW, Mail Stop 9410, Washington, DC 20250-9410;
- Fax: (202) 690-7442; or
- Email: program.intake@usda.gov
- USDA is an equal opportunity provider, employer, and lender.
- Federal Civil Rights Complaints.
- A client may address complaints directly to the organization in which they receive assistance. Additionally, federal civil rights complaints may be submitted directly to the United States Department of Agriculture (USDA):
- Online via the Program Discrimination Complaint Portal. You can now file a complaint directly through the USDA's Program Discrimination Complaint Porta. This convenient, secure portal allows you to submit your complaint electronically.
- By Form. Complete the USDA Program Discrimination Complaint Form or the Formulario de quejas por discriminacion en los programas del USDA.
- By Email or Letter. To file a program discrimination complaint, you may email the required details of this complaint to program.intake@usda.gov.
- Lead Agencies and their Sub Agencies must accept and process all federal civil rights complaints received by a client regardless of whether the complaints are written, verbal, or anonymous.
- Client information and the identity of the person making a complaint or allegation against persons participating in or administering TEFAP must be kept confidential.
- Verbal Complaints: In the event that a complainant makes the allegations verbally or in person and refuses or is not inclined to place such allegations in writing, the person to whom the allegations are made must write up the elements of the complaint for the complainant. Every effort should be made to have the complainant provide the following information:
- Name, address, telephone number, or other means of contacting the complainant.
- Specific location and name of the state agency, local agency, or other sub-recipient delivering the service or benefit.
- Nature of the incident or action that led the complainant to feel discrimination was a factor, and an example of the method of administration that is having a disparate effect on the public, potential eligible persons, applicants, or clients.
- Basis on which the complainant believes discrimination exists. The bases for nondiscrimination are race, color, national origin, age, disability, or sex.
- Names, telephone numbers, titles, and business or personal addresses of persons who may have knowledge of the alleged discriminatory action.
- The date(s) during which the alleged discriminatory actions occurred, or if continuing, the duration of such actions.
- Civil rights complaints may be submitted on behalf of a client or the client may address complaints directly to the USDA using the USDA Program Discrimination Complaint Form (AD-3027).
- If a Lead Agency or their Sub Agency submits a civil rights complaint on behalf of a client, then Food Assistance (FA) must be notified within five calendar days of receiving a complaint. If available, attach the completed USDA Program Discrimination Complaint Form (AD-3027).
- Make sure that all civil rights complaints are properly documented and reported. All civil rights complaints will be investigated by the FA Program Manager (or delegate) and notification will be given to USDA FNS Western Region upon receipt. FA will maintain a record of and track all federal civil rights complaints including complaint status (pending, follow-up, completed, or referred to USDA FNS).
- A client may address complaints directly to the organization in which they receive assistance. Additionally, federal civil rights complaints may be submitted directly to the United States Department of Agriculture (USDA):
- State Civil Rights Complaints.
- In accordance with state law, everyone has the right to be free from discrimination at work, in housing, in a public accommodation, or when seeking credit and insurance. A discrimination charge in employment, public accommodation, credit and insurance must be filed with the Washington State Human Rights Commission (WSHRC) within six months from the date of the alleged violation in order to protect your rights. A discrimination charge in housing must be filed with the WSHRC within one year from the date of the alleged violation. Washington State protected classes are race/color, national origin, creed, sex/pregnancy, sexual orientation/gender identity, veteran/military status, the presence of any sensory, mental, or physical actual disability or perceived disability, use of a service animal, HIV or Hepatitis C, marital status (except in public accommodation), breastfeeding (in public accommodation), age (40+, employment only), families with children (housing only), state employee whistleblower, and immigration status.
- Filing a State Discrimination Complaint.
- Advise people who allege discrimination based on one or more of the state-protected classes of people listed above that they may file a discrimination complaint with the Washington State Human Rights Commission (WSHRC). A description of the processes and a link to the forms are online and can be found at: https://wahum.my.site.com/FileaComplaintOnline/s/?language=en_US.
5.7 Client Eligibility and Data Collection
- This applies to participating agencies providing direct client services.
- Client Eligibility and Required Information for Food Pantries:
- The Washington State Department of Agriculture (WSDA) Food Assistance (FA) establishes the eligibility criteria for client and household data collection requirements with approval from the USDA. Eligibility information must be gathered for household distribution using the TEFAP Client Intake Form (AGR-2271) or the TEFAP Individual Client Intake Form - Annual (AGR-2342), or an FA approved alternate client intake form and/or method. If not using an approved TEFAP intake form, the participating agency should request approval from the organization with which they hold the TEFAP Agreement.
- An eligible client must self declare:
- Their name and household size provided is correct.
- Client's name
- Household size - the number of persons residing at the client’s household/family members
- They live within this state (there is no minimum length of residency required).
- Their income is at or below 400 percent of the Federal Poverty Guidelines (net, after taxes) as posted for the distribution.
- They agree that TEFAP USDA Foods are for home consumption and the household is in need of this food.
- Their name and household size provided is correct.
- All clients receiving TEFAP USDA Foods must be informed of the following:
- They will not be denied TEFAP USDA Foods if they do not wish to disclose any information that is not a requirement of TEFAP.
- They will never need to provide their address, social security number, or identification.*
- They will never need to provide proof of: citizenship, immigration status, household size, or income.*
- Food is not for resale.
- A copy of the full USDA Nondiscrimination Statement is available upon request.
- Ensuring that the same level of service is provided to all clients regardless of where the client lives within the state of Washington.
- A Sub Agency's service area must not limit or deny services to any client, including a person experiencing homelessness, that resides outside of the Sub Agency's "declared" service area.
- The Sub Agency must provide eligible clients seeking services with TEFAP USDA Foods no less than once per month.
- All clients are to be treated with dignity and respect. Any attempts to limit client access based on where a client lives within the state of Washington is a barrier and not allowed for TEFAP.
- As a courtesy to the client, the Sub Agency may provide the client with information regarding TEFAP Food Pantries serving the area in which the client resides. However, the client is under no obligation to seek services somewhere else.
- Food Pantries with appointment-based intake process must allow all clients within the state of Washington to be eligible for an appointment.
- Allowable exceptions include:
- A Food Pantry at a school (pre-K-12 or college) that only serves current students.
- A domestic violence shelter that only serves current residents/service recipients.
- A home delivery program or a delivery program targeted towards clients experiencing homelessness.
- A kid's weekend backpack program.
- *Note: This information is on the TEFAP Client Intake Form (AGR-2271), TEFAP Individual Client Intake Form - Annual (AGR-2342), or the TEFAP Client Notification Handout (AGR6-2509-031).
- Income Guidelines:
- At all participating TEFAP Food Pantries, income guidelines are 400 percent of federal poverty level are based on net income (after taxes), and are updated and provided to Lead Agencies annually by WSDA FA. Lead Agencies must ensure that their Sub Agencies are using current income guidelines, the guidelines are incorporated into the TEFAP client intake process to be viewed at the point of client intake.
- The TEFAP Income Eligibility Guidelines (AGR6-2509-030) can be found on the FA website and are also available in Chinese, Korean, Russian, Somali, Spanish, Ukrainian, and Vietnamese.
- At all participating TEFAP Food Pantries, income guidelines are 400 percent of federal poverty level are based on net income (after taxes), and are updated and provided to Lead Agencies annually by WSDA FA. Lead Agencies must ensure that their Sub Agencies are using current income guidelines, the guidelines are incorporated into the TEFAP client intake process to be viewed at the point of client intake.
- Food Pantry Categorical Eligibility:
- Household Distribution: Children receiving free or reduced-price meals through the National School Lunch Program are considered categorically income eligible for participating in weekend backpack programs supported with TEFAP USDA Foods.
- A parent must give consent for their child to participate, at least annually.
- This standard must be applied to all TEFAP clients statewide, whether they seek assistance at a school or any other TEFAP distribution site.
- Household Distribution: Children receiving free or reduced-price meals through the National School Lunch Program are considered categorically income eligible for participating in weekend backpack programs supported with TEFAP USDA Foods.
- Food Pantry Data Collection for Household Distribution:
- FA provides standardized client intake forms for participating agencies. There may be a need for alternate forms as agencies may also operate other programs with different data collection requirements, which will be allowed as long as forms receive FA approval.
- The TEFAP Household Intake Form (AGR-2271), is used to collect data from multiple clients on one form each time the client receives TEFAP USDA Foods.
- To protect client PII, many pantries incorporate a privacy shield (piece of paper) over sections of the form that have already been filled out so that personal information is not compromised.
- The TEFAP Individual Client Intake Form - Annual (AGR-2342), is used to collect data from one client/household and is updated on an annual basis.
- If using this form the Sub Agency must still track each time the client receives food.
- The client is assumed to be eligible for future distributions, up to 12 months.
- The client must be informed that they are required to report any changes in their eligibility information immediately.
- Alternate client intake forms, including electronic, must receive FA approval. Sub Agencies contact their Lead Agency if using an alternate client form and the Lead Agency will work with FA to ensure compliance.
- Regardless of what type of client intake form the Sub Agency uses, the following information must be visible to clients at the point of client intake. See FA provided intake documents for details.
- Required self-declaration.
- Required client information posting.
- Required postings.
- Current TEFAP income guidelines.
- Full USDA Nondiscrimination Statement.
- And Justice For All Poster, original copy.
- Partnerships with Faith-Based and Neighborhood Organizations Final Rule Written Notice of Beneficiary/Client Rights (AGR-10017). The Lead Agency shall provide new posters upon request.
- The TEFAP Household Intake Form (AGR-2271), is used to collect data from multiple clients on one form each time the client receives TEFAP USDA Foods.
- FA provides standardized client intake forms for participating agencies. There may be a need for alternate forms as agencies may also operate other programs with different data collection requirements, which will be allowed as long as forms receive FA approval.
- Electronic Client Intake Systems:
- The use of electronic client intake and record keeping systems is permitted in TEFAP, provided that the same degree of confidence regarding the accuracy of eligibility determinations results from the electronic system as from the traditional, paper-based system. Lead Agency and FA approval is required for all intake systems.
- Food Pantry Reporting Requirements:
- Sub Agencies report all monthly TEFAP activity (all TEFAP clients served - all visits) to their Lead Agency on a monthly basis using the TEFAP Sub Agency Inventory Report (AGR-2272E) or an FA approved inventory report. Required reporting includes:
- Monthly total households served – how many households were served that month.
- Monthly total clients served – how many total people were served that month.
- TEFAP monthly inventory
- Beginning inventory (TEFAP USDA Foods remaining from previous month), TEFAP USDA Foods received, distributed to clients, damaged (as applicable), and remaining in inventory. To be completed on the last business day of the month, after all TEFAP USDA Foods have been received and/or distributed for the period.
- Sub Agencies report all monthly TEFAP activity (all TEFAP clients served - all visits) to their Lead Agency on a monthly basis using the TEFAP Sub Agency Inventory Report (AGR-2272E) or an FA approved inventory report. Required reporting includes:
- Use of a Proxy:
- If a client is unable to pick up a TEFAP distribution due to a disability, health concern, transportation issues, or conflicting work hours, the eligible client and their proxy may complete the TEFAP Receipt of USDA Commodities Proxy Form (AGR-2345). A proxy means any person designated by a client or caretaker to obtain TEFAP USDA Foods on behalf of the client and are especially helpful to clients with limited mobility.
- It is important to remember:
- The form must be signed by both the client and the proxy, as well as site personnel.
- The proxy may self-attest or otherwise verify their identity by stating their name, signing a document, or otherwise verbally confirming their identity when picking up TEFAP USDA Foods on behalf of the client.
- Food Pantry Guidelines for Providing Service to Staff/Volunteers that are also Eligible Clients:
- If participating TEFAP agency staff or volunteers also qualify to receive USDA Foods they may receive those foods at the same time as other clients without preferential treatment.
- The staff person would go through the same process to receive TEFAP USDA Foods as would a client. They would fill out the TEFAP Client Intake Form (AGR-2271) and/or approved client intake form; they would receive the same type of USDA Foods, same amount of USDA Foods and at the same time.
- The quantity and type of USDA Foods will be the same for eligible staff as it is for clients. At no time may staff or volunteers receive more or “better” types of USDA Foods than what the clients are receiving.
- If participating TEFAP agency staff or volunteers also qualify to receive USDA Foods they may receive those foods at the same time as other clients without preferential treatment.
- Client Eligibility and Required Information for Meal Programs:
- There is no federal standard or requirement for determining the eligibility of people to receive prepared meals. They are presumed to be needy because they seek meals at an approved TEFAP site.
- No means testing of clients is allowed.
- Sites do not have to request any client information nor maintain records of the names of the people to whom they serve meals.
- There is no federal standard or requirement for determining the eligibility of people to receive prepared meals. They are presumed to be needy because they seek meals at an approved TEFAP site.
- Meal Program Categorical Eligibility:
- All WA residents are categorically eligible for service at a TEFAP participating meal program (congregate meal program). There is no standard or requirement for otherwise determining the eligibility of individuals, including children, to receive prepared meals.
- Note: Participating agencies are only approved for participation in TEFAP if serving predominately needy residents.
- All WA residents are categorically eligible for service at a TEFAP participating meal program (congregate meal program). There is no standard or requirement for otherwise determining the eligibility of individuals, including children, to receive prepared meals.
- Meal Program Reporting Requirements:
- Sub Agencies report all monthly activity to their Lead Agency monthly using the TEFAP Sub Agency Inventory Report (AGR-2272E). Reporting requirements include:
- Total meals served.
- TEFAP USDA Foods monthly inventory.
- Beginning inventory (TEFAP USDA Foods remaining from previous month), USDA Foods received, served to clients, damaged (as applicable), and remaining in inventory. To be completed on the last business day of the month, after all USDA Foods have been received and/or distributed for the period.
- Sub Agencies report all monthly activity to their Lead Agency monthly using the TEFAP Sub Agency Inventory Report (AGR-2272E). Reporting requirements include:
- Meal Program Guidelines for Providing Service to Staff/Volunteers that are also Eligible Clients:
- Participating agencies may institute an internal policy prohibiting staff or volunteers from receiving USDA Foods meals during a scheduled distribution because of the potential for abuse and the negative perception or effects it may have on an agency’s ability to maintain transparency and a positive relationship with the community it serves.
- Specifically, it is prohibited to use USDA (no matter how small) for staff luncheons, potlucks, or functions.
- It is allowable (and an allowable expense) to provide volunteers and staff non-TEFAP meals (on-site) rather than closing the site during a scheduled lunch period. See USDA Policy FD-017 for more detail. Meals must be:
- Reasonable
- Adequately documented. A participating agency must maintain the following information on file to support costs applied to the program:
- Each volunteer’s name;
- Hours each volunteer worked;
- Receipts, invoices, or other evidence of the cost of providing lunches to volunteers; and
- The volunteer’s signature for each lunch received.
- Participating Agencies may have additional internal rules that regulate this activity – a Sub Agency should reach out to their Lead Agencies for more information.
- Under no circumstances can a participating agency use TEFAP funding for the purchase of (unprepared) food.
- Participating agencies may institute an internal policy prohibiting staff or volunteers from receiving USDA Foods meals during a scheduled distribution because of the potential for abuse and the negative perception or effects it may have on an agency’s ability to maintain transparency and a positive relationship with the community it serves.
5.8 Unallowable Activities
- Unallowable Activities
- TEFAP clients must not be pressured or influenced to support any explicitly religious activities, or social or political point of view in association with the receipt of TEFAP USDA Foods for home consumption or prepared meals.
- Unrelated activities may be conducted at distribution sites as long as:
- The activity is separated by time or location i.e. in a room not being used for distribution or at a time when the location isn’t being used for distribution;
- The person conducting the activity makes it clear that the activity is not part of TEFAP and is not endorsed by the USDA;
- Information not related to TEFAP is not placed in or printed on TEFAP USDA Foods distribution containers;
- The person conducting the activity makes it clear that cooperation is not a condition of receipt of TEFAP USDA Foods, i.e., attending religious services, contributing money, signing petitions, or conversing with the people; and
- The activity does not disrupt distribution of TEFAP USDA Foods.
- The Lead Agency and distribution site personnel are responsible for ensuring that activities unrelated to the distribution of TEFAP USDA Foods are conducted in a manner consistent with the above conditions. Agencies found in violation of the policies regarding unrelated activity are subject to termination from TEFAP.
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