CSFP Section 2


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CSFP Procedures Manual Section 2: Introduction to CSFP

2.1 Definitions

Acquisition Cost: The total costs incurred in acquiring and readying an asset for its intended use, including the cost of modifications, accessories, and ancillary charges.

Administrative Expenses: The expenses incurred in the overall operation and management of the organization that are direct billed. Salaries, wages, supplies, general expenses, and membership dues that are direct billed.

Agreement: A written agreement (Grant – state funding, Subaward – federal funding) between the Washington State Department of Agriculture (WSDA) Food Assistance (FA) and the Lead Agency identifying the rights and obligations of both parties governed by the Agreement, including the following of exhibits, attachments or other documents incorporated by reference.

Ancillary Charges: The expenses involved in the transaction, but not directly related or incidental. These expenses include items such as taxes, duty, transit insurance, freight, and installation may be included in the acquisition cost, in accordance with the participating organization’s accounting practices.

Applicant: Any person who applies to receive CSFP benefits. Applicants include program participants applying for CSFP recertification.

Assistance Listing Number: Assistance listings are detailed public descriptions of federal programs that provide grants, loans, scholarships, insurance, and other types of assistance awards. Previously known as the Catalog of Federal Domestic Assistance (CFDA).

Authorized Representative: For FA, the designee authorized in writing to act on the Director’s behalf; for the Lead Agency, the Authorized Signer.

Authorized Signature: Signature of the board president, tribal chairperson, agency director, or other official authorized to sign.

Bill Of Lading (BOL): A document provided by the shipping/trucking agent or warehouse as a written record of program food shipped to or received by the Lead Agency or Sub Agency. The BOL details the types and amounts of food shipped or received.

Capital Assets: Tangible or intangible assets used in operations having a useful life of more than one year which are capitalized in accordance with Generally Accepted Accounting Principles (GAAP). See Federal Guidance 2 CFR §200.1 and §200.465.
  • Capital assets include land, buildings (facilities), equipment, equipment repair, and intellectual property (including software) whether acquired by purchase, construction, manufacture, lease-purchase, exchange, or through capital lease. FA funding is not to be utilized for the purchase of land or new buildings. Some exceptions may apply.
  • Capital assets do not include intangible right-to-use assets and right-to-use operating lease assets. For example, capitalized assets that recognize a lessee's right to control the use of property and/or equipment for a period of time under a lease contract.
Capital Expenditures: Spending funds by an organization to acquire, maintain, or improve capital assets thereby extending their useful life and increasing their value.

Capital Improvement Project: The actual additions, improvements, modifications, replacements, rearrangements, reinstallations, renovations, or alterations to property, infrastructure, or facilities that increase their value or useful life (not ordinary repairs and maintenance), has a per unit cost which equals or exceeds the lesser of the capitalization level established by the organization for financial statement purposes, of $10,000 (if procured October 1, 2024, or thereafter).

Capitalization Policy: The criteria used by an organization to determine which capital expenditure should be reported as a capital asset. Capital assets with a unit cost (including ancillary costs) of $10,000 or greater, or collections of capital assets with a total cost of $10,000 or greater, are capitalized, unless otherwise noted.

Caseload: The number of persons authorized by FA for the Lead Agency to serve on a monthly basis. The state caseload is determined by FNS.

Caseload Cycle: The period from January 1 through the following December 31. Caseload may be adjusted based on the Federal Fiscal Year or during the course of the Federal Fiscal Year.

Certification: The use of criteria and procedures to assess, determine and document each applicant’s eligibility for CSFP.

CFR: The Code of Federal Regulations. 7 CFR Parts 247 and 250 have CSFP specific information.

Contract: A written Agreement between FA and the Contractor/Vendor identifying the rights and obligations of both parties governed by the Contract, including the following of exhibits, attachments or other documents incorporated by reference.

Coordinated Services: Making contact with and sharing information about other programs and establishing procedures for referring clients between food pantries and other services.

CSFP: The Commodity Supplemental Food Program authorized by 7 USC §612c and subject to 7 CFR Parts 247 and 250.

CSFP Client: Senior adult, 60 years of age or older, authorized by a local agency to receive a CSFP package in a given month. Also called a participant.

CSFP Household: To determine income eligibility, a household consists of a group of related or non-related individuals, exclusive of boarders, who are not residents of an institution, but who are living as one economic unit and for whom food is customarily purchased and prepared in common. Also, it refers to the number of people reported by the CSFP client and is inclusive of a single individual living alone.

CSFP Lead Agency Inventory Report: A form used by CSFP Lead Agencies to track the receipt, issuance and inventory of CSFP USDA Foods on a monthly basis; includes client data.

CSFP State Plan: The required plan submitted by the state agency and approved annually by USDA FNS describing the manner in which the state agency will implement and operate all aspects of the program within its jurisdiction.

CSFP Sub Agency Inventory Report: A form used by CSFP Sub Agency food pantries to track the receipt, issuance and inventory of CSFP USDA Foods on a monthly basis; includes client data.

CSFP USDA Foods: The nutritious foods purchased by USDA to supplement the diets of CSFP participants. Also referred to as USDA Foods.

Current Fair Market Value: The value of equipment and supplies determined by selling them in a competitive market or by researching advertised prices for similar items on the used market.

Davis-Bacon Act: Federal law requiring the payment of prevailing wage in certain contracts (minimum threshold of $2,000.00) for the construction, alteration, or repair (including painting and decorating) of public buildings or public works supported with federal funding and required by the fund source. Exceptions may apply.

Debarment, Suspension, and Ineligibility: The act of being suspended or being declared ineligible by any state or federal agency from participating in any transactions with them. Also referred to as suspension and debarment.
  • Lead Agencies certification is required in all written Agreements that indicates neither they nor their principals are not presently debarred, declared ineligible, or voluntarily excluded from participation in transactions by the state of Washington and, if federal funds are a source of funding, any Federal department or agency.
Direct Client Services: Conducting programming that has direct contact with clients such as food distribution and/or certifying clients for a program or services.

Disqualification: The act of ending CSFP participation of a participant as a punitive sanction.

Dual Participation: Simultaneous participation by an individual in CSFP at more than one CSFP distribution site.

Emergency Food: Food that is given to clients who do not have the means to acquire that food themselves, so that they will not go hungry.

Equipment: Tangible personal property (including information technology systems) that has a useful life of more than one year, is movable, and has a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-federal entity (organization) for financial statement purposes, or $10,000.

Equipment Repairs: Equipment repairs with a cost of $10,000 or more are considered a capital expenditure and should be capitalized when they prolong the useful life of the equipment being repaired. Equipment repair costs which equal or exceed the lesser of the capitalization level established by the non-federal entity (organization) for financial statement purposes, or $10,000. Equipment repairs funded in part or entirely with FA funds must be pre-approved by FA.

Federal Award Uniform Guidance: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, available at https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II.

Federal Fiscal Year (FFY): The accounting period of the federal government. It begins on October 1 and ends on September 30 of the next calendar year.

First In, First Out (FIFO): An inventory control system to ensure that the USDA Foods received in “first” are also the “first” to be issued out. Typically, USDA Foods are to be stored so that the stock rotation of USDA Foods with the nearest expiration/Best If Used By dates are in front and used first, followed by USDA Foods with the oldest pack dates.

Food Assistance (FA): Washington State Department of Agriculture's (WSDA) Food Assistance (FA) and its programs.

Food Assistance Advisory Committee (FAAC): Part of the Washington Food Coalition (WFC) that makes recommendations to FA for program and policy improvements.

Food Bank: An organization that collects, warehouses, and distributes food, including perishable foods, or other products to hunger relief organizations on a regional, county, or statewide basis. Also referred to as a Provider.

Food and Nutrition Services (FNS): The section of the United States Department of Agriculture (USDA) that manages the majority of the federal food assistance programs.

Food Pantry: An eligible hunger relief organization that distributes unprepared food without charge to its clients and is selected to participate in CSFP. The organization must provide direct client services, food storage, and distribution with consistency. Also referred to as a Provider. 

Hunger Relief Organization: An eligible entity that provides low-income clients with any kind of emergency food including prepared meals.

Income Eligibility: The client who falls within the Federal Poverty Income Guidelines set forth by the government. For CSFP this is 150% of the Federal Poverty Income Guidelines.

Indirect Expenses: The general overhead expenses of an organization that cannot be readily identified with a particular program.

Interested Party: Any eligible organization wishing to be considered for Lead Agency. Also referred to as a prospective Lead Agency.

Lead Agency: The entity that holds a written Agreement with Washington State Department of Agriculture (WSDA) to implement the program at the local level and/or through its Sub Agencies. The term Grantee is used for state pass-through funded grants. The term Subrecipient is used for federal pass-through funded subawards. Also referred to as a Provider.

Mobile Food Pantry: An eligible hunger relief organization that distributes unprepared food without charge to its clients and is selected to participate in CSFP. The organization must provide direct client services, food storage, and distribution with consistency. A food distributor that travels to communities, oftentimes with a regular or semi-regular distribution schedule.

Modified Total Direct Cost (MTDC): All direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $50,000 of each subaward (regardless of the period of performance of the subawards under the award). MTDC excludes equipment, capital expenditures, rental costs, and the portion of each subaward in excess of $50,000.

Nonprofit: A private agency or organization with 501(c)(3) tax-exempt status under the Internal Revenue Code, or that has applied for 501(c)(3) tax-exempt status with the Internal Revenue Service.

Operational Expenses: Those costs that are clearly identifiable with providing direct services to CSFP clients.

Participant: Senior adult, 60 years of age or older, authorized by a local agency to receive a CSFP package in a given month. Also called a CSFP client.

Participating Agency: A Lead or Sub Agency operating CSFP.

Period of Performance: The timeframe when an eligible program expense may be incurred and includes additional time for fiscal close out of each fiscal year as defined in the written Agreement. It may include one or more budget periods.

Period of Use: The additional length of time beyond the period of performance for which equipment and capital improvements must be in use, per program requirements and procurement guidelines.

Program Review: Any planned, ongoing, or periodic activity that measures and ensures Lead Agency and Sub Agency compliance with the terms, conditions, and requirements of an Agreement. Monitoring for program reviews will be based on a risk assessment of the ability to deliver services and its performance in delivering those services under the terms of the Agreement. It could be on-site, virtual, or a desk review.

Proxy: Any person designated by a CSFP client or by a participant’s caretaker to obtain CSFP USDA Foods on behalf of the participant.

RCW: Revised Code of Washington.

Risk Assessment: The process of evaluating exposure to harm or loss that could arise from an activity associated with the Agreement. It consists of identifying and classifying risks based on certain characteristics and measuring and evaluating the consequences of those risks.

Sealed Bid: Bid that is publicly solicited, a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for the bids, is the lowest in price.

Single Audit: An organization-wide audit of an entity that expends $1,000,000 (for fiscal years beginning October 1, 2024 or later) or more of federal assistance (funds, grants, awards) as required by federal 2 CFR Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards.

Sponsored Site: Any site or program used for distribution of food that the participating agency doesn't directly operate, manage, or maintain; including any on-site food pantry, any off-site temporary distribution location, mobile food pantry, homebound delivery program, or meal program. 

State: The state of Washington.

State Distributing Agency (SDA): The state-level agency that administers CSFP for the State is WSDA.

State Prevailing Wage: State law requiring the payment of prevailing wage in certain contracts for the construction, alteration, or repair (including painting and decorating) of public buildings or public works.

Sub Agency: The entity that holds a written Agreement with a Lead Agency to implement the program at the local level. The term Subgrantee is used for state pass-through funded grants. The term Subawardee is used for federal pass-through funded subawards. The Agreement between the Lead Agency and Sub Agency for state pass-through is also referred to as a subgrant and the federal pass-through is also referred to as a sub-subaward.

USDA: United States Department of Agriculture.

USDA Foods: The nutritious foods purchased by USDA to supplement the diets of CSFP participants. Also may be referred to as CSFP USDA Foods.

WAC: Washington Administrative Code.

Washington Food Coalition (WFC): A nonprofit organization that advocates for the emergency food system and provides education and training to a statewide membership of food banks, food pantries, meal programs, state agencies and other partners. WFC also houses the FA Advisory Committee which acts as an advisory body to FA.

WSDA: Washington State Department of Agriculture.

2.2 Program History

Commodity Supplemental Food Program (CSFP)

The Commodity Supplemental Food Program (CSFP) began in 1969 and originally aimed at providing foods to pregnant or postpartum women, infants, and children up to the age of six. As every Farm Bill passed, the program evolved. In 1973, the program was officially authorized and funded with the Agriculture and Consumer Protection Act, and with the 1977 Farm Bill, its current name was set.

Eight years later, with the Food Security Act of 1985, the program expanded to include the participation of senior adults 60 years of age or older, albeit at a lower priority than the original participants. However, in the Food, Conservation, and Energy Act of 2008, the priority status given to women, infants, and children before the senior adults in program participation was removed and food packages are distributed equally.

With the Agricultural Act of 2014, the Commodity Supplemental Food Program stopped serving women and receiving new eligible children, focusing only on serving seniors. And as of February 2016, the remaining women and children have been completely phased out of the program.

CSFP began in the state of Washington in 2001 and has continued to grow since that time. In the state of Washington CSFP is not available in all counties. The population served by CSFP is low-income senior adults at least 60 years of age. CSFP participants must reside in one of the states or on one of the Indian reservations that participate in CSFP. States establish income limits for eligible seniors that are at or below 150 percent (updated from 130 percent in 2025) of the Federal Poverty Income Guidelines. States may establish local residency requirements based on designated service areas (but may not require a minimum period of residency).

CSFP food packages do not provide a complete diet but rather are good sources of the nutrients typically lacking in the diets of the beneficiary population. CSFP food packages include a nutritious variety of foods such as canned fruits and vegetables, canned meat, poultry and other protein items, and grain products.

Currently, CSFP provides approximately 27 pounds of nutritious foods each month to over 5,372 seniors in 29 of our 39 counties. We work with 13 Lead Agencies throughout the state to operate the program at the local level through over 139 food pantries and other outlets. This program has been extremely effective for helping to meet the needs of lower-income seniors in rural areas, including providing nutrition education and outreach materials. Given the scope of CSFP, and its limited operational funding, FA typically only utilize a multi-shipment system (USDA direct ships food to Lead Agencies) and provide additional state funds (if available) to augment CSFP programming in the state of Washington.

CSFP Flowchart

2.3 CSFP Process and Allocations

  1. Availability of Funds and Allocations.
    1. The amounts of each agreement are based on the overall availability of funds and the following allocation formula:
      1. Initial Allocation: The initial allocation is comprised of a base amount per Lead Agency and a per caseload dollar amount. The current base is $4,000 per Lead Agency. The remaining pass-through funding is then calculated based on each Lead Agency’s assigned caseload.
      2. Allocation Adjustment: If there is a reduction or increase in the amount of program funds available, Food Assistance (FA) may reduce or increase the amount of a Lead Agency’s original award. However, there may be other causes prompting a change in funding.
        1. With any increase or reduction in funding, FA sends the Lead Agency an Amendment specifying the amount of the reduction or increase.
        2. The Lead Agency must also amend the Agreements of all affected Sub Agencies indicating their budget changes, where applicable.
      3. Remaining Funds: Any remaining funds at year-end will be issued to Lead Agencies submitting documented claims in excess of their original allocations. These funds are allocated based on the fair share percentage of assigned caseload.
  2. Food Allocation.
    1. USDA Foods are allocated to Lead Agencies based on their caseload amounts in accordance with the approved food package guide rate. USDA Foods are ordered only in amounts that can be expeditiously distributed without waste, with a maximum of a three-month inventory. FA works with each Lead Agency to determine their monthly order. FA is responsible for placing the order on behalf of the Lead Agency.
  3. Caseload Monitoring and Adjustments.
    1. FA will monitor each Lead Agency’s ability to meet its assigned caseload level. In addition, FA will monitor and adjust Lead Agencies’ caseload levels to ensure that the State is eligible to request caseload expansion for the following year.
    2. FA may only request an expansion of caseload (more caseload) if the statewide combined caseload level is 95 percent or greater. FA may periodically adjust a Lead Agency’s caseload during the current year if the Lead Agency is serving more or less than its assigned caseload. If adjustments are made to the caseload during the year, FA may make proportionate adjustments to a Lead Agency’s funding level depending on the circumstances.
    3. In the case of a Lead Agency serving under or over the allocated caseload for a sustained period, the following steps may take place to ensure that maximum statewide caseload is achieved:
      1. FA will counsel the Lead Agency on steps to achieve maximum caseload.
      2. FA will identify Lead Agencies with waiting lists and temporarily transfer the unused caseload from other Lead Agencies.
      3. A Lead Agency may also request to serve above their assigned caseload.
    4. At the end of the Federal Fiscal Year (FFY), FA will evaluate and make final caseload assignments, which may include making any temporary caseload adjustments permanent.
    5. Annually, FA will adjust, as applicable, Lead Agency caseload levels based on past performance with a particular focus on the final quarter of the FFY and projected caseload needs. The Lead Agency’s annual projected budget will be adjusted accordingly.

2.4 Interested Parties

  1. Food Assistance (FA) is responsible for the selection of Lead Agencies. Existing CSFP Lead Agencies are considered ongoing (permanent). If FA terminates a Lead Agency due to performance issues or a Lead Agency notifies FA that it no longer wishes to be the Lead Agency, then a new Lead Agency must be selected. Selection criteria and considerations include, but are not limited to, the following:
    1. Being able to meet Section 4.1, Eligibility Criteria for Lead Agencies and Section 4.2, Lead Agency Program Responsibilities and all requirements of the Lead Agency Agreement.
    2. Preference for a new Lead Agency may be given to existing FA Lead Agencies in close proximity to the county with the capacity to expand their service area(s).
    3. FA reserves the right to select Lead Agencies based on their performance as an existing Lead Agency or Sub Agency and/or their ability to improve the effectiveness and efficiency of CSFP services.
    4. FA may prioritize service areas that are currently not being served by an existing CSFP Lead Agency.
    5. FA defines priority targets for rural areas.
    6. USDA and FA determine availability of caseload.
    7. FA assesses the impact on other Lead Agencies implementing other FA programs.
    8. Prospective Lead Agencies are subject to an FA conducted site visit (in-person or virtual) to assess the eligibility of the organization.
  2. Note: If an existing Lead Agency is determined by FA to not be the most effective option then FA will make every effort to work with the impacted Sub Agencies to seek input on determining the most effective alternatives for filling the Lead Agency. However, FA reserves the right to select a new Lead Agency immediately to prevent any gap in service. 
  3. Organizations Interested in Becoming a CSFP Lead Agency.
    1. Any organization interested in becoming a CSFP Lead Agency may submit a letter of interest to FA. The letter of interest must address the specific requirements of this section. FA will evaluate the letter of interest based on the criteria listed in the FA Interested Party Lead Agency Eligibility Verification Checklist (AGR-8007).
    2. FA will respond to the letter of interest within 60 days of receipt. The response will be to inform the requesting agency of their eligibility status only and is not a guarantee of participation in the program as a Lead Agency. FA will maintain a list of interested parties who submitted a letter of interest for future consideration.
    3. Prospective organizations and existing Lead Agencies interested in operating CSFP must send a letter of interest to FA (foodassistance@agr.wa.gov) that addresses the criteria listed in the FA Interested Party Lead Agency Eligibility Verification Checklist (AGR-8007).
    4. The prospective Lead Agency must make apparent on the checklist that it:
      1. Meets minimum requirements.
      2. Has appropriate certification.
      3. Has management capabilities.
      4. Has contracting abilities.
    5. The prospective Lead Agency indicates their interest in being considered for any future Lead Agency vacancies or service area expansion.
    6. The letter of interest must include:
      1. Interested Party Contact information:
        1. Agency information:
          1. Agency Name.
          2. Business address.
          3. Primary operating county.
        2. Contact information:
          1. Name.
          2. Title.
          3. Phone number.
          4. Email address.
        3. County(ies) in which your organization seeks to provide CSFP Lead Agency services.
        4. Business Information:
          1. Description.
          2. Qualifications.
          3. Experience managing agreements.
          4. The organization’s specific work related to hunger-relief:
            1. A description of how the interested organization would:
              1. Deliver CSFP services.
              2. Operate the program in accordance with state and federal regulations.
              3. Meet nutrition education requirements.
            2. Identify any challenges or benefits this might have on the county’s current emergency food assistance system.
      2. Assurance that the interested party meets the eligibility criteria:
        1. IRS 501(c)(3), public agency, or federally recognized tribe.
        2. Active WA SOS Corporation registration.
        3. Active SAM.GOV registration.
        4. Board (or equivalent) support for this new role. This may be a vote to support the action, a letter of support, etc.
        5. Adequate facilities:
          1. Sufficient dry, cold, and frozen storage.
          2. Transportation capacity for USDA Foods.
  4. Selecting A New Sub Agency.
    1. Lead Agencies are responsible for the selection of their Sub Agencies. Sub Agencies must meet the requirements of Section 4.3, Eligibility Criteria for Sub Agencies and Section 4.4, Sub Agency Responsibilities. The selection criteria may include, but are not limited to, the following:
      1. Lead Agencies may place limits on accepting any new Sub Agencies if service areas are already being served by other Sub Agencies.
      2. Lead Agencies may choose to have multiple Sub Agencies provide service to the same area, serving the needs of specific populations within the service area.