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EFAP-T Section 5

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EFAP-Tribal Procedures Manual Section 5: Client Management and Support

5.1 Qualifying Eligible Clients

  1. Food Assistance (FA) defines eligible clients.
    1. Eligible clients are people who are in need of food and reside in the State of Washington.
      1. Employees and volunteers meeting the same client eligibility requirements for services must be given the same opportunity to receive services and must be treated the same as other clients.
      2. Tribes or tribal Organizations participating in the EFAP-Tribal Food Pantry Program and/or Voucher Program may further define eligible clients to include only tribal members and/or any client living in the tribal service area. Tribes may also prioritize target clientele.
    2. There are no documentation requirements for clients participating in EFAP.
    3. This is the eligibility standard required by the State.
  2. Client notification.
    1. Client eligibility standards, policies, and intake practices must be posted for a client to view prior to receiving services, including online applications.
      1. These standards, policies, and intake practices are subject to review and approval by the Tribal Lead Agency or Food Assistance, as applicable.
      2. If changes are made the Food Pantry must ensure that these are also updated on the Food Pantry’s website.
    2. The client must be informed that:
      1. The client will not be denied food if they refuse to disclose any information.
      2. If the client is participating in the Voucher Program, they must be informed of the following:
        1. Clients are to use vouchers as required by the EFAP-Tribal Voucher Program Lead Agency.
        2. Clients may only purchase essential food and/or essential nonfood items, only as indicated on the voucher, store agreement, or other applicable policies. Unallowable purchases include the following:
          1. Any kind of carbonated beverage or flavored sugared drinks such as soda, drinks in pouches, pre-made sweetened beverage or powdered drink mix to make, all flavored water, Gatorade, pre-made teas, any energy drinks, on-the-go drink packets, all sports drinks. (Note: Bottled water is allowed)
          2. Any kind of “snack” foods such as candy, gum, cookies, crackers, granola, protein or energy bars, gummy type fruit snacks, popcorn, potato/corn/veggie chips, and beef jerky.
          3. Any kind of alcoholic beverages.
          4. Any kind of tobacco products.
          5. Any kind of dessert, such as ice cream, pies, and cakes.
          6. Any kind of donuts, breakfast pastries and muffins.
          7. Pet food and pet supplies.
        3. Essential food purchases must come from the following main food groups as identified by USDA:
          1. Meats – Such as turkey, chicken, fish, pork, and beef. Other foods in this group include beans, nuts, and seeds.
          2. Dairy – Such as milk, yogurt, cheese, or non-dairy products like soy milk.
          3. Vegetables – Such as fresh, frozen, and canned. Beans also fall into this group, such as pinto, kidney, and black beans.
          4. Fruits – Such as fresh, frozen, dried, canned, berries, and 100% fruit juice.
          5. Grains – Such as whole grain cereals, breads, rice, and pasta.
          6. Water
        4. Tribes decide whether or not they will allow purchases of essential nonfood items. However, essential nonfood items may not exceed twenty-five percent (25%) of the total Agreement amount and are restricted to the following:
          1. Essential nonfood items include: Cleaning supplies, dental adhesive, deodorant, detergent, diapers, dish soap, facial tissue, feminine products, hand soap, paper towels, napkins, shampoo, shaving products, teeth/denture cleaner products, toilet paper, and toothbrushes.
        5. Tribes may choose to set more strict policies on what essential foods and nonfood items can and cannot be purchased than the state dictates. Limitations on purchases must be identified in the tribe’s Voucher Program policies.
  3. Service areas.
    1. All clients are to be treated with dignity and respect.
  4. Food Pantry and Voucher Program Client data. 
    1. The Tribal Lead Agency is responsible for rolling up the client data that each Sub Agency reports. The Sub Agency is responsible for reporting their specific client data. Required data collected for EFAP includes:
      1. The number of full-service clients (total number of people living in a household) and households (total number of households, not the total number of people living in a household).
        1. A household’s status (new or returning)
        2. Number of clients living at that household, self-declared by the client.
        3. More than one household may reside at a residence or home and would be counted as separate households for the purposes of EFAP.
      2. The number of full-service clients by age group
        1. Age groups: 0-2 years old; 3-18 years old; 19-54 years old; 55+ years old.
      3. Client and household new or returning status
        1. To improve data quality, Food Assistance has established a statewide requirement that all participating agencies collect required data based on the calendar year (January 1- December 31).
          1. New client and household are defined as the first time a client visits ANY Food Pantry in the State of Washington or receives a voucher in a calendar year (starting January 1 of each year).
          2. Returning client and household are defined as any subsequent visit a client makes to ANY Food Pantry in the State of Washington or receives a voucher in a calendar year (starting January 1 of each year).
    2. Other required Food Pantry report data:
      1. EFAP-Tribal Food Pantry Food Purchases per Month
      2. Food Pantry Pounds of Food Distributed (all sources) per month.
      3. Food Pantry Full Service
      4. Supplemental
      5. Food Bank Distribution Center, if applicable
      6. Kids Weekend Bags, if applicable
    3. Optional data collected for EFAP-Tribal Food Pantries includes:
      1. The number of Special Dietary Needs (SDN) Clients served (new and returning). These clients are also reported in “full-service” client counts.
      2. The number of Supplemental Clients served (new and returning). These clients are in addition to “full-service clients” and are served less than 3 of any of the 5 main food groups.
      3. The number of Kids Weekend Bags Clients (new and returning) and the total number of Kids Weekend Bags distributed (new and returning). Include only full-service kids weekend bags that contain a minimum of 2 days/4 meals/3 or more food groups.
      4. Total Kids Weekend Bags. Include only the total number of kids weekend bags that contain a minimum of 2 days/4 meals/3 or more food groups.
    4. Documentation must not be required to verify eligibility or assist in your data collection practices for EFAP. This includes pieces of mail, school records, birth certificates, driver’s license, or medical records. Under no circumstances should a Sub Agency require a client to provide a social security number, proof of citizenship, proof of income, proof of address, or proof of household size.
      1. Requiring documentation from clients is considered a barrier to service.
      2. If other funders require additional data collection outside of EFAP, which encourage or require verifying client information through documentation, then please work with those organizations to clarify the data they need and understand why this is required, with the goal of shifting policy toward acceptance of self-declaration of information.

5.2 Written Client Confidentiality Policies

  1. Must have written client confidentiality policies.
    1. All providers must respect the privacy of clients. Personally Identifiable Information (PII) collected, used, or acquired in connection with providing Food Pantry or Voucher Program services must be used only for the purpose of those programs.
    2. PII includes any information that directly identifies an individual (e.g., name, address, social security number or other identifying number or code, telephone number, email address, etc.) or by which an agency intends to identify specific individuals in conjunction with other data elements, i.e., indirect identification. (These data elements may include a combination of gender, race, birth date, geographic indicator, and other descriptors). Additionally, information permitting the physical or online contacting of a specific individual is the same as personally identifiable information. This information can be maintained in either paper, electronic or other media.
    3. Providers with direct client contact must have written client confidentiality policies on file.
    4. A provider cannot release, make referrals, divulge, publish, transfer, sell, or otherwise make known to unauthorized persons or other organizations, client PII without a signed client release of information form.
      1. A signed client release of information form shall include what client information can be shared and to whom or which agencies it will be shared.
      2. If the provider shares PII with other organizations, the Tribal Lead Agency must have a copy of the client release of information template on file.
    5. Providers agree to implement physical, electronic, and managerial safeguards to prevent unauthorized access to PII.
  2. Monitoring by Food Assistance of personal information collected.
    1. Food Assistance reserves the right to monitor, audit, or investigate the use of PII collected, used, or acquired by Tribal Lead Agencies. Not properly maintaining client PII could result in termination of the Agreement.
      1. Tribal Lead Agencies must monitor the use of PII collected by Sub Agencies for compliance.

5.3 Informational Resources for Clients

  1. All Tribal Lead Agencies and Sub Agencies providing direct services must provide information about wrap-around services.
    1. A Food Pantry must prominently display the 211 number and outreach materials for the benefit of its customers. See wa211.org for more details.
    2. Make available information regarding additional information that may be helpful to clients. This can include links to websites, handouts, pamphlets, or a list of services clients can take home with them about programs.
      1. Tribal Lead Agencies are responsible for ensuring Sub Agencies have referral information. Here are some examples:
        1. Supplemental Nutrition Assistance Programs (SNAP).
        2. School breakfast, lunch, and summer feeding programs.
        3. Rental Assistance programs.
        4. Senior centers.
        5. Organizations and associations for people with disabilities.
        6. Emergency shelters.
        7. Multi-cultural organizations.
        8. Local job training programs and local employment security offices.
        9. Public transportation facilities.
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EFAP-Tribal Procedures Manual Table of Contents
Section 4 Section 6
Revision History
Section 5 Revision 2024-07-01