TEFAP State Plan

WSDA FA Conducts Risk Assessments of Lead Agencies:

WSDA FA conducts an initial Risk Assessment prior to executing Agreements. Lead Agencies must have completed the FA Accounting System and Financial Capability Questionnaire (AGR-2383).

• The questionnaire must be submitted to Food Assistance and used to initially assess risk based upon responses provided.
  • The Lead Agency must have submitted at least one Financial Capability Questionnaire within the last 12 months. One completed Questionnaire per year, regardless of the various types of funding an entity receives.
• Responses will be scored according to Questionnaire’s scoring rubric and total score will be rated as low, medium, or high-risk.
  • Lead Agencies with a High-Risk rating will require additional program reviews and more in-depth monitoring.

 

WSDA FA Staff Shall Monitor Fiscal Reports on a Monthly Basis:

WSDA FA staff conducts monitoring of Lead Agencies by evaluating monthly submitted expenditure reports and responses. At any time, WSDA FA may request a Lead Agency to send in all supporting documentation for expenditures. 

• If a Lead Agency violates any conditions set forth in the Agreement, WSDA FA staff will investigate the violation.

 

WSDA FA Compliance Reviews of Lead Agencies and Sub Agencies:

WSDA FA is responsible for monitoring the operation of the program to ensure that it is being administered in accordance with federal and state requirements and promotes program integrity. 

The WSDA FA monitoring system includes:

• An annual review of at least 25 percent of all Lead Agencies provided that each such agency must be reviewed no less frequently than once every four years.
• An annual review of 20 TEFAP Sub Agencies which receive TEFAP foods and/or administrative funds pursuant to an Agreement with a Lead Agency. Sub Agencies are chosen for a review based on the TEFAP Annual Risk Assessment and includes 1) 50% selected based on high-risk scores and 2) 50% based on other factors as determined by WSDA FA. In addition, Sub Agencies may be chosen for review based on performance concerns.
• Lead Agencies that have serious performance issues will have a program review more often if warranted.
• If a Lead Agency or Sub Agency violates any of the more critical conditions set forth in the Agreement, WSDA FA staff may conduct a site visit to investigate the violation.
• Reviews should be conducted, to the maximum extent feasible, simultaneously with actual distribution of USDA Foods and/or meal service and eligibility determinations, if applicable.  However, due to the lessons learned during the pandemic we have modified our reviews to include a combination of on-site, virtual and desk reviews.
• Lead Agencies are also required to conduct compliance reviews of at least 10% of their Sub Agencies on an annual basis. 
• When FNS concurs, reviews of Lead Agencies or Sub Agencies which have been conducted by USDA Food and Nutrition Services (FNS) Regional Office personnel may be incorporated into the minimum coverage required.
• At a minimum, each review must encompass, as applicable, eligibility determinations, distribution rate formula, storage and warehousing practices, fiscal and inventory control, reporting and record keeping requirements, and compliance with civil rights policies and training. WSDA FA compliance review forms for Lead Agencies and Sub Agencies are updated on an annual basis and available on the TEFAP Forms webpage.

Federal Civil Rights Training

WSDA FA, its Lead Agencies, and Sub Agencies, comply with the civil rights instructions, procedures and regulations. Pursuant to FNS Policy Memo FD-113, Lead Agencies are responsible for providing their frontline and non-frontline staff and volunteers with training on civil rights. Lead Agencies also ensure their Sub Agencies’ frontline and non-frontline staff and volunteers receive the same training. WSDA FA provides civil rights training instructions and training checklists on its website for Lead Agencies and Sub Agencies to use as a minimum standard for annual civil rights training. Our compliance reviews also incorporate questions regarding civil rights training.

All WSDA FA staff civil rights training occurs annually in October. This training includes not only civil rights but also training regarding accessing interpreter services through the state system.  
 

Federal Civil Rights Complaint Process

Lead Agencies and their Sub Agencies must accept and process all federal civil rights complaints received by a participant regardless of whether the complaints are written, verbal, or anonymous.  Civil rights complaints may be submitted on behalf of a participant or the participant may address complaints directly to the United States Department of Agriculture (USDA) using the USDA Program Discrimination Complaint Form (AD-3027). 

If a Lead Agency submits a civil rights complaint on behalf of a participant, then WSDA FA must be notified within 5 calendar days of receiving a complaint.  If available, the completed USDA Program Discrimination Complaint Form (AD-3027) is also sent to WSDA FA.

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.  WSDA FA will maintain a record of and track all federal civil rights complaints including complaint status (pending, follow-up, completed, or referred to FNS).
 

Written Notice of Beneficiary Protections

WSDA FA complies with the “Partnerships with Faith‐Based and Neighborhood Organizations Final
Rule” (89 FR 15671 and 7 CFR Part 16) by ensuring that Lead Agencies and their Sub Agencies give written notice to all beneficiaries and prospective beneficiaries of certain protections in a manner and form prescribed by USDA Memo FD-155. WSDA FA received USDA approval to modify the language and create a “universal” poster/handout for local agencies to use for TEFAP, CSFP, and LFPA. Lead Agencies and Sub Agencies are required to display and/or distribute the Written Notice of Beneficiary/Client Rights (AGR PUB 609-10017) to clients before enrolling in the program or receiving services.

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TEFAP State Plan Table of Contents
Section 4	Section 6
Revision 2024-12