- A. Purpose and Terminology
- B. Policies and Procedures
- C. Program Deliverables and Outcomes
- D. Contracts and Amendment Procedures
- E. Program Budget
- F. Food Distribution Services
- G. Allowable/Unallowable Costs
- H. Program Monitoring
A. Purpose and Terminology
The Emergency Food Program (EFP), federally funded by the U.S. Department of Agriculture (USDA), is a program that provides supplemental, emergency food assistance at no cost to eligible Illinois residents. USDA food commodities, in conjunction with privately donated and purchased food, are distributed by contracted Foodbanks to participating food pantries, soup kitchens and homeless shelters serving every county in Illinois. The purpose of the program is to prevent hunger and help provide food security for low-income households and individuals. The program provides USDA food commodities and administrative funds for costs associated with storage, handling and food distribution. Both USDA food commodities and administrative funds are distributed formulaically to each contracted Foodbank based upon 60% of the people in poverty and 40% of the unemployed people in its geographic service area relative to those figures for the entire State of Illinois. The Foodbanks, in turn, employ a service/needs-based formula to distribute the USDA food commodities to its partnering pantries, shelters and soup kitchens, based upon service data provided by those entities. Any Illinois resident, who self-attests that they are at or below 185% of the Federal Poverty Guideline (income guidelines are provided annually), is eligible for the Emergency Food Program. The following terminology is used in the EFP Program:
Distribution Site - Location where the eligible recipient agency actually distributes commodities to needy persons for household consumption or serves prepared meals to needy persons. May be a pantry, soup kitchen or homeless shelter.
EFP - Emergency Food Program - State-level abbreviation for the Federal program name TEFAP (The Emergency Food Assistance Program).
Foodbank - A not for profit public or charitable institution or organization that maintains an established operation involving the provision of food or edible commodities, or the products of food or edible commodities, to food pantries, soup kitchens, homeless shelters, or other food or feeding centers that, as an integral part of their normal activities, provide meals or food to feed needy persons on a regular basis.
FNS - Food and Nutrition Service - Division of USDA responsible for the nationwide administration of numerous federal nutrition programs, including the Emergency Food Assistance Program.
Food Pantry - A public or private non-profit organization that distributes food to eligible families or individuals, including food from sources other than USDA.
Fiscal Year - A twelve-month period used for accounting and reporting purposes.
FFY - The Federal Fiscal Year (FFY), from October 1 to September 30.
SFY - The State Fiscal Year (SFY), from July 1 to June 30.
Homeless Shelter - A facility that provides temporary residence and at least one meal a day to homeless people for a period not to exceed 24 months.
Household - A group of related or non-related individuals living as one economic unit who buy and cook food together. It also means a single individual living alone.
Non-Discrimination - A Federally-mandated policy which prohibits discrimination at all levels of food distribution on the basis of race, color, national origin, sex, age, or disability.
Soup Kitchen - A public or charitable organization that maintains an established feeding operation to provide food to needy homeless persons on a regular basis, without charge.
USDA - United States Department of Agriculture - Cabinet level agency responsible for federal aspects of the Emergency Food Assistance Program as well as all other federal agriculture and nutrition programs.
WBSCM - Web Based Supply Chain Management - New to EFP in Calendar Year 2011, this is a USDA web-based commodity ordering and tracking system intended to replace the Processed Commodity Inventory Management System (PCIMS) and satellite systems including USDA's Electronic Commodity Ordering System (ECOS).
B. Policies and Procedures
- Funding: All funds awarded to a provider must be obligated by the end of the agreement period and expended by the end of the lapse period.
- 501(c)(3): If the provider is not a governmental entity, the provider must be a federally tax exempt, non-profit agency legally authorized to operate in the State of Illinois with a Not-for-Profit Corporation Charter from the Illinois Secretary of State and verification from the Internal Revenue Service of exemption from federal income tax liability under the applicable Section 501(c)(3) or 501(c)(4) of the Internal Revenue Code. Each provider must submit documentation of not-for-profit status and their 501(c)(3) status. Each provider must certify that it complies with all provisions of the Federal Internal Revenue Code, the Illinois Revenue Act, and all rules promulgated thereunder, including withholding provisions and timely deposits of employee taxes and unemployment insurance taxes. Also, an annual report must be on file with the Secretary of State that the provider is a not-for-profit provider. This report will be sent, by the Secretary of State, to each provider's registered agent 45 to 60 days in advance of the date of the provider's incorporation. A provider can contact the Secretary of State, Office/Annual Report Section at (217) 782-6961 with any questions or conflict resolutions.
- Records: The provider must maintain written policies and procedures regarding its fiscal activities, including but not limited to, payroll, purchasing, cash management, relevant fee schedules, contracts and risk management. The provider must submit and have on file a copy of their Annual Report to the Internal Revenue Service Form 990 and an Annual Report to the Attorney General Form AG 990. The provider must show proof that its governing body has approved a budget at least annually. All fiscal records are to be maintained for at least five years after the end of the fiscal year to which they relate. Failure to maintain adequate records to document the expenditure of IDHS funds creates a presumption in favor of the Department for recovery of the funds. The provider must have on file the by-laws, policies and procedures and a current organization chart. The provider must maintain policies concerning the hiring, termination, evaluation and discipline of staff. Also, the provider must have policies on non-discrimination in hiring, employment, sexual harassment as well as written job descriptions of employee's duties and responsibilities.
- Fiscal Information and Data: Each EFP provider is required to submit monthly financial reports detailing allowable expenditures for the stated month based on the provider's annual, approved budget or through approval of an amendment to the approved budget. DHS provides a web-based EFP reporting system for use by each contracted provider that records, tracks and reconciles pre-approved budget line-items.
- Inventory Information and Data: Each EFP provider is required to submit monthly inventory reports detailing receipts and distributions of all USDA commodities for the stated month. DHS provides a web-based EFP reporting system for use by each contracted provider that records, tracks and reconciles EFP inventory.
- Participant Information and Data: Each EFP provider is required to submit monthly participant outcome data, compiled from participant Signature Sheets for food pantries and meal-service reports for soup kitchens and homeless shelters, regarding the number of individuals and households served, the number of meals served, as well as those that receive and/or do not receive SNAP benefits based on household self-declaration. DHS provides the participant Signature Sheet and a web-based EFP reporting system for use by each contracted provider.
- Participant Intake and Assessment Forms: The Department provides a form to document EFP food distribution to eligible participants at food pantries, the DHS Signature Sheet. The DHS Signature Sheet must be the only intake form used to document eligibility for EFP at a food pantry. Participants at soup kitchens and homeless shelters are presumed eligible. While verification of identity and residency is not required, pantries may ask for proof of identity and residency, limited to one of the following types of documentation: driver's license, state identification card, piece of mail or utility bill showing the recipient name and address, or a letter from a landlord verifying identity and residency. Every participant being served at a food pantry must sign the DHS Signature Sheet. The signatory for the household receiving EFP commodities self-attests that the monthly income of the household is equal to or less than the approved EFP income ceiling of 185% of the federal poverty level for the household. Every DHS Signature Sheet shows a table with income ceilings for various household sizes. The DHS Signature Sheet must also record the participant's full address and number of persons in the household. Homeless participants may use the address of the nearest DHS office or 'NONE' in the address section of the DHS Signature Sheet. Additionally, the DHS Signature Sheet records whether or not each participating household receives SNAP benefits as well as the number of children in the household who are 18 years of age or younger, which requires completion when TANF food is available and a TANF-eligible household receives additional TANF food (see the TANF Food Purchase Program section of the Program Manual for details). The DHS Signature Sheet includes a warning that misuse of EFP foods subjects the participant to federal and state prosecution. When a participant signs the DHS Signature Sheet, they are certifying that their information entered on the Signature Sheet is accurate and in compliance with EFP regulations and that they agree to follow EFP regulations. USDA and the State of Illinois hold the participant responsible for the accuracy of DHS Signature Sheet entries. Providers are not responsible or liable for accuracy of participant entries.
- Participant, Fiscal and Inventory Files: Each EFP provider is required at a minimum to keep all participant, fiscal and inventory files for a five year period.
C. Program Deliverables and Outcomes
All providers are required to meet all standard terms, conditions, deliverables and certifications as delineated in the Department's Emergency Food Program Request for Proposals (RFP) published in February, 2012 and authorized from July 1, 2012 through June 30, 2015, with the option to renew for two additional one-year periods.
All deliverables will be verified by on-site monitoring, and/or through review of data in the required web-based reporting system or by other means as the Department deems necessary.
- Distribute donated food to pantries, soup kitchens and homeless shelters at least once a month through pickup and delivery services in accordance with the USDA policy of non-discrimination. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Distribute food to counties and distribution sites in the assigned service area in accordance with fair-share allocation percentages (county fair-share percentages provided annually by the Department). The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Assure that each participating distribution site has a contract to distribute USDA commodities which must include a policy of non-discrimination and an assurance that donated food is made available to all eligible households without regard to race, color, national origin, sex, age, or disability, to the extent that such food is available. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Assure that food commodities are distributed to eligible participants according to established program guidelines and that eligibility for receipt of USDA food commodities is based on self-declaration via certification on the Department's Signature Sheet or Proxy Form; receive, track and verify the accuracy of completed Signature Sheets and Proxy Forms on a monthly basis. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Assure that pantries, soup kitchens and homeless shelters are open to the general public in their service area for at least 2 hours every week, unless there is a Department-approved Rural Exemption on file or a Foodbank-approved temporary closure due to holidays or extenuating circumstances. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Assure that each storage site used by Foodbanks and distribution sites is sufficient to accommodate projected amounts of refrigerated, frozen and dry products; and that all storage sites comply with proper warehousing procedures and storage requirements to prevent loss/damage of food commodities, including cleanliness, stock rotation, regulated temperature, inventory accountability, security and pest control. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Maintain accurate receipt, distribution, inventory and fiscal records for regular EFP, the TANF Food Purchase Program, and the Hunger Relief Tax Check-Off Program. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Reconcile EFP grant funding received, deposited and expended on a monthly basis, document and isolate all EFP program expenditures in accounting records, maintain all expenditure documentation, and complete mandatory monthly on-line financial reporting, no later than 21 days after the end of each calendar month. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Track the number of USDA commodity cases received and distributed, as well as any USDA commodity damage or loss on a monthly basis; and complete mandatory monthly on-line commodity inventory reporting, no later than 21 days after the end of each calendar month. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Track on a monthly basis the number of meals served in soup kitchens and homeless shelters and the number of individuals and households served in food pantries as well as the number of households reporting receipt of SNAP; and complete mandatory monthly on-line service reporting, no later than 21 days after the end of each calendar month, to include data compiled from participant Signature Sheets and Proxy Forms. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Conduct formal EFP policy and procedure training to distribution site staff at least once each year (in accordance with the EFP policy manual provided annually by the Department) to assure adherence to program policies; and provide technical assistance to distribution sites and staff on an ongoing basis. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Conduct monitoring of all EFP distribution sites at least once every 2 years to ensure that all required EFP criteria are met as specified in the EFP Site Monitoring Instrument developed by the food banks and approved by the Department. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Track the pounds of privately donated/purchased (non-government) food distributed on an annual basis. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Verify receipt, location and condition of all equipment, funded wholly or in part with EFP Federal administrative funding, at least once every two years; and tag, track, comply with authorized disposal protocols, and complete/update Federally Funded Equipment Inventory Worksheets in accordance with both State and Federal regulations. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Conduct at least three types of structured outreach activities in the assigned service area on an ongoing basis to include a detailed description for notifying the community of the EFP Program, hours of operation and eligibility requirements. The Department provides printed materials and posters for distribution to participating food pantries, soup kitchens and homeless shelters. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Handle complaints of irregularities and provide reports to the Department. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Distribute SNAP applications to food pantries, soup kitchens and homeless shelters for distribution to potentially eligible participants; and distribute additional information to food pantries, soup kitchens and homeless shelters to provide program or other information to distribution site staff and/or persons accessing sites for food, including but not limited to the EFP Site Manual and brochures on various programs. The outcome will be verified through on-site field monitoring and/or monthly reporting.
D. Contracts and Amendment Procedures
- Contract Procedures and Approvals: Providers to be awarded funding will be notified, in writing, of annual contract award submittal dates and procedures for contracting. Awards for this federal grant are entirely based on the final, annual funding levels announced and made available by USDA. Funds are then awarded to providers in accordance with an approved federal formula based on the pro-rata share of each of the 102 Illinois counties as determined by 60% poverty population and 40% of the unemployed population relative to those figures for all counties in the State of Illinois. Those pro-rata percentages are then applied to total available funding to determine the funding amount for each county awarded to the provider. The Department may, however, set a maximum amount of funds awarded to any one provider.
- Amendments, Submittals and Approvals: Amendments for this federal grant typically correspond with funding level changes announced by USDA. The Department also reserves the right to impose contract amendments, within the confines of the federal grant, when it is in the best interest of the Department to do so. Providers will be notified, in writing, of any amendments and necessary amendment procedures. Any provider request to modify or amend its services plan - as delineated in the current, approved RFP - must be submitted by the provider, in writing, and is subject to approval by the Illinois Department of Human Services, Bureau of Basic Supports and/or USDA.
- Sub-Contracts and Pass-Through Funding: All sub-contracts or pass-through funding agreements must meet all terms and conditions of the IDHS Community Services Agreement and must be approved by IDHS prior to entering into any sub-contractual or pass-through funding arrangement.
- Contract Budget Line Item Transfers: Emergency Food Program providers are allowed to transfer funds among pre-approved budget line-items without prior approval from IDHS. The EFP web-based reporting system allows for, reconciles, and documents all transfers. Capital expenditure requests greater than $5,000.00 do require approval by the IDHS Bureau of Basic Supports.
E. Program Budget
- Annual Emergency Food Program Budget: The annual Emergency Food Program budget establishes how Federal/State administrative funding, formulaically awarded to providers for the storage, handling and distribution of both USDA commodities and other privately donated/purchased food, is utilized for program implementation during the fiscal year. Providers are required to track all IDHS funds by allowable cost categories (as defined in Section G below) and budget line items.
- Financial Management System: Providers must have an established financial management system which provides complete, separate, and accurate accountability of funds. The provider's accounting system must be well-maintained, up to date, and provide the following original documentation:
- Bank reconciliations;
- Trial balance;
- Separate identification of program expenses in a general ledger;
- Complete accountability of all obligations, payments, and reimbursements;
- Justification of allocations;
- Written administrative and accounting procedures;
- Segregation of duties for internal control; and
- Isolation of IDHS funds and tracking of IDHS expenditures.
- Budget Revisions - Amendment Process:
All budget revisions and amendments for the Emergency Food Program must be made within the parameters of and in accordance with the federal grant awarded by USDA. The budget revision/amendment process may include:
- Letters of increase or decrease; A letter is sent to the provider stating the intent to increase or decrease dollars to a contract. There is no need for the provider to sign and return this document.
- Formal amendments; An agreement executed by the provider and IDHS constitutes a formal amendment. The following is required for a formal amendment to be processed:
- Adding new program services: An amendment to add a new program service must contain a detailed summary of services to be provided under the amended contract and the method of payment.
- Extending the service date of the contract: An amendment to extend the service date of the contract must contain the following information: Agreement number as it appears on the original contract; provider name; clause stating the new term; signatures of the provider and the Secretary of the Illinois Department of Human Services.
- Extending the service dates of an existing program: An amendment to extend the dates of a specific program in the existing contract must contain the following information: Agreement number as it appears on the original contract; provider name; clause stating the new term of the agreement; signatures of the provider and the Secretary of the Illinois Department of Human Services.
- Changing the language within an existing program attachment only: An amendment to change the language of a specific program attachment of an existing contract must contain the following information: Agreement number as it appears on the original contract; provider name; clause(s) stating the new language of the agreement; signatures of the provider and the Secretary of the Illinois Department of Human Services.
- Fiscal Audits: If deemed necessary, a program and fiscal audit will be conducted by the IDHS Office of Contract Administration.
- Match Requirements: No provider match is required for the Emergency Food Program. In accordance with EFP Federal Regulations, the Department is required to provide a cash or in-kind match equal to the amount of EFP administrative funds retained by the Department for State-level costs.
- Recovery: The Office of Contract Administration (OCA) is responsible for financial reconciliation and financial recovery of unspent funds. As part of the funds recovery procedure, the Office of Contract Administration will send to each provider an "Informal Notice" letter containing the state fiscal year, the provider's name, and FEIN number and the amount of IDHS funds provided to each provider. The letter will also include a Grant Reconciliation Report to be completed by each provider. The provider will have fifteen days from the receipt of the informal notice to request, in writing, an informal hearing on lapsed funds or a plan of correction dealing with other violations. If the informal hearing does not result in a resolution of the lapsed funds, a "Formal Notice to Recover Lapsed Funds" letter will be sent by registered mail to the provider. The provider will then have thirty-five days to request, in writing, a Formal Hearing. At the end of thirty-five days, if no request has been received, the OCA may proceed to recover the amount of funds. If the provider does not have an upcoming fiscal year contract from which to deduct the lapsed funds owed, the Bureau of Collections will establish a collection amount in the name of the provider. The Bureau of Collections will generate an invoice and mail it to the provider for payment. The provider will then receive monthly billing statements. The debt may also be referred by the IDHS to the Attorney General's Office if the debt remains unpaid for one year.
- Program Payments: Payments for the Emergency Food Program will be made monthly or as prescribed by the IDHS, who reserves the right to advance additional funds to the agency beyond the prescribed method when it is in the best interest of the provider to do so.
- Provider Responsibilities: Participant service, fiscal and inventory report submittals. The provider must submit, on a timely basis, complete and accurate participant service, fiscal and inventory reports. Access to a computer and the Internet are required for electronic reporting to IDHS. Unless otherwise notified in writing by the IDHS, Emergency Food Program providers are required to submit monthly participant service, fiscal and inventory reports on the IDHS web-based EFP reporting system not later than 21 days after the end of each state fiscal month. The State of Illinois' fiscal year operates from July 1 to June 30 each year. Participant service reports provide details on the number of meals served in soup kitchens and homeless shelters and the number of individuals and households served in food pantries. Participant service reports also provide the number of households receiving/not receiving SNAP benefits based on household self-declaration. Fiscal reports provide detailed line item expenditures documented for each month. Inventory reports provide detailed monthly accounting of USDA food product receipts, distributions and available inventory. The IDHS will provide all providers with the web-based reporting system.
F. Food Distribution Services
Providers (i.e., contracted Foodbanks) will distribute EFP food commodities through food pantries, soup kitchens, and homeless shelters. Distribution sites must meet all the criteria in the following definitions:
- Food Pantry: A food pantry provides emergency and supplemental food to income eligible households on a periodic basis. Food pantries must have regular hours of at least two hours per week, have food available on a continuous basis, and have food available in addition to USDA commodities. Food pantries must allow participants to receive service at least once in a thirty day period and can not require participants to obtain written referrals from external agencies. Food pantries must obtain participant signatures attesting that the household meets IDHS income eligibility standards. Food pantries may request documentation to verify identity and residency.
- Soup Kitchens and Homeless Shelters: Soup kitchens and homeless shelters serve prepared, congregate meals to homeless, transient, or other needy people. All persons requesting meal service at a soup kitchen are presumed eligible for service. Soup kitchens and homeless shelters cannot charge for these meals and must have regular hours of at least two hours per week for meal service. Although homeless shelters serve only their own residents, soup kitchens must be open to the general, needy public. Meals must be served in a clean, secure environment.
All facilities utilized in the program must meet local health and safety code requirements.
The pantries, soup kitchens and homeless shelters must be federally tax-exempt, nonprofit private or governmental agencies legally authorized to operate in the State of Illinois. Private agencies must have a Not-for-Profit Corporation Charter from the Illinois Secretary of State or a current verification of exemption from Federal Income Tax Liability under Section 501(c)(3) or 501(c)(4) of the Internal Revenue Code unless an organization is exempt from filing under Internal Revenue Service regulations. The Foodbank must have a written contract with all pantries, soup kitchens and homeless shelters. All pantries, soup kitchens, and homeless shelters receiving USDA commodities are subject to IDHS approval.
Each provider is required to provide open access to the Emergency Food Program for everyone on a non-discriminatory basis; which includes - but is not limited to - race, color, national origin, sex, age, or disability.
G. Allowable/Unallowable Costs
All expenditures of EFP grant funds must meet federal cost standards as established by federal regulations and Office of Management and Budget (OMB) Circulars. OMB Circular A-87 provides cost principles for State and Local Governments.
Federal regulations for the EFP limit allowable expenditures to specific cost categories directly associated with the distribution, handling and storage of USDA food commodities and other privately donated/purchased food. In order to be allowable, expenditures must be reasonable and appropriate and must be reported at the price actually paid. Documentation must be maintained to substantiate all EFP expenditures. The following are allowable and unallowable costs under the Emergency Food Program:
- Accounting: The cost of establishing and maintaining accounting and other information systems required for the management of the program is allowable. Costs of an independent audit are allowable.
- Advertising: The cost of advertising for the purpose of public outreach of distribution site locations and schedules is allowable.
- Building and Facility Rentals/Leases: The cost of rental facilities for office space and/or food storage associated with donated food storage and distribution is allowable. The cost of rentals allocated to the donated food program must be pro rated in direct proportion to the space utilized. Facilities must meet criteria outlined in the contract. Rates may not exceed those for comparable facilities within the area.
- Compensation for Personnel Services: Salaries and fringe benefits for services of employees directly involved with the EFP is allowed to the extent compensation is reasonable and pro rated in direct proportion to the percentage of time engaged with the donated food program. Expenditures for personnel services must be supported by records of payment, in addition to time and attendance records for individual employees. In the event of a substantial increase in an organization's level of employee compensation, an examination will be made to determine the reasonableness of the increased compensation, particularly when the increased compensation level was concurrent to an increase in the ratio of funding for federal program activities to other activities of the organization. Compensation to members of the organization, trustees, directors, associates, officers, or immediate families will be reviewed to determine if compensation is reasonable for actual services rendered. When an organization is predominantly engaged in activities other than those that are federally funded, employee compensation will be considered reasonable to the extent that it is consistent with compensation for similar work in the organization's other activities. Records to support salaries paid by the EFP must be available for examination, including the number of employees, salary and amount of time each employee is engaged in these activities. Compensation to employees of an organization predominantly engaged in federally funded activities will be considered reasonable to the extent it is comparable to prevailing compensation for similar work in the area labor market.
- Equipment: The cost of office, warehouse, and other equipment necessary to perform donated food distribution is allowable when authorized by DHS as part of the Contractors approved line-item budget.
- Insurance Expenses: The cost of insurance coverage for the donated food program is allowable.
- Subcontractor Payments: A subcontractor may be paid by the Foodbank for expenses, if these expenses would be allowable if incurred by the Foodbank. Such expenses include staff salaries and equipment. All sub-contracts or pass-through funding agreements must be approved by IDHS prior to entering into any sub-contractual or pass-through funding arrangement.
- Maintenance and Repairs: Expenditures for necessary maintenance, repair or upkeep of equipment and property utilized in the donated food program are allowable.
- Materials and Supplies: Expenditures for materials and supplies (e.g., postage, printing, xeroxing) directly needed for the program operation are allowable.
- Training and Education: Expenditures for in service training and meetings of agency and sub contract or personnel, which directly benefit the donated food program, are allowable.
- Delivery of Donated Food: Expenditures for freight, cartage and delivery costs associated with distribution and handling of donated food are allowable.
- Staff Travel: Program-related travel expenses of Foodbank staff and volunteers may be charged to the EFP at the Foodbank's prevailing rate of reimbursement.
- Utilities: The cost of utilities (gas, electricity, telephone, etc.) for facilities used in the operation of the program is an allowable expense. The amount charged must be in direct proportion to the space utilized for the donated food program or be documented actual expenditures for program staff.
Anything other than what is outlined above is deemed unallowable. The following are some examples of unallowable costs with EFP administrative funds.
- Food Purchase: EFP administrative grant funds are to only be used for costs associated with the distribution, handling and storage of USDA food commodities and other privately donated/purchased food. The funds must not be used to purchase food.
[See details on the TANF Food Purchase Program and the Hunger Relief Tax Check-Off Program, which do allow for the purchase of food].
- Fundraising: The cost of any activity directly or indirectly related to raising funds for an institution, charitable organization, or political cause.
If a provider has any doubt about whether or not a certain expenditure is allowable, they should contact the Department.
H. Program Monitoring
Representatives of the IDHS may perform periodic monitoring reviews, during normal business hours, to review the management practices, fiscal procedures or other aspects of the provider's operations to ensure compliance with IDHS, State and Federal rules, regulations and policies. Providers must maintain all participant and fiscal records on site to facilitate program monitoring by IDHS.
- Notification: The IDHS will send a written notification thirty days prior to visiting a provider, if at all possible. Official notice will include a confirmation letter of dates/times as well as a monitoring instrument that must be reviewed before the IDHS representative arrives.
- Initial Site Visit: Once a new grant is awarded by the IDHS a representative from the IDHS may conduct a site visit to advise the provider of the IDHS program standards and reporting documents. The visit is to help the provider understand and follow IDHS rules and regulations. The initial visit to the site is also to make sure all State rules and regulations are followed. The IDHS, when doing a site visit, will review a sampling of documents to determine organizational capacity, amount of privately donated food distributed, geographic coverage, distribution/delivery plans and methodologies, ability to receive and store food and ability to comply with allocation requirements, outreach, training and site monitoring. Examples of documentation for review are: copies of shipping notices and release vouchers, signature sheets and meal-served reports, income and expense reports, and the contract file for distribution sites.
- Program Review: Whenever problems or issues are identified during monitoring, the IDHS may issue a Corrective Action Plan. Technical assistance may be provided by appropriate staff from the IDHS. The IDHS may also make recommendations to the provider.
- Monitoring Report Results: All monitoring results will be issued in a preliminary or final report to the provider within thirty days of the conclusion of the monitoring visit. Preliminary reports require some type of response or corrective action from the provider. Final reports do not require a response or corrective action from the provider.
- Corrective Action Plans: Problems of continuing or serious nature may result in a Corrective Action Response from the IDHS. If a site has a serious violation, the provider will be notified in writing within ten days. The provider will then have thirty days to respond with a mandatory written plan of action to the violation. If necessary, the IDHS will conduct a follow-up visit to the provider to ensure implementation of the approved Corrective Action Plan.
- Distribution Site Monitoring: The provider is responsible for reviewing the activities and operations of their pantries, soup kitchens and homeless shelters. The review must include verification of adherence to eligibility criteria, residency requirements, and adequacy of storage of commodities. It is the responsibility of the Foodbank to take necessary actions to correct deficiencies identified through monitoring of distribution sites. Copies of reviews must be available for inspection by the USDA/IDHS upon request. All pantries, soup kitchens and homeless shelters under contract with the Foodbank must be monitored at least once every two years by the Foodbank.
- Technical Assistance: The IDHS will provide technical assistance to the providers, if needed. Upon request, the IDHS will respond to questions pertaining to fiscal, service or inventory reports, policies and procedures, rules and regulations and Federal and State laws.
- Fiscal Reporting: Throughout the year, the IDHS will be available to help with questions pertaining to the monthly EFP fiscal reporting that is required by the IDHS.
- Program: The IDHS is available to advise the provider, if needed, on the policy and procedures of the program. Throughout the year, the IDHS will also be available to help with questions pertaining to the monthly EFP participant service and inventory reporting that is required by the IDHS.
- Provider Training: The IDHS may conduct mandatory provider training sessions throughout the year for contracted Foodbanks. If feasible, and to the extent possible, the IDHS will notify Foodbanks at least 30 days in advance of a mandatory training. These training seminars will cover areas such as fiscal, service and inventory reporting, food distribution, contract compliance and other areas designed to help Foodbanks meet State and Federal guidelines and requirements. The Foodbanks are required to attend mandatory training sessions.
- Distribution Site Training: Foodbanks are required to provide formal EFP policy and procedure training to distribution site staff at least once each year in accordance with the EFP distribution site policy manual provided annually by IDHS.