- A. Purpose and Terminology
- B. Policies and Procedures
- C. Program Deliverables and Outcomes
- D. Contracts and Amendment Procedures
- E. Program Budget
- F. TANF Food Distribution Services
- G. Allowable/Unallowable Costs
- H. Program Monitoring
A. Purpose and Terminology
The TANF Food Purchase Program works to supplement the food distributed through the Emergency Food Program (see the Emergency Food Program section of the Program Manual for details) and supports the Department's mission to provide an emergency response to hunger and to increase food security for low-income households and individuals residing in Illinois. In addition to the USDA commodities and privately donated/purchased food distributed to all eligible Emergency Food Program (EFP) households, some EFP households are eligible for additional food purchased through the TANF Food Purchase Program. Temporary Assistance for Needy Families (TANF) funds are federal funds awarded to the Department by the U.S. Department of Health and Human Services and are used to support a variety of DHS programs for pregnant women and families with one or more dependent children. Based upon an annual, DHS-approved budget for the TANF Food Purchase Program, contracted EFP Foodbanks are awarded a TANF grant to purchase nutritional food items in bulk for distribution to food pantries who, in turn, distribute those food items to TANF-eligible households in need. TANF Food Purchase grant amounts are determined by the same federally approved formula used in the EFP, which is based upon 60% of the people in poverty and 40% of the unemployed people in each contracted Foodbank's geographic service area relative to those figures for the entire State of Illinois. Households with at least one dependent member 18 years of age or younger are considered TANF-eligible and may receive the additional commodities specifically designated for the TANF Food Purchase Program (TANF-eligible households meet income eligibility under regular EFP guidelines). TANF foods are not available year-round but are instead purchased by contracted EFP Foodbanks at a time prescribed by the Department. TANF-eligible households that receive both USDA commodities and TANF food products must complete the TANF Column on the EFP Signature Sheet to self-declare eligibility for both the EFP and the TANF Food Purchase Program. The following terminology is used in the TANF Food Purchase Program:
Distribution Site - Location where the eligible recipient agency actually distributes commodities to needy persons for household consumption. Pantries that participate in the Emergency Food Program are the only eligible distribution sites for the TANF Food Purchase Program.
EFP - Emergency Food Program - State-level abbreviation for the Federal program name TEFAP (The Emergency Food Assistance Program), with which the TANF Food Purchase Program works in conjunction.
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.
Food Pantry - public or private non-profit organization that distributes food to eligible families or individuals, including food from other non-government sources.
Fiscal Year - 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.
HHS - U.S. Department of Health and Human Services - responsible for the nationwide administration of essential federal health and human services programs, including TANF.
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.
TANF - Temporary Assistance for Needy Families (TANF) funds are federal funds awarded to the Department by the U.S. Department of Health and Human Services (HHS) and are used to support a variety of DHS programs for pregnant women and families with one or more dependent children.
TANF-Eligible - household with at least one dependent member who is 18 years of age or younger.
TANF-Food - Nutritional food items purchased in bulk by contracted EFP Foodbanks with TANF Food Purchase Program funds. TANF food is distributed to EFP food pantries who, in turn, distribute those food items to TANF-eligible households in need.
B. Policies and Procedures
- Funding: All funding under this program is limited to current Emergency Food Program (EFP) providers. Funds are awarded to contracted providers (i.e., Foodbanks) based on the same federally-approved formula used in the EFP, which is determined by 60% of the people in poverty and 40% of the unemployed people in each contracted Foodbank's geographic service area relative to those figures for the entire State of Illinois. Funding for the TANF Food Purchase Program is not available year-round; rather, the program is considered a recurring, short-term TANF Special Project and funds are issued during the state fiscal year for a specific period of time as prescribed by the Department. When TANF Food Purchase Program funds are issued by the Department to a contracted provider, the funds must be obligated within 30 days of receipt in accordance with Federal TANF rules.
- 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 provider is required to have on file the bills of lading, purchase orders and/or receipts verifying food purchase dates and amounts. Each provider is also required to submit TANF Food Purchase Program expenditures as a line-item on their monthly EFP 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. TANF Food Purchase Program funds must be obligated within 30 days of receipt and the 30-day obligation requirement will be verified by DHS through the web-based financial reports and/or through on-site field monitoring. DHS provides a web-based reporting system for use by each contracted provider that records, tracks and reconciles pre-approved budget line-items.
- Inventory Information and Data: Each provider is required to have on file the bills of lading, purchase orders and/or receipts verifying the type(s) and case amount(s) of food purchased with TANF Food Purchase Program funds to substantiate inventory. Each provider is also required to maintain a log of their TANF food distribution timeline to ensure that all TANF product is distributed to participating pantries as expeditiously as possible not to exceed the parameters of the agreement period. The TANF food purchases and distribution log will be verified by DHS through on-site field monitoring and/or annual close-out reporting.
- Participant Information and Data: Each provider is required to submit monthly participant outcome data, compiled from participant Signature Sheets used in the EFP for food pantries, regarding the total number of individuals and households served, as well as the number of households served that were TANF-eligible and received additional food purchased through the TANF Food Purchase Program. DHS provides the participant Signature Sheet and a web-based reporting system for use by each contracted provider.
- Participant Intake and Assessment Forms: The Department provides a form to document TANF 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 the TANF Food Purchase Program at a food pantry. 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. If TANF food is available and the participant household self-declares that there is at least one dependent member 18 years of age or younger residing in the household, then that household is considered TANF-eligible and may receive the additional commodities specifically designated for the TANF Food Purchase Program, at which time the household is required to complete the TANF Column on the DHS Signature Sheet with the number of dependent children 18 years of age or younger residing in the household. The signatory for the household receiving EFP commodities and TANF food 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 based on household self-declaration. The DHS Signature Sheet includes a warning that misuse of EFP foods (TANF Food is subject to the same EFP guidelines) 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 program regulations and that they agree to follow program regulations. The State of Illinois holds the participant responsible for the accuracy of DHS Signature Sheet entries relating to the TANF Food Purchase Program. Providers are not responsible or liable for accuracy of participant entries.
- Participant, Fiscal and Inventory Files: Each provider is required at a minimum to keep all participant, fiscal and inventory files for a five-year period.
C. Program Deliverables and Outcomes
The TANF Food Purchase Program works to supplement the food distributed through the Emergency Food Program (EFP); therefore, 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 each year and authorized from SFY July 1st through June 30th 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 TANF food to pantries through pickup and delivery services in accordance with the program policy of non-discrimination. TANF food must be distributed to pantries as expeditiously as possible and in a timeframe not to exceed the agreement period. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Distribute TANF 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 and TANF food which must include a policy of non-discrimination and an assurance that donated food is made available to all eligible households without regard 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 TANF food is based on self-declaration of household members 18 years or younger via certification on the Department Signature Sheet or Proxy Form; receive, track and verify the accuracy of completed EFP Signature Sheets (including any TANF food information) on a monthly basis. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Compile information from participant Signature Sheets which includes the number of individuals and households served, the number of children in TANF-eligible households served, as well as those households that receive/do not receive SNAP benefits based on household self-declaration. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Assure that participating pantries are open to the general public in their service area for at least 2 hours every week, unless there is a Department-approved Rule 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. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Expend and/or obligate TANF Food Purchase Program funding within 30 days of receipt. Document and isolate all TANF Food Purchase Program expenditures in accounting records, maintain all expenditure documentation and complete mandatory on-line financial reporting, no later than 15 days after the end of the calendar month in which TANF Food Purchase expenditures were incurred. The outcome will be verified through on-site field monitoring and/or monthly reporting.
- Conduct formal EFP and TANF Food Purchase Program policy and procedure training to distribution site staff at least once a 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 participating distribution sites at least once every year to ensure that all required EFP and TANF Food Purchase Program criteria are met as specified in the EFP Site Monitoring Instrument developed by the Foodbanks and approved by the Department. 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.
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 by the U.S. Department of Health and Human Services (HHS) and made available by DHS for TANF Special Projects. Funds are 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 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 HHS. 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 the Department's TANF Reporting Unit.
- Sub-Contracts and Pass-Through Funding: 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.
- Contract Budget Line Item Transfers: Funds awarded to providers for the TANF Food Purchase Program must only be used for the purchase of food. A maximum of 5% can be used for allowable distribution and handling costs (i.e., fuel, freight, warehousing costs) directly associated with the storage, handling and distribution of the TANF food. No other budget line items or transfers beyond what is prescribed herein are allowable for the TANF Food Purchase Program.
E. Program Budget
- Annual TANF Food Purchase Program Budget: The annual TANF Food Purchase Program budget is included as a line item on the EFP budget which establishes how the Federal funding is utilized for program implementation during the fiscal year. Funds awarded to providers for the TANF Food Purchase Program must only be used for the purchase of food. A maximum of 5% can be used for allowable distribution and handling costs (i.e., fuel, freight, and warehousing costs) directly associated with the storage, handling and distribution of the TANF food. The TANF Food Purchase Program budget is approved by the Department in conjunction with the annual EFP budget. Providers are required to track all 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 TANF Food Purchase Program must be made within the parameters of and in accordance with the federal grant awarded by HHS and administered by the DHS TANF Reporting Unit. The budget revision/amendment process may include:
- Letters of increase or decrease; A letter/email 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: The TANF Food Purchase Program does not require a match of funds.
- 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: Upon approval of the TANF Food Purchase Program budget, providers will receive a prospective payment as prescribed by the Department. Provider payments must be obligated within 30 days of receipt in accordance with Federal TANF rules. Receipt of funds, food purchases, and any approved distribution and handling costs will be verified by on-site field monitoring.
- Provider Responsibilities: TANF Food Purchase Program providers must submit, on a timely basis, complete and accurate fiscal and participant service reports. Data is submitted as part of the monthly EFP reporting; participant service numbers for the TANF Food Purchase Program are not isolated from service data for the EFP (since TANF-eligible households receive both EFP and TANF food). Access to a computer and the Internet are required for electronic reporting to IDHS. Unless otherwise notified in writing by the IDHS, TANF Food Purchase Program providers are required to submit fiscal reports no later than 15 day after the end of each state fiscal month and participant service reports on the IDHS web-based EFP reporting system not later than 21 days after the end of each state fiscal month in which TANF program expenditures and services occur. The State of Illinois' fiscal year operates from July 1 to June 30 each year. Participant service reports provide details on the number of individuals and households served in EFP food pantries, to include those households that were TANF-eligible and received additional TANF food when it was available. Fiscal reports provide line-item details on expenditures incurred for the purchase of food and allowable distribution and handling costs (5% maximum). The IDHS will provide all providers with the web-based reporting system. An annual TANF Food Purchase Program close-out report, submitted separately from the web-based reporting system, is also required by providers and must be submitted no later than 45 days after the end of the agreement period in which funding is available. The annual close-out report outlines how many TANF-eligible families and children were served during the agreement period. The close-out report may also include, when not verified through on-site field monitoring, documentation of approved food purchases (dollar amounts, quantities and types), a TANF food distribution log, and documentation of any approved distribution and handling costs.
F. TANF Food Distribution Services
Providers (i.e., contracted Foodbanks) will distribute TANF food commodities through food pantries currently participating in the Emergency Food Program, and those 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 and TANF food. Food pantries must allow participants to receive service at least once in a thirty-day period and cannot 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.
All facilities utilized in the program must meet local health and safety code requirements.
The pantries 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 participating pantries. All pantries receiving TANF food 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 TANF Food Purchase Program 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.
Program regulations for the TANF Food Purchase Program limit allowable expenditures to the purchase of food. A maximum of 5% can be used for allowable distribution and handling costs (i.e., fuel, freight, and warehousing costs) directly associated with the storage, handling and distribution of the TANF food. Expenditures must be reasonable and appropriate and must be reported at the price actually paid. Documentation must be maintained to substantiate all TANF Food Purchase Program expenditures.
- Food Purchase: Food items purchased in bulk by contracted EFP Foodbanks for distribution to EFP food pantries, who, in turn, distribute those food items to TANF-eligible households in need.
- Distribution & Handling Costs (5% Maximum): A maximum of 5% can be used for allowable distribution and handling costs (i.e., fuel, freight, labor, warehousing costs) associated with the storage, handling and distribution of the TANF food.
Unallowable Costs: Anything other than what is outlined above is deemed unallowable.
If a provider has any doubt about whether or not certain expenditure(s) 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 EFP pantries participating in the TANF Food Purchase Program. 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 IDHS upon request. All EFP distribution sites under contract with the Foodbank, to include those participating in the TANF Food Purchase Program, must be monitored at least once every year 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 required reporting, policies and procedures, rules and regulations and Federal and State laws.
- 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, to include TANF Food Purchase Program policies and procedures, at least once each year in accordance with the EFP distribution site policy manual provided annually by IDHS.