TEFAP Distribution Site Civil Rights Compliance Audit

Biennial civil rights compliance audit for TEFAP (The Emergency Food Assistance Program) distribution sites. Reviews posted nondiscrimination statements, complaint procedures, language access plans, and volunteer/staff training records in accordance with USDA civil rights requirements and 7 CFR Part 272.

Site & Audit Information

• Distribution site name
  Legal name of the TEFAP subrecipient distribution site being audited.
• Site address
  Full street address, city, state, and ZIP code of the distribution site.
• Date of audit
  Date on which this on-site civil rights compliance audit is being conducted.
• Auditor name and title
  Full name and job title of the food bank or state agency representative conducting the audit.
• Site coordinator / contact present during audit
  Name and title of the site representative present during the review.
• Date of previous civil rights audit at this site
  Record the date of the most recent prior biennial audit for this location. Enter N/A for new sites.
• Were any corrective actions required from the previous audit?
  If yes, document the prior deficiencies and current status in the comments.

Nondiscrimination Postings & Statements

• USDA 'And Justice For All' poster posted in a conspicuous location visible to all participants
  The current version of the USDA 'And Justice For All' nondiscrimination poster must be displayed at the point of service where participants check in or receive food. Verify it is the most current version (check USDA FNS website for current poster).
• Nondiscrimination statement included on all program materials distributed to participants (flyers, intake forms, newsletters)
  All participant-facing printed or digital materials must include the USDA nondiscrimination statement or the short-form tagline. Review at least three current materials on-site.
• Nondiscrimination statement is complete and contains all required elements (protected bases, USDA contact information, TTY number)
  Verify the statement lists all protected bases: race, color, national origin, sex, religious creed, disability, age, political beliefs, reprisal or retaliation for prior civil rights activity. Must include USDA Office of the Assistant Secretary for Civil Rights mailing address, phone, and TTY number.
• Nondiscrimination statement or poster is posted in all languages spoken by a significant portion of the service area population (≥5% or 1,000 persons per Executive Order 13166 LEP threshold)
  If the service area has a significant LEP population, the nondiscrimination notice must be available in the relevant language(s). Check against the site's language access plan or local census data.
• Site does NOT display any signage, materials, or messaging that restricts, discourages, or implies exclusion of any protected class
  Walk the entire participant-facing area and review all posted materials. Flag any signage that could be interpreted as limiting access based on race, color, national origin, sex, disability, age, or other protected basis.
• Photo documentation of nondiscrimination posting location(s)
  Capture a photo showing the 'And Justice For All' poster and any additional nondiscrimination materials as posted at the site. Include enough context to confirm visibility and placement.

Civil Rights Complaint Procedures

• Written civil rights complaint procedure is on file at the site
  The site must maintain a written procedure describing how participants can file a civil rights complaint. Request to review the document on-site.
• Complaint procedure includes instructions for filing directly with USDA (online, mail, and phone/fax options)
  Participants must be informed they may file complaints with USDA Office of the Assistant Secretary for Civil Rights at: USDA, Director, Office of Adjudication, 1400 Independence Ave SW, Washington DC 20250-9410; (866) 632-9992; or online at www.usda.gov/oascr/how-to-file-a-program-discrimination-complaint.
• Complaint procedure is posted or made available to participants at the point of service
  The complaint procedure or a summary must be visible or available to participants — not just kept in a binder in the back office. Confirm how participants are informed of this right.
• Site has a designated staff or volunteer contact responsible for receiving civil rights complaints
  There must be a named individual (or role) responsible for accepting and escalating complaints. Verify the person is identified in writing and is aware of their responsibility.
• Log or record of any civil rights complaints received in the past 24 months is maintained
  Sites must retain records of any complaints received, including date, nature of complaint, and resolution. A log with zero entries is acceptable if no complaints were received — the log itself must exist.
• Number of civil rights complaints received at this site in the past 24 months
  Enter the count from the complaint log. Enter 0 if no complaints were received. Flag any unresolved complaints in comments.

Language Access for Limited English Proficient (LEP) Participants

• Site has identified the LEP languages spoken in its service area (e.g., via census data, participant intake data, or food bank guidance)
  The site or parent food bank must have conducted or referenced a LEP needs assessment. Ask to see the documentation or the food bank's language access plan covering this site.
• Vital program documents (intake forms, eligibility notices, participant rights) are available in the identified LEP language(s)
  For each identified significant LEP language, key participant-facing documents must be translated. Review available translated materials on-site. If no significant LEP population exists, mark N/A and note in comments.
• Bilingual staff, trained volunteer interpreters, or a telephone/remote interpretation service is available during distribution hours
  The site must have a documented method for providing oral language assistance to LEP participants during distribution. Verify the method (bilingual staff roster, interpreter list, or contract/free service such as Language Line).
• Participants are notified of the availability of free language assistance (e.g., via 'I Speak' cards, multilingual signage, or intake form notice)
  Participants must know they can request language assistance at no cost. Verify the notification method is visible or provided at intake.
• Site does NOT rely solely on minor children or untrained family members to interpret for LEP participants
  USDA FNS LEP guidance discourages use of minor children as interpreters and requires competent interpretation. Confirm with site coordinator that this practice is not occurring.
• LEP languages identified as significant for this service area
  List all languages identified as significant (≥5% or 1,000 persons). Enter 'None identified' if the food bank's LEP assessment found no significant LEP population for this site.

Civil Rights Training — Staff & Volunteers

• Civil rights training was conducted for all current staff and volunteers within the past 12 months
  USDA FNS requires annual civil rights training for all personnel who interact with program participants. Request the training log or sign-in sheets for the most recent training session.
• Training records (sign-in sheets, completion certificates, or LMS records) are on file and available for review
  Documentation must identify each trained individual by name, the date of training, and the topics covered. Electronic records are acceptable.
• Training content covers all required topics: nondiscrimination requirements, protected bases, complaint procedures, and LEP obligations
  Review the training agenda, slides, or curriculum used. Confirm all four topic areas are addressed. A training that covers only one or two topics is a deficiency.
• New staff and volunteers receive civil rights orientation before interacting with participants
  Ask the site coordinator to describe the onboarding process for new volunteers. There should be a documented procedure ensuring civil rights training occurs prior to or at the start of service.
• Percentage of current active volunteers/staff with documented civil rights training in the past 12 months
  Calculate: (# trained / # active staff+volunteers) × 100. A rate below 100% requires explanation and corrective action plan.

Program Accessibility & Equal Treatment

• Physical site is accessible to persons with disabilities (accessible parking, entrance, and service area per ADA standards)
  Observe the participant pathway from parking/drop-off through the service area. Look for: accessible parking spaces with proper signage, ramp or level entry, door width ≥32 inches clear, and accessible service counter height or alternative. Note any barriers.
• Site does NOT impose eligibility criteria beyond those authorized by the food bank / state agency (e.g., no unauthorized residency, ID, or income documentation requirements)
  TEFAP eligibility is determined by the state agency. Sites may not add unauthorized barriers such as requiring a specific form of ID, proof of citizenship, or documentation not required by the program. Ask the coordinator what documentation is requested and verify against food bank policy.
• Participants with disabilities are offered reasonable accommodations upon request (e.g., carry-out service, alternative pickup arrangements)
  Ask the coordinator how accommodation requests are handled. There should be a process — even informal — for ensuring participants with mobility or other limitations can access the program.
• Distribution process is conducted in a manner that treats all participants with dignity and without differential treatment based on protected characteristics
  Observe the distribution process if active, or interview the coordinator and at least one volunteer. Look for evidence of differential treatment, segregated lines, or disparate service quality.

Recordkeeping & Documentation

• Civil rights records (training logs, complaint records, LEP materials, posting documentation) are retained for a minimum of 3 years
  USDA FNS requires retention of civil rights records for at least 3 years. Verify the site has records going back to the prior audit cycle.
• Records are organized and retrievable within a reasonable time during an unannounced monitoring visit
  Ask the coordinator to locate the civil rights training log and complaint log. If either cannot be produced within 10 minutes, note as a deficiency.
• Overall civil rights recordkeeping rating
  Rate the overall quality and organization of the site's civil rights recordkeeping.

Audit Summary & Corrective Action

• Overall compliance determination
  Select the auditor's overall determination for this site based on findings.
• Summary of deficiencies identified
  List all deficiencies found during this audit, referencing the section and item number. For each deficiency, note whether it is a repeat finding from the prior audit.
• Required corrective actions and deadlines
  For each deficiency, specify the required corrective action and the deadline for completion. Deadlines must align with the food bank's corrective action policy (typically 15–30 days for non-critical, immediate for critical).
• Follow-up visit required?
  Select Yes if the severity of findings requires a follow-up on-site visit to verify corrective actions were implemented.
• Auditor signature
  Auditor signature certifying that this audit was conducted in accordance with the food bank's civil rights monitoring procedures and that findings are accurately recorded.
• Site coordinator acknowledgment signature
  Site coordinator signature acknowledging receipt of audit findings. Signature does not constitute agreement with findings.