TEFAP Self-Declaration Eligibility File Audit

Verifies that signed TEFAP self-declaration eligibility forms are on file for each household and that records meet the required five-year retention period. Used by food bank monitors and state agency staff during subsite reviews per USDA TEFAP regulations.

Site & Review Setup

• Subsite / pantry name and address
  Record the full legal name and physical address of the subsite under review.
• Date of review
  Date on which this file audit is being conducted.
• Reviewer / monitor name and affiliation
  Name of the food bank monitor or state agency reviewer conducting this audit.
• Subsite contact person present during review
  Name and title of the subsite staff or volunteer present during the audit.
• Review type
  Select the type of review being conducted.
• Sample size: number of household files selected for review
  Enter the number of individual household eligibility files pulled for this audit sample.

Form Availability & Version Control

• Current USDA-approved TEFAP Self-Declaration form is in use (not an expired version)
  Verify the form version matches the state agency's currently approved version. Expired or superseded forms are a non-conformance.
• Blank forms are available in sufficient quantity at the point of service
  Blank self-declaration forms must be accessible to clients at each distribution. Shortage is a deficiency.
• Forms are available in languages reflecting the primary languages of the client population served
  USDA nondiscrimination requirements (7 CFR 272.6) require meaningful access for limited English proficient individuals. Note languages available.
• "Every Visit" or per-visit eligibility collection policy: confirm subsite's collection frequency matches state agency requirement
  Some states require a new self-declaration at every visit; others allow annual or per-program-year collection. Verify the subsite's practice matches the state-approved policy.
• Staff/volunteers can correctly explain the self-declaration process to a client (brief verbal check)
  Ask one staff member or volunteer to describe how they collect eligibility information. Confirm they understand no additional documentation is required from the client.

Sampled File Review — Form Completeness

• Number of sampled files with household name or identifier present
  Count of sampled files where the household name or unique identifier field is completed.
• Number of sampled files with date of distribution/visit recorded
  Date of each distribution or visit must be recorded on or with the form.
• Number of sampled files with household size recorded
  Household size is required for eligibility determination under TEFAP income guidelines.
• Number of sampled files with eligibility basis indicated (income category or categorical eligibility program checked)
  The form must show the basis for eligibility: income at or below 185% FPL, or categorical eligibility (e.g., SNAP, TANF, SSI, Medicaid). See FAQs on Revised TEFAP 2025 Self-Declaration.
• Number of sampled files with client signature (or documented refusal/alternative) present
  A client signature on the self-declaration is required. If a client is unable to sign, the subsite must document the reason and an authorized representative signature or staff notation.
• Any sampled files where subsite improperly required additional documentation beyond the self-declaration (e.g., ID, pay stub)?
  TEFAP regulations prohibit requiring documentation beyond the signed self-declaration. Answering YES is a critical non-conformance requiring corrective action.
• Overall completeness rate of sampled files (estimated %)
  Reviewer's overall estimate of the percentage of sampled files that are fully and correctly completed. Target ≥ 95%.

Record Retention Compliance

• Subsite can produce signed eligibility forms for the current program year
  Current-year forms must be immediately accessible for review.
• Subsite can produce signed eligibility forms for the prior program year (Year -1)
  Prior-year records must be retained and retrievable within the five-year window.
• Records dating back five full program years are present and retrievable
  Per 7 CFR 251.10, records must be retained for five years. Spot-check oldest required year. Inability to produce records is a critical deficiency.
• Oldest program year for which records are currently on file
  Record the program year (e.g., 'FY2020') of the oldest eligibility files available at this site.
• Records storage method
  How does the subsite store completed eligibility forms?
• Records containing client PII (name, household data) are stored securely and access is limited to authorized staff
  Client self-declaration forms contain personally identifiable information. Access must be restricted to authorized personnel only.
• Subsite has a written records retention and destruction policy covering the five-year TEFAP requirement
  A written policy helps ensure consistent compliance across staff turnover. Absence is a deficiency but not critical.

Distribution Log & Eligibility Reconciliation

• Distribution log or sign-in sheet is maintained for each distribution event
  A distribution log is required to reconcile households served against eligibility records.
• Spot-check: sampled distribution log entries can be matched to a signed eligibility form on file
  Select 5–10 entries from a recent distribution log and confirm each has a corresponding signed self-declaration. Document any unmatched entries.
• Number of distribution log entries reviewed in spot-check
  Record how many log entries were cross-referenced against eligibility files.
• Number of distribution log entries with no matching eligibility form found
  Any unmatched entries represent a potential eligibility documentation gap. Zero is the target.
• Describe any discrepancies found between distribution log and eligibility files
  Document specific households, dates, or patterns of missing documentation. Enter 'None' if no discrepancies found.

Findings, Corrective Actions & Sign-Off

• Overall audit result
  Reviewer's overall determination based on findings.
• Summary of deficiencies identified
  Provide a concise narrative summary of all deficiencies noted during this audit, referencing section and item numbers where applicable.
• Corrective action(s) required and due date(s)
  List each required corrective action with the responsible party and target completion date. Enter 'None required' if fully compliant.
• Photo documentation of file storage area or deficiencies (if applicable)
  Attach photos of the records storage area, any deficient conditions, or supporting evidence as needed.
• Reviewer signature
  Signature of the food bank monitor or state agency reviewer certifying the accuracy of this audit record.
• Subsite representative signature (acknowledgment of findings)
  Signature of the subsite contact acknowledging receipt of audit findings. Signature does not constitute agreement with findings.