TEFAP Distribution Site Civil Rights Compliance Audit

Legal name of the TEFAP subrecipient distribution site being audited.

Full street address, city, state, and ZIP code of the distribution site.

Date on which this on-site civil rights compliance audit is being conducted.

Full name and job title of the food bank or state agency representative conducting the audit.

Name and title of the site representative present during the review.

Record the date of the most recent prior biennial audit for this location. Enter N/A for new sites.

If yes, document the prior deficiencies and current status in the comments.

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).

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.

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.

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.

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.

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.

The site must maintain a written procedure describing how participants can file a civil rights complaint. Request to review the document on-site.

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.

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.

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.

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.

Enter the count from the complaint log. Enter 0 if no complaints were received. Flag any unresolved complaints in comments.

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.

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.

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 must know they can request language assistance at no cost. Verify the notification method is visible or provided at intake.

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.

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.

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.

Documentation must identify each trained individual by name, the date of training, and the topics covered. Electronic records are acceptable.

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.

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.

Calculate: (# trained / # active staff+volunteers) × 100. A rate below 100% requires explanation and corrective action plan.

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.

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.

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.

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.

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.

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.

Rate the overall quality and organization of the site’s civil rights recordkeeping.

Select the auditor’s overall determination for this site based on findings.

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.

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).

Select Yes if the severity of findings requires a follow-up on-site visit to verify corrective actions were implemented.

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 signature acknowledging receipt of audit findings. Signature does not constitute agreement with findings.