Run TEFAP Distribution Site Civil Rights Compliance Audit — Free

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.

Yes No N/A

Nondiscrimination Postings & Statements

USDA 'And Justice For All' poster posted in a conspicuous location visible to all participants critical (required)

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).

Yes No N/A

Photo evidence (optional)

Nondiscrimination statement included on all program materials distributed to participants (flyers, intake forms, newsletters) critical (required)

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.

Yes No N/A

Nondiscrimination statement is complete and contains all required elements (protected bases, USDA contact information, TTY number) critical (required)

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.

Yes No N/A

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.

Yes No N/A

Site does NOT display any signage, materials, or messaging that restricts, discourages, or implies exclusion of any protected class critical (required)

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.

Yes No N/A

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 critical (required)

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

Yes No N/A

Complaint procedure includes instructions for filing directly with USDA (online, mail, and phone/fax options) critical (required)

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.

Yes No N/A

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.

Yes No N/A

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.

Yes No N/A

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.

Yes No N/A

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.

Yes No N/A

Vital program documents (intake forms, eligibility notices, participant rights) are available in the identified LEP language(s) critical (required)

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.

Yes No N/A

Bilingual staff, trained volunteer interpreters, or a telephone/remote interpretation service is available during distribution hours critical (required)

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).

Yes No N/A

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.

Yes No N/A

Site does NOT rely solely on minor children or untrained family members to interpret for LEP participants critical (required)

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.

Yes No N/A

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 critical (required)

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.

Yes No N/A

Training records (sign-in sheets, completion certificates, or LMS records) are on file and available for review critical (required)

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

Yes No N/A

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.

Yes No N/A

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.

Yes No N/A

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) critical (required)

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.

Yes No N/A

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) critical (required)

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.

Yes No N/A

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.

Yes No N/A

Distribution process is conducted in a manner that treats all participants with dignity and without differential treatment based on protected characteristics critical (required)

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.

Yes No N/A

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.

Yes No N/A

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.

Yes No N/A

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.

Note (optional)

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.

Yes No N/A

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.

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Run: TEFAP Distribution Site Civil Rights Compliance Audit

Site & Audit Information

Nondiscrimination Postings & Statements

Civil Rights Complaint Procedures

Language Access for Limited English Proficient (LEP) Participants

Civil Rights Training — Staff & Volunteers

Program Accessibility & Equal Treatment

Recordkeeping & Documentation

Audit Summary & Corrective Action

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