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Run: TEFAP Self-Declaration Eligibility File Audit

Audit TEFAP self-declaration files to confirm signed eligibility forms are on file, current, and retained for five program years. Use it to catch missing sig...

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Site & Review Setup

Record the full legal name and physical address of the subsite under review.
Date on which this file audit is being conducted.
Name of the food bank monitor or state agency reviewer conducting this audit.
Name and title of the subsite staff or volunteer present during the audit.
Select the type of review being conducted.
Enter the number of individual household eligibility files pulled for this audit sample.

Form Availability & Version Control

Verify the form version matches the state agency's currently approved version. Expired or superseded forms are a non-conformance.
Blank self-declaration forms must be accessible to clients at each distribution. Shortage is a deficiency.
USDA nondiscrimination requirements (7 CFR 272.6) require meaningful access for limited English proficient individuals. Note languages available.
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.
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

Count of sampled files where the household name or unique identifier field is completed.
Date of each distribution or visit must be recorded on or with the form.
Household size is required for eligibility determination under TEFAP income guidelines.
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.
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.
TEFAP regulations prohibit requiring documentation beyond the signed self-declaration. Answering YES is a critical non-conformance requiring corrective action.
Reviewer's overall estimate of the percentage of sampled files that are fully and correctly completed. Target ≥ 95%.

Record Retention Compliance

Current-year forms must be immediately accessible for review.
Prior-year records must be retained and retrievable within the five-year window.
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.
Record the program year (e.g., 'FY2020') of the oldest eligibility files available at this site.
How does the subsite store completed eligibility forms?
Client self-declaration forms contain personally identifiable information. Access must be restricted to authorized personnel only.
A written policy helps ensure consistent compliance across staff turnover. Absence is a deficiency but not critical.

Distribution Log & Eligibility Reconciliation

A distribution log is required to reconcile households served against eligibility records.
Select 5–10 entries from a recent distribution log and confirm each has a corresponding signed self-declaration. Document any unmatched entries.
Record how many log entries were cross-referenced against eligibility files.
Any unmatched entries represent a potential eligibility documentation gap. Zero is the target.
Document specific households, dates, or patterns of missing documentation. Enter 'None' if no discrepancies found.

Findings, Corrective Actions & Sign-Off

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

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