RESPONSIBILITY:  The Oklahoma Department of Human Services (DHS) is responsible for the distribution of TEFAP foods and administrative funds in the State of Oklahoma.  The address is 2400 N. Lincoln Blvd.  Oklahoma City, OK, 73125.  Jeffrey Cartmell, Director of DHS, signs the annual agreement with USDA.  Gina Kazerooni, Programs Administrator, manages the program, authorizes claims for administrative funds disbursement, and is responsible for the program operations.

PLAN TO DISTRIBUTE TEFAP FOODS: DHS has contractual agreements with Regional Food Bank of Oklahoma and the Food Bank of Eastern Oklahoma for the storage and distribution of TEFAP foods. DHS staff oversees orders for TEFAP foods that are directly delivered to the two food banks.  The Food Banks serve the food pantries, soup kitchens and shelters that receive TEFAP foods statewide.  Both Food Banks also distribute non-TEFAP foods through other donations and their affiliation with the Feeding America network.  Our agreement is to reimburse the Food Banks 14 cents per pound or actual expenses, whichever is less, to the extent that funding is available. 

EXISTING NETWORKS are described in section 251.4 (h) (3) of the TEFAP regulations.  This gives the State Agency authority to “give priority in the distribution of TEFAP commodities to existing food bank networks and other organizations whose ongoing primary function is to facilitate the distribution of food to low-income households, including food from sources other than the Department.”  The Regional Food Bank of Oklahoma (serving 53 counties of central and western Oklahoma) and the Food Bank of Eastern Oklahoma (serving 24 counties of eastern Oklahoma) are the only two affiliated Food Banks in Oklahoma.  The two Food Banks provide an existing network for food distribution statewide, they distribute food only to agencies in Oklahoma, they already distribute food received from many other private sources, and they serve over 900 food assistance organizations in the State, many of whom also meet the criteria to receive TEFAP foods.

The Program Directors of the two food banks provide eligibility criteria to those interested in participating.  Food Bank staff complete pre-approval site visits to applicant agencies to determine eligibility and inspect facilities prior to approval.  Approved agencies are then regularly monitored by the Food Banks.  Termination of approved agencies can occur when there are instances of non-compliance with USDA and Food Bank Policies.

In disaster situations, the Food Banks make additional deliveries as needed to areas affected.  There are no concerns or problems in this area in the state of Oklahoma, due to the excellent program operations at both Food Banks.

The food orders and TEFAP Administration Funds are split between the two Food Banks based on the percentage of poverty and unemployment in the areas of the state served by each Food Bank.  The Regional Food Bank of Oklahoma in Oklahoma City receives approximately 60% and the Food Bank of Eastern Oklahoma in Tulsa receives 40%.

The partnership between the Regional Food Bank of Oklahoma in Oklahoma City and the Food Bank of Eastern Oklahoma in Tulsa and the Food Distribution Programs Unit of the Oklahoma Department of Human Services is successful.  The entire state is covered for emergency feeding and disasters.  The use of the two Food Banks is logical, efficient and fiscally responsible for the storage and delivery of TEFAP foods.

DISTRIBUTION TO ELIGIBLE RECIPIENT AGENCIES-TIER SYSTEM-251.4 (h):  DHS sets the criteria for eligible recipient agencies for the receipt of TEFAP foods in Oklahoma.  DHS has determined that only emergency feeding organizations, including food pantries, soup kitchens, and shelters, will be eligible to receive TEFAP foods from one of the two Food Banks in Oklahoma.  Within these parameters, DHS has delegated the responsibility to the two Food Banks to select the local pantries, soup kitchens, and shelters and to determine the eligibility of these organizations to distribute food.  DHS feels that the limited available TEFAP food supplies should be reserved for emergency feeding organizations in our State, since the amount of food available has not been sufficient to meet the needs of these organizations and the hungry Oklahomans they serve.  DHS therefore gives First Priority, as described in 251.3 (e) to emergency feeding organizations.

The Food Banks are responsible for distributing food on a “fair share basis” to the emergency feeding organizations in their areas.  Our plan is to try to assure that communities in our state have adequate organizations to assist in the feeding of those with emergency needs. 

Organizations that are approved to receive the TEFAP foods and distribute them to the needy in their community must be 501-C-3 organizations or places of worship that operate a food pantry, soup kitchen or shelter or they must be direct service soup kitchen or pantry programs operated by one of the Food Banks.  Except in rare circumstances of need, the Food Banks require that these organizations be a participant with the other programs at the Food Banks for several months before they are eligible for TEFAP foods.  This provides an opportunity to monitor the organization to assess accurate record keeping and compliance with established program regulations.  This also gives the Food Bank an accurate count of participants and records to substantiate.  There are limited amounts of some TEFAP foods and we must do all possible to assure that these foods are shared for distribution only with stable organizations that provide accurate information.

Direct service soup kitchens operated by Food Banks will include Kid Cafés or other after school or summer soup kitchen serving children from low-income areas.  Direct service food pantries operated by the Food Banks will include pantries such as mobile food pantries, pantries located in DHS county offices, and pantries located in low-income schools.  All direct service pantries that distribute TEFAP foods will document the eligibility of the households that receive TEFAP food based on the pantry recipient criteria noted below. 

If TEFAP pantries are located in low-income schools, they will utilize records documenting student eligibility for Free and Reduced Price School Meals or SNAP to confirm that students meet TEFAP income eligibility.  If a student does not meet the Free and Reduced Price School Meals or SNAP eligibility, students can receive TEFAP if their household falls within the TEFAP income eligibility guidelines for Oklahoma; the pantry must retain an approved application on file.  Only students that meet those criteria will receive TEFAP foods.  Records will be kept to document eligibility as well as the dates the food is distributed and the names of all households that receive food.  Any direct service to children will comply with USDA Policy Memo FD-041. 

In the event that a TEFAP commodity item should be available in such large quantities that it could not be utilized by existing emergency feeding organizations in a reasonable timeframe without putting the product at risk, the Food Banks, with approval from DHS, can open distribution of this specific TEFAP food item to active Food Bank agencies that serve needy senior citizens.  This limited distribution would be done as a Second Priority distribution of TEFAP foods, after the product had first been offered to emergency feeding organizations.

CRITERIA FOR DETERMINING RECIPIENT ELIGIBILITY AS DESCRIBED IN 251.15(b):

Oklahoma DHS has established the eligibility criteria for households that receive TEFAP foods from food pantries for home consumption.  These criteria were set by DHS in accordance with FNS guidelines.  For Income Eligibility, Oklahoma uses income levels that are within 200% of the current Federal Poverty Guidelines.  Households self-declare income and residency.   The Food Banks provide the current income guidelines to their TEFAP partners each June, as the new income guidelines for TEFAP go into effect July 1^st of each year.

Adjunct Eligibility: Applicants who participate in specific Federal programs, including SNAP, FDPIR, SSI, WIC, and CSFP, will be considered income eligible for TEFAP. To demonstrate income eligibility via participation in one or more of these Federal programs, applicants must document that they are certified as fully eligible for the Federal program(s) on the TEFAP intake form.  Oklahoma will use self-attestation as the method for applicants/participants to document their participation in one or more of the designated programs.  Applicants who are determined to be income eligible based on their participation in these Federal programs shall not be asked for additional income information (e.g., monthly income).

To determine residency, a TEFAP partner that distributes TEFAP for home consumption will ask each applicant to provide their zip code and county of residence on a TEFAP intake form; the household will self-attest the zip code and county of residence and will not be asked for verification.  Households will not be required to provide full addresses and they will not be asked to provide a form of identification.  ERAs may collect additional information, such as household addresses, from TEFAP applicants and participants for reasons other than TEFAP eligibility determination (e.g., to deliver USDA Foods to participants’ residences or for food recall notification purposes).  However, it must be made clear the additional collection of information is unrelated to TEFAP eligibility, and the receipt of USDA Foods is not conditional on providing the information.  TEFAP applicants and participants must have the option of not providing the additionally requested information.  Types of additionally requested information could also include veteran’s status, racial and ethnicity information, ages of household members, birthdates of household members, etc.  To ensure only the required information to determine TEFAP eligibility is collected for each household, a uniform TEFAP intake form will be used by all TEFAP ERAs in the state that distribution TEFAP food for home consumption.  If an ERA wishes to request additional information, a separate questionnaire may be given to the applicant when they complete the TEFAP intake form, but the separate questionnaire must be clearly marked as “optional,” and the applicant must be informed that the separate questionnaire is voluntary and is not required for determining TEFAP eligibility.  Ideally, any additional information requested from a household should be requested after TEFAP eligibility has been determined.

In addition to complying with income eligibility, TEFAP food pantries distributing food for home consumption are required to record the following:

• The name of the household receiving USDA Foods
• The household’s self-declared zip code and county of residence
• The number of the persons in the household
• The date USDA food is distributed

All households must complete a TEFAP intake form during their initial visit to a TEFAP pantry in order to receive TEFAP food, and then annually in July so household eligibility can be redetermined using the new IEG chart (the updated guidelines go into effect each July 1^st).  A uniform TEFAP intake form will be used by all TEFAP partner pantries and will collect the following information: Household name, number of people in household, zip code, county of residence, income eligibility (including the current TEFAP IEG chart), and an adjunctive eligibility statement.  The intake form will also state TEFAP recipients must report all household changes to the TEFAP pantry immediately.  The head of household will sign and date the TEFAP intake form during the initial application, and each July during recertification.  For subsequent TEFAP distributions, the TEFAP pantry will document all TEFAP distributions to the household using a physical or digital log, or a program such as Link2Feed or Service Insights.  If a pantry uses Link2Feed or Services Insights, a signature via digital pad during initial application is acceptable; however, if a digital signature is not captured and saved, a physical signature on a TEFAP intake form should be obtained.  All TEFAP intake records must retained per TEFAP recordkeeping requirements.

Congregate meal site recipients and shelter residents do not need to complete an intake form in order to receive a prepared meal, but they should either sign a sign-in sheet or the site coordinator will maintain a meal count log.  The meal counts will be reported to the Food Bank and should be kept for three years plus the current fiscal year.

It is best practice for TEFAP pantries to distribute TEFAP to households once every 30 days; however, households may receive TEFAP more frequently, if necessary, as long as the pantry’s inventory will meet the need of other households requiring assistance. There is no frequency limit on congregate meals or shelter meals prepared using TEFAP.

Confidentiality Protections: Applicant and participant information must be kept confidential.  TEFAP regulations at 7 CFR 251.10(c)(2) outline that State agencies and ERAs must restrict the use and disclosure of information obtained from TEFAP applicants or participants to persons directly connected with administration or enforcement of TEFAP. This could include State agency staff conducting management evaluations and ERA staff and volunteers who process TEFAP intake forms. With the consent of the participant, State agencies and ERAs may share information obtained from TEFAP applicants and participants with other health and welfare programs for use in determining eligibility in those programs, or for program outreach. However, the State agency must sign an agreement with the administering agencies of those health and welfare programs to ensure that the information will be used only for the specified purpose, and that the agencies receiving the information will not further share it.  Currently, DHS and the ERAs do not plan to share information with other health and welfare programs.  However, if DHS and/or the ERAs wish to share information with other health and welfare programs for program eligibility purposes or for program outreach purposes in the future, the State agency and/or the ERAs will explicitly obtain consent from TEFAP applicants and participants by incorporating a written consent question into the intake process at the ERA, using the guidance from Policy Memo FD-160. 

USDA FOOD PREFERENCES:  In Oklahoma, the two Food Banks contracting with DHS provide a list of foods available through the TEFAP program online.  Monthly, ERAs and emergency feeding organizations place orders based on preferences and needs.  Local sites have the ability to alternate food items month to month.  The Food Banks send out customer satisfaction surveys requesting feedback on the program. Clients provide feedback on USDA Foods, sizes, and quantities.

 

Signature of State Agency Official                                                    Date         12-20-2024_                   

Gina Kazerooni, Programs Administrator

Food Distribution Unit, Oklahoma Human Services