Atlanta Food Banks: USDA / TEFAP Compliance Software

Atlanta is anchored by the Atlanta Community Food Bank - one of the largest food banks in the Feeding America network - which serves a 29-county service area across north and central Georgia, with a network of partner pantries, soup kitchens, and shelters distributing food at the community level. USDA TEFAP is one of multiple commodity and cash funding sources that flow through the food bank’s operations, alongside USDA CSFP for low-income seniors, FEMA Emergency Food and Shelter Program funds where applicable, USDA Foods program activity, Feeding America network allocations, and a substantial private giving base.

The federal compliance regime under TEFAP has two parallel threads. Commodity inventory and distribution records on one side. TEFAP administrative fund expenditure documentation on the other. They have to reconcile, and they have to support state and federal reporting on a monthly or quarterly cadence.

TEFAP and the path through Georgia DHS

TEFAP is authorized under the Emergency Food Assistance Act of 1983 and implemented through 7 CFR Part 251. USDA’s Food and Nutrition Service allocates TEFAP commodities and administrative funds to states by formula. Each state designates a state agency to administer TEFAP - in Georgia, the Department of Human Services - and the state contracts with Eligible Recipient Agencies (ERAs) that receive commodities and redistribute them to local partner agencies.

For the Atlanta Community Food Bank or any other TEFAP ERA in the metro region, the contract structure looks like this: the state delivers commodities (or coordinates USDA delivery), the ERA receives and stores them, the ERA distributes commodities to partner agencies (food pantries, soup kitchens, shelters that meet TEFAP eligibility under 7 CFR Part 251), and the partner agencies distribute to eligible households. At each step, records must support the state’s reporting to USDA-FNS.

The federal regulations cascade through. Subrecipients are subject to TEFAP regulations at 7 CFR Part 251, the Uniform Guidance at 2 CFR 200, USDA’s adoption at 2 CFR Part 400, and USDA civil rights requirements under Title VI and related statutes implemented at 7 CFR Part 15.

Commodity tracking: pounds, categories, lots, dates

TEFAP commodity tracking is a logistics discipline as much as a compliance discipline. The records that must exist:

• Receipt records: each delivery of TEFAP commodities to the ERA, captured by USDA item code, quantity (pounds and units), lot number where applicable, date, and condition on receipt.
• Storage records: consistent with food safety standards, including temperature monitoring for refrigerated and frozen commodities and pest control for dry storage.
• Distribution to partner agencies: each distribution to a partner agency captured by partner agency, USDA item code, quantity, date, and (typically) signed receipt.
• Partner agency household-level records: distribution to households, including the recipient self-declaration of eligibility under TEFAP household income criteria, that supports the state’s reporting on numbers served. The ERA’s monitoring of its partner agencies includes verifying that partner-level household records exist.

For a food bank moving millions of pounds of TEFAP commodities annually, the inventory management system has to do this work - manual spreadsheet tracking does not scale. State-mandated reporting formats vary; the Georgia DHS reporting requirements specify what fields must be reported and at what frequency.

TEFAP administrative funds and 2 CFR 200

TEFAP administrative funds reimburse the costs of storing, transporting, and distributing TEFAP commodities. The cost principles at 2 CFR 200 Subpart E apply, as adopted by USDA at 2 CFR Part 400. Allowable costs typically include warehouse rent and operations, refrigeration, transportation, distribution staff time, and certain inventory management costs.

The financial system must keep TEFAP administrative funds separate from other operational funds. Costs charged to TEFAP administrative funds must be allocable to TEFAP-related activities. Where staff or facilities serve multiple programs (TEFAP commodities, CSFP commodities, donated food distribution, FEMA EFSP-supported activities), cost allocation methodologies must be written and consistently applied. The cost principles do not bend just because the activities all happen in the same warehouse.

Procurement of contracted services (transportation, warehousing services from third parties, IT systems) is subject to Subpart D of 2 CFR 200, which sets standards for competitive procurement, sole-source justification, and contract administration consistent with federal requirements.

Civil rights compliance: signage, training, data, complaint procedures

USDA program nondiscrimination requirements apply to TEFAP at every level. The food bank, the partner agencies, and any sub-distribution sites must comply with USDA civil rights expectations, which include:

• Posting the USDA program nondiscrimination statement at distribution sites and on materials.
• Civil rights training for staff and volunteers handling distribution.
• Voluntary collection of race and ethnicity data on recipients (with appropriate safeguards on storage and use).
• Complaint procedures and visible complaint contact information.
• Language access for limited English proficient populations consistent with USDA guidance.

Compliance reviews can be conducted by USDA-FNS or by the state agency. Partner-agency-level civil rights compliance is the ERA’s responsibility to monitor - meaning the ERA’s partner agency monitoring program must include civil rights checks alongside food safety, eligibility, and operational checks.

Other commodity and cash programs

CSFP (Commodity Supplemental Food Program) provides monthly food packages to low-income seniors. The program operates on similar warehouse and distribution infrastructure but has distinct rules: monthly enrollment-based distribution to specific eligible seniors, separate inventory tracking under USDA’s CSFP regulations at 7 CFR Part 247, and separate state and federal reporting.

The USDA Foods program supports school meal programs through commodity allocations to school food authorities. Where a food bank participates as an intermediary or operator of a USDA Foods activity, separate records and reporting apply.

FEMA Emergency Food and Shelter Program is a different program - the funding flows through local EFSP boards under National Board oversight, with allowable cost categories specific to EFSP. Commingling EFSP funds with TEFAP, CSFP, or other USDA program funds is a finding waiting to happen.

LFPA (Local Food Purchase Assistance) and LFS (Local Food for Schools) programs, where active, are USDA-funded programs with their own implementing rules; food banks participating in these programs must track activity separately.

Single Audit and the federal threshold

Atlanta food banks expending $1,000,000 or more in federal awards in a fiscal year (effective for fiscal years ending on or after October 1, 2024) are subject to Single Audit under 2 CFR 200 Subpart F. For larger food banks, federal pass-through funding from TEFAP, CSFP, and other USDA programs (counted at fair market value of commodities received and at face value of administrative funds) routinely exceeds the threshold.

The Single Audit will identify TEFAP and other major federal programs through risk assessment and test compliance with cost principles, allowability, period of performance, performance reporting, eligibility, special tests and provisions specific to the program (commodity inventory and distribution for TEFAP), procurement, and other requirements specified in the OMB Compliance Supplement. The grant compliance checklist is a useful structure for the finance team to walk readiness areas.

What software actually has to do here

A food bank running TEFAP and adjacent commodity programs typically needs three integrated capabilities. Warehouse and inventory management captures commodity flow at the item-code level. Grants management and accounting handle restricted fund tracking, cost allocation, administrative fund expenditure documentation, and SF-425 reporting. Donor management handles individual, corporate, and foundation giving, including in-kind food donations from grocery and corporate partners.

These can be one platform or three, but the data must reconcile. Inventory pounds reported to Georgia DHS must reconcile to the receipt and distribution records. Administrative fund expenditures reported to the state must reconcile to the general ledger. Donated food values must reconcile across the inventory system and the audited financial statements. Most month-end and audit-prep work happens at these reconciliation points.

For Atlanta-area private and foundation funder relationships that supplement federal funding, the community foundation grants guide covers the broader funder universe. The grant compliance software shortlist is a starting point for evaluating the financial layer.