Retroactive Food Package Distributions (Revised)
The purpose of this memorandum is to clarify FNS policy regarding CSFP retroactive food package distributions. Per CSFP regulations at 7 CFR Part 247.10(a), the local agency must distribute a food package to participants each month, or a two month supply of food to participants every other month. These food packages must be distributed in accordance with established guide rates and must not be distributed retroactively under normal circumstances.
To the greatest extent practical, CSFP state agencies should work with their local agencies to distribute CSFP food packages early in the month to allow for unforeseen circumstances and maximize caseload use. Further, CSFP regulations provide flexibility to ensure that participants may receive food packages in instances when they cannot get to a distribution center. State and local agencies should review current policies and procedures to ensure, to the greatest extent possible, continued service to participants who are unable to pick up food packages. Per program regulations at § 247.6(c), CSFP state agencies must include in their state plans a description of the means by which the state will meet the needs of homebound seniors. Per CSFP regulations at § 247.5(c), local agencies must, to the extent possible, meet the special needs of these individuals. These requirements extend to those individuals who may be temporarily homebound.
CSFP state agencies may permit the use of proxies, particularly when participants are unable to pick up food packages in a given month. Proxy designations must be in writing, must indicate the period of time such designations are intended to cover, and must be maintained on file by the local agency. A designated proxy must provide some form of identification prior to picking up a CSFP food package (see CSFP Policy Memorandum FD-099, “Questions and Answers about Waiting Lists and Caseload Management”).
There may be rare instances where a local agency is unable to distribute CSFP food packages, or participants may be unable to pick up such food packages in a given month. This could be due to unforeseen circumstances including road closures, lack of electricity, staff shortages, or unsafe conditions. In such extreme circumstances, if an alternate CSFP food package delivery date cannot be scheduled within the same month, the state agency must immediately seek guidance from its respective FNS Regional Office on how to proceed. The FNS Regional Offices and FNS Headquarters will work together with state agencies to address such situations.