CSFP: Tentative Caseload Assignments for the 2022 Caseload Cycle

The Commodity Supplemental Food Program (CSFP) is currently funded under a Continuing Resolution (CR) at a funding level prorated to $325 million. Based on this funding level, the Food and Nutrition Service (FNS) is issuing a tentative national caseload allocation of 757,942 for the 2022 caseload cycle (Jan. 1, 2022 to Dec. 31, 2022). This is a 2,692 slot decrease from the 2021 national caseload level of 760,634. This decrease is due to state agencies requesting less caseload than in 2021.

The tentative national caseload allocation is contingent on the availability of program resources in 2022. Final caseload and administrative grants will be allocated once Congress takes final action on the fiscal year (FY) 2022 appropriation, and may be different than these tentative assignments. Caseload assignments and projected full fiscal year administrative grants could be adjusted should the full-year appropriation be lower or higher than the current funding level. However, until directed otherwise, states and Indian Tribal Organizations (ITOs) should work to meet their 2022 tentative caseload assignments as soon as possible.

FNS is allocating tentative caseload and administrative grants for 2022, as provided below.

Tentative Caseload Assignments for Currently Participating CSFP States and ITOs

In accordance with CSFP regulations at 7 CFR Part 247, base caseload is assigned in part based on the number of years each state and ITO has been in the program. Wichita and Affiliated Tribes, which FNS added to the program in 2021, is receiving base caseload levels equal to their respective 2021 assigned caseload levels. For all other states and ITOs which began CSFP participation prior to 2020, base caseload for the 2022 caseload cycle is equal to the highest of:

1. Average monthly participation for FY 2021; or
2. Average monthly participation for the last quarter of FY 2021; or
3. Participation during September 2021, but only if¹:
   1. The state agency received additional caseload equal to or greater than ten percent of its base caseload in 2021; and
   2. October 2021 participation was equal to or greater than 95 percent of September 2021 participation.

CSFP regulations further provide that for each CSFP state and ITO, calculated base caseload for 2022 cannot be greater than total assigned caseload for 2021.

Based on the funding provided in the CR and because several states and ITOs did not fully use their 2021 assigned caseload, there are sufficient program resources available in 2022 to meet all additional caseload requests by currently participating states and ITOs. Additionally, FNS determined that all additional caseload requests were reasonable based on each state’s and ITO’s history of caseload usage and knowledge of program operations. Accordingly, each requesting state and ITO that utilized equal to or greater than 95 percent of its assigned caseload on an average monthly basis during FY 2021, the last quarter of FY 2021, or, under the circumstances outlined in the Additional Caseload Eligibility and COVID-19 section below, is receiving additional caseload for 2022. Thus, 81,537 additional caseload slots are being allocated in 2022.

Additional Caseload Eligibility and COVID-19

Per program regulations at 7 CFR 247.21(a)(2), CSFP state agencies must achieve a participation level which was equal to or greater than 95 percent of assigned caseload for the previous caseload cycle in order to be eligible for additional caseload. Eligibility is calculated based on the highest of (1) average monthly participation for the previous fiscal year; or (2) average monthly participation for the last quarter of the previous fiscal year.

During FY 2021, the continued COVID-19 pandemic led to CSFP participation drops which caused some states to be ineligible for additional caseload. Approximately three-fourths of state agencies which did not meet the 95 percent regulatory threshold submitted requests to FNS for additional caseload along with a justification explaining how the COVID-19 pandemic impacted their participation in FY 2021.

Section 301 of The Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act, 42 USC 5141) allows federal agencies to waive or modify administrative conditions for assistance during major disasters if so requested by the applicant state or local authorities. All 50 states, the District of Columbia, and four territories were issued major disaster declarations in response to the COVID-19 public health emergency.

FNS is using this authority to waive the 95 percent additional caseload eligibility threshold for these 39 state agencies and allowing them to receive additional caseload in 2022. These 39 state agencies are noted in the attached chart, Attachment A.

Tentative Caseload Assignments for New CSFP States and ITOs

In accordance with CSFP regulations, FNS assigns caseload, to the extent resources are available, in the following order: 1) To meet base caseload for currently participating states and ITOs, 2) to meet additional caseload requests of currently participating states and ITOs in amounts that FNS determines are needed and can be efficiently utilized, and 3) to each state agency and ITO requesting to begin participation in the program with an approved state plan.

As the amount of additional caseload available in 2022 is sufficient to fully meet all reasonable requests from currently participating states and ITOs, FNS is also allocating 300 caseload slots to the Mississippi Band of Choctaw Indians and 150 caseload slots to Winnebago Tribe of Nebraska. These are the only ITOs with approved state plans that are not currently participating in CSFP.

Caseload Use and Food Orders in 2022

Program regulations require that CSFP state agencies ensure that program participation levels do not exceed assigned caseload on an average monthly basis. In order to ensure sufficient resources are available to serve CSFP participants throughout the year, any states currently exceeding 2022 caseload assignments must work to reduce participation levels to reflect such assignments.

At the same time, states must attempt to fully use their 2022 caseload assignments. States that are receiving caseload increases should work to increase participation levels immediately. In order to efficiently utilize caseload, States must monitor participation carefully. Per CSFP regulations, caseload assignments in 2023 will depend on each state’s caseload use this year.

It is crucial that states manage caseload and USDA Foods in the most efficient manner possible. States are required to accurately track and maintain appropriate inventory levels at the state level. Regulations at 7 CFR Part 250 prohibit CSFP state level inventories from exceeding three months on-hand without approval from FNS.

FNS regional offices (ROs) closely monitor states’ year-to-date participation levels and food orders. FNS ROs will reduce food orders to ensure that states do not exceed their assigned caseloads or over-order USDA Foods.

Administrative Grant per Assigned Caseload Slot

The Agriculture and Consumer Protection Act of 1973 (PL 93-86), as amended, mandates an administrative grant per assigned caseload slot to be adjusted each fiscal year to reflect inflation The mandatory grant per assigned caseload slot for FY 2022 is $84.47.

The attached chart, Attachment A, displays final caseload assignments and administrative grants for each state. Administrative funds for use over the remainder of the fiscal year are subject to apportionment by the Office of Management and Budget. We will keep you informed regarding the availability of such funds.

CSFP state agencies should address questions to their FNS regional offices, which may in turn contact the Food Distribution Policy Branch.

Laura Castro
Director
Food Distribution Division

Attachment

• 2022 CSFP Tentative Caseload Worksheet (xlsx)

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¹ Since additional caseload was provided from the American Rescue Plan Act of 2021, which was signed into law on March 11, 2021, 7 CFR 247.21 applies for base caseload calculations using September-only participation data for 2022 caseload calculations.