COM 0384.000 2012-2014 - Laserfiche WebLink

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111OGPE U 0 40" j Mall Island's FM end Challenges A number of factors contribute to TFBI's continued ability to completely distribute food and serve all areas. Firstly,the County proposed a restrictive set of guidelines for COHEF-purchased foods. TFBI already follows a number of State and Federal regulations regarding the distribution of donated and USDA-purchased product. These regulations include frequent inspection of the food safety conditions of the sub-agencies based on the product they receive, collection of statistical and demographic data, and eligibility criteria for both recipient agencies and residents. The chief governing regulations in question are 7 CFR 250 and 7 CFR 251. These regulations were crafted over a number of years to give the correct balance of accountability and flexibility,as the Federal government does not intend to create restrictive paperwork requirements for needy homeless persons, those without ID, or those who do not necessarily have income verification readily available, such as in a natural disaster. Although TFBI believes the County's requests for information are reasonable,they do not align with the current,tested regulatory framework. As such,this difference creates duplicative paperwork that is burdensome to partner agencies. Although it is TFBI who is accountable under the grant, it is the partner agencies, in many cases,who directly service clients and ultimately must adhere not only to the current data collection schema, but also the responsibilities passed on through the COHEF funding. This has resulted in limited participation by agencies in the program. Of the over eighty(80)agencies currently participating in TFBI's various feeding programs, only seventeen(17)chose to participate,primarily because of the increased record-keeping burden. This underscores the effect that imposing additional burdens can have on the success of the program. Secondly,the County Council issued funding on a timeline convenient for the fiscal year,however incompatible with the storage of perishable food. TFBI is fully aware of governmental constraints on funding and the expedient execution of measures proposed in the approved mayoral budgets to avoid lapse. We are also aware of the difficulties in extending funds beyond biennia in which allotment occurs, and the internal controls necessary to adhere to regulation and Generally Accepted Accounting Principles. With this being said, TFBI would like to draw a distinction between salaries,equipment,capital improvement, and food. Salaries are drawn based on payroll records, and can be budgeted through any number of time periods with a minimum and maximum incurred liability. Equipment and capital improvements are depreciable assets which, once purchased,have useful lives, can most likely can be stored, and often do not exhibit time-sensitivity. Food cannot be budgeted for based on the same principles other governmental purchases are. Food is perishable,the demand can fluctuate immensely depending on not only population but external environmental factors,and must be stored in specific ways to ensure safety. TFBI is a food wholesaler, and like any wholesaler of perishable merchandise, success depends upon efficient rotation of food. Unlike other food wholesalers or grocery stores TFBI did not have control over how many agencies would be available to purchase commodities, The County guidelines mandated expedient expenditure of funds. TFBI, thus,had to estimate which types of product to purchase and extrapolate the demand for the product over a period of time. An accurate estimate must also include the variables of what type of product would be donated by both the public and the USDA, and the level of need of the community from month-to-month. TFBI also had to clear floor space for the immediate influx of a large quantity of food. 4