Exhibit_B_-_SNAP_Outreach_Partnership_Policy_and_Procedure_Manual.pdf

SNAP Outreach Partnership

Policy and Procedure Manual

October 2022 – September 2023

Table of Contents Table of Contents

I. How to Use This Manual II. About the SNAP Partnership

a. Role of DES

b. Role of Contractor

c. Role of Partners III. Community Partners

a. Who Can Partner?

b. Partnership Activities

Outreach Education Partner:

Self-Service Partner:

Full-Service Partner:

IV. Partnership Funding V. Activities

a. Allowable Activities

b. Reasonable and Necessary Activities VI. Financial Solvency VII. Accurate and Complete Reporting

a. Revised Reports

b. Tracking Time VIII. Consumer Surveys IX. Changes in Scope of Work X. Budget Amendments XI. Training and Technical Assistance XII. Required Trainings

b. Civil Rights Training

c. Monthly Partner Calls

d. SNAP Training Curriculum XIII. Materials

a. Types of Documents/Communications

b. USDA Funding Statement:

c. USDA SNAP Full Nondiscrimination Statement (English)

d. USDA SNAP Full Nondiscrimination Statement (Spanish)

D037999 Highlight

e. Short, Combined Funding and Nondiscrimination Statement

f. The “And Justice for All” Poster XIV. Site Visits and Monitoring XV. Record Keeping XVI. Continuing Partnership and Partnership Referrals XVII. Contractor Compliance and Records XVIII. Conflict Resolution

a. Conflict between Partner and Contractor

b. Conflict between Partner and DES

c. Conflict between Partner and DES Local Office

d. Conflict between Partner and Separate State Agency regarding SNAP XIX. Contact Information

b. Department of Economic Security/Hunger Relief Program Appendix A. USDA SNAP Outreach State Plan Guidance - Excerpt on

Allowable/Unallowable Activities Appendix B. Sample Outreach Invoice Tracker Appendix C. Sample Monthly Invoice & Activity Tracker Appendix C1. Sample Monthly Invoice & Activity Tracker Appendix E. Memorandum of Understanding Appendix G. Federal Poverty Levels and Important Reminders

I. How to Use This Manual

This Policy and Procedure Manual (PPM) is intended for use by community and faith-based organizations participating in the Supplemental Nutrition Assistance Program (SNAP) Outreach Partnership. The purpose of this manual is to serve as a guide to federal requirements pertaining to SNAP Outreach as well as to outline discretionary policy and procedures of the Department of Economic Security Coordinated Hunger Relief Program (DES/HRP) and Contractor for program implementation by partner organizations.

This manual should be considered a living document, meaning the manual contains current SNAP Outreach program policies and procedures required by the Federal government, DES/ HRP and Contractor. Clarification and/or policies and procedures may be added as situations in the field prompt the need for further interpretation or greater program structure or if changes in Federal regulations occur.

It is the responsibility of each SNAP Community Partner (SCP) to complete the following:

• Read this manual carefully and apply the policies and procedures herein;

• Ensure that staff have access to the manual for reference;

• Stay current with the subsequent policy and information notices issued after the distribution of this manual and adhere to the policies and procedures therein; and

• Contact Contractor's Grants Program Manager when further clarification is needed.

II. About the SNAP Partnership

The Supplemental Nutrition Assistance Program (SNAP) is the cornerstone of the nation’s nutrition safety net. It offers nutrition assistance to millions of eligible, low-income individuals and families and provides economic benefits to communities. The Food and Nutrition Service (FNS) works with State agencies, nutrition educators, and neighborhood and faith-based organizations to ensure that those eligible for nutrition assistance can make informed decisions about applying for the program and can access benefits.

The United States Department of Agriculture (USDA) allows State SNAP agencies to receive reimbursement for approximately 50 percent of their administrative costs for outreach to low-income people. Each year, DES writes a SNAP Access and Information Plan for the USDA detailing how information about SNAP will be conveyed to communities in need and the State’s planned efforts for increased SNAP accessibility. DES contracts out the outreach portion of the Access and Information Plan to a community-based organization with statewide reach. DES is working with Contractor to expand and improve this model in order to engage community and faith-based partners across Arizona.

Community and faith-based organizations may serve as contractors (in this case, Contractor) under the State Access and Information Plan, or the State may conduct the work “in-house.” In 2010, DES broadened the State Outreach Plan to allow Contractor to engage Partners throughout the state and assist those Partners with training, support, and the facilitation of drawdown of Federal funds from the USDA to support their work with SNAP outreach and application assistance. See Section II(a) and II(b) for more information on the roles of DES and Contractor.

Each year SNAP helps millions of eligible households supplement their grocery budgets. It is an essential program that provides nutrition assistance for individuals and families with low incomes and provides economic benefits to communities. SNAP outreach provides information and application assistance to anyone who may be eligible for SNAP.

Some of the most common reasons for not participating in SNAP are due to: myths or misunderstandings about SNAP; stigma associated with SNAP; the belief it’s too time consuming to apply for benefits; no desire to accept government assistance; language barriers; the inability to take time off work to apply; or limited access to transportation. The goals of SNAP outreach are: to help people make an informed decision about whether to apply for the program, and to increase participation by eligible individuals and families (www.fns.usda.gov).

SCPs represent a diverse group of community and faith-based organizations throughout Arizona. Partners range from agencies run primarily by volunteers serving a very small area, in terms of both geography and population, to large agencies reaching hundreds of thousands of people in several counties in any given year. One of the greatest strengths of the SNAP Partnership is the flexibility to provide support to all types of agencies.

For more information from the USDA regarding Community Partners and SNAP, please visit the Tool Kit at https://www.fns.usda.gov/search?keywords=outreach+toolkit.

a. Role of DES

DES Mission: The Arizona Department of Economic Security makes Arizona stronger by helping Arizonans reach their potential through temporary assistance for those in need, and care for the vulnerable.

DES Vision: All Arizonans who qualify receive timely DES services and achieve their potential.

DES is the state agency responsible for administering SNAP throughout the state of Arizona. In addition to SNAP, DES sites administer other state programs and hundreds of thousands of individuals are served each year.

Related to the Partnership Application Process, DES is responsible for:

• Drafting and submitting the SNAP Access and Information Plan to USDA each year;

• Providing a mechanism for funding a community-based organization (in this case, Contractor) to administer funds and support Partners;

• Overseeing the management of the outreach contract currently held by Contractor;

• Supporting Contractor with training and outreach events related to recruitment of Partners; and Review of Contractor's recommendation of Partnership application documents and final approval of all SNAP Partnership applications for submission to the USDA.

Related to the training and support of Contractor and Partners, DES is responsible for:

• Providing oversight to Contractor in developing accurate training materials and verifying policy information;

• Providing assistance with training and support of Partners, including, but not limited to, SNAP eligibility training, civil rights training (Conducted Solely by DES), site visits, monitoring, and collaboration between Partners and local DES FAA offices; and

Providing annual approval of Arizona SNAP Outreach Policy and Procedures that support the Partnership and are included in this Policy and Procedure Manual.

Related to the monthly reporting and reimbursements for Contractor and Partners, DES is responsible for:

• Providing ongoing oversight and approval of all SNAP Partner monthly reports and invoices;

• Submitting reimbursement requests to the USDA monthly;

• Providing Contractor with reimbursement for approved invoices;

• Providing approval to budget amendment requests; and

• DES may, at any time, perform an audit of programs and/or fiscal records of any organization supported by this partnership.

b. Role of Contractor

Mission:

Vision:

• Strengthen, represent and promote Arizona’s Community Action Agencies;

• Encourage and enhance interagency cooperation;

• Represent low-income concerns;

• Assure maximum feasible participation of low-income people;

• Develop partnerships with the public and private sectors; and

• Engage in research and education in order to develop solutions to poverty.

Contractor is the voice for poverty in Arizona. For the future of the state, we advocate for fair polices, support Community Action Agencies, and collaborate with local businesses, elected officials and nonprofit organizations to ignite lasting change.

Contractor serves as the Partnership lead for community and faith-based agencies statewide who conduct SNAP outreach, prescreening, application assistance and more.

Related to the Partnership Application Process, Contractor is responsible for:

• Conducting in-service outreach and education to community and faith-based organizations statewide about the Partnership model;

• Creating and distributing application documents;

• Assisting community and faith-based organizations with the application process, providing guidance and support, and ensuring completeness of Partnership applications for submission to DES;

• Conducting initial review and approval of all SNAP Partnership applications and requests for correction or clarification from applicants;

• Collaborating with DES to review all Partnership applications for completeness and accuracy;

• Notifying community and faith-based organization applicants when SNAP Partnership applications are approved, denied, or amended; and

• Notifying Partners when budget amendments, changes in scope of work, materials, or other changes requested by Partners are approved, denied, or amended.

Related to the training and support of Partners, Contractor is responsible for:

• Creating accurate training materials tailored when possible to the specific needs of Partners and the communities they serve;

• Conducting or coordinating training and support of Partners, including but not limited to: SNAP eligibility training, Arizona Self Help (ASH) prescreening training, Health-e- Arizona Plus online application assistance training, outreach training, and any other trainings to support and promote Partner success;

• Providing ongoing monthly support through SNAP Partner Calls;

• Providing direct support and oversight during site visits with Partners; and

• Providing regional networking opportunities for Partners to gather and share best practices and discuss barriers.

Related to the monthly reporting and reimbursements for Contractor and Partners, Contractor is responsible for:

• Providing Partners with reporting documents;

• Helping to ensure timely submission of monthly reports by Partners;

• Providing ongoing oversight and approval of all SNAP Partner monthly reports and invoices;

• Submitting reimbursement requests to DES monthly;

• Providing Partners with reimbursement for approved invoices;

• Monitoring expenditures by Partners and notifying Partners of any concerns from

Contractor and/or DES related to expenditure patterns;

• Providing oversight of budget amendment requests and submitting to DES for approval;

and

• Contractor may, at any time, perform an audit of program and/or fiscal records of any Partner.

c. Role of Partners

Related to the Partnership Application Process, Partners are responsible for:

• Attending trainings provided by Contractor and DES to gather information about timely submission of a completed Partnership application in the correct formats as specified by Contractor; retaining updated/approved partnership documents.

• Timely response to requests from Contractor for corrections, additions, or clarifications to the application submitted; and

• Providing accurate information.

• Familiarity of the different entities administering SNAP services (DES/DBME, HEAplus/AHCCCS) vs SNAP-Outreach (DES HRP, Contractor), and respective roles.

Related to trainings and support, Partners are responsible for:

• Attending mandatory trainings. Partners who are unable to attend mandatory trainings provided by Contractor or DES must notify Contractor to schedule alternative trainings;

• Participating and actively engaging in mandatory monthly SNAP Partner Calls;

• Participating in site visits conducted by Contractor;

• Participating in regional networking opportunities for Partners, including, but not limited to, at least one convening in each region to bring together local Partners;

• Notifying Contractor if concerns arise related to the work being done by Partners and request assistance if needed; and

• Participating and supporting customer satisfaction by:

o Completing Partner Surveys at the completion of trainings and calls (See Appendix A).

o Distributing and collecting SNAP customer surveys (See Appendix B). Surveys are one of the means by which DES and Contractor measure partner effectiveness, identify training needs, and opportunities for improved policies.

Related to the monthly reporting and reimbursements, Partners are responsible for:

Accurately submitting both monthly Invoice and Activity Reports, no later than the 10th of each month to ensure timely processing and reimbursement;

• Submitting invoices every month whether funds are expended for the partnership or not (include a $0 invoice when there is no activity during the month of service);

• Submitting receipts with invoices for all theft-sensitive electronic supply purchases (e.g. laptops, printers, scanners, etc.);

• Monitoring agency expenditures and ensuring that agency expenses do not exceed allotted budget (see Appendix D for monitoring expenditures);

• Submitting documentation to Contractor for budget amendments; and

• Providing fiscal records to Contractor, if requested.

III. Community Partners

DES and Contractor recognize the need for trusted community and faith-based organizations to reach individuals and families in need within the community. Partnership allows community and faith-based organizations to drawdown Federal funds to help support their anti-hunger work and provides an avenue for members of the community to seek information and assistance at trusted community sites.

Note: Partners must comply with periodic satisfaction surveys as directed by Contractor and/or DES

a. Who Can Partner?

The Partnership is open to government and tax-exempt, nonprofit community and faith-based organizations throughout the State of Arizona. In general, for-profit organizations and the for-profit face of a hybrid organization (e.g., a for-profit medical insurance company may open a subsidiary nonprofit agency to participate in the Partnership or other programs that for-profit agencies are generally not authorized to join or operate) are prohibited from becoming members of the Partnership.

b. Partnership Activities The level of Contractor partner activity may vary by organization. Partner activity may include some or all activities. Partners will engage in outreach activity, facilitate self-service activity and/ or provide full-service activity. Partner activity levels outlined below represent a breakdown of the activities most commonly conducted by SNAP Partners. During the Partnership application process, Partner agencies will indicate the activities in which they will participate during the contract year.

Partnerships are broken down into Outreach, Self-Service, and Full-Service. Applicants must participate in outreach but are not required to participate in all activities included under self-service or full-service activity levels, as they may choose self- or full-service activities as they wish.

Outreach Education Partner:

• Provide information and distribution of materials to clients.

• Attend/host outreach events (or meetings) in the community to provide information about SNAP eligibility.

• Provide information about the application process and required documents to clients and at outreach locations.

Self-Service Partner:

• Provide access to a computer to prescreen through www.arizonaselfhelp.org.

• Provide access to a computer to apply online through www.healthearizonaplus.gov.

• Provide access to equipment for clients to copy, print, scan, or fax application documents.

• Provide paper applications as requested by the applicant.

• Provide access to a telephone to call DES

Full-Service Partner:

• Provide assistance with prescreening through www.arizonaselfhelp.org.

• Provide assistance with applying online through www.healthearizonaplus.gov.

• Provide assistance in copying, printing, scanning and faxing documents for applicants.

• Assist clients with completing paper applications as requested.

• Assist applicants and/or recipients in tracking their case via MyFamilyBenefits website.

• Assist clients and applicants with contacting DES via telephone.

In addition to providing the services listed here, some of our Partners choose to engage in additional activities related to SNAP outreach and assistance. The USDA provides guidance on

• The Partner receives 40 cents (40% of the expenditure).

• The other 60 cents are not reimbursed (60% of the expenditure).

which activities are considered allowable through this funding (see Appendix A). All activities not provided within the Partnership application will be reviewed by Contractor and DES to ensure they comply with USDA guidance. Final approval of all activities is at the discretion of the USDA.

IV. Partnership Funding

Cost-reimbursement funding is a resource available to Partners for activities that support SNAP outreach and application assistance.

Cost-Reimbursement: The SNAP Partnership is funded through a cost-reimbursement model from the USDA. Funding is based on expenditures of allowable, reasonable and necessary activities. Partners must be able to support 100% of their SNAP outreach and access program costs up front. Each month, Partners must submit to Contractor an Activity Report and Invoice in order to request reimbursement for activities completed in the prior month. Once approved by Contractor and DES, a reimbursement check will be issued from Contractor to the Partner directly. Contractor and DES make every effort to process reports and reimbursements in a timely manner and are generally able to provide reimbursement to Partners within 8-10 weeks of the invoice submission.

Note: Utilizing the Cost-Reimbursement resource is not a requirement for participation in the SNAP Partnership. Organizations not requesting reimbursement are only required to submit the Contractor Activity Report each month; the invoice is not required.

For every $1 a Partner spends on allowable activities:

Partners must be able to support 100% of their program costs up front. Reimbursement funding availability is determined at the Federal level and subject to change at the discretion of cognizant Federal administrative, oversight or legislative authorities.

When completing the Partnership application, Partners must provide a staffing budget and a program budget for the full program costs (100%). Reimbursement will be 40% of total allowable costs expended. Volunteer time is not a reimbursable cost, but all the expenses associated with volunteers are (e.g. space, equipment, etc.) Federal funds may NOT be used to drawdown a reimbursement for this Partnership (i.e. “double-dipping”).

V. Activities

a. Allowable Activities

Allowable activities are those activities permitted by the USDA under SNAP Outreach.

However, volunteer time is not a reimbursable cost, but the expenses associated with supporting volunteer activities are potentially eligible for reimbursement. All Partners are responsible for abiding by the guidelines for allowable activities provided by the USDA. Partner applications should include only allowable activities, and each month’s Activity Report and Invoice should reflect these same activities. If there are questions about whether an activity is allowable with these funds, please refer to the USDA guidelines or contact Contractor.

For examples of allowable activities that your agency may choose to utilize, please see the USDA SNAP State Outreach Plan Guidance, Section B: Policy- (Pages 15-20).

Monthly reports and invoices should reflect activity and expenditures related to allowable activities included on the Partnership application only. All monthly activity reports and invoices are subject to approval by Contractor and DES, and any activity that is not allowable cannot be reimbursed under this project.

b. Reasonable and Necessary Activities

All costs must also be reasonable and necessary. All costs reimbursed by USDA must be valid obligations for the organization’s SNAP Outreach activities. Reasonable costs are those that provide a program benefit generally commensurate with the amount incurred. Necessary costs are those that are needed to carry out essential functions of SNAP outreach and/or application assistance. See the link in Appendix C for a full text of the USDA SNAP State Outreach Plan Guidance.

VI. Financial Solvency

It is the responsibility of the Partner to ensure that the organization can cover the full costs of personnel and activities related to this project. This Partnership is based on reimbursement after activities are completed. Partner organizations must be able to cover 100% of the costs of completing the work while awaiting the 40% reimbursement, which takes approximately 8-10 weeks to receive. Partners must also agree to accept sole responsibility for any costs incurred that are not in compliance with those agreed to in the Partnership MOU (see Appendix H), application, or are disallowed by DES or the USDA.

Contractor will provide each Partner with an individual SNAP Outreach Invoice Tracking worksheet at the beginning of each new fiscal year. Partners are expected to keep an accurate account of their available funds. Each month after a Partner enters their expenses, the Invoice Tracking worksheet will inform the Partner what percentage of their allotted budget has been used. This worksheet is simply a tool for Partners to keep track of their budgets and does not need to be turned in to Contractor.

VII. Accurate and Complete Reporting

Accurate and complete reporting by the 10th day of each and every month will help ensure timely reimbursement.

It is the Partner’s responsibility to ensure accurate and complete monthly Activity Reports and Invoices are submitted and received by Contractor no later than the 10th of each month for the prior month’s outreach activity. Activity Reports and Invoices are to report the prior month’s activity. For example, October’s Activity Report and Invoice will be due on November 10th.

In months when the 10th falls on a weekend or holiday, reports are due by the next business day following the 10th. On the 20th of each month, Contractor submits aggregate information to DES of all Activity Reports and Invoices received. Contractor and DES have the right to request additional information regarding invoices at any time.

If the partner organization knows or anticipates the reporting deadline will be missed, then the partner must notify Contractor as soon as possible prior to reports being due.

In months when a partner does not complete any activity under this Partnership or does not incur any expenses related to the Partnership, the partner must still submit an Invoice showing no expenses ($0) were incurred for the month. An Activity Report is not required in this situation.

Complete and Accurate Reporting requires:

• Activity Reports and Invoices must be received by Contractor no later than the 10th of month

• Submitting an Invoice and Activity Report (if applicable) every month

• Submitting an Invoice even when no expenses related to the Partnership are incurred when attending conferences and trainings outside of those provided by Contractor or DES, partners must submit the agenda prior to requesting reimbursement.

• Travel, lodging, and registration fees are reimbursable when the subject matter directly supports SNAP eligibility.

Reporting of time and effort, relevant to SNAP activity, is required for all paid staff (full and part time/hourly and salaried) and volunteers supported by the outreach plan. Time records are used to calculate the charges, including salaries and benefits, for time spent on allowable activities.

Sample monthly reports can be found in Appendix E.

IMPORTANT: All reports must be submitted in their original format. PDF copies of the report may be maintained for your records; however, PDF copies are not acceptable formats for submitting reports to Contractor. Invoices and amendments received more than 90 days after the end of the month of activity will impact the opportunity to receive reimbursement.

a. Revised Reports

When an invoice needs to be corrected because of incorrect billing for a prior month, resubmit the invoice indicating the service month affected and that it is a SUPPLEMENTAL invoice.

Include a clear explanation regarding the reason for the correction and the amount being corrected in the designated area on the invoice. Amended invoices received more than 90 days after the end of the month of activity will impact the opportunity to receive a corrected reimbursement for the amended month.

When an Activity Report needs to be corrected, resubmit the report indicating the service month affected and that it is a SUPPLEMENTAL invoice. Please submit any revised Activity Reports or Invoices to the Contractor Finance Specialist.

In the event of overbilling, Partners must notify Contractor of the overbilled amount and return a check to Contractor within 30 days.

b. Tracking Time

The administrative office that converts the time and effort records into dollars charged must maintain accounting records that substantiate the charges. These costs must relate to the total accounting documentation maintained by the organization that is asserting the claim.

Appendix I provides an example form to track time and activity. Partners may create their own form or process, but it must contain the elements as noted on the form. The time tracker does not need to be submitted to Contractor or DES with monthly reports. The documents must be maintained and readily available upon request of Contractor and DES (see Compliance and Records, section XVI).

VIII. Consumer Surveys

Contractor developed consumer surveys that Partners should make available to consumers who visit the organization for SNAP assistance. These surveys are designed to help Partners, Contractor, and DES determine additional successes or barriers indicated by the consumer.

Surveys should be confidential. Contractor recommends offering surveys to consumers after service is provided and allowing the consumer privacy to complete the survey and to return it to the Partner agency confidentially.

Surveys are available in paper and electronic formats.

IMPORTANT: Contractor requires that partners complete the survey twice every year for 2 weeks at the end of January and 2 weeks at the end of July.

IX. Changes in Scope of Work

Organizations are required to submit a Scope of Work with their application, which includes a plan of allowable activities in which the Partner will participate during the contract year.

Changes made to this Scope of Work must be submitted to Contractor in writing for approval.

When additional funding is needed to support changes, the Partner must also send Contractor an amended line-item budget, budget narrative, and staffing detail, if required.

X. Budget Amendments

DES will notify Contractor about partners’ ability to amend their budgets during the course of the fiscal year; if applicable, this would occur in a single group submission.

In cases permitted by DES, partners may request an amendment to the budget as a whole or to specific line items within the budget during the budget year. Budget amendments are necessary when Partners desire to change the amount available in a specific line item, shift money from one-line item to another, or modify the overall budget by changing multiple line items. Amendment requests must be made in advance of the expenditures in question.

To request a budget amendment, Partners must submit a revised program line-item budget and budget narrative with all proposed changes (reductions, increases or line-item shifts) made in red font. The Partner should use the budget narrative to explain clearly the need for the budget amendment to Contractor. Once Contractor has reviewed and approved the request, the amendment request will be reviewed by DES for final approval. A notice of decision will be sent via email after the review process is completed by Contractor and DES.

If the amendment request is approved, a revised program line-item budget and budget narrative will be attached to the email.

Contractor is authorized to process and approve SCP budget amendments (i.e.

reduction or line- item shifting) received during the fiscal year provided that:

• The amendment would not result in an overall increase to the SCPs total program budget;

• The amendment does not request funding for unreasonable, unallowable, or unnecessary outreach activities;

• The amendment does not request new funding or funding under any line to be shifted to the “Equipment and Capital Expenses” line item;

• The amendment does not result in an SCP staff member being approved for greater than 50% SNAP FTE if the staff member is not already approved for greater than 50% FTE in the SCP’s current, approved budget narrative and staffing budget for the relevant FFY; and

• The amendment does not conflict with any Federal, State or program rules, requirements or laws.

The DES/HRP is made aware of the new SCP budget as soon as possible but no later than 10 workdays after the new budget is approved. Contractor will send an updated Outreach Invoice Tracker and brief summary of the changes made to DES to inform them of the amendment. Supporting documentation must be provided and reviewed prior to approving the amendment. For example, a shift of $2,500 from the Supplies line to the Long-Distance Travel line would require the same supporting documentation as if the Long Distance Travel funding had been requested in the SCP’s original Partnership application.

IMPORTANT: Amendment requests may take several weeks to process and approve. The Partner must continue to work from the original budget. Expenses outside the scope of the original budget are not eligible for reimbursement prior to approval.

For example, Partner XYZ’s telephone company notifies Partner XYZ in March that their rates will increase in June. If Partner XYZ waits to submit an amendment in June and is not approved until August, Partner XYZ must continue to invoice on their original budget until August. In August, Partner XYZ will be able to invoice on their new approved budget. Amendments are not applied retroactively.

XI. Training and Technical Assistance

Training and Technical Assistance will be provided to Partners by Contractor, DES, and any other qualified parties throughout the contract year. At the start of the contract year, Contractor will host a Partner Orientation training to cover the basics of the Partnership as provided in this Policy and Procedure Manual. Additional training and technical assistance will be made available throughout the year and can be requested by the Partner at any time. Contractor recommends that all Partner staff and volunteers completing work under this Partnership utilize trainings available early in the contract year and on an ongoing basis as needed in order to provide high quality, knowledgeable services within communities.

XII. Required Trainings

a. Contractor Policy and Procedure Manual (Partnership Orientation)

It is the responsibility of the organization to attend the mandatory procedure manual training and train newly appointed/hired staff or request additional support from Contractor.

b. Civil Rights Training

DES will conduct a Civil Rights training at a minimum of twice a year. Civil Rights and program training are mandatory for frontline staff and volunteers who interact with program applications or participants and supervisors of frontline staff. At least one staff member from each SCP must attend a Civil Rights training presented by DES. The SCP staff member may then train all other required staff and volunteers.

c. Monthly Partner Calls

Contractor and DES co-host mandatory Monthly Partner Calls which consist of a conference call and webinar. The schedule for these calls will be made available in advance. Calls generally last for 60 minutes. An agenda is provided in advance of each call, and requests to cover specific topics are always welcome from Partners; these topic requests should be directed to Contractor. Partner Calls provide an opportunity for networking, education, policy updates from DES and discussion of related issues.

IMPORTANT: Partners are required to have at least one staff member or volunteer attend each monthly call. The staff member should share the slides and link to the recording of the SNAP call with everyone in their agency. However, there is no limit to the number of individuals from any given agency who may attend.

d. SNAP Training Curriculum (a.k.a SNAP Module Training)

Contractor offers online SNAP Training modules. All frontline staff must participate in this training. Additionally, many Partners have extensive experience with providing training and technical assistance related to outreach and application assistance within communities.

Therefore, Contractor may request the expertise of seasoned Partners to provide support and education to other Partners wishing to enhance or expand their outreach efforts.

Agencies interested in providing support, training, or mentoring to Partners are invited to notify Contractor of their interest, and Contractor will make connections between Partners for this kind of support.

XIII. Materials

Partners may order materials provided free of charge from the USDA, DES, and Contractor.

Materials from the USDA can be ordered here: https://pueblo.gpo.gov/SNAP/SNAPPubs.php.

These agencies create and distribute materials, often in multiple languages, so that Partners do not have to undertake the work and expense of creating and printing documents.

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Partners may also opt to create original materials. Documents prepared by organizations using program funding for external release, in print or other media, or via the internet, must undergo appropriate review and approval prior to release.

Documents and Communications are defined as one time, periodic or occasional information distribution that provides factual information to the public or target audience to increase enrollment in SNAP among potentially eligible populations and convey a specific message to a select target audience about SNAP.

Examples:

• Brochures

• Fact sheets

• Newsletters

• Press release or other press materials

Press releases announcing events sponsored by Partners shall not require prior approval unless information is included about the Partnership described herein or SNAP eligibility or rules. Social networking, such as Facebook, Twitter and blog posts, require prior approval in cases where the Partnership created herein or information regarding SNAP eligibility or programmatic rules is included. Contractor shall be notified upon release of any press release or social media piece released.

Materials containing information about SNAP require an appropriate USDA funding statement and USDA nondiscrimination statement in accordance with State and Federal agency specifications. Partners will submit materials to the Grants Program Manager for feedback and approval prior to printing. After Contractor's approval, materials will be sent to DES for final review and approval. Partners will then be notified upon completion of DES’ review; reviews may take up to ten working days.

b. USDA Funding Statement:

“This work is/was supported by the USDA National Institute of Food and Agriculture.”

c. USDA SNAP Full Nondiscrimination Statement (English)

In accordance with federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, this institution is prohibited from discriminating on the basis of race, color, national origin, sex (including gender identity and sexual orientation), religious creed, disability, age, political beliefs, or reprisal or retaliation for prior civil rights activity.

IMPORTANT: Documents prepared by Partners must receive the necessary departmental approvals from Contractor and DES prior to publishing or distribution. Reviews may take up to ten (10) working days.

a. Types of Documents/Communications

Program information may be made available in languages other than English. Persons with disabilities who require alternative means of communication to obtain program information (e.g., Braille, large print, audiotape, American Sign Language), should contact the agency (state or local) where they applied for benefits. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339.

To file a program discrimination complaint, a Complainant should complete a Form AD-3027, USDA Program Discrimination Complaint Form which can be obtained online at: https:// www.usda.gov/sites/default/files/documents/USDA-OASCR%20P-Complaint- Form-0508-0002-508-11-28-17Fax2Mail.pdf, from any USDA office, by calling (833) 620-1071, or by writing a letter addressed to USDA. The letter must contain the complainant’s name, address, telephone number, and a written description of the alleged discriminatory action in sufficient detail to inform the Assistant Secretary for Civil Rights (ASCR) about the nature and date of an alleged civil rights violation. The completed AD-3027 form or letter must be submitted to:

1. Mail: Food and Nutrition Service, USDA 1320 Braddock Place, Room 334 Alexandria, VA 22314; or

2. Fax: (833) 256-1665 or (202) 690-7442; or

3. Email: FNSCIVILRIGHTSCOMPLAINTS@usda.gov

This institution is an equal opportunity provider.

d. USDA SNAP Full Nondiscrimination Statement (Spanish)

De acuerdo con la ley federal de derechos civiles y las normas y políticas de derechos civiles del Departamento de Agricultura de los Estados Unidos (USDA), esta entidad está prohibida de discriminar por motivos de raza, color, origen nacional, sexo (incluyendo identidad de género y orientación sexual), credo religioso, discapacidad, edad, creencias políticas, o represalia o retorsión por actividades previas de derechos civiles.

La información sobre el programa puede estar disponible en otros idiomas que no sean el inglés. Personas con discapacidad que requieran medios alternos de comunicación para obtener información sobre el programa (por ejemplo, Braille, letra grande, cinta de audio, lenguaje de señas americano), debe ponerse en contacto con la agencia (estatal o local) donde solicitaron los beneficios. Las personas sordas, con dificultades auditivas o con discapacidades del habla pueden comunicarse con el USDA a través del Servicio Federal de Retransmisión al (800) 877- 8339.

Para presentar una queja por discriminación en el programa, el reclamante debe llenar un formulario AD-3027, formulario de queja por discriminación en el programa del USDA que puede obtenerse en línea en: https://www.fns.usda.gov/sites/default/files/resource-files/ usdaprogram-discrimination-complaint-form-spanish.pdf, en cualquier oficina del USDA, llamando al (833) 620-1071, o escribiendo una carta dirigida al USDA. La carta debe contener el nombre del demandante, la dirección, el número de teléfono y una descripción escrita de la acción discriminatoria alegada con suficiente detalle para informar al Subsecretario de Derechos Civiles (ASCR) sobre la naturaleza y fecha de una presunta violación de derechos civiles. El formulario AD-3027 completado o la carta debe presentarse por:

1. Correo: Food and Nutrition Service, USDA 1320 Braddock Place, Room 334 Alexandria, VA 22314; o

2. Fax: (833)-256-1665 , o (202)-690-7442; o

3. Correo electrónico: FNSCIVILRIGHTSCOMPLAINTS@usda.gov

Esta institución es un proveedor que ofrece igualdad de oportunidades.

e. Short, Combined Funding and Nondiscrimination Statement

If space constraints on the material exist, the following abbreviated version of the funding and nondiscrimination statement can be used in print size no smaller than the text in the majority of the material:

English: “This institution is an equal opportunity provider.

Spanish: “Esta institución es un empleador y proveedor de oportunidades equitativas.”

1. Program Availability: Each State agency, local agency, or other sub-recipient that distributes program benefits and services must take specific action to inform applicants, participants and potentially eligible persons of their program rights and responsibilities and the steps necessary for participation.

2. Complaint Information: Applicants and participants must be advised at the service delivery point of their right to file a complaint, how to file a complaint, and the complaint procedures.

3. Nondiscrimination Statement: All information materials and sources, including websites, used by FNS, State agencies, local agencies, or other sub-recipients to inform the public about FNS programs must contain a nondiscrimination statement. It is not required that the nondiscrimination statement be included on every page of the program information

IMPORTANT: All materials must be pre-approved by Contractor and DES prior to print.

f. The “And Justice for All” Poster

The “And Justice for All” Poster 475-B should be visible at all sites. This poster is an approved method of public notification by the Food and Nutrition Service (FNS). The purpose of this system is to inform applicants, participants, and potentially eligible persons of program availability, program rights and responsibilities, the USDA policy of nondiscrimination, and the procedure for filing a complaint of program discrimination (see FNS Instruction 113-1, Civil Rights Compliance and Enforcement – Nutrition Programs and Activities, IX Public Notification).

Basic Elements of Public Notification: The public notification system must include the following three basic elements:

or website. At a minimum, the nondiscrimination statement, or a link to it, must be included on the home page of the program information site.

If the material is too small to permit the full statement to be included, the material will, at a minimum, include the short, combined funding and nondiscrimination statement in print size no smaller than the majority of the text in the body of the material.

Posters are available through USDA, Contractor, or DES. Posters must be displayed in full color and full size; therefore, a copy of the online PDF is not an acceptable alternative to the full color, full size poster.

XIV. Site Visits and Monitoring

Contractor may complete a site visit to each Partner site. Site visits are conducted for the purpose of identifying the work being done by each Partner, helping to problem-solve any issues or concerns, identifying best and promising practices happening at Partner sites, and addressing any ongoing or one-time needs for support and/or training.

Partners should be prepared to review expenditures of Federal pass-through funds and provide supporting documentation outlined in the Partner Site Visit Form. Appendix F is Contractor's Partner Site Visit Form for Partners to review ahead of time.

Site visits are intended to be an interactive opportunity for Contractor and Partner staff/ volunteers to share information, resources and identify ways to strengthen partnerships.

Partners will be asked to make 1-2 hours available for a site visit and include activities such as a site tour in the visit. While we are interested in seeing Partners “in action,” it is not the intent to interfere with or compromise the trust or confidentiality of clients being served onsite. Contractor will contact each Partner to arrange a site visit and specifics of the visit can be addressed at that time.

DES/HRP will conduct site monitoring and desktop reviews ensuring SCPs are utilizing approved materials, providing approved and allowable activities for reimbursement, and recording percentage of time spent appropriately. The Department will utilize a Risk Assessment Indicator Tool to determine which SCP will be reviewed. A minimum of five organizations will be selected to participate in the DES on-site review process during each Partnership year.

XV. Record Keeping

It is the responsibility of the Partner to maintain complete records of work performed as well as time records for staff and volunteers. At the discretion of Contractor, DES, or USDA, a review of records may be requested at any time. Please refer to IRS regulations (http://www.irs.gov/pub/irs-pdf/p4221pc.pdf) for detailed guidance on which records must be maintained for your organization and the time period each must be kept. Contractor will keep a copy of all records related to the Partner MOU, Partnership agreement, monthly reports, and reimbursements as required of Contractor by law. Partners should maintain these documents in their records.

DES/HRP maintains Partnership records for five years after the close of the relevant fiscal year or date of the most recent activity on the records, whichever is later. Partners must maintain all financial and other records related to the Partnership for the same five-year period used by DES/HRP and Contractor. Partners are required to complete a confidentiality agreement with any paid staff or volunteers who may have access to confidential or sensitive information provided by clients. If Partners do not have a confidentiality agreement already in place, a sample confidentiality agreement is provided in Appendix G.

IMPORTANT: In the event that a request is made for access to client information or records from any agency or entity, please be aware of confidentiality rules in place. The Partner MOU, Section IV, subsection 1.4 provides detailed information on this topic. Requests for release of records or information related to clients served within a Partner’s organization should be elevated to DES.

XVI. Continuing Partnership and Partnership Referrals

Partners that wish to continue partnership with Contractor, DES, and USDA must submit a new application in March prior to the beginning of the new Federal fiscal year. Additionally, if Partners know of other organizations that would benefit from partnering with Contractor, DES, and USDA, please encourage the potential partner to email the Grants Program Manager for information and direction regarding the Partnership.

XVII. Contractor Compliance and Records

Contractor will not request confidential client records from Partners and will not accept the submission of confidential information from Partners for any reason. Any confidential information conveyed to Contractor will be sent back to the Partner. In the case of electronic information, the information will be deleted after being sent back. In the case of paper documentation, items will be submitted to DES if action is needed and shredded by Contractor agrees to act in compliance with all agreements set forth in the Partnership MOU.

Contractor will maintain records related to Partnership agreements, monthly reports, invoices, reimbursement requests submitted to DES, and reimbursements made to Partners according to the laws governing such records.

DES/HRP maintains Partnership records for five years after the close of the relevant fiscal year or date of the most recent activity on the records, whichever is later.

Contractor may respond to records requests from the USDA or DES and share information received from Partners with these entities at any time. None of the information stored by Contractor can be considered confidential. Financial information for Partners will not be shared by Contractor on our website or by other means unless in aggregate form. Individual Partner financial information will only be shared internally to Contractor staff, Board of Directors, DES, and the USDA. Any other requests for financial information may be subject to approval by Contractor Board of Directors and/or DES.

XVIII. Conflict Resolution

In the event a conflict arises between any of the parties involved in this Partnership, it is the goal of Contractor to address such conflict in a professional and courteous manner. As such, Contractor provides the following steps for conflict resolution.

a. Conflict between Partner and Contractor

Notify Contractor, verbally or in writing, of the concern. Notifying Contractor's designated staff should always be the first step in addressing concerns. When the Partner is not comfortable notifying Contractor directly or is dissatisfied with Contractor's response, notify DES’ Hunger Relief Program Specialist in writing of the situation. Information shared with DES/HRP may be made available to Contractor in the process of attempting to resolve the issue.

In the event that neither Contractor nor DES is able to address the concern to the satisfaction of the Partner, a face-to-face meeting among the three parties (Partner, Contractor, and DES) may be necessary.

In the event that a face-to-face meeting is not able to address concerns, Partners…