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some of the other federally-funded programs, e.g. the Summer Food Program. Therefore, unrelenting efforts must continue to assure that all of the poor who are eligible and who wish to participate in these programs are given an opportunity to do so. CFNP grantees need to advocate for the establishment of new and the expansion of existing child nutrition programs where the need exitsts (e.g., School Breakfast and WIC), and they need to advocate for greater participation by the elderly poor in programs that are designed to meet the nutritional needs of the elderly, such as congregate feeding programs sponsored by the Administration of Aging. In addition, grantees must continue to monitor these programs at the state and local level to assure that the new statutes and regulations are adhered to, that effective outreach efforts are undertaken, and that the programs are adininistered effectively, efficiently and fairly.

(3) Applicants are urged to increase and strengthen activities that promote the selfsufficiency of the poor. Self-Help activities contribute directly to self-sufficiency and it is for this reason we are again assigning this category of activity the highest priority after Access. There are other activities, however, that contribute indirectly to selfsufficiency. Therefore, CSA wishes not only to encourage applicants to design proposals that include Self-Help activities where such activities are appropriate and feasible, but to stress the importance for CFNP grantees to utilize every means in whatever activities they undertake, in all program categories, to achieve the goal of self-sufficiency for the poor, whether they contribute directly or indirectly to that goal.

(4) In the category of Access for example, buying food from poor farmers for the School Breakfast and School Lunch programs contributes directly to self-sufficiency. So does an arrangement which permits food stamp recipients to buy food directly from poor farmers with their food stamps, or having a non-profit organization run by and for the poor distribute food stamps. Also, in Access, expanding the School Breakfast and WIC programs contributes indirectly to self-sufficiency since, to the extent that one enables a child to get off to a healthy start in life and to acquire a solid education, he has helped to provide that child with the equipment necessary to become a self-sufficient adult. In working to expand and increase participation in the School Breakfast and WIC programs, grantees are also, happily, focusing on two of the federal programs where there is the greatest unmet need.

(5) Under the new category, Food Supply, whose aim is to stimulate the private sector, there are a variety of activities which contribute directly and indirectly to self-sufficiency. Hiring the poor to work in wholesale

and retail outlets and in the manufacturing and distribution aspects of the industry obviously contributes directly. Initiatives by the food industry to make more nutritious food available to the poor at more reasonable prices contribute indirectly, as do advertising and educational programs sponsored by private industry to make the poor more nutritionally aware.

(6) With respect to Crisis Relief, the provision of emergency food assistance often is necessary “to tide over" a family or individual while they are between jobs. To the extent that such assistance helps to keep a person going until the new job or paycheck comes in, it is contributing directly to the achievement of the self-sufficiency of the individual. Further, there are opportunities for the poor to become directly involved in the provision of emergency food assistance either as paid workers or as volunteers until other work is available.

(7) In considering options for the provision of emergency food assistance, communities are urged to give consideration to the establishment of food pantries and emergency food box projects which draw upon a variety of community resources (including the food industry) for their continued support. Because of the extremely adverse impact upon the poor of continued high inflaticn and high energy costs, CSA recognizes the increased need for emergency food assistance, has given this category of activities a higher priority, and urges local communities to create mechanisms for the provision of such assistance.

(8) Under Nutrition Education, activities which improve “the ability of low-income individuals and families to understand the connection between diet and health, to obtain at the lowest prices nutritionally superior foods and to prepare and preserve these foods in ways that minimize the loss of nutrients” obviously contribute to selfsufficiency. CNFP grantees are urged to monitor existing nutrition/consumer education programs to make sure: (1) That they are targeted to meet the specific needs of the poor, (2) That the poor are involved in the planning of new efforts, and (3) That to the extent possible the poor are hired to conduct outreach and assist in conducting nutrition and consumer education activities.

(9) All CNFP grantees should seek to hire the poor wherever possible in the conduct of project activities, and they should advocate the hiring of the poor in all publicly-funded food programs and by the private sector in the manufacture, distribution and sale of foodstuffs. A suitable job is, after all, the primary and ultimate means of achieving self-sufficiency in our society.

(10) While CSA is again establishing national priorities, it is important to note that applicants may, without penalty, select ac

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sible packaging and advertising practices, is indeed an advocacy activity.

4. Under Crisis Relief.

a. Direct Service. Most direct service activity in the Crisis Relief category is non-catalytic, for example, issuing emergency food vouchers, paid for by CFNP funds, to a family in need.

b. Advocacy. Examples of advocacy in the Crisis Relief category are: (1) Spinning off a currently CAA operated food pantry or food box project to a community coalition that raises funds to carry out the projects independently of CAA subsidy; (2) negotiating with USDA, the Federal Disaster Assistance administration, church and civic groups and local government entities to establish a mechanism in the community that will insure prompt distribution of foodstuffs to low-income individuals in emergency situations; (3) monitoring the operation of a local food stamp program to insure that the new USDA regulation is followed which cuts food stamp issuance time for a destitute individual or family to the same day the application is filed (the so-called “same-day-service").

5. Under Nutrition/Consumer Education.

a. Direct Service. As in the case of “Access" and "Self-help" activities, it is hard to think of a direct service activity in the "Nutrition Education" category which does not have some catalytic effect. For example, there is surely some multiplier effect in the activity of teaching a group of lowincome individuals how to compare foods and shop wisely, in terms of nutritional content or price or both. But given the fact that other agencies have been furnished Federal monies to carry out nutrition education activities, a more cost-effective expenditure of limited CFNP funds would be on advocacy activities relating to nutrition education.

b. Advocacy. Examples of advocacy in the Νυ rition Education category are: (1) Working with USDA's Extension Service or with other appropriate state agencies to insure that federally-financed nutrition education programs are, to the extent provided for under the law, designed for and directed at the low-income population; (2) Organizing groups in the low-income community to monitor in local retail food outlets price increases that exceed Administration inflation guidelines.

mine their effectiveness in achieving stated goals, their impact on related programs, and their structure and mechanisms for delivery of services *

Since the USDA is the principal operator of federal food programs, the bulk of CFNP monitoring activities will be aimed at programs operated by USDA at the state and local level. Carol Tucker Foreman, Assistant Secretary for Food and Consumer Services, USDA, in commenting upon the FY 79 proposed CFNP regulations, recognized and supported this critically important role of CSA's CFNP grantees. Having stated her commitment to improve the operation of USDA's food programs she said:

“We need support and, I am not afraid to admit, pressure we need the help and expertise of CFNP grantees. We can write the rules and publish guidelines, but we cannot peer into every community in this land to see how our programs reach people. We need to see how the programs function and receive guidance as to how they can be improved. CFNP must see this function as its major responsibility. There must be informed and aggressive actions state-wide and in communities across the country to monitor program implementation, to help governmental agencies do their jobs and, where necessary, insure that the law is enforced. Certainly we intend to improve our capacity to aid in this process, but most of this work must be undertaken locally where only CFNP, and the volunteer work of other civic organizations, can truly be effective.” (emphases added)

Thus the monitoring role of CFNP grantees has not only been recognized by USDA, it has been strongly encouraged, and the letter of Ms. Foreman underscores once again its importance.

It should be emphasized that the type of monitoring described above is not the same as the monitoring and oversight functions that USDA and other federal agencies, by law, must themselves carry out to insure that programs they administer comply with relevant statutes and regulations, are managed soundly, and achieve the purposes for which they were instituted. Therefore, in carrying out this function, CFNP grantees should carefully avoid conveying the impression that they are supplanting or usurping the monitoring functions proper to these other agencies.

III. MONITORING The statutory authority for CSA's and CSA grantees' monitoring of other federally-administered programs is found in Title IX of the Economic Opportunity Act which states: "The Director shall, directly through grants or contracts, measure and evaluate the impact of all programs authorized by this Act and of poverty-related programs authorized by other Acts, in order to deter

IV. OUTREACH Grantees involved in access activities are urged to obtain a copy of USDA's Final Rule, dated November 6, 1979, implementing the outreach provisions of the Food Stamp Act of 1977 (Ref. 7 CFR Part 272). In its final rule, USDA distinguishes between two types of outreach as follows:

on-one service could be greatly increased if the project were to include a specific plan to induce other public or private institutions to make land available and assume at least part of the burden of providing seeds and technical assistance.

It may be difficult and sometimes impossible to score successes in local advocacy activity. But the rule calls on all local project operators to make a bona fide effort in this direction. It is especially important, in this era of dwindling public funds, to engage in vigorous private sector advocacy. Grantees inexperienced in advocacy techniques should seek help from the CFNP's regional and national T&TA providers.

The following examples may help to further clarify what is meant by catalytic direct service, advocacy, etc., and how these different activities can be combined in one project:

1. Under Access.

a. Direct Service. Any one-on-one direct service activity in the Access category can be considered, for the purposes of this rule, to be catalytic. For example, an activity which is catalytic and therefore quite acceptable is searching out low-income persons eligible for food stamps, alerting them to their entitlements and referring them to the local certification office for additional counseling and enrollment in the Food Stamp program. Another example is representing an applicant for food stamps at a local or State-level hearing.

Some activities, however, are more catalytic than others, that is, they produce an even greater return for the dollars invested. For example, a CFNP project, instead of directly representing individuals at Food Starnp hearings, may help low-income individuals learn the techniques needed to enable them to speak to themselves at Food Stanıp hearings and to organize and train others to do the same. The most catalytic of all is the advocacy approach.

b. Advocacy. Examples of advocacy in the access category are: (1) Working out arrangements with a grantee of the national Legal Services Corporation to provide oneon-one legal counseling and representation for food stamp recipients experiencing difficulties with welfare offices; (2) monitoring of local welfare offices to insure that they comply with USDA regulations so that clients obtain the benefits to which they are entitled; (3) organizing a corps of county volunteers to provide elderly food stamp recipients with support services, such as transportation to food stamp outlets and grocery stcres; (4) disseminating information locally on the national School Breakfast Program and seeking to persuade local officials and school board members to institute breakfast programs in schools serving low-income communities.

2. Under Self-Help.

a. Direct Service. Any one-on-one direct service in the Se!f-Help category is catalytic. For example, the provision of seeds and T&TA to low-income gardeners not only stimulates them to pursue an activity which promotes self-sufficiency (the goal of all Title II programs), but the gardeners, by investing their own labor at no cost to the project, are able to produce and preserve food whose value far exceeds the cost of the seeds and T&TA. Nonetheless, a gardening project becomes catalytic in the full sense if, in addition to providing seeds and T&TA, it includes a strong advocacy component.

b. Advocacy. Examples of advocacy in the Self-Help category are: (1) Negotiating with USDA's Extension Service or other public or private agencies to provide seeds and ongoing T&TA for low-income gardeners; (2) persuading a local government to change its regulation governing the use of vacant land so as to make it available for family and community gardens; (3) negotiating with local governments to remove barriers, resulting from local ordinances or regulations, to the establishment of farmers' markets and food co-ops.

3. Under Food Supply.

a. Direct Service. Since most of the activi. ties listed under Food Supply are aimed at the private sector, very few of them involves the provision of direct services to the poor. One exception is where a food bank operated by a grantee provides foodstuffs to organizations operating feeding programs for the poor. However, a food bank project can be truly catalytic by taking a small amount of grant funds and mobilizing considerably greater resources and services from the public and private sectors of the community it serves. Some food banks have managed to provide ten to fifteen dollars worth of food to the poor for every CFNP dollar invested.

b. Advocacy. Almost all of the activities under Food Supply are by definition advocacy activities, e.g., organizing consumer action to get food sales tax laws repealed; encouraging food retailers to join with city governments and community based groups to bring supermarkets back to inner cities; and enlisting the support of retailers for the establishment of consumer monitoring and advisory panels. Developing a broad base of community support for the establishment of a food bank and continued mobilization of resources and solicitation of foodstuf from the food industry to support the bank are also examples of advocacy. While many of the activities under Food Supply result eventually in improved services to the poor, such as making available a variety of inexpensive, quality foods (in order to promote optimum nutrition among the poor), the activity required to bring that about, namely, encouraging industry to adopt more respon.

sible packaging and advertising practices, is indeed an advocacy activity.

4. Under Crisis Relief.

a. Direct Service. Most direct service activity in the Crisis Relief category is non-catalytic, for example, issuing emergency food vouchers, paid for by CFNP funds, to a family in need.

b. Advocacy. Examples of advocacy in the Crisis Relief category are: (1) Spinning off a currently CAA operated food pantry or food box project to a community coalition that raises funds to carry out the projects independently of CAA subsidy; (2) negotiating with USDA, the Federal Disaster Assistance administration, church and civic groups and local government entities to establish a mechanism in the community that will insure prompt distribution of foodstuffs to low-income individuals in emergency situations; (3) monitoring the operation of a local food stamp program to insure that the new USDA regulation is followed which cuts food stamp issuance time for a destitute individual or family to the same day the application is filed (the so-called "same-day-service").

5. Under Nutrition/Consumer Education.

a. Direct Service. As in the case of “Access" and "Self-help" activities, it is hard to think of a direct service activity in the “Nutrition Education" category which does not have some catalytic effect. For example, there is surely some multiplier effect in the activity of teaching a group of lowincome individuals how to compare foods and shop wisely, in terms of nutritional content or price or both. But given the fact that other agencies have been furnished Federal monies to carry out nutrition education activities, a more cost-effective expenditure of limited CFNP funds would be on advocacy activities relating to nutrition education.

b. Advocacy. Examples of advocacy in the Nutrition Education category are: (1) Working with USDA's Extension Service or with other appropriate state agencies to insure that federally-financed nutrition education programs are, to the extent provided for under the law, designed for and directed at the low-income population; (2) Organizing groups in the low-income community to monitor in local retail food outlets price increases that exceed Administration inflation guidelines.

mine their effectiveness in achieving stated goals, their impact on related programs, and their structure and mechanisms for delivery of services * * *".

Since the USDA is the principal operator of federal food programs, the bulk of CFNP monitoring activities will be aimed at programs operated by USDA at the state and local level. Carol Tucker Foreman, Assistant Secretary for Food and Consumer Services, USDA, in commenting upon the FY 79 proposed CFNP regulations, recognized and supported this critically important role of CSA's CFNP grantees. Having stated her commitment to improve the operation of USDA's food programs she said:

“We need support and, I am not afraid to admit, pressure * * * we need the help and expertise of CFNP grantees. We can write the rules and publish guidelines, but we cannot peer into every community in this land to see how our programs reach people. We need to see how the programs function and receive guidance as to how they can be improved. CFNP must see this function as its major responsibility. There must be informed and aggressive actions state-wide and in communities across the country to monitor program implementation, to help governmental agencies do their jobs and, where necessary, insure that the law is enforced. Certainly we intend to improve our capacity to aid in this process, but most of this work must be undertaken locally where only CFNP, and the volunteer work of other civic organizations, can truly be effective." (emphases added)

Thus the monitoring role of CFNP grantees has not only been recognized by USDA, it has been strongly encouraged, and the letter of Ms. Foreman underscores once again its importance.

It should be emphasized that the type of monitoring described above is not the same as the monitoring and oversight functions that USDA and other federal agencies, by law, must themselves carry out to insure that programs they administer comply with relevant statutes and regulations, are managed soundly, and achieve the purposes for which they were instituted. Therefore, in carrying out this function, CFNP grantees should carefully avoid conveying the impression that they are supplanting or usurping the monitoring functions proper to these other agencies.

III. MONITORING The statutory authority for CSA's and CSA grantees' monitoring of other federally-administered programs is found in Title IX of the Economic Opportunity Act which states: "The Director shall, directly through grants or contracts, measure and evaluate the impact of all programs authorized by this Act and of poverty-related programs authorized by other Acts, in order to deter

IV. OUTREACH Grantees involved in access activities are urged to obtain a copy of USDA's Final Rule, dated November 6, 1979, implementing the outreach provisions of the Food Stamp Act of 1977 (Ref. 7 CFR Part 272). In its final rule, USDA distinguishes between two types of outreach as follows:

“'Informal outreach' is the conveying of information about the Program through such means as publications, telephone hot lines, films, media and face-to-face contacts. 'Non-informational outreach' is the providing of transportation to certification or issuance offices, or similar physical program support."'

The USDA rule officially recognizes the contribution CSA has been making to the Food Stamp outreach effort in the past and assumes that there will be joint USDA-CSA outreach activity in the future, with USDA coordinating the overall program. Under the USDA rule, for example, while USDA will not reimburse State agencies for non-informational outreach where a CAA is doing such outreach, USDA may pay for such outreach where a CAA is not providing it. In addition, a State agency may be reimbursed for doing informational outreach in the same area a CAA may be doing it. This is simply a recognition of the fact that the combined USDA/CSA resources for outreach are generally insufficient to meet the total need.

Granted that CSA has a continuing role in the area of Food Stamp outreach, this does not nean that the CFNP should bear a major part of the outreach burden. For one thing, all CAA's whether or not they are recipients of CFNP funds, have a Food Stamp outreach responsibility. Secondly, CFNP funds are limited and should be applied primarily to advocacy activities directed at institutions rather than on direct services to individuals.

A partial solution to CSA's outreach dilemma is provided by USDA's assumption of a major part of the outreach responsibility and in particular by the policy, newly reaffirmed in USDA's final rule on outreach, that State agencies may delegate Food Stamp outreach responsibilities, on a reim

bursable basis, to CAA's and CFNP grantees. There is an opportunity here for some very significant catalytic activity on the part of CFNP grantees and CAA's, namely, the leveraging, by means of a contract with a State agency, of USDA funds for outreach performed by CSA's grantees. V. NATIONAL CONSUMER COOPERATIVE BANK

The National Consumer Cooperative Bank authorized by Congress in 1978 is required by law to make its “best efforts” to provide 35% of its loan money to low-income organizations including food co-ops. The Bank will publish its final regulations by the end of May, 1980. In the meantime, they have a brochure, available upon request, which explains application procedures and eligibility criteria. Applications are currently being accepted and will be processed on a first come first served basis. CFNP grantees and prospective applicants for food co-op projects are therefore urged to submit their applications to the Bank promptly. All CAA's are supposed to be on the Bank's mailing list. CAA's which are not yet on the list and other interested CFNP grantees or prospective applicants for CFNP funds for food coop projects should contact the Bank at the following address for further information: National Consumer Cooperative Bank, Attn: Ms. Pru Pemberton, 2001 S Street, N.W., Washington, D.C. 20009; Telephone: 4242481.

In addition applicants may wish to contact the Cooperative Bank Monitoring Project whose principal purpose is to ensure full participation by eligible low-income organizations. The address of the Project is: Conference on Alternatives, State and Local Policies, Attn: Mr. Norman Davis, Co-op Bank Monitoring Project, 2000 Florida Avenue, N.W., Washington, D.C. 20009; Telephone 202-387-6030.

VI. FISCAL YEAR 1980 ALLOCATIONS 1

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1 CSA reserves the right to make adjustments in these allocations in the event that a region or conduit is unable to expend its full allocations due to a lack of qualified applicants.

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