Community Action Agencies should indicate the amount of local initiative funds, as well as other resources, which are currently being applied to anti-hunger activities.

(3) Adequacy of work program and budget. The third criterion-the adequacy of the work program and budget-refers to the project goals, activities, and budget described in the Form 419 and project narrative. The project goals (item 11 of Form 419) should be stated in specific and measurable terms and they should be appropriately related to the needs described in the needs analysis. They should reflect the changes or results which the project activities are expected to bring about. The activities should be listed in summary form on the Form 419 (item 13) and described in detail in the project narrative. The description should indicate not only what will be done but how it will be done, i.e., the strategy that will be pursued in achieving goals. The activities should be appropriately related to the goals. If an applicant is proposing to carry out activities in more than one program category, the categories would be listed on the Form 419 in priority order, and the goals, activities and funds required for each category should be clearly delineated. The applicant need only submit one budget (325 and 325a) for the entire proposal whether one or more program categories is included.

(4) Anticipated Impact. The statement of project goals should include a description of what the applicant intends to accomplish, i.e., what results or changes the applicant intends to bring about in relation to the problem to be solved. Thus the statement of goals is a statement of anticipated impact. The anticipated impact of the project should be stated in specific and measurable terms and should inIclude the number of persons to be served, the extent to which their nutritional needs will be met and the extent to which unmet needs will remain after the project is completed. The applicant should also include a statement indicating the per/person cost of serving those for whom the project is intended and the dollar value of services or benefits derived.

(5) Coordination. Each applicant must indicate to what extent other organizations conducting anti-hunger activities were involved in the planning of the project, and the ways in which the project will be coordinated in the implementation phase with the activities of these organizations. CAA's must indicate how they intend to coordinate their activities with antihunger groups and anti-hunger groups must indicate how they intend to coordinate their activities with CAA's.

(6) Catalytic Effect of Project on Institutions. Catalytic activity which is aimed at institutions should attempt to bring about two results: Institutional change and mobilization of resources. The means of achieving these is advocacy. The applicant, therefore, should describe in detail how the project staff will, through advocacy for low-income persons seek to change interpretations of laws, regulations, policies, procedures, and attitudes in order to insure that low-income persons receive the benefits to which they are entitled. Advocacy of this sort may and should include enlisting the poor to speak on their own behalf in order to insure that their views are heard, their rights are observed, the benefits to which they are entitled are provided, and their needs are met. The applicant should also state how the project staff will, through advocacy for lowincome persons, leverage dollars or inkind contributions from other elements in the community in support of the project and what the overall end effect of the project itself will be in terms of leveraging dollars or services for low-income individuals.

(7) Ability of Applicant to Perform. Part 1050, Subpart I, of this chapter requires Title II grantees to submit a semi-annual and annual project progress review report (CSA Form 440). Since the ability of the applicants to carry out successfully their proposed work program is one of the important criteria, applicants who are currently operating (or have operated in the past) a CFNP project must attach to the application a copy of the CFNP portion of the most recent Form 440, updating it where necessary. CSA grantees who have never operated a CFNP project must attach to the ap

plication that portion of their most recent Form 440 which relates to a project they have operated that is similar to CFNP projects. Applicants not previously funded by CSA should attach to the application a third-party or self-evaluation of a project they have been operating that is similar to CFNP projects, along with a brief statement summarizing their overall administrative ability and general performance record. All applicants currently operating CFNP projects are encouraged to conduct a third-party evaluation of their current CFNP project (or in the absence of such, a self-evaluation) and attach copies of these evaluations to their applications.

(i) Training and Technical Assistance. The applicant's need for training and technical assistance in carrying out the project should be carefully described in item 15 of the Form 419. It is presumed that most, if not all, projects will need some form of technical assistance. The training and technical assistance plans proposed by the regional T&TA providers will be based in part upon the statement of goals, activities, and T&TA needs expressed by applicants on their Form 419s. It is important, therefore, that applicants be precise and specific in defining and articulating their T&TA needs.

(j) Program Accounts. The following program account numbers for the various program categories should be entered in item 16 of Form 419:

12-Access.

13-Self-Help.

14-Food Supply.

15-Nutrition education.

16-Crisis relief.

17-Special Support.

29-Research.

39-Demonstration.

42-T&TA.
48-Evaluation.

[45 FR 33789, May 20, 1980, as amended at 45 FR 56348, Aug. 25, 1980]

APPENDIX A TO SUBPART 1061.50

I. PROGRAM PRIORITIES

(1) In continuing Access as the number one priority, CSA recognizes both accomplishments and continued need. The primary emphasis of the CFNP over the past two years, under the head of Access activi

ties, has been to increase the participation of the poor in the various public feeding programs at the federal, state and local level. Partly as a result of that emphasis, a substantial momentum has developed among anti-hunger advocates and the various administering agencies which has, in fact, resulted in sizable increases in the number of poor participating in those programs and in significant improvements in program administration. Funding levels for the federally-funded programs have been increased and the statutes and regulations governing them have been considerably improved.

(2) Much has been done, yet much remains to be done. Forty percent (40%) of the nation's poor and near-poor who are eligible still do not participate in the Food Stamp Program; seventy-five percent (75%) do not participate in the School Breakfast Program; and eighty-five percent (85%) are still not reached by the WIC Program. These statistics are unacceptably high, and the unmet need is great with respect to 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 administered 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 inflation 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 activities and program categories that best meet the needs of the poor in the communities which they serve. However, all projects, in addition to containing activities that promote the self-sufficiency of the poor, will be expected to continue the priority of emphases established by last year's rule, i.e., they must be catalytic, contain a strong advocacy thrust, and mobilize significant other resources. Failure to include these elements may result in an applicant's inability to score high enough to be funded.

II. FURTHER CLARIFICATION OF THE KEY TERMS: CATALYTIC ACTIVITY, ADVOCACY, DIRECT SERVICE DELIVERY AND MONITORING (SEE § 1061.50-2)

The CFNP policy makes explicit two assumptions: (1) That not all catalytic activity is advocacy and (2) that some forms of direct service delivery can be catalytic. These assumptions can be diagrammed as follows:

Direct Service as a Catalytic Activity Although providing one-on-one service makes little sense in the context of advocacy and coalition-building at the state level and even less at the level of the national anti-hunger groups and T&TA providers, such service is important at the level at which community action agencies operate. A local CFNP project which completely severs the service link between its staff and low-income individuals, not only risks a loss of credibility in the community but is depriving itself of one of its richest resources, first-hand knowledge of the nutritional problems of those the CFNP is ultimately intended to benefit. In addition, the one-onone relationship created through out-reach activity at the local level has two other consequences which are vital for the success of the CFNP: (1) By enhancing the opportunity to involve recipients of services in the planning and implementation of programs set up to serve them, it contributes to the achievement of the overall goal of Title II programs-self-sufficiency-and (2) it makes possible the kind of grass-roots support needed for really effective advocacy at the state and national levels.

However, as indicated earlier [in § 1061.50-4 (a) and (b) of this subpart], the same passage of the EOA which establishes the goal of self-sufficiency, points to catalytic activity as the principal means of achieving this goal. This should not be construed as ruling out one-on-one service. If the delivery of a direct service by a CFNP

worker to a low-income individual produces a benefit which has a continuing and expanding effect on that individual and others, even after the reduction or termination of direct CFNP support, then the delivery of that service qualifies as a catalytic activity. Non-catalytic service delivery, on the other hand, should be kept to a minimum, be provided on a temporary or emergency basis only and be supported wherever possible from local initiative funds. The intent of the EOA is reinforced by a practical consideration: the very limited funding of the CFNP. The fact that the CFNP budget is less than 3/10ths of 1% of the total federal food outlay suggests not only that most of the direct service provided should be of the catalytic variety, but that there should be a very strong emphasis on that type of catalytic activity known as advocacy.

Advocacy as a Catalytic Activity

It can be inferred from the statment of the five purposes of Title II programs (see § 1061.50-6) that the two most important objectives of the CFNP are the mobilization of resources and institutional change. The techniques used to bring about these two results are what is meant in this rule by the term "advocacy". Because advocacy, unlike catalytic activity of the direct service variety, is aimed at institutions and the general public, it obviously has the potential for producing far greater dividends for the lowincome population than direct service.

The intent of the rule is that an advocacy component be built into each project but not necessarily into each project activity. For example, a self-help project may include as one of its activities the provision of seeds and technical assistance to low-income gardeners. The catalytic potential of this oneon-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 Stamp hearings, may help low-income individuals learn the techniques needed to enable them to speak to themselves at Food Stamp 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 stores; (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 Self-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, re

sulting 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 activities 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 foodstuffs 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 responsible 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 appli