Implementation of Modifications to the TEFAP Allocation Formula

The purpose of this memorandum is to announce the implementation, effective Dec. 15, 2007, of the modifications to the TEFAP allocation formula that we proposed in the Federal Register notice published on Oct. 24, 2007.

In that notice, we announced our intent to modify the current TEFAP allocation formula by using data sources that are more accurate, reliable, and up-to-date than current data sources to calculate it, unless public comments revealed a significant disadvantage to doing so.

We received six comments (three state agencies, two food bank associations, and one food bank). Of these, three – a state agency, a food bank association, and a food bank – were from the same state.

In summary, four commenters opposed the proposed changes because their state would receive a smaller allocation under the new data sources than under the current data sources, and three commenters recommended that implementation be delayed until fiscal year (FY) 2009 because planning for FY 2008 has already begun. One of the commenters opposed the proposed changes because poverty data from one of the new data sources, the U.S. Census Bureau’s American Community Survey (ACS), does not provide county-level data for all of his state’s counties, which precludes its use in making intra-state allocations.

While we understand these concerns, we do not believe they provide a compelling justification for the continued use of current data sources or to delay the use of the new data sources in calculating annual TEFAP allocations because:

1. use of current data sources also result in variations in each state’s annual allocation of TEFAP resources,
2. state and local agencies have only received resources based on the current data sources for one quarter, and
3. the Annual Social and Economic Supplement to the Current Population Survey, which is currently used to compute annual TEFAP allocations, also does not include county-level poverty data.

Moreover, we do not require that such data be used when making intra-state allocations. However, states wishing to use ACS data to make such allocations should know that, although ACS data is currently available only for areas with populations greater than 65,000, such data will be available for all areas within the next three years.

Because none of the commenters identified any significant disadvantage to our proposed modifications, the TEFAP allocation formula will be calculated using ACS poverty data and 10-month unemployment data from the Bureau of Labor Statistics (BLS), and any funds appropriated on Dec. 15, 2007 or thereafter will be allocated accordingly.

Cathie McCullough
Director
Food Distribution Division