Alleged Intervention of the Food Research and Action Center (FRAC) Into Certain Food Stamp Program Activities

HRD-81-16: Published: Oct 14, 1980. Publicly Released: Oct 31, 1980.

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The Food Research Action Center (FRAC) is a private, nonprofit organization primarily funded by the Community Services Administration (CSA). It also receives financial support from churches and foundations. FRAC uses its funds to help ensure, through advocacy efforts at the national, State, and local levels, that the various Federal food programs work effectively and efficiently to meet the nutritional needs of the Nation's poor. It attempts to provide training and technical assistance to State and local groups who, in turn, assist FRAC in efforts to improve the legislation, regulation, and administration of Federal food programs. GAO reviewed the FRAC program to determine the source and use of Federal funds received by FRAC, whether these funds were commingled with non-Federal funds, and whether any of the FRAC activities which used Federal funds were contrary to the purpose for which they were provided or contrary to Federal programs authorized or mandated by law. CSA regulations place certain restrictions on the use of CSA funds for lobbying. Grant funds may not be used to pay dues or support any organization or group that devotes or contributes any of its resources from whatever source to any activity with the purpose to influence legislation or to politicize. The amount of resources devoted to such an activity is immaterial.

The GAO review of the source and use of Federal funds by FRAC showed that it received funds only from CSA provided under grants. All other funds received were from non-Federal sources. CSA grant funds are to be used by FRAC to implement legal strategies to improve the responsiveness of Federal food programs; train and maintain field staff to assist antihunger advocate groups; ensure that food stamp programs provide low-income persons with benefits that meet their needs; and act as a clearinghouse on the Food Stamp Act. Federal standards for administering grants do not require physical segregation of cash depositories for Federal funds which are provided to a grantee, but impose standards for financial management systems of grantees. FRAC does physically commingle Federal and non-Federal funds in one bank account. However, GAO concluded that the FRAC financial management system met the requirements of the Uniform Federal Standards. All receipts of CSA funds and all expenditures during 1978 and 1979 were correctly identified and recorded. In two instances, CSA regulatory restrictions had been violated. CSA regulations should be amended to prohibit using funds for any direct lobbying effort. Five of ten FRAC mailings reviewed by GAO contained material that could be construed as lobbying; two of these were prepared with Federal funds. This kind of activity by agencies with appropriated funds is prohibited by legislation. Appropriate action should be taken to recover the amount illegally expended.

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