Food security research with resettled refugees in the United States and other Global North countries has found alarmingly high rates of food insecurity, up to 85% of surveyed households. This is well above the current US average of 12.7%. However, the most common survey tool used to measure food security status in the US, the US Household Food Security Survey Module (HFSSM), has not been sufficiently validated for resettled refugee populations, leading to the risk that the HFSSM may actually be underestimating the prevalence of food insecurity among resettled refugees in the US. Though research has attempted to establish validity of the HFSSM for resettled refugees through statistical associations with other risk factors for food insecurity, no efforts have been made to first explore and establish the content validity of the HFSSM for measuring food security among resettled refugees. Content validity is an essential component of construct validity. It first requires a qualitative theoretical foundation for demonstrating the relationships of the test contents to the underlying construct (ie food security) that the test intends to measure. Our research explores these theoretical relationships through a qualitative grounded study of food insecurity and food management experiences described by resettled refugees living in Vermont. Dr. Linda Berlin and I conducted 5 semi-structured focus groups in the summer and fall of 2015 with Bhutanese (2 groups), Somali Bantu (1 group), and Iraqi (2 groups) resettled refugees. During the focus groups, we inquired about food management practices under typical circumstances and under circumstances of limited household resources, as well as difficulties participants have faced in these processes. Additionally, I conducted 18 semi-structured interviews and 1 focus group in the same time frame with service providers who have worked with resettled refugees in capacities primarily related to food, health, and household resources. These interviews provided additional data about context, household food management practices among clients, and triangulating data for the focus groups. A Grounded Theory analysis of the focus group data yielded 5 major emergent themes: 1) Past food insecurity experiences of resettled refugee participants exerted significant influence on the subjective perception of current food insecurity. 2) Barriers other than just financial resources restricted participants’ food security, especially for recently resettled refugees. 3) Preferred foods differed significantly between generations within households. 4) Common elements of quality and quantity included in the definition and measurement of food security did not translate into the languages or experiences of food insecurity among participants. 5) Strategic and adaptive food management practices prevailed among participants, highlighting the temporality and ambiguity of food security concepts. These themes present potential problems of content validity for every HFSSM question. They also reveal the importance of food security concepts that are not covered by the HFSSM, including elements of nutritional adequacy of food, food safety, social acceptability of food and of means of acquiring food, short and long term certainty of food access, and food utilization. I conclude by discussing implications of our findings for service providers and local governments in Vermont who seek to better serve resettled refugee and other New American populations.