Oversight of the Emergency Food Assistance Program, Interim Report — Inspection Report 27801-0001-21(1)

Summary

Office of Inspector General, U.S. Department of Agriculture, Interim Inspection Report 27801-0001-21(1) on COVID-19—Oversight of the Emergency Food Assistance Program, dated August 24, 2021, addressed to Cindy Long, Acting Administrator of the Food and Nutrition Service (FNS). The report states that FNS did not formally evaluate what impact the COVID-19 pandemic could have on the safe and efficient distribution of food assistance to States. It states that the Families First Coronavirus Response and CARES Acts increased TEFAP funding by $850 million, with funding totaling more than $1.2 billion. It recommends that FNS develop and implement a formal process to identify, assess, and document risks, and states that FNS agreed.

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Issuer: Source documents
Document type: Report
Case: Covid19 Tefap Oversight Interim Report 1

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United States Department of Agriculture

COVID-19—Oversight of the
Emergency Food Assistance
Program-Interim Report

Inspection Report
27801-0001-21(1) OFFICE OF INSPECTOR GENERAL
August 2021
COVID-19—Oversight of the Emergency Food
Assistance Program

Inspection Report 27801-0001-21(1)
The objective of our ongoing inspection is to evaluate FNS’ oversight of TEFAP—
this report provides interim results on whether FNS identified risks related to the safe
and efficient distribution of USDA-food assistance to States during the COVID-19
pandemic.
OBJECTIVE WHAT OIG FOUND
One of the four objectives of The Emergency Food Assistance Program (TEFAP) is
our ongoing inspection was a United States Department of Agriculture (USDA)
to determine what risks FNS program that provides supplemental food assistance to
identified related to the safe
persons in need. TEFAP provides Federally purchased
and efficient distribution of
USDA-food assistance provided
commodities (USDA-foods) to States and territories
to States during the COVID-19 (States) to distribute to recipient agencies serving low-
pandemic. Specifically: (a) did income households and individuals. TEFAP also provides
FNS accept any risk related administrative funds to cover States’ and recipient
to the safe distribution of food agencies’ costs associated with the processing, storage,
assistance without implementing and distribution of USDA-foods and foods provided
an offsetting internal control?; through private donations.
and (b) what controls did FNS
establish to manage risks it did We concluded that the Food and Nutrition Service (FNS)
not accept?
did not formally evaluate what impact the coronavirus
disease 2019 (COVID-19) pandemic could have on the
safe and efficient distribution of food assistance to States.
REVIEWED This occurred because FNS had not established a formal
enterprise risk management process to continuously
We evaluated if FNS identified identify and assess risks related to TEFAP program
risks related to the safe and operations, including changing conditions that could
efficient distribution of USDA impact the integrity of the program. Without a formal
food assistance provided to the risk management process for TEFAP, there is no
States between March 1, 2020, assurance that FNS periodically reviews and documents
and October 31, 2020. its response to the impact of changing conditions on
the safe and effective distribution of food assistance
to States. In fiscal year 2020, the Families First
Coronavirus Response (FFCR) and Coronavirus Aid,
RECOMMENDS Relief, and Economic Security (CARES) Acts increased
TEFAP funding by $850 million, with funding totaling
We recommend that FNS
more than $1.2 billion, thus increasing the potential risk
develop and implement a formal
process to periodically identify,
that food assistance may not go to those in need.
assess, and document risks
that could impact the integrity FNS agreed with our finding and recommendations,
of TEFAP. FNS should also and we accepted management decision on both
document its response to the recommendations.
risks identified during its
assessment and document and
implement mitigation strategies,
as applicable.
OFFICE OF INSPECTOR GENERAL
United States Department of Agriculture

DATE: August 24, 2021

INSPECTION
NUMBER: 27801-0001-21(1)

TO: Cindy Long
Acting Administrator
Food and Nutrition Service

ATTN: Melissa Rothstein
Director
Office of Internal Controls, Audits and Investigations

FROM: Gil H. Harden
Assistant Inspector General for Audit

SUBJECT: COVID-19—Oversight of the Emergency Food Assistance Program

This report presents the results of the subject review. Your written response to the official draft
is included in its entirety at the end of the report. We have incorporated excerpts from your
response, and the Office of Inspector General’s position, into the relevant sections of the report.
Based on your written response, we are accepting management decision for both inspection
recommendations in the report, and no further response to this office is necessary. Please follow
your internal agency procedures in forwarding final action correspondence to the Office of the
Chief Financial Officer (OCFO).

In accordance with Departmental Regulation 1720-1, final action needs to be taken within 1 year
of each management decision to prevent being listed in the Department’s annual Agency
Financial Report. For agencies other than OCFO, please follow your internal agency procedures
in forwarding final action correspondence to OCFO.

We appreciate the courtesies and cooperation extended to us by members of your staff during our
audit fieldwork and subsequent discussions. This report contains publicly available information
and will be posted in its entirety to our website (http://www.usda.gov/oig) in the near future.
Table of Contents

Background and Objectives ................................................................................... 1
Section 1: What risks has FNS identified related to the safe and efficient
distribution of USDA-food assistance provided to States during the pandemic? . 5
a. Did FNS accept any risk related to the safe distribution of food assistance
without implementing an offsetting internal control?............................................ 5
b. What controls did FNS establish to manage risks it did not accept? ............... 5
Recommendation 1 ........................................................................................8
Recommendation 2 ........................................................................................9
Scope and Methodology ........................................................................................ 11
Abbreviations ........................................................................................................ 12
Agency’s Response ................................................................................................ 13
Background and Objectives

Background

The Emergency Food Assistance Program (TEFAP) is a United States Department of Agriculture
(USDA) program that provides supplemental food assistance to persons in need. 1 TEFAP
provides Federally purchased commodities 2 (USDA-foods) 3 to States and territories (States) 4 to
distribute to recipient agencies 5 serving low-income households and individuals. TEFAP also
provides administrative funds to cover States’ and recipient agencies’ costs associated with the
processing, storage, and distribution of USDA-foods and foods provided through private
donations.

The Food and Nutrition Service (FNS) administers TEFAP in collaboration with USDA’s
purchasing agencies: Agricultural Marketing Service, Farm Service Agency, and Commodity
Credit Corporation. At the Federal level, FNS is responsible for allocating aid to States and for
coordinating the ordering, processing, and distribution of USDA-foods. FNS allocates and
distributes food and administrative funds 6 according to a formula based on each State’s
population of low-income and unemployed persons. State agencies 7 administer TEFAP at the
State level. State agencies are responsible for distributing USDA-foods and funds to recipient
agencies and general oversight of the program at the local level. Figure 1 depicts the general
responsibilities of TEFAP and the flow of USDA-foods and funds through TEFAP.

1
In 1981, TEFAP was first authorized to distribute surplus commodities under the Temporary Emergency Food
Assistance Program in order to help supplement the diets of low-income Americans, including seniors. The
Emergency Food Assistance Act of 1983 authorized TEFAP to provide other types of surplus foods.
2
Commodities include fruits, vegetables, meats, and grains, among other foods.
3
The term “commodities” is no longer commonly used, as it has been replaced by “donated foods” or “USDA-
foods.”
4
States are defined as all 50 States of the United States, the District of Columbia, Puerto Rico, the Virgin Islands,
Guam, and Northern Mariana Islands.
5
Recipient agencies include emergency feeding organizations, such as food banks, food pantries, soup kitchens, and
charitable institutions, which receive USDA-foods and/or administrative funds.
6
Funds are provided to the State and recipient agencies for the costs associated with processing, storage, and
distribution of USDA-foods or food provided through private donations.
7
Examples of State agencies that administer TEFAP include entities such as the Department of Health and Human
Services, the Department of Social Services, the Department of Agriculture, or the Department of Education.

INTERIM INSPECTION REPORT 27801-0001-21(1) 1
FEDERAL LEVEL STATE LEVEL RECIPIENT AGENCIES

Food pantries
USDA State agencies
-Issues regulations -Places food orders
and guidance -Creates eligibility Food banks 1
-Purchases criteria -Distributes food Soup kitchens
commodities -Selects recipient to local
-Allocates aid to agencies organizations
States -Distributes
Other
-Oversees States commodities and funds
-(e.g. shelters)
to recipient agencies
-Oversees and manages
State and local
operations

Figure 1. Flow of Food and Funds through TEFAP.
1. States may distribute food to recipient agencies directly or task recipient agencies with food distribution to
other recipient agencies. States often delegate this responsibility to food banks.

Section 27 of the Food and Nutrition Act authorizes mandatory funding for TEFAP. 8 In fiscal
year (FY) 2020, Congress appropriated more than $397 million to TEFAP: $317.5 million for
USDA-foods and $79.63 million for food distribution costs. 9

In January 2020, the Secretary of Health and Human Services declared the coronavirus
disease 2019 (COVID-19) pandemic 10 a public health emergency for the United States. The
pandemic resulted in catastrophic loss of life and substantial damage to the global economy,
societal stability, and global security. In response to this unprecedented global crisis, Congress
and the administration took a series of actions, including providing additional funding for
programs serving low-income households. The Families First Coronavirus Response (FFCR)
Act, 11 enacted on March 18, 2020, provided $400 million for TEFAP under the Commodity
Assistance Program (CAP). Furthermore, the Coronavirus Aid, Relief, and Economic Security
(CARES) Act, 12 enacted on March 27, 2020, provided an additional $450 million in
supplemental funding to CAP for TEFAP. The CARES Act additionally required that funds be
used to “prevent, prepare for, and respond to coronavirus.” The FFCR and CARES Acts did not

8
The Food and Nutrition Act of 2008, Pub. L. No. 88–525 (Aug. 1964), amended by Pub. L. No. 116-94
(Dec. 2019).
9
The Further Consolidated Appropriations Act, 2020, Pub. L. No. 116-94 (Dec. 2019).
10
COVID-19 is an infectious disease caused by a newly discovered coronavirus. On January 31, 2020, the
Secretary of Health and Human Services declared a public health emergency for the United States, retroactive to
January 27, 2020. On March 11, 2020, the World Health Organization characterized COVID-19 as a pandemic.
11
Families First Coronavirus Response Act, Pub. L. No. 116-127 (Mar. 2020).
12
Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136 (Mar. 2020).

2 INTERIM INSPECTION REPORT 27801-0001-21(1)
change TEFAP’s regulatory requirements; however, these Acts increased FY 2020 funding by
$850 million.

Figure 2 depicts the TEFAP funding from the FFCR and CARES Acts.

Figure 2. FFCR and CARES Act Funding

INTERIM INSPECTION REPORT 27801-0001-21(1) 3
Objectives
One of our inspection objectives 13 was to determine what risks FNS identified related to the safe
and efficient distribution of USDA-food assistance provided to States during the pandemic.
Specifically:

a. Did FNS accept any risk related to the safe distribution of food assistance without
implementing an offsetting internal control?

b. What controls did FNS establish to manage risks it did not accept?

13
During the course of our inspection, we plan to issue additional interim reports as we complete the other three
objectives. In this report, we are addressing objective 3.

4 INTERIM INSPECTION REPORT 27801-0001-21(1)
Section 1: What risks has FNS identified related to the safe and
efficient distribution of USDA-food assistance provided to States
during the pandemic?

a. Did FNS accept any risk related to the safe distribution of food assistance
without implementing an offsetting internal control?

b. What controls did FNS establish to manage risks it did not accept?
FNS did not formally evaluate the impact the pandemic could have on the safe and efficient
distribution of food assistance to States. This occurred because FNS had not established a formal
enterprise risk management (ERM) process to continuously identify and assess risks related to
TEFAP program operations, including changing conditions that could impact the integrity of the
program. Without a formal risk management process for TEFAP, there is no assurance that FNS
periodically reviews and documents its response to the impact of changing conditions on the safe
and effective distribution of food assistance to States. In FY 2020, the FFCR 14 and CARES 15
Acts increased TEFAP funding by $850 million, with funding totaling more than $1.2 billion,
thus increasing the potential risk that food assistance may not go to those in need.

The Office of Management and Budget (OMB) Circular No. A-123 states that identifying risk is
a continuous and ongoing process. Agencies must regularly review and monitor risk to identify
whether risks still exist, whether new risks have arisen, and whether the likelihood and impact of
risks have changed; report significant changes that adjust risk priorities; and deliver assurance on
the effectiveness of controls. 16 Furthermore, changing conditions often create new risks or
changes to existing risks that prompt management to perform a risk assessment to identify,
analyze, and respond to risks caused by these changing conditions. 17

OMB defines ERM as an effective, agency-wide approach to address the full spectrum of
significant internal and external risks by understanding the combined impact of risks as an
interrelated portfolio, rather than addressing risks only within silos. ERM is a part of overall
organizational governance and accountability functions and encompasses all areas where an
organization is exposed to risk. 18

The FFCR and CARES Acts increased TEFAP funding by a total of $850 million to purchase
and distribute food to those in need. FNS modified or implemented oversight controls in
response to the requirements of the CARES Act and the pandemic that:

14
Families First Coronavirus Response Act, Pub. L. No. 116-127 (Mar. 2020).
15
Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136 (Mar. 2020).
16
OMB, Management’s Responsibility for Enterprise Risk Management and Internal Control, Circular A-123
(July 2016).
17
Government Accountability Office (GAO), Standards for Internal Control in the Federal Government, GAO-14-
704G (Sep. 2014).
18
OMB, Management’s Responsibility for Enterprise Risk Management and Internal Control, Circular A-123
(July 2016).

INTERIM INSPECTION REPORT 27801-0001-21(1) 5
• required separate reporting of pandemic funds in its financial reports;
• prioritized the use of CARES Act funds over other funding; 19
• required that States provide a written justification for how they would use additional
funds to ensure they would meet the intent of the CARES Act;
• revised its management evaluations (ME) 20 to include pandemic-specific questions to
assess whether State agencies complied with FNS’ pandemic guidance beginning in
FY 2021; and
• modified the timing of MEs and State agency monitoring reviews.

However, FNS did not perform a formal program-wide risk assessment 21 to evaluate what impact
the pandemic could have on TEFAP’s operations and processes. 22 We concluded the pandemic
created challenges for TEFAP, including difficulties in fulfilling TEFAP food orders and delays
in conducting monitoring activities. Had FNS formally evaluated the impact of the pandemic on
program operations, the agency could have further identified ways to mitigate risks to program
integrity.

Delivery of USDA-Foods

In November 2020 23 and March 2021, 24 GAO reported that FNS faced several challenges
implementing TEFAP during the pandemic. For example, GAO reported that FNS canceled
multiple TEFAP orders during the pandemic—such as orders for canned meats, soups, and
vegetables—that left food banks without the USDA-foods they were expecting to distribute to
participants. 25 GAO’s review of FNS data disclosed that food order cancelations were an
ongoing challenge. In terms of both estimated value and total truckload, GAO reported the
magnitude of canceled TEFAP orders was similar from March to September 2020, compared to
the same months in 2019, and canceled orders were greater from October to December 2020,
when compared to March to September 2020. We asked FNS officials if they identified canceled
orders as a risk to the program and, if so, did they implement any changes to address this issue.
FNS officials stated they had not assessed risks related to canceled orders. However, in the fall
of 2020, they began working more closely with their procurement department to identify

19
The CARES Act required funds to be used to “prevent, prepare for, and respond to coronavirus.” As a result, FNS
prioritized using these funds over FFCR Act and regular TEFAP funds.
20
FNS regional offices conduct MEs, which include a review of all of the State agency’s program operations. This
includes an assessment of financial management, as well as compliance with eligibility requirements, inventory
controls, distribution procedures, records and reports for TEFAP foods, and the State agencies’ compliance with its
own monitoring requirements. FNS regional offices review the five TEFAP State agencies identified as the most at
risk for fraud, waste, or abuse on an annual basis.
21
A program-wide risk assessment encompasses all areas where an organization is exposed to risk (financial,
operational, reporting, compliance, governance, strategic, reputation, etc.).
22
FNS did perform an annual risk assessment of TEFAP improper payments, as required by the Payment Integrity
Information Act.
23
GAO, COVID-19: Urgent Actions Needed to Better Ensure an Effective Federal Response, GAO-21-191
(Nov. 2020).
24
GAO, COVID 19: Sustained Federal Action is Crucial as Pandemic Enters Its Second Year, GAO-21-387
(Mar. 2021).
25
According to GAO, FNS officials and representatives from organizations who distribute food stated several
factors contributed to canceled TEFAP orders during the pandemic, including vendors not bidding on a given order,
supply chain issues making food unavailable, and increasing transportation and raw materials costs.

6 INTERIM INSPECTION REPORT 27801-0001-21(1)
additional vendors, make modifications to the list of food offerings, and increase their
involvement within the food industry to reduce the risk of canceled orders.

Oversight

Travel restrictions due to the pandemic prevented FNS regional offices from completing MEs for
two State agencies FNS identified as high risk for waste, fraud, and abuse of program
resources. 26 Although FNS rescheduled these two MEs from FY 2020 to FY 2021, the agency
did not formally identify or assess potential risks caused by postponing the MEs. For example,
FNS did not formally evaluate and document whether it should implement alternate mitigating
controls—such as a desk review of State agencies’ operations—to replace or supplement the
monitoring reviews postponed due to the pandemic.

Travel restrictions also impacted State agencies’ ability to complete on-site monitoring of their
TEFAP operations and processes. State agencies are required to annually review recipient
agencies that participate in TEFAP. 27 In light of the pandemic, FNS provided the State agencies
the option to delay their oversight activities and encouraged virtual reviews to be conducted to
the extent practicable. 28 However, FNS modified these existing controls without performing a
formal risk assessment to determine how these delays could impact the State’s ability to monitor
program operations effectively.

ERM has six essential elements that fit together to form a continual process for managing
enterprise risks. The absence of any one of the elements would likely result in an agency
incompletely identifying and managing risk. For example, if an agency did not monitor risks, it
would have no way to ensure it successfully respond to risks. If FNS had performed formal risk
assessments as part of a continuous risk management process (depicted in Figure 3), FNS could
have more timely identified the challenges OIG and GAO reported and may have been able to
develop and implement strategies to mitigate the risks these challenges presented to the safe and
efficient distribution of USDA-foods to States.

26
FNS conducts an annual risk-based assessment to determine State agencies that pose the highest risk for waste,
fraud, and abuse of TEFAP resources. Based on the results of the assessment, FNS selects the top five states its
assessment identified as presenting the highest risk for fraud, waste, and abuse and performs a ME of those states.
In FY 2020, FNS completed three of the five MEs before the pandemic and rescheduled the remaining two MEs to
be completed in FY 2021.
27
These on-site reviews evaluate how organizations conduct eligibility determinations, food ordering procedures,
storage and warehouse practices, inventory controls, and adherence to reporting and recordkeeping requirements.
28
According to 7 C.F.R. § 250, storage facility reviews and physical inventory counts must be conducted on-site.

INTERIM INSPECTION REPORT 27801-0001-21(1) 7
Figure 3: Essential Elements of Federal Government Enterprise Risk Management.
Source: GAO-17-63. 29

While we acknowledge that FNS modified oversight controls in response to the pandemic, the
agency did not conduct a comprehensive, formal risk assessment of all aspects of TEFAP,
including an assessment of FNS’s TEFAP operations and processes and an assessment of the
impact that changing conditions caused by the pandemic and an increase in Federal funding
could have on TEFAP operations. Although we noted FNS modified program operations in
response to the pandemic, FNS officials shared they did not formally identify and document the
risks of these modifications to the effective oversight of TEFAP. As a result, FNS cannot ensure
that the oversight controls it modified did not create additional risks that FNS should have
mitigated and that all risks to TEFAP operations are identified and assessed. FNS needs to
conduct and document a formal risk assessment of TEFAP, including evaluating the impact of
the pandemic on its operations. In addition, to ensure FNS appropriately uses current and future
TEFAP funds, FNS needs to document any determinations regarding whether it is willing to
accept risks to program integrity or identify and implement additional internal controls to
mitigate risks.

Recommendation 1

Develop and implement a formal process to periodically identify, assess, and document risks,
beyond improper payments, that could impact the integrity of TEFAP. This should include a
comprehensive assessment of all aspects of TEFAP, including those that would arise as a result
of changes in operations due to a significant event.

GAO, Enterprise Risk Management, Selected Agencies’ Experiences Illustrate Good Practices in Managing Risk,
29

GAO-17-63 (Dec. 2016).

8 INTERIM INSPECTION REPORT 27801-0001-21(1)
Agency Response

In its August 13, 2021, response, FNS stated:

FNS concurs with this recommendation and will work to develop and implement a formal
process to periodically identify, assess, and document risks that could affect the integrity
of TEFAP, including those that would arise as a result of changes in operation due to a
significant event such as the COVID-19 pandemic. Though risk assessment is built into
routine program operations and did inform FNS’ response to the pandemic, we recognize
that we do not have a formal risk evaluation process in place in which known risks,
responses to risks, and mitigation strategies are documented and formally evaluated.
Moving forward, we will implement a formal ERM process using the Office of
Management and Budget’s Management Responsibility for Enterprise Risk Management
and Internal Control, Circular A-123 as a guide. We recognize that such an assessment
is a best practice in program administration and will help to ensure the effective and
efficient administration of the program.

FNS provided an estimated completion date of May 1, 2022, for this action.

OIG Position

We accept management decision for this recommendation.

Recommendation 2

Document FNS’ response to the risks identified during its assessment. Document and implement
mitigation strategies, as applicable.

Agency Response

In its August 13, 2021, response, FNS stated:

FNS concurs with this recommendation. The ERM process that will be developed and
implemented will include a process for documenting FNS’ response to any risks
identified during the risk assessment and any corresponding mitigation strategies that will
need to be put into place. In many cases, the process to document risks and mitigation
strategies will simply be an articulation of known risks and strategies that FNS already
has in place; however, we recognize that a formal process may yield different solutions or
strategies than what FNS has already implemented for TEFAP.

FNS provided an estimated completion date of August 1, 2022, for this action.

INTERIM INSPECTION REPORT 27801-0001-21(1) 9
OIG Position

We accept management decision for this recommendation.

10 INTERIM INSPECTION REPORT 27801-0001-21(1)
Scope and Methodology
Our inspection scope covered the period of March 1, 2020, through October 31, 2020. We
conducted our fieldwork on Objective 3 from November 2020 through June 2021.

To accomplish Objective 3, we:

• Obtained and reviewed applicable laws, policies, procedures, and regulations relating
to TEFAP, FFCR Act and CARES Act;
• Reviewed GAO Reports to Congressional Committees: “COVID-19: Urgent Actions
Needed to Better Ensure an Effective Federal Response” (November 2020) and
“COVID-19: Sustained Federal Action is Crucial as Pandemic Enters Its Second
Year” (March 2021);
• Interviewed FNS officials and reviewed written responses to our questions;
• Reviewed and evaluated FNS’ FY 2020 TEFAP improper payment risk assessment;
• Identified and reviewed controls implemented by FNS in response to the FFCR and
CARES Acts; and
• Reviewed FNS’ process for conducting MEs, including FNS’ risk-based assessment
for selecting States for ME reviews and the ME module.

We conducted this inspection in accordance with the Council of the Inspectors General on
Integrity and Efficiency’s Quality Standards for Inspection and Evaluation. 30 Those standards
require that we obtain sufficient, competent, and relevant evidence to provide a reasonable basis
for our findings, conclusions, and recommendations based on our inspection objectives. We
believe that the evidence obtained provides a reasonable basis for our finding, conclusions, and
recommendations based on our inspection objective.

30
Council of the Inspectors General on Integrity and Efficiency, Quality Standards for Inspection and Evaluation
(Dec. 2020).

INTERIM INSPECTION REPORT 27801-0001-21(1) 11
Abbreviations
CAP ........................................Commodity Assistance Program
CARES Act ............................Coronavirus Aid, Relief, and Economic Security Act
C.F.R. .....................................Code of Federal Regulations
COVID-19..............................coronavirus disease 2019
ERM .......................................Enterprise Risk Management
FFCR Act ...............................Family First Coronavirus Response Act
FNS ........................................Food and Nutrition Service
FY ..........................................fiscal year
GAO .......................................Government Accountability Office
ME..........................................management evaluation
OMB ......................................Office of Management and Budget
TEFAP ...................................The Emergency Food Assistance Program
USDA.....................................United States Department of Agriculture

12 INTERIM INSPECTION REPORT 27801-0001-21(1)
Agency’s Response

FNS’
Response to Audit Report

INTERIM INSPECTION REPORT 27801-0001-21(1) 13
Food and
Nutrition
Service
DATE: August 13, 2021

1320 INSPECTION
Braddock NUMBER: 27801-0001-21(1)
Place
Alexandria
, VA TO: Gil H. Harden
22314 Assistant Inspector General for Audit

FROM: Cindy Long /s/
Acting Administrator
Food and Nutrition Service

SUBJECT: Interim Report, COVID-19: Oversight of The Emergency Food Assistance
Program

This letter responds to the interim report official draft for inspection number 27801-0001-21(1),
COVID-19: Oversight of The Emergency Food Assistance Program (TEFAP). Specifically, the
Food and Nutrition Service (FNS) is responding to the two recommendations in the report.

FNS supports the Office of Inspector General’s (OIG) objectives to assess the controls FNS has
in place to monitor and evaluate risk in TEFAP. Such exercises only serve to bolster and
improve the effective and efficient administration of the program. As the COVID-19 pandemic
has demonstrated, TEFAP’s vast network of food banks, food pantries, soup kitchens, and other
local agencies are a lifeline for low-income Americans in need of emergency food assistance.
We appreciate OIG’s due diligence in helping to ensure that TEFAP remains a stable and reliable
source of food assistance for those in need under any circumstances that may arise.

OIG Recommendation 1:

FNS Response:

FNS concurs with this recommendation and will work to develop and implement a formal
process to periodically identify, assess, and document risks that could affect the integrity of
TEFAP, including those that would arise as a result of changes in operation due to a significant
event such as the COVID-19 pandemic. Though risk assessment is built into routine program
operations and did inform FNS’ response to the pandemic, we recognize that we do not have a
formal risk evaluation process in place in which known risks, responses to risks, and mitigation
strategies are documented and formally evaluated. Moving forward, we will implement a formal
enterprise risk management (ERM) process using the Office of Management and Budget’s
Management Responsibility for Enterprise Risk Management and Internal Control, Circular A-
USDA is an Equal Opportunity Provider, Employer and Lender
Gil H. Harden
Page 2

123 as a guide. We recognize that such an assessment is a best practice in program
administration and will help to ensure the effective and efficient administration of the program.

Estimated Completion Date:

May 1, 2022

OIG Recommendation 2:

Document FNS’ response to the risks identified during its assessment. Document and implement
mitigation strategies, as applicable.

FNS Response:

FNS concurs with this recommendation. The ERM process that will be developed and
implemented will include a process for documenting FNS’ response to any risks identified
during the risk assessment and any corresponding mitigation strategies that will need to be put
into place. In many cases, the process to document risks and mitigation strategies will simply be
an articulation of known risks and strategies that FNS already has in place; however, we
recognize that a formal process may yield different solutions or strategies than what FNS has
already implemented for TEFAP.

Estimated Completion Date:

August 1, 2022

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age, marital status, family/parental status, income derived from a public tion Complaint Form, AD-3027, found online at How to File a Program Discrimination
assistance program, political beliefs, or reprisal or retaliation for prior civil Complaint and at any USDA office or write a letter addressed to USDA and provide
rights activity, in any program or activity conducted or funded by USDA (not all in the letter all of the information requested in the form. To request a copy of the
bases apply to all programs). Remedies and complaint filing deadlines vary by complaint form, call (866) 632-9992. Submit your completed form or letter to USDA
program or incident. by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for
Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410; (2) fax:
Persons with disabilities who require alternative means of communication for (202) 690-7442; or (3) email: program.intake@usda.gov.
program information (e.g., Braille, large print, audiotape, American Sign
Language, etc.) should contact the responsible Agency or USDA’s TARGET USDA is an equal opportunity provider, employer, and lender.

File and source

File: covid19-tefap-oversight-interim-report-1.pdf
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Our copy: covid19-tefap-oversight-interim-report-1.pdf
Original: usdaoig.oversight.gov