Opportunities Exist for USDA to Identify Successes and Challenges of the Farmers to Families Food Box Program to Inform Future Efforts (GAO-20-711R)

Summary

A GAO report to congressional committees, GAO-20-711R, dated September 16, 2020, on the Department of Agriculture's (USDA) Farmers to Families Food Box Program. It describes how COVID-19 disrupted the U.S. food supply chain and how the closure of schools, restaurants and hotels made it difficult for producers to market their commodities. It explains that through the program USDA plans to purchase up to $3 billion in fresh fruits and vegetables, dairy products and meat products, contract with distributors to pack them into family-sized boxes, and transport the boxes to food banks and other nonprofits. Its title states that opportunities exist for USDA to identify the program's successes and challenges to inform future efforts.

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441 G St. N.W.
Washington, DC 20548



September 16, 2020


Congressional Committees

Agriculture Spending: Opportunities Exist for USDA to Identify Successes and
Challenges of the Farmers to Families Food Box Program to Inform Future Efforts

Coronavirus Disease 2019 (COVID-19) has caused disruptions in the U.S. food supply chain,
from the farms where raw agricultural commodities are produced to the food processing and
distribution network that enables these commodities to be used by consumers. The closure of
institutions (e.g., schools, restaurants, and hotels) made it difficult for agricultural producers to
market their commodities, leading to the spoilage of crops, dumping of milk, and euthanization
of livestock. As part of its response to the pandemic, the U.S. Department of Agriculture (USDA)
developed the Farmers to Families Food Box Program. Through this program, USDA plans to
purchase up to $3 billion in fresh fruits and vegetables, dairy products, and meat products;
contract with distributors to package these products into family-sized boxes; and transport these
boxes to food banks, community and faith-based organizations, and other nonprofits that will
then provide the food boxes to persons in need. The program is implemented through USDA’s
Agricultural Marketing Service and involves about 200 contractors.

We reviewed the Farmers to Families Food Box Program in response to a provision in the
CARES Act for GAO to conduct monitoring and oversight of the use of funds made available to
prepare for, respond to, and recover from the COVID-19 pandemic. Specifically, our objective
was to review the key actions USDA has taken, to date, to respond to and recover from COVID-
19. We last reported on the Farmers to Families Food Box Program in June 2020 as part of
GAO’s mandated 90-day report to Congress. 1 We conducted this work as part of GAO’s
mandated 60-day report to Congress. We reviewed the most recent USDA Farmers to Families
Food Box Program delivery data on its website as of August 27, 2020; federal laws, agency
policy and other guidance, and expenditure data provided to us by USDA as of August 14,
2020; and written responses to our questions by USDA officials in the Agricultural Marketing
Service. We determined that the USDA Farmers to Families Food Box Program delivery data
and obligations and expenditures data were sufficiently reliable for the purpose of describing
delivery and spending information. We examined USDA’s implementation of the Farmers to
Families Food Box Program, including the collection and evaluation of information and
assessing USDA’s approach against relevant guidance from the Office of Management and
Budget (OMB) and Federal Standards for Internal Control. 2 GAO continues its work on various

1GAO, COVID-19: Opportunities to Improve Federal Response and Recovery Efforts, GAO-20-625 (Washington,

D.C.: June 25, 2020).
2Office of Management and Budget, Increased Emphasis on Program Evaluations, OMB Memorandum M-10-01

(Washington, D.C.: 2009); Office of Management and Budget, Evaluating Programs for Efficacy and Cost-Efficiency,
OMB Memorandum M-10-32 (Washington, D.C.: 2010); and GAO, Standards for Internal Control in the Federal
Government, GAO-14-704G (Washington, D.C.: September 2014). Specifically, the monitoring control activities
component of the Federal Standards for Internal Control—that management should establish and operate monitoring
activities to monitor the internal control system and evaluate results—was significant to this objective.



Page 1                                                                    GAO-20-711R Agriculture Spending
aspects of the program, including program implementation and contracting. We conducted this
performance audit from June 2020 to September 2020 in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objectives.

USDA Continues Spending on the Farmers to Families Food Box Program

As of August 14, 2020, USDA continued to spend funds for food purchases for redistribution to
food banks, nonprofits, and other entities as part of the Farmers to Families Food Box Program.
USDA reported on its website that through this program, it has delivered more than 74 million
food boxes to nonprofits, food banks, and other entities throughout the country since May 15,
2020, (as of August 27, 2020). According to USDA, the agency obligated $2.6 billion during the
first and second rounds of the program—entering into 190 contracts during the first round and
adding 16 contracts during the second round. On July 24, 2020, USDA announced a third round
of the program for purchases that would spend the balance of the $3 billion allocated for the
program (or about $450 million). Finally, on August 25, the administration and USDA announced
that USDA intends to add up to $1 billion to the third round of the program. Table 1 shows the
obligations and purchases (or expenditures), as of August 14, by each round of the program.



Table 1: Obligations and Purchases for Each Round of the U.S. Department of Agriculture’s Farmers to
Families Food Box Program, as of August 14, 2020
(in dollars)
                                     Round 1             Round 2                Round 3              Total
                             (May 15 through     (July 1 through (September 1 through
                               June 30, 2020)   August 31, 2020)      October 31, 2020)
  Obligations                      1.11 billion        1.44 billion    To be determined      Up to 3 billion

  Purchases (or                                          949 million   672 million     To be determined To be determined
  expenditures)
Source: U.S. Department of Agriculture. I GAO-20-711R.
Notes: According to USDA, expenditures (or purchases) are determined by the payments USDA makes on invoices it receives from
contractors. As of August 14, 2020, USDA had not announced contracts for Round 3 of the program. USDA stated that $1 billion will
be added to the third round of the program.


USDA Implementation of Farmers to Families Food Box Program Includes Some
Oversight and Monitoring Mechanisms but Has Not Included Program Reviews

As we reported in June 2020, according to USDA, the Farmers to Families Food Box Program
represents a completely different way of doing business for USDA. 3 USDA officials told us they
consider the program a success, having implemented an innovative, multi-billion-dollar system
for purchases and redistribution in weeks. According to officials, the need to move quickly
created numerous implementation challenges, including limited time to design and implement
the program, lack of suppliers and recipient agencies, limited staff, and use of a new contracting
approach by the Agricultural Marketing Service. 4

3GAO-20-625.

4According to USDA, this contracting approach was new to the Agricultural Marketing Service, not to the federal

government. Specifically, USDA used contracting flexibilities provided by Federal Acquisition Regulation (FAR) Part
18 which streamlines standard acquisition processes during an emergency declaration.



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On July 24, 2020, USDA announced a third round of spending, as described above. For this
third round of spending, USDA said it would first approve a pool of potential contractors (through
an initial solicitation) who are qualified to respond to region-specific solicitations for food box
deliveries in food insecure communities around the country. According to USDA officials, the
focus on providing food to food insecure communities is a programmatic change from the first
two rounds of the program. The first two rounds of the program, according to USDA, focused on
purchasing surplus food from farmers and other agricultural entities and routing the food to any
community rather than targeting specific communities. USDA made other changes related to the
initial solicitation for this pool of contractors. For example, USDA will require contractors to
cover all costs, including the “last mile,” which includes delivery to the recipient of the food box. 5
According to USDA, including costs for the “last mile” ensures that food banks do not incur costs
to provide food boxes. USDA had not issued region-specific solicitations and did not have a
timeline for doing so, as of July 28, 2020.

USDA has said that it has developed various oversight and monitoring mechanisms as part of
its program implementation approach. 6 In July 2020, USDA reiterated what it stated on its
website—that it would oversee the Farmers to Families Food Box Program throughout the
contract period by conducting audits of, among other things, contractors’ plans for ensuring that
the food deliveries are safe for consumption. In addition, according to USDA, the program
conducts a range of oversight activities such as producing reports from its electronic system to
track delivery progress at the contractor level on a state-by-state basis and nationwide. USDA
also stated that it has a range of oversight options to monitor and address fraud by contractors.
For example, USDA officials told us that even though the Farmers to Families Food Box
Program is new, USDA is conducting ongoing evaluations regarding potential fraud risks.
However, according to USDA officials, USDA has not evaluated programmatic aspects for the
first two rounds of the program. USDA said in July 2020 that it developed the Farmers to
Families Food Box Program as a short-term solution to hardships faced by American farmers
due to the COVID-19 outbreak. According to USDA officials, changes to the program for the
third round were a result of emails, phone calls, and letters from industry associations, recipient
organizations, Congress, and others providing feedback on the program.

While the Famers to Families Food Box Program is not a permanent program, there are
opportunities to identify successes and challenges from the implementation of the program and
to obtain lessons learned that could be used to inform future similar efforts or if the program is
extended. This would be consistent with OMB guidance on the use of evaluations and other
forms of evidence and federal standards for internal control to strengthen the design and
operation of programs. The guidance and standards outline the need to conduct evaluations for
program effectiveness and reviews and evaluations as a feature of monitoring within an internal
control system, respectively. 7 Evaluations can be separate or a part of ongoing monitoring, at a



5According to USDA, the “last mile” is defined as the final movement of goods from a transportation or distribution

hub to the final delivery destination—the individual user of the food box.
6Members of Congress continue to raise questions about USDA’s implementation of the Farmers to Families Food

Box Program. The first two rounds have faced questions about accountability and transparency around program
participation, contractor qualifications, and food distribution decisions. In an August 24, 2020 letter to the Secretary of
Agriculture, the U.S. House of Representatives Select Subcommittee on the Coronavirus Crisis announced that it is
conducting an investigation into the program.
7GAO-17-743.




Page 3                                                                           GAO-20-711R Agriculture Spending
specific time, or of a specific function or process. The USDA FY 2018-2022 Strategic Plan also
emphasizes the role of evaluation in improving USDA’s programs. 8

USDA officials indicated that, to date, they have focused on oversight efforts related to
contractor performance, as described earlier. Going forward, an evaluation, for example, could
focus on better understanding program participation, stakeholder perspectives, and lessons
learned for future programs. As described earlier, one change USDA made for the third round of
spending was the inclusion of costs for the “last mile” of delivery to the recipient of the food box.
Program reviews or an evaluation focused on the perspectives of nonprofits, food banks, and
other entities —a key stakeholder group in the program— could allow USDA to incorporate
additional changes for this stakeholder group, for example. By conducting an evaluation of the
Farmers to Families Food Box Program after the third round of the program, USDA would have
better assurance it has identified successes and challenges from its implementation of the
program that could be used to inform future similar efforts or if the program is extended.

Conclusions

As part of USDA’s response to the pandemic, it developed and implemented the Farmers to
Families Food Box Program in a matter of weeks and, according to the department, has
delivered millions of food boxes. Getting food out quickly was a necessity to address farmers’
surplus food because of institutional closings and to provide food to the public. USDA has
implemented some changes for the third round of the program. By conducting an evaluation of
the Farmers to Families Food Box Program after the third round of the program, USDA would
have better assurance it has identified successes and challenges from its implementation of the
program that could be used to inform future similar efforts or if the program is extended.

Recommendation for Executive Action

The Secretary of the U.S. Department of Agriculture should direct the Agricultural Marketing
Service to conduct an evaluation of the Farmers to Families Food Box Program after the third
round of the program. (Recommendation 1)

Agency Comments and Our Evaluation

We provided a draft of this report to USDA for review and comment. In its comments, USDA
stated that it appreciated the opportunity to respond to the report; and, did not explicitly agree or
disagree with our recommendation.

First, USDA stated that rather than evaluating the programmatic aspects for the first two rounds
of the program, the Agricultural Marketing Service initiated an internal review of the program at
the beginning of August 2020. This internal review, according to USDA, includes a risk-based
methodology to verify that procurements were properly accounted for and that payments made
to vendors were based on appropriate documentation provided by non-profit organizations.
USDA said that, in the agency’s view, such review would be more impactful, cost-effective, and
provide assurance that funds were adequately expended. Second, according to USDA, the
Farmers to Families Food Box Program is expected to be completed by the end of October
2020. Therefore, USDA stated, the costs of conducting an evaluation after the program is over
would seem to outweigh the benefits. Finally, USDA said that any reviews could be redundant

8U.S. Department of Agriculture, USDA Strategic Plan FY 2018-2022 (May 2018).




Page 4                                                                   GAO-20-711R Agriculture Spending
because the program is being reviewed internally by the Office of the Chief Financial Officer and
externally by GAO and the USDA Office of Inspector General.

We agree that the types of reviews that USDA cites are important to assuring that funds are
properly spent and contractors are monitored for compliance. Such reviews are an expected
component of on-going monitoring in a program. We continue to believe that by conducting an
overall evaluation of the Farmers to Families Food Box Program after the third round of the
program, USDA would have better assurance it has identified successes and challenges which
could inform future efforts to address similar situations. The overall evaluation, for example,
could consider the results of the procurement reviews USDA cites as well as lessons learned
about the program’s design and implementation approach, including the views and perspectives
of participants and stakeholders.



We are sending copies of this report to the appropriate congressional committees, the Secretary
of the Department of Agriculture, and other interested parties. In addition, the report is available
at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at (202) 512-3841 or
morriss@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs
may be found on the last page of this report. GAO staff who made key contributions to this
report are listed in Enclosure I.




Steve D. Morris
Director, Natural Resources and Environment

Enclosures – 1




Page 5                                                            GAO-20-711R Agriculture Spending
List of Committees

The Honorable Richard C. Shelby
Chairman
The Honorable Patrick J. Leahy
Vice Chairman
Committee on Appropriations
United States Senate

The Honorable Lamar Alexander
Chairman
The Honorable Patty Murray
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate

The Honorable Ron Johnson
Chairman
The Honorable Gary C. Peters
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Nita M. Lowey
Chairwoman
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives

The Honorable Frank Pallone, Jr.
Chairman
The Honorable Greg Walden
Republican Leader
Committee on Energy and Commerce
House of Representatives

The Honorable Bennie Thompson
Chairman
The Honorable Mike D. Rogers
Ranking Member
Committee on Homeland Security
House of Representatives

The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives



Page 6                                                    GAO-20-711R Agriculture Spending
Enclosure I: GAO Contact and Staff Acknowledgments

GAO Contact

Steve D. Morris, (202) 512-3841 or morriss@gao.gov

Staff Acknowledgments

In addition to the contact named above, Tahra Nichols (Assistant Director), Sahar Angadjivand,
Tara Congdon, Steve Cleary, Andy Furillo, Marc Meyer, Amanda Mullan, and Lillian Slodkowski
made key contributions to this report.




(104394)




Page 7                                                        GAO-20-711R Agriculture Spending
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