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USDA Coronavirus Disease 2019 Funding Engagement 50025-0001-23 (Office of Inspector General, September 2020)

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U.S. Department of Agriculture Office of Inspector General memorandum, USDA Coronavirus Disease 2019 Funding, Engagement 50025-0001-23, dated September 30, 2020, from Gil H. Harden, Assistant Inspector General for Audit, to G. Scott Soles, Principal Deputy Chief Financial Officer. The memorandum states that on May 28, 2020 OIG initiated a non-audit service to identify USDA's COVID-19 funding streams as of May 31, 2020. It states that the FFCR Act and the CARES Act provided more than $47.7 billion to USDA, that the Secretary transferred $6.5 billion from the Commodity Credit Corporation to support the Coronavirus Food Assistance Program, and that the funding sources total $54.3 billion, of which 64.2 percent has gone to the Food, Nutrition, and Consumer Services mission area.

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“USDA Coronavirus Disease 2019 Funding Engagement 50025-0001-23 (Office of Inspector General, September 2020).” Original at usdaoig.oversight.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/usda-covid19-funding/, SHA-256 3b9af1bd82e1a9f0cf82a3985e03f50e49c5fdf4049bab6310144333ed2753d6.

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     United States Department of Agriculture




USDA Coronavirus Disease 2019
Funding




Engagement 50025-0001-23
September 2020
                                               OFFICE OF INSPECTOR GENERAL
                                United States Department of Agriculture
                                         Office of Inspector General
                                           Washington, D.C. 20250


DATE:             September 30, 2020

ENGAGEMENT
NUMBER: 50025-0001-23

TO:               G. Scott Soles
                  Principal Deputy Chief Financial Officer
                  Office of the Chief Financial Officer

ATTN:             Annie Walker
                  Director
                  Office of the Chief Financial Officer

FROM:             Gil H. Harden
                  Assistant Inspector General for Audit

SUBJECT:          USDA Coronavirus Disease 2019 Funding

On May 28, 2020, we initiated a non-audit service to identify U.S. Department of Agriculture’s
(USDA) coronavirus disease 2019 (COVID-19) funding. 1 Our objective was to identify the
funding streams USDA used to respond to the COVID-19 pandemic as of May 31, 2020.
Specifically, we identified the programs, appropriations, and any other funding streams used; and
key controls and mechanisms, including applicable information systems for the identified
programs. To report the various funding streams, we reviewed agency websites, surveyed
Departmental mission area and agency officials, and identified sources of funding from
COVID-19 legislation as well as repurposed appropriations used for COVID-19 relief activities
through May 31, 2020. 2

Congress enacted four public laws in response to the COVID-19 pandemic, two of which
provided USDA with funding: the Families First Coronavirus Response (FFCR) Act on
March 18, 2020; 3 and the Coronavirus Aid, Relief, and Economic Security (CARES) Act on


1
  A non-audit service, also known as a consulting service, is a service other than an audit, attestation engagement,
inspection, evaluation, or investigation. A non-audit service consists of tasks or services consistent with auditors’
skills and expertise. Therefore, the data and information provided were not verified or analyzed, and no audit
procedures were performed on them.
2
  The Department submitted their spending plan to the Pandemic Response Accountability Committee on
September 3, 2020. The spending plan provided information appropriated by the Coronavirus Aid, Relief, and
Economic Security Act (CARES Act). We are reporting funding appropriated by both the CARES and Families
First Coronavirus Response (FFCR) Acts, as well as general appropriations transferred and repurposed for
COVID-19 response activities. Therefore, the numbers will not be the same.
3
  Families First Coronavirus Response Act, Pub. L. No. 116-127, 134 Stat. 178.
G. Scott Soles                                                                                                     2


March 27, 2020. 4, 5 As of May 31, 2020, these two laws provided more than $47.7 billion to
USDA for pandemic relief activities. 6 Additionally, the Secretary transferred $6.5 billion from
the Commodity Credit Corporation (CCC) to support the Coronavirus Food Assistance Program
(CFAP). 7

Finally, the Research, Education, and Economics (REE) and Farm Production and Conservation
(FPAC) mission areas repurposed $47.3 million for purposes related to COVID-19. 8 (See the
figure on the next page.) Other Departmental mission area agencies used some of their regular
appropriations—but did not formally allocate funds—to address expenses related to
COVID-19. Since this engagement identified appropriated or allocated funds, we are not
reporting COVID-19 funding expenses.

These funding sources total $54.3 billion. Of this amount, 64.2 percent has gone to the Food,
Nutrition, and Consumer Services mission area for nutrition programs. FPAC also received
29.5 percent of USDA’s COVID-19 funding to establish and administer CFAP, which was
created to provide assistance to agricultural producers impacted by the effects of the
COVID-19 outbreak. Additionally, the Marketing and Regulatory Programs mission area
received 5.7 percent for the Farmers to Families Food Box Program and salary expenses
associated with the Agriculture and Quarantine Inspection Program. Other mission areas
accounted for the remaining 0.5 percent of the COVID-19 funding. 9 For more detailed
information on how the Departmental mission areas and agencies plan to spend this money,
please see Exhibit A.


4
  Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136, 134 Stat. 281.
5
  In addition to the FFCR and CARES Acts, Congress passed the Coronavirus Preparedness and Response
Supplemental Appropriations Act, 2020, Pub. L. No. 116-123, 134 Stat. 146 (2020), and the Paycheck Protection
Program and Health Care Enhancement Act, Pub. L. No. 116-139, 134 Stat. 620 (2020). Together, these four
statutes authorized approximately $2.4 trillion in Federal spending.
6
  The FFCR Act provided the Secretary the authority to allocate additional funds for purposes related to COVID-19.
The Secretary allocated $2.1 billion for the Food, Nutrition, and Consumer Services mission area’s Pandemic
Electronic Benefits Transfer Program, an additional $1 billion for the Marketing and Regulatory Programs mission
area’s Farmers to Families Food Box Program, and an additional $14 billion for the Farm Production and
Conservation mission area’s Coronavirus Food Assistance Program 2. We are not including these amounts in our
funding totals, as they are outside the scope of our work. These allocations were made after May 31, 2020.
7
  CCC is a wholly-owned Government corporation created within the USDA by the CCC Charter Act. CCC funds
are used to implement specific programs established by Congress and carry out activities under the broad authorities
of the CCC Charter Act to stabilize, support, and protect farm income and prices; assist in maintaining balanced and
adequate agricultural commodities; and facilitate orderly agricultural commodities distribution. CCC is subject to
the general supervision and direction of the Secretary of Agriculture.
8
  The Office of Management and Budget (OMB) issued an exception that allows USDA to repurpose its Federal
assistance awards (in whole or part) to support the COVID-19 response, as consistent with applicable laws. OMB,
Repurposing Existing Federal Financial Assistance Programs and Awards to Support the Emergency Response to
the Novel Coronavirus (COVID-19), Apr. 9, 2020.
9
  As part of the CARES Act, Pub. L. No. 116-136, 134 Stat. 281, USDA’s OIG received $750,000 to provide
oversight of USDA funding received in the CARES Act. This is not included in the final total. Additionally, the
CARES Act reimbursed the CCC $14 billion for net realized losses. We are not including this number in the final
amount, as it is a reimbursement for losses already realized. Even though these funds were provided in the CARES
Act, the $14 billion is exempt from use for pandemic-related purposes. However, CCC officials told us that these
funds may or may not be used for pandemic-related purposes and were unable to provide an exact amount of
COVID-19 funding.
G. Scott Soles                                                                               3




The data and information contained in this report were obtained from the Office of the Chief
Financial Officer and appropriate Departmental mission area and agency officials. We also
obtained documentation to support the key controls and mechanisms, including applicable
information systems for the programs that received COVID-19 funding, from the mission area and
agency officials. We did not assess or evaluate this information and are not reporting on it.

This report contains information as a non-audit service; it does not provide conclusions,
findings, or recommendations, as we did not evaluate or validate any data or information
G. Scott Soles                                                                                               4


provided by Department officials. This non-audit service was conducted in accordance with
USDA OIG guidance, which also incorporates the applicable independence standards from
the Government Auditing Standards, American Institute of Certified Public Accountants
standards, and CIGIE Quality Standards for Inspection and Evaluation. All work
performed was not done in accordance with Generally Accepted Government Auditing
Standards or CIGIE Quality Standards for Inspection and Evaluation, except for
independence standards. However, before we performed this non-audit service, we
determined that it would not impair our independence to perform audits, inspections,
attestation engagements, or any other future or ongoing reviews of the subject.

In recent and coming months, OIG will provide oversight for these funds. 10 Please see our OIG
COVID-19 Oversight Plan for more information on our work. To see our progress and the
results of our oversight activities, please visit our pandemic-related reports. 11




10
   USDA OIG, OIG COVID-19 Oversight Plan (Apr. 2020), https://www.usda.gov/oig/reports/oig-plan-oversight-
covid-19-funding.
11
   USDA OIG, Other Inspector General Reports, https://www.usda.gov/oig/reports/inspector-general-reports.
Exhibit A: USDA COVID-19 Funding by Mission Area and Agency

   Mission Area/
                              Amount            Legislative          Assistance                  Eligible
      Agency/
                            (thousands)          Source                Type                     Recipients
 Program Activities
                           Farm Production and Conservation
 Farm Service Agency (FSA)
    Coronavirus        $9,500,000 CARES Act direct payments                             Government—
    Food Assistance                             with                                    Federally-recognized
    Program                                     unrestricted                            Tribal Governments,
                                                use 12                                  individuals/families,
                                                                                        profit organizations
     Coronavirus               $6,500,000 CCC Charter             direct payments       Government—
     Food Assistance                      Act                     with                  Federally-recognized
     Program                                                      unrestricted use      Tribal Governments,
                                                                                        individuals/families,
                                                                                        profit organizations
    Salaries and            $3,000 CARES Act                      not applicable        N/A
    Expense                                                       (N/A)
 Natural Resources Conservation Service (NRCS)
    Environmental         $25,000 2018 Farm                       salaries and          Government—
    Quality                          Bill 13                      expenses, direct      Federally-recognized
    Incentives                                                    payments for          Tribal Governments,
    Program                                                       specified use 14      individuals/families,
                                                                                        anyone/general public
 Subtotal                    $16,028,000




12
   “Direct payments with unrestricted use” are financial assistance from the Federal Government provided directly to
beneficiaries who satisfy Federal eligibility requirements with no restrictions being imposed on the recipient as to
how the money is spent. Included are payments under retirement, pension, and compensatory assistance listings.
13
   Agriculture Improvement Act of 2018, Pub. L. No. 115-334, 132 Stat. 4490 (2018 Farm Bill).
14
   “Direct payments for specified use” are financial assistance from the Federal Government provided directly to
individuals, private firms, and other private institutions to encourage or subsidize a particular activity by
conditioning the receipt of the assistance on a particular performance by the recipient. This does not include
solicited contracts for the procurement of goods and services for the Federal Government.
   Mission Area/
                                Amount            Legislative           Assistance                   Eligible
      Agency/
                              (thousands)          Source                 Type                      Recipients
 Program Activities
                                          Food Safety
 Food Safety and Inspection Service (FSIS)
   Cooperative              $33,000 CARES Act salaries and                                  Government—States 16
   Agreements with                                   expenses,
   States for                                        project grants 15
   Intrastate Meat
   and Poultry
   Inspection
   Meat, Poultry,                                    salaries and                           individuals/families,
   and Egg Products                                  expenses,                              profit organizations,
   Inspection                                        provision of                           other private
                                                     specialized                            organizations
                                                     services 17
 Subtotal                   $33,000
                           Food, Nutrition, and Consumer Services
 Food and Nutrition Service (FNS)
   Child Nutrition       $8,800,000 CARES Act formula                                       Government—States,
   Programs                                          grants 18                              local, 19 U.S. territories
                                                                                            and possessions;
                                                                                            public/private nonprofit
                                                                                            organizations
     Supplemental             $15,510,000 CARES Act                  formula grants,        Government—States,
     Nutrition                                                       project grants,        U.S. territories and
     Assistance                                                      direct payments        possessions
     Program—                                                        for specified
     Contingency                                                     use, salaries and
     Reserve                                                         expenses
     Supplemental            $8,858,000 20       FFCR Act            formula grants, Government—States,
     Nutrition                                                       project grants,   U.S. territories and
     Assistance                                                      direct payments possessions
     Program                                                         for specified
     (Pandemic EBT)

15
   “Project grants” are the funding, for fixed or known periods, of specific projects. Project grants can include
fellowships, scholarships, research grants, training grants, traineeships, experimental and demonstration grants,
evaluation grants, planning grants, technical assistance grants, survey grants, and construction grants.
16
   Within this report, “States” includes the District of Columbia.
17
   “Provision of specialized services” are assistance listings that provide Federal personnel directly to perform
certain tasks for the benefit of communities or individuals. These services may be performed in conjunction with
non-Federal personnel, but involve more than consultation, advice, or counseling.
18
   “Formula grants” are allocations of money to States or their subdivisions in accordance with distribution formulas
prescribed by law or administrative regulation, for activities of a continuing nature not confined to a specific project.
19
   Includes State-designated Tribes.
20
   The FFCR Act appropriated to the Secretary such amounts as are necessary to carry certain provisions of the act.
As of May 31, 2020, the Secretary allocated more than $8.85 billion for the Pandemic EBT Program.
  Mission Area/
                       Amount      Legislative     Assistance               Eligible
     Agency/
                     (thousands)    Source           Type                  Recipients
Program Activities
                                                 use, salaries and
                                                 expenses
  Nutrition             $200,000 CARES Act       project grants,   Government—U.S.
  Assistance for                                 direct payments territories and
  Puerto Rico                                    for specified     possessions
  American Samoa                                 use
  and the
  Commonwealth
  of the Northern
  Mariana Islands
  Nutrition             $100,000 FFCR Act        project grants,     Government—U.S.
  Assistance for                                 direct payments     territories and
  Puerto Rico,                                   for specified       possessions
  American Samoa                                 use
  and the
  Commonwealth
  of the Northern
  Mariana Islands
  Commodity             $450,000 CARES Act       formula grants      Government—States
  Assistance
  Program
  Commodity             $400,000 FFCR Act        formula grants      Government—States
  Assistance
  Program
  Food                  $100,000 CARES Act       direct payments     Government—States,
  Distribution                                   for specific use,   Federally-recognized
  Program on                                     project grants,     Tribal Governments;
  Indian                                         sale, exchange,     public nonprofit
  Reservations                                   or donation of      organizations, other
                                                 property and        public organizations,
                                                 goods               non-Government
                                                                     organizations
  Special               $500,000 FFCR Act        formula grants,     Government—State,
  Supplemental                                   project grants      local, and
  Nutrition                                      (discretionary)     Federally-recognized
  Program for                                                        Governments, U.S.
  Women, Infants,                                                    territories; private
  and Children                                                       nonprofit organizations
Subtotal             $34,918,000
   Mission Area/
                              Amount            Legislative          Assistance                  Eligible
      Agency/
                            (thousands)          Source                Type                     Recipients
 Program Activities
                            Marketing and Regulatory Programs
 Agricultural Marketing Service (AMS)
   Food Box           $3,000,000 21 FFCR Act        sales, exchange,                    nonprofit and
   Distribution                                     or donation of                      governmental
   Program                                          property and                        organizations 22
                                                    goods
   Marketing                $45,000 CARES Act N/A                                       N/A
   Services—
   Salaries and
   Expenses
 Animal and Plant Health Inspection Service (APHIS)
   Salaries and             $55,000 CARES Act N/A                                       N/A
   Expenses—
   Agriculture
   Quarantine and
   Inspection
   Program
 Subtotal                      $3,100,000
                                   Natural Resources and Environment
 Forest Service (FS)
   Capital                $26,800 CARES Act                       N/A                   N/A
   Improvement and
   Maintenance
   Forest and               $3,000 CARES Act                      N/A                   N/A
   Rangeland
   Research
     Research Joint Venture and Cost                              direct payments       Government—States, 23
     Reimbursable Agreements                                      for specified         Federal; other
                                                                  use                   public/private
                                                                                        organizations
     National Forest              $34,000 CARES Act
     System—
     Recreation
     Heritage and
     Wilderness



21
   The FFCR Act appropriated to the Secretary such amounts as are necessary to carry out certain provisions of the
act. As of May 31, 2020, the Secretary allocated $3 billion for the Food Box Distribution Program.
22
   Food banks, food pantries, churches, schools, and community groups.
23
   Public institutions of higher education and hospitals.
   Mission Area/
                      Amount                     Legislative           Assistance              Eligible
      Agency/
                    (thousands)                   Source                 Type                 Recipients
 Program Activities
      Law Enforcement Agreements                                    cooperative        Government—general,
                                                                    agreements         States, 24 local, 25 State
                                                                                       cooperators. 26
         Partnership Agreements                                     direct payments    Government—general,
                                                                    for specified      State, 27 local, 28
                                                                    use, direct        Federally-recognized
                                                                    payments for       Tribal Governments,
                                                                    specified use      U.S. territories and
                                                                    (cooperative       possessions; public
                                                                    agreements)        nonprofit
                                                                                       organizations, 29 other
                                                                                       public organizations,
                                                                                       private nonprofit
                                                                                       organizations, 30 quasi-
                                                                                       public nonprofit
                                                                                       organizations, Native
                                                                                       American
                                                                                       organizations 31
         Schools and Roads—Grants to States                         cooperative        Government—States,
                                                                    agreements,        local, 32 U.S. territories
                                                                    formula grants     and possessions
 Wildland Fire              $7,000 CARES Act
 Management
      Cooperative Forestry Assistance                               project grants,    Government—States, 33
                                                                    formula grants     local, 34 U.S. territories
                                                                                       and possessions; private
                                                                                       nonprofit
                                                                                       organizations 35




24
   Public institutions of higher education and hospitals.
25
   State-designated Tribes, excludes institutions of higher education and hospitals.
26
   Any State or political subdivision (that is, local governments).
27
   Public institutions of higher education and hospitals.
28
   State-designated Tribes, excludes institutions of higher education and hospitals.
29
   Institutions of higher education and hospitals.
30
   Institutions of higher education and hospitals.
31
   Tribal groups, cooperatives, corporations, partnerships, associations.
32
   State-designated Tribes, excludes institutions of higher education and hospitals.
33
   Public institutions of higher education and hospitals.
34
   State-designated Tribes, excludes institutions of higher education and hospitals.
35
   Institutions of higher education and hospitals.
   Mission Area/
                        Amount                  Legislative         Assistance                  Eligible
      Agency/
                      (thousands)                Source               Type                     Recipients
 Program Activities
      Partnership Agreements                                     direct payments       Government—general,
                                                                 for specified         State, 36 local, 37
                                                                 use,                  Federally-recognized
                                                                 direct payments       Tribal Governments,
                                                                 for specified         U.S. territories and
                                                                 use                   possessions; public
                                                                 (cooperative          nonprofit
                                                                 agreements)           organizations, 38 other
                                                                                       public organizations,
                                                                                       private nonprofit
                                                                                       organizations, 39
                                                                                       quasi-public nonprofit
                                                                                       organizations, Native
                                                                                       American
                                                                                       organizations 40
 Subtotal                    $70,800
                              Research, Education and Economics
 National Institute of Food and Agriculture (NIFA)
   Agriculture and           $21,100 discretionary project grants                      Government—Federal,
   Food Research                       funds 41                                        State, 42 public
   Initiative—                                                                         nonprofit
   Foundation and                                                                      organizations, 43
   Applied Science                                                                     individuals/families,
   Program                                                                             profit organizations,
                                                                                       quasi-public nonprofit
                                                                                       organizations
   Small Business                   $1,200 discretionary         project grants        small businesses (less
   Innovation                              funds 44                                    than 500 employees)
   Research
   Program—Phase
   I
 Subtotal                         $22,300

36
   Public institutions of higher education and hospitals.
37
   State-designated Tribes, excludes institutions of higher education and hospitals.
38
   Institutions of higher education and hospitals.
39
   Institutions of higher education and hospitals.
40
   Tribal groups, cooperatives, corporations, partnerships, associations.
41
   Competitive, Special, and Facilities Research Grant Act, Pub. L. 89-106 (section 2), amended through
Pub. L. 115-334 (August 4, 1965).
42
   Public institutions of higher education and hospitals.
43
   Institutions of higher education and hospitals.
44
   National Defense Authorization Act for Fiscal Year 2017, Pub. L. 114-328, 1130 Stat. 2001(enacted
Dec. 23, 2016).
   Mission Area/
                                Amount            Legislative           Assistance                   Eligible
      Agency/
                              (thousands)          Source                 Type                      Recipients
 Program Activities
                                                 Rural Development
 Rural Business Service (RBS)
   Business and            $19,885 CARES Act                         guaranteed/            Government—
   Industry CARES                                                    insured loans          Federally-recognized
   Act Program                                                                              Tribal Governments,
                                                                                            public bodies, 45
                                                                                            nonprofit/profit
                                                                                            organizations,
                                                                                            cooperative
                                                                                            organizations 46
   Salaries and                 $615 CARES Act                       N/A                    N/A
   Expense
 Rural Utilities Service (RUS)
   Distance                  $24,250 CARES Act                       project grants         Government—
   Learning and                                                                             Federally-recognized
   Telemedicine                                                                             Tribal Governments,
   Grants                                                                                   States, local
                                                                                            government entities,
                                                                                            nonprofit/profit
                                                                                            organizations, consortia
                                                                                            of eligible entities
     Rural e-                       $97,000 CARES Act                project grants         Government—
     Connectivity                                                                           Federally-recognized
     Pilot Program                                                                          Tribal Governments,
                                                                                            States, local or any
                                                                                            agencies, subdivisions,
                                                                                            instrumentalities, or
                                                                                            political subdivisions
                                                                                            thereof, U.S. territories
                                                                                            or possessions;
                                                                                            cooperatives,
                                                                                            nonprofits, or mutual
                                                                                            associations; profit
                                                                                            corporations or limited
                                                                                            liability companies



45
   A “public body” is a municipality, county, or other political subdivision of a State; a special purpose district; a
Tribe on a Federal or State reservation or other Federally-recognized Tribe; or an organization controlled by any of
the above.
46
   A “cooperative organization” is an entity that is legally chartered as a cooperative or an entity that is not legally
chartered as a cooperative, but is owned and operated for the benefit of its members, with returns of residual
earnings paid to such members on the basis of patronage.
   Mission Area/
                        Amount      Legislative    Assistance            Eligible
      Agency/
                      (thousands)    Source          Type               Recipients
 Program Activities
   Salaries and            $3,750 CARES Act       N/A            N/A
   Expense
 Subtotal                  $145,500
                           Trade and Foreign Agricultural Affairs
 Foreign Agricultural Service (FAS)
   Salaries and              $4,000 CARES Act N/A                 N/A
   Expense
 Subtotal                    $4,000
Total COVID-19          $54,321,600
Funding
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