USDA Farmers to Families Food Box Program, OAI Report 22-001-01 (Office of Inspector General, June 2022)

Summary

USDA Office of Inspector General OAI Report 22-001-01, USDA Farmers to Families Food Box Program, dated June 22, 2022, addressed to Bruce Summers, Administrator of the Agricultural Marketing Service (AMS). The transmittal states that the report is the first in a new data product called Data Stories, which uses unaudited AMS data, U.S. Census Bureau data and other sources to explore the program's distributors, food boxes and recipients. The attached AMS response states that the boxes cost between $1.80 and $150.00 per box depending on packaging, distribution and contents, that the average price was $27 per box in total, and that AMS did not collect household or individual recipient information. It also states that AMS considers the Opportunity Zone and zip code key takeaways misleading.

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    OFFICE OF INSPECTOR GENERAL
    U. S. DEPARTMENT OF AGRICULTURE




USDA Farmers to Families Food Box
Program




OAI Report 22-001-01
June 2022
                       OFFICE OF INSPECTOR GENERAL
                      United States Department of Agriculture

DATE:          June 22, 2022

PRODUCT
NUMBER:        22-001-01

TO:            Bruce Summers
               Administrator
               Agricultural Marketing Service

ATTN:          Wing Padilla
               Auditor
               Internal Audits Branch
               Compliance, Safety and Security Division

FROM:          Craig Goscha
               Acting Assistant Inspector General for Analytics and Innovation

The United States Department of Agriculture (USDA) Office of Inspector General (OIG) has
launched a new data product called Data Stories. This product’s purpose is to enhance
transparency of significant USDA programs using data analytics and visualizations while
integrating data storytelling methods.

The first in this series focuses on USDA’s Farmers to Families Food Box Program (Food Box
Program). Using unaudited data from USDA’s Agricultural Marketing Service (AMS), U.S.
Census Bureau data, Housing and Urban Development Opportunity Zone data, and other data
sources, OIG explores the program (distributors, food boxes, and recipients) and invites the
reader to examine the data in different ways.

AMS’ written response to the data story is included in its entirety at the end of the product and
this report. OIG applied the established Office of Analytics and Innovation quality assurance
standards to ensure the information presented in this product is adequately supported.

We appreciate the courtesies and cooperation extended to us by members of your staff during the
data story development. The product contains publicly available information and will be posted
in its entirety to our website (usdaoig.oversight.gov).



Attachment
Topic:      Response to Office of Inspector General Data Story – USDA Farmers to
            Families Food Box Program
______________________________________________________________________________

To:            Virginia E. Banner Rone, Virginia.Rone@oig.usda.gov
               Assistant Inspector General for Analytics and Innovation, Office of Inspector General

From:       Bruce Summers, Bruce.Summers@usda.gov         BRUCE   Digitally signed by
                                                                  BRUCE SUMMERS
            Administrator, Agricultural Marketing Service SUMMERS Date:  2022.04.22
                                                                  10:56:21 -04'00'
______________________________________________________________________________

The Agricultural Marketing Service (AMS) appreciates the Office of Inspector General’s (OIG)
interest and work necessary to present the data story. We also appreciate OIG for providing
AMS an opportunity to respond to the OIG’s Data Story – USDA Farmers to Families Food Box
Program. Below are our comments.

“Background” Section:

AMS would like to provide the following additional context to this section:

At the request of the Secretary, AMS designed and implemented a purchase program to respond
to a multifaceted and rapidly unfolding crisis caused by the onset of the COVID-19 Pandemic.
The loss of demand at restaurants and other retail outlets was causing produce to be left to rot in
the fields and milk to be dumped, among other food loss. At the same time, people were losing
their jobs and lining up at food banks for help. Drawing on their acquisition expertise, and with
support at all levels of the U.S. Department of Agriculture’s (USDA) management, the AMS
acquisition staff designed a purchase and distribution program that was up and running in
approximately a month.

“How Much Did the Boxes Cost?” Section:

AMS would like to provide additional context to the sentence “The map below shows the
distributors with the highest total boxes delivered, highest average cost per box, and the highest
contracted dollar amount used to purchase boxes.” AMS would like to clarify that the extreme
price range was driven primarily by box content, packaging, and distribution variables. As users
analyze the data, it should be noted that efforts to normalize or draw conclusions on cost data by
box may be difficult. Variability in box contents, even of similar product groupings, could
include higher-cost specialty crop items that may not be universally distributed geographically.
Box distributions were intended to reach often remote areas of the country and, thus, include
highly variable transportation costs, which are not visible in the overall blended cost of the box.
Although USDA differentiated box types for various product groupings, and while box types
varied greatly in size, contents, and destination, a “box” referenced in these data should not be
construed to a “one size fits all” type of analysis.

   •   Combination box price range: $10.30 - $150.00.
   •   Dairy box price range: $5.00 - $85.20.
   •   Milk box price range: $1.35 - $35.05.
   •   Produce box price range: $9.70 - $90.00.
   •   Meat box price range: $17.65 - $149.01.

Prices were evaluated as “fair and reasonable.” Price ranges were due to the following factors,
among others:

   •   Packaging. Box sizes (both in dimension and weight) varied, and some products were
       delivered in totes as agreed to by some food banks.
   •   Distribution. Deliveries were made to rural and difficult-to-reach places, such as remote
       Alaska, which is reachable only by plane. Transportation costs were likely one of the
       larger contributors to variations in box prices. Recall one of the key program drivers was
       to extend food support to areas of the country with the greatest need.
   •   Box Contents. Different prices for meat, dairy and produce. The commodity variety and
       quantity caused a range in box prices. Another key aspect of the program was to support
       American farmers, including those with higher-cost specialty crops. These higher-cost
       crops added layers of variability to the range of box prices.

Similarly, under Key Takeaways, the wide variance of $1.80 per box to $150.00 per box
depended on the packaging, distribution factors, and box contents. As a clarification, the cost of
the box was incurred by the Government, not the recipient agency or individual. The price range
is accurate but deserves additional explanation. As an example, the low price of $1.80 represents
a gallon of milk and the high range of $150 represents boxes that were shipped to remote parts of
Alaska via small plane. On average, boxes ranged from 10 to 25 pounds.

   •   Fresh Produce Box: Average price of $25 per box.
   •   Dairy Box: Average price of $33 per box.
   •   Meat Box (chicken and pork): Average price of $53.94 per box.
   •   Combination Box (produce, dairy, or meat): Average price of $62.56 per box.
   •   Fluid Milk: Average price of $12.78 per box.
   •   Total: Average price of $27 per box.

“Producers” Section:

The U.S. Government Accountability Office (GAO) report stated that “USDA did not
systematically collect and analyze data about producers necessary to assess the extent to which
the Food Box Program achieved its goal of supporting producers.”

At the request of the Secretary of Agriculture, AMS developed and implemented the
multi-billion dollar Food Box Program within a month. While critical vendor performance
                                                 2
information was the priority, the Administration’s most immediate priority was the urgent
distribution of perishable food, support of American farmers, and getting food to hungry
Americans. The aggressiveness of the rollout of the new program did not allow AMS sufficient
time to develop additional data collection and reporting needs to assess impacts to producers. In
addition, the USDA did not require this data to be collected. As the program progressed and
additional data was requested, AMS adapted to the extent possible. As an example, to assist with
planning and to ensure deliveries were distributed where it was most needed, AMS adapted the
type of information collected to provide better visibility on box deliveries nationwide.

“Recipients” Section:

Recipients are correctly defined as the non-profits that received the boxes. AMS collected the
name, city, and zip code of the non-profit to report food box delivery locations. AMS also
purchases food on behalf of USDA’s Food and Nutrition Service to support domestic nutrition
assistance programs, including The Emergency Food Assistance Program (TEFAP), but does not
collect recipient data beyond delivery locations. Therefore, the recipient data collected during
the Farmers to Families Food Box Program is consistent with data collected in other purchase
programs.

“Data Exploration: County View” Section:

Under Key Takeaways, GAO stated that “on average, 6,739 households living at/below poverty
by county received food boxes,” and “on average, 832 households living at/below poverty by
county did not receive food boxes.”

As clarification, AMS did not collect household or individual recipient information; instead,
AMS collected the names of the non-profit organizations and their location by city and zip code.
These individual locations more than likely served surrounding counties, zip codes, and
opportunity zones. AMS does not have data to validate the number of households that received
boxes. An attempt to utilize the non-profit’s city and zip code data to determine the number of
households that received food boxes is pure conjecture.

“Opportunity Zones View” Section:

AMS believes the following information presented as Key Takeaways is misleading:

   •   “21.7 percent of designated Opportunity Zones received food boxes.”
   •   “On average, 399 households living at/below poverty by Opportunity Zones received
       food boxes.”
   •   “On average, 351 households living at/below poverty by Opportunity Zones did not
       receive food boxes.”

AMS only tracked the zip code where the product was delivered – a field entered by the vendor.
As in other nutrition assistance programs, these destinations typically are warehouses or other
locations that then distribute food across a geographic area. If deliveries were made to a zip code


                                                3
within a county, more than likely people within the opportunity zones and other zip codes in that
county and surrounding counties received food.

AMS randomly selected seven food banks of various sizes and locations to illustrate how the
utilization of the delivery zip code to report on distribution to zip codes and opportunity zones is
misleading and erroneous. These food banks participate in TEFAP and received food boxes
through the Farmers to Families Food Box Program.

In the figure below, a report from AMS would show that 13 locations received products, each
within 1 county and with 1 zip code. The location may or may not be in an opportunity zone.
However, based on information pulled from these food bank’s websites on the counties served
by those locations, and using the counties to determine the potential number of zip codes and
opportunity zones served, the food banks serve over 100 counties, over 2,000 zip codes, and over
1,000 opportunity zones. Attempting to link only the limited data point of delivery locations to
zip codes and opportunity zones greatly understates the reach of both the TEFAP program and
the Farmers to Families Food Box Program.


                 Food Bank                     Number of Delivery   Counties Zip Codes Opportunity Zones
                                                  Locations          Served Served          Served
Los Angeles Regional Food Bank                        3                 1       290          274
Farm Share Inc. (Florida)                             5                67       961          427
Feedmore Western New York                             1                 4       155           41
Houston Food Bank                                     1                18       324          195
Utah Food Bank                                        1                29       284           46
Fredericksburg Regional Food Bank (Virginia)          1                 5        44           10
Greater Cleveland Food Bank                           1                 6       109           56

As illustrated, the data OIG used is insufficient to make the connection to opportunity zones and
zip codes, creating a misleading and inaccurate percentage.

“Zip Code View” Section:

Same comment as above with the Key Takeaways:

   •   “20.2 percent of zip codes received food boxes.”
   •   “On average, 1,232 households living at/below poverty by zip codes received food
       boxes.”
   •   “On average, 234 households living at/below poverty by zip codes did not receive food
       boxes.”




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