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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

July 2012: 

Trade Adjustment Assistance: 

USDA Has Enhanced Technical Assistance for Farmers and Fishermen, but 
Steps Are Needed to Better Evaluate Program Effectiveness: 

GAO-12-731: 

GAO Highlights: 

Highlights of GAO-12-731, a report to congressional committees. 

Why GAO Did This Study: 

Agricultural imports—-including imports of fruit, vegetables, seafood, 
and other commodities that directly compete with U.S. products—-have 
more than doubled over the last decade, according to data from USDA. 
The department’s TAA for Farmers program provides technical and 
financial assistance to producers of commodities certified by USDA as 
eligible for assistance. The Trade and Globalization Adjustment 
Assistance Act of 2009 reauthorized and amended the program and 
directed GAO to prepare and submit a report on the operation and 
effectiveness of the amendments. In particular, GAO examined (1) the 
commodities and producers USDA approved for assistance and the type 
and amount of assistance it provided, and (2) the approach USDA is 
taking to evaluate the program’s effectiveness and limitations, if 
any, in this approach. GAO analyzed USDA data and documents; 
interviewed USDA officials, their academic partners, producer groups, 
and commodity experts; and conducted fieldwork in two states to meet 
with producer groups for certified commodities. 

What GAO Found: 

The U.S. Department of Agriculture (USDA) certified relatively few 
commodities under its Trade Adjustment Assistance (TAA) for Farmers 
program, as reauthorized by the Trade and Globalization Adjustment 
Assistance Act of 2009, but provided assistance to most individual 
farmers and fishermen who produced certified commodities and applied 
for assistance. Specifically, USDA certified 5 of the 18 commodities 
for which it received petitions. As of April 2012, USDA approved 
9,852, or about 90 percent, of the applicants who produced a certified 
commodity to participate in the program. In addition, out of the 
$202.5 million in appropriations for the reauthorized program, USDA 
paid nearly $50 million in financial assistance to help producers 
implement long-term business plans in order to become more 
competitive. GAO identified two issues regarding USDA’s process for 
approving applications from spouses of producers and providing 
financial assistance: 

* USDA determined that producers’ spouses also shared in the risk of 
producing a commodity and could thus separately apply for assistance 
as individual producers. However, unlike other producers, spouses did 
not need to submit documentation showing how they contributed to and 
shared in the risk of production. USDA officials said they disapproved 
applications if spouses voluntarily disclosed that they did not 
contribute to producing a commodity but they likely approved 
applications from other spouses who similarly did not contribute. As a 
result, USDA did not have assurance that it targeted assistance to 
individuals who shared in the risk of production. 

* USDA made financial assistance payments without requiring producers 
to show that the assistance would be used for the intended purpose. 
Under the 2009 legislation, payments for completion of approved long-
term business plans are to be used to implement the plans, but 
approval of plans was not contingent on producers documenting how 
payments would be used. USDA officials said they received feedback 
that led them to believe that some producers used payments for 
unrelated expenses, such as housing costs. 

USDA’s approach to evaluating the TAA for Farmers program relies on 
performance measures and a series of surveys administered to 
producers. This approach provides USDA with data on producers’ 
completion of program requirements and perceptions of effectiveness, 
but the approach has several limitations that hinder USDA’s ability to 
fully determine the extent to which the program as a whole is 
effective. In particular, the performance measures do not measure 
outcomes, such as the percentage of producers who are able to remain 
in business. Leading practices indicate that outcome-oriented goals 
and quantifiable performance measures are important tools to determine 
if a program is achieving intended results. In addition, the time 
frame for administering the surveys is too short to gather producers’ 
perceptions of long-term effectiveness. Moreover, the surveys provide 
little information on producer perceptions of the program’s financial 
assistance, and USDA has not corroborated survey results by collecting 
data to help determine whether improvements in producers’ conditions 
are due to the program or some external factor. It can be difficult to 
isolate the causal impact of programs from other influences on 
outcomes, but the use of multiple sources of data can help overcome 
this challenge. 

What GAO Recommends: 

GAO recommends that, as part of any future TAA for Farmers program 
funding, USDA require spouses applying for assistance to submit 
documentation on how they contribute to producing a commodity, take 
steps to help ensure the program’s financial assistance is used for 
the intended purpose, and broaden its program evaluation approach. 
USDA generally agreed with the recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-12-731]. For more 
information, contact Lisa Shames at (202) 512-3841 or shamesl@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

USDA Certified Relatively Few Commodities but Has Provided Assistance 
to Most Covered Applicants: 

USDA's Program Evaluation Approach Relies on Performance Measures and 
Surveys That Do Not Fully Assess Effectiveness: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Commodities Certified and Denied for TAA for Farmers 
Assistance: 

Appendix III: Technical and Financial Assistance Provided to Producers 
Approved for TAA for Farmers Assistance: 

Appendix IV: Comments from the U.S. Department of Agriculture: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: USDA's Use of $202.5 Million in Trade and Globalization 
Adjustment Assistance Act of 2009 Appropriations for the TAA for 
Farmers Program: 

Table 2: Commodities Certified for Assistance under the 2009 
Reauthorization of the TAA for Farmers Program: 

Table 3: Basis Cited by FAS for Denying Commodities under the 2009 
Reauthorization of the TAA for Farmers Program: 

Table 4: Number of TAA for Farmers Applicants as of April 2012, by 
Certified Commodity and Application Status: 

Table 5: Financial Assistance Provided to Producers as of April 2012, 
by Certified Commodity (Dollars in Millions): 

Figures: 

Figure 1: USDA Agency Roles in TAA for Farmers Program: 

Figure 2: Commodities and Geographic Areas Certified as Eligible for 
or Denied TAA for Farmers Assistance: 

Abbreviations: 

FAS: Foreign Agricultural Service: 

GPRA: Government Performance and Results Act of 1993, as amended: 

NIFA: National Institute of Food and Agriculture: 

Recovery Act: American Recovery and Reinvestment Act of 2009: 

TAA: Trade Adjustment Assistance: 

USDA: U.S. Department of Agriculture: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

July 12, 2012: 

The Honorable Max Baucus:
Chairman:
The Honorable Orrin G. Hatch:
Ranking Member:
Committee on Finance:
United States Senate: 

The Honorable Dave Camp:
Chairman:
The Honorable Sander Levin:
Ranking Member:
Committee on Ways and Means:
House of Representatives: 

Data from the U.S. Department of Agriculture (USDA) show that 
agricultural imports have more than doubled over the last decade. 
According to these data, the imports include fruit, vegetables, 
seafood, and other commodities that directly compete with U.S. 
agricultural products. USDA's Trade Adjustment Assistance (TAA) for 
Farmers program offers assistance to farmers and fishermen hurt by 
competition from such imports. In particular, the program provides 
help to individual producers of raw agricultural commodities, such as 
farmers and fishermen, to become more competitive in producing their 
current commodity or transitioning to a different commodity.[Footnote 
1] 

Producers apply for TAA for Farmers assistance through a two-step 
process, which USDA publicizes through its website, news releases, and 
other means when funding to implement the program is available. First, 
a group of producers of a particular commodity, or an association that 
represents producers, must submit a petition for certification of 
eligibility for assistance. Petitions cover all producers of that 
commodity in the United States or in one or more specifically 
identified states. Petitions must be submitted within the filing 
period announced by USDA and provide supporting information, such as 
national data showing that the commodity's price declined in the most 
recent year for which such data are available. Second, after USDA 
certifies a commodity as eligible, any producer of the commodity who 
is interested in participating in the program must apply for 
assistance within 90 days of the certification. The benefits of the 
program include both technical and financial assistance. The technical 
assistance, which must be completed within the 3-year period following 
a commodity's certification, includes a minimum of 12 hours of 
training geared toward improving producers' competitiveness, as well 
as assistance in developing business plans. Individuals who complete 
approved business plans are entitled to receive payments of up to 
$12,000 to help them implement the plans. 

The TAA for Farmers program was established by the Trade Act of 2002, 
which appropriated funding for the program at $90 million per year for 
fiscal years 2003 through 2007. In December 2006, we reported that the 
criteria for program eligibility were difficult for many producers to 
meet and that USDA spending for the program was well below the amount 
provided for by the Trade Act.[Footnote 2] We also reported that the 
program's technical and financial assistance appeared to assist 
producers in adjusting to the effects of import competition on a 
limited, short-term basis. Funding for the program lapsed in fiscal 
year 2008. 

The Trade and Globalization Adjustment Assistance Act of 2009, which 
was enacted as part of the American Recovery and Reinvestment Act of 
2009 (Recovery Act), reauthorized and amended the program.[Footnote 3] 
Appropriations for the reauthorized program were $90 million per year 
in fiscal years 2009 and 2010 and $22.5 million for the first quarter 
of fiscal year 2011.[Footnote 4] USDA accepted petitions and certified 
commodities under the reauthorized program in 2010 and later that year 
began providing assistance to producers of certified commodities. 
These producers have until 2013 to complete the program's technical 
assistance. The Trade Adjustment Assistance Extension Act of 2011 
reauthorized the program through the first quarter of fiscal year 2014 
but did not appropriate funds. USDA is continuing to spend funds to 
complete the program as reauthorized in 2009 but does not have funding 
to accept additional petitions for certification of commodities and 
continue the program. 

The 2009 legislation mandated that GAO prepare and submit a report on 
the operation and effectiveness of the amendments to the TAA for 
Farmers program. In response, we examined (1) the commodities and 
producers that USDA approved for assistance under the program as 
reauthorized in 2009 and the type and amount of assistance it provided 
and (2) the approach USDA is taking to evaluate the program's 
effectiveness and limitations, if any, in this approach. 

To examine the commodities and producers USDA approved for assistance 
and the type and amount of assistance it provided, we reviewed four 
key areas of the TAA for Farmers program as amended: the commodity 
certification process, the producer application process, technical 
assistance, and financial assistance. In particular, for commodity 
certification, we reviewed the criteria established by the 2009 
legislation for USDA to use when certifying commodities, petitions 
submitted by groups of commodity producers, and USDA's documentation 
explaining the basis for its decisions to certify or deny commodities. 
We examined the producer application process by reviewing eligibility 
requirements for individual producers of certified commodities and 
USDA data on applications from individual producers, including the 
numbers approved and disapproved and the reasons for disapproval. We 
examined the amount of technical and financial assistance USDA 
provided to approved producers by reviewing data from USDA. We 
assessed the reliability of USDA data by checking for obvious errors 
in accuracy and completeness and through other means. We determined 
that the data were sufficiently reliable for reporting on the number 
of approved and disapproved applicants and the amount of technical and 
financial assistance provided to producers. 

To examine the approach USDA is taking to evaluate the program's 
effectiveness and to identify any limitations in this approach, we 
reviewed USDA's performance measures for the program, and we analyzed 
surveys of producers participating in the program and preliminary 
survey results as of December 2011. We compared USDA's approach to 
principles for evaluating the effectiveness of programs, such as those 
embodied in the Government Performance and Results Act of 1993, as 
amended (GPRA), GAO guidance on designing evaluations, and federal 
standards for internal control. 

For further explanation regarding both of our objectives, we 
interviewed USDA officials, USDA's academic partners for organizing 
and overseeing the program's technical assistance, and a 
nonprobability sample of producer groups that submitted petitions. 
Because we selected a nonprobability sample of producer groups to 
interview, the information we obtained from these interviews cannot be 
generalized to other groups. The interviews instead provided us with 
the perspectives of various producer groups about the program. We also 
interviewed the USDA Office of the Inspector General team conducting a 
separate review of the TAA for Farmers program. We planned our audit 
to minimize duplication in areas evaluated by the Office of Inspector 
General, such as USDA internal controls over the application of 
eligibility requirements for individual producers. Appendix I presents 
a more detailed description of the scope and methodology of our review. 

We conducted this performance audit from September 2011 to July 2012 
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 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

In its amendments to the TAA for Farmers program, the Trade and 
Globalization Adjustment Assistance Act of 2009 changed the program in 
four key areas: 

* Commodity certification. The act changed the criteria for groups of 
commodity producers to demonstrate they had been harmed by import 
competition and for USDA to certify commodities. Prior to the 
amendments, USDA certified a commodity if (1) imports of a "like or 
directly competitive" commodity--that is, imports that are 
substantially identical in inherent or intrinsic characteristics or 
substantially equivalent for commercial purposes--had increased and 
(2) the average price of the commodity submitted for certification 
decreased by more than 20 percent compared to the average of the 
previous 5 years. If these two criteria were met, USDA had to 
determine that the imports contributed importantly to the decrease in 
price, with "contributed importantly" defined by the TAA for Farmers 
legislation as a cause that is important but not necessarily more 
important than any other cause. Under the 2009 reauthorization, 
imports must have increased compared to the average of the previous 3 
years. In addition, the act lowered the threshold for a decrease in 
price to more than 15 percent compared to the average of the previous 
3 years. Furthermore, the act allowed groups of commodity producers to 
demonstrate harm on the basis of a more than 15 percent decrease in 
any one of three factors other than price: quantity of production, 
value of production, and cash receipts. The act retained the criterion 
for an increase in imports to have contributed importantly to a 
commodity's harm. 

* Producer application. The act eliminated a requirement that a 
producer of a certified commodity experience a decline in net farm 
income. The act instead required a producer to have produced the 
commodity in the year covered by a certification and in at least 1 of 
the 3 years preceding the certification. In addition, the act required 
a producer to demonstrate a decrease in the individual producer's 
production quantity, or a decrease in the commodity's price--either 
the actual price received by the producer or the average price at the 
local level. Moreover, the act required that individual producers' 
applications for assistance include sufficient information to 
establish that a producer is not receiving benefits under another TAA 
for Farmers petition or under related TAA programs for workers or 
firms. 

* Technical assistance. The act modified the technical assistance 
benefit that the program provides to eligible producers, which 
previously consisted of a workshop and counseling to improve 
competitiveness and profitability. Specifically, the act provided for 
a series of courses to help producers become more competitive in 
producing their current commodity or to transition to producing 
another commodity, and it required that eligible producers complete 
initial and long-term business plans before receiving financial 
assistance. The act specified that for an initial business plan to be 
approved, it must reflect the skills producers gained through the 
program's courses and demonstrate how those skills are to be applied 
to the circumstances of the producer. The act also specified criteria 
for approval of long-term business plans, including that plans 
incorporate steps to adjust to changing market conditions, take into 
consideration the interests of workers employed by producers, and 
demonstrate sufficient resources to implement the plans. 

* Financial assistance. The act eliminated a formula that USDA was 
previously required to use to calculate the amount of financial 
assistance to a producer. The act instead entitled producers who 
complete an approved initial business plan to receive payments of up 
to $4,000 to implement the plan or develop a long-term business plan. 
The act further entitled producers who complete an approved long-term 
business plan to receive additional payments of up to $8,000 to 
implement the plan. 

The Foreign Agricultural Service (FAS), which works to improve foreign 
market access for U.S. products, is the lead USDA agency for 
administering the TAA for Farmers program and is responsible for 
accepting petitions for assistance from groups or associations of 
commodity producers and certifying or denying commodities. After the 
reauthorization of the program in February 2009, FAS began developing 
regulations for the program, as amended, and completed the regulations 
in March 2010. FAS accepted petitions under the reauthorized program 
during two filing periods, first under the program's fiscal year 2010 
appropriation of $90 million and then under the fiscal year 2011 
appropriation of $22.5 million. Both filing periods occurred in 2010 
after FAS completed regulations for the program--the first from March 
11 through April 14, and the second from May 21 through July 16. The 
second filing period presented producer groups with an opportunity to 
resubmit petitions filed during the first period, either to provide 
additional supporting information (for denied commodities) or to 
petition for recertification of a commodity and thereby extend the 90-
day postcertification period in which individual producers could apply 
for assistance (for certified commodities). 

In addition to FAS, several other USDA agencies play or have played a 
role in implementing the program. The Economic Research Service, which 
conducts economic research and provides information related to 
agriculture, conducted analyses after FAS received petitions to verify 
the decline in the price, quantity of production, value of production, 
or cash receipts for petitioned commodities and to assess possible 
causes, including imports. A petition review committee with 
representatives from four USDA agencies--the Office of the Chief 
Economist, the Farm Service Agency, the Agricultural Marketing 
Service, and FAS--reviewed the analyses and made recommendations to 
FAS to certify or deny commodities. For commodities that FAS 
certified, the Farm Service Agency, which administers programs for 
farmers and ranchers, drew on its network of state and county offices 
to establish a system for accepting and approving individual 
applications for assistance and distributing payments to approved 
producers who have completed relevant program requirements. The 
National Institute of Food and Agriculture (NIFA), which supports 
state and local research and education efforts related to agriculture, 
administers the program's technical assistance component. After the 
2009 reauthorization of the program, NIFA entered into a cooperative 
agreement with a lead academic partner--the Center for Farm Financial 
Management at the University of Minnesota, which had been involved in 
implementing the initial TAA for Farmers program--to organize and 
oversee the program's technical assistance. The Center for Farm 
Financial Management established relationships with other academic 
partners across the country to promote the availability of assistance 
to producer groups and individual producers of certified commodities 
and to coordinate the delivery of technical assistance. Figure 1 
depicts the roles of these agencies in administering the program. 

Figure 1: USDA Agency Roles in TAA for Farmers Program: 

[Refer to PDF for image: illustration] 

Foreign Agricultural Service (FAS): 
Accept petitions for commodity certification.      

Economic Research Service: 
Conduct analyses of petitions for commodity certification. 

Petition review committee[A]: 
Recommend commodity certification or denial. 

Foreign Agricultural Service (FAS): 
Certify or deny commodities. 

Farm Service Agency: 
Process individual applications[B]. 

National Institute of Food and Agriculture (NIFA): 
Administer technical assistance. 

Farm Service Agency: 
Distribute financial assistance payments. 

Source: GAO analysis of USDA information. 

[A] The petition review committee includes representatives from four 
USDA agencies: the Office of the Chief Economist, the Farm Service 
Agency, the Agricultural Marketing Service, and FAS. 

[B] The Farm Service Agency approves applications, and FAS decides 
whether to disapprove applications that do not meet eligibility 
requirements and whether to approve or deny appeals. 

[End of figure] 

The TAA for Farmers program is one of four trade adjustment assistance 
programs; the other three provide assistance for workers, firms, and 
communities harmed by international trade. Under the TAA for Workers 
program, the Department of Labor provides services and benefits, such 
as training and re-employment services and income support, to eligible 
workers in manufacturing and service industries. The Department of 
Commerce administers a TAA program that provides funds for 
manufacturing and other types of firms to develop and implement a 
business recovery plan. Under a TAA program to assist trade-affected 
communities, the Department of Labor awards grants to institutions of 
higher education for expanding or improving education and career 
training programs for persons eligible for training under the TAA for 
Workers program, and the Department of Commerce provides technical 
assistance to trade-affected communities and awards and oversees 
strategic planning and implementation grants. In addition to mandating 
that GAO report on the TAA for Farmers program, the Trade and 
Globalization Adjustment Assistance Act of 2009 mandated that GAO 
report on the other TAA programs. Our reports on the other TAA 
programs are forthcoming. 

USDA Certified Relatively Few Commodities but Has Provided Assistance 
to Most Covered Applicants: 

USDA certified relatively few commodities as eligible for assistance 
under the reauthorized TAA for Farmers program, but it has provided 
technical and financial assistance to most individual applicants who 
produced a certified commodity. Specifically, FAS, the lead agency for 
administering the program, certified 5 of the 18 commodities for which 
it received petitions under the reauthorized program. For the 5 
certified commodities, the Farm Service Agency approved most 
applications from individual producers, including from producers' 
spouses, who were not required to show how they contributed to 
production. Producers who were approved to participate in the program 
received technical assistance that was tailored to their individual 
needs. In addition, as of April 2012, the Farm Service Agency paid 
close to $50 million in financial assistance to producers who 
completed initial and long-term business plans. The Trade and 
Globalization Adjustment Assistance Act of 2009 specifies that 
producers are to use payments for long-term business plans to 
implement those plans; however, approval of long-term business plans 
was not contingent on producers documenting how payments would be used 
to implement the plans. 

FAS Certified Relatively Few Commodities: 

FAS certified 5 of the 18 commodities for which it received petitions 
under the reauthorized program (see figure 2). The commodities for 
which FAS received petitions included seafood and specialty crops, 
such as fruits and vegetables, as opposed to commodities such as 
grains. Two of the 5 certifications--for asparagus and catfish--
covered producers nationwide. All other petitions covered producers of 
a commodity in a particular state or group of states. (See appendix II 
for further information on the certified and denied commodities.) 

Figure 2: Commodities and Geographic Areas Certified as Eligible for 
or Denied TAA for Farmers Assistance: 

[Refer to PDF for image: list] 

Certified commodities: 
Asparagus (nationwide); 
Catfish (nationwide); 
Lobster (Connecticut, Maine, Massachusetts, New Hampshire, and Rhode 
Island); 
Shrimp (Alabama, Alaska, Florida, Georgia, Louisiana, Mississippi, 
North Carolina, South Carolina, and Texas); 
Wild blueberries, frozen (Maine). 

Denied commodities: 
Apples (Maine, Michigan, Minnesota, and New York); 
Blue crabs (Georgia); 
Coffee (Hawaii and Puerto Rico); 
Cranberries (New Jersey, Oregon, and Washington); 
Crawfish (Louisiana); 
Cut lilies (Georgia, North Carolina, South Carolina, and Virginia); 
Lamb (Idaho, Montana, Ohio, Utah, and Wyoming); 
Multispecies fish[A] (Connecticut, Maine, Maryland, Massachusetts, New 
Hampshire, New Jersey, New York, and Rhode Island); 
Prunes (California); 
Spiny lobster (Florida); 
Tilapia (Arkansas); 
Wild blueberries, fresh (New Hampshire); 
Wool (Idaho, Kansas, Montana, Ohio, Utah, and Wyoming). 

Source: GAO analysis of USDA information. 

[A] Multispecies fish includes various species of fish, such as cod 
and halibut. 

[End of figure] 

The 2009 changes to the TAA for Farmers program's certification 
criteria were a factor in the decision to support 4 of the 5 commodity 
certifications, according to our review of the Economic Research 
Service's analyses of petitions under the reauthorized program and 
FAS's decision memos. For example, FAS would likely not have been able 
to certify asparagus or shrimp on the basis of a decrease in price--a 
requirement under the previous certification criteria--because the 
analysis of petitions for both commodities indicated that their prices 
had increased from the average of the 3 previous years. Under the 
modified certification criteria, FAS was instead able to certify these 
two commodities on the basis of a factor other than price, 
specifically a decrease in the quantity of production. For example, 
the Economic Research Service found that asparagus producers had 
reduced the number of acres harvested to adjust to the rapidly rising 
volume of imports. 

The most common reason FAS cited for denying commodities was that the 
petitions for such commodities did not meet the criteria for both an 
increase in imports and a decrease in price or another factor. For 
example, the Economic Research Service found that Hawaiian coffee met 
the criterion for a decrease in price, but FAS denied the commodity 
because coffee imports had declined. FAS also denied several 
commodities that it determined did not meet the criterion for imports 
to have contributed importantly to a decline in price or another 
factor. For example, according to FAS's documentation explaining the 
basis for its determination, the agency found that California prunes 
met the criteria for both an increase in imports and a decrease in 
price but that imports were not an important factor in determining the 
price. FAS instead determined that the price decline had been affected 
by an increase in domestic production and other factors. To support 
such determinations on whether imports contributed importantly to a 
commodity's harm, the Economic Research Service conducted qualitative 
analyses that examined the impact of other factors, such as domestic 
production, consumption, and exports. 

Through our interviews and analyses, we identified additional factors 
that contributed to FAS's denial of commodities. Because the 
certification criteria take into account a number of factors, it is 
difficult to identify these factors as the direct cause for a 
commodity being denied: 

* The time frame over which import competition had occurred. Under the 
certification criteria, a commodity can face competition from imports 
over a long time frame but still be denied if, in the year covered by 
the petition, imports that compete with the commodity do not increase 
compared to the average of the 3 previous years. For example, an FAS 
official said that Florida fishermen of spiny lobsters had competed 
against imports over a long time frame but that FAS denied the 
commodity because imports that compete with such lobsters declined in 
2009, the year covered by the petition and the most recent calendar 
year for which data were available during the period FAS accepted 
petitions under the reauthorized program. The FAS official attributed 
the decline in these imports to the economic recession. According to 
data compiled by the U.S. International Trade Commission, overall 
imports of agricultural products declined in 2009--a year 
characterized by a significant economic downturn. A USDA official who 
was a member of the committee that made recommendations to FAS to 
certify or deny petitions said that the certification criteria favor 
commodities that have experienced a surge in imports, as opposed to 
slow, steady erosion that occurs over time as a result of sustained 
competition from imports. 

* Information presented by producer groups in their petitions. The 
outcome of the certification process depended in part on information 
producer groups presented in their petitions, such as which states to 
include in a petition and whether to submit a petition for a commodity 
that is frozen or fresh. For example, FAS certified frozen wild 
blueberries from Maine on the basis of an Economic Research Service 
analysis showing that the commodity met the criteria for a decrease in 
price and an increase in imports. In contrast, FAS denied fresh wild 
blueberries from New Hampshire in part because the quantity of 
production--the factor cited in the petition for demonstrating harm 
from import competition--had increased rather than decreased. 

USDA Approved Most Individual Applications, Including from Spouses Who 
Were Not Required to Show They Contributed to Producing a Commodity: 

In contrast to the relatively small proportion of commodities that 
were certified as eligible for TAA for Farmers assistance, most 
applications submitted by individual producers of certified 
commodities were approved. Specifically, as of April 2012, the Farm 
Service Agency had approved 9,852, or about 90 percent, of the 
approximately 11,000 applications from individual producers. 

The shrimp and lobster certifications accounted for 8,596 (87 percent) 
of the approved applications, and the asparagus, catfish, and frozen 
wild blueberry certifications accounted for the remaining 1,256 (13 
percent). The distribution reflects the relative numbers of fishing or 
farming operations for the certified commodities. For example, 
according to data collected by the Maine Department of Marine 
Resources, in 2011 there were 4,341 active commercial lobster 
harvesters in the state (one of the five states covered by the 
certification for lobster). In contrast, according to USDA data, in 
2011 there were 389 catfish operations in Alabama, Arkansas, and 
Mississippi, which are the three major catfish producing states. (See 
appendix III for additional detail on individual applications.) 

FAS officials said the agency took steps to broaden the scope of 
individuals eligible to apply for assistance in order to implement the 
program as reauthorized in 2009 and to increase program participation. 
For example, FAS determined that certain employees of eligible 
producers of certified commodities, such as crew members helping to 
harvest lobster or shrimp, met the definition of agricultural 
commodity producers as sharing in the risk of producing a commodity 
and could thus separately apply for assistance as individuals. To be 
approved for assistance, such individuals needed to provide sufficient 
documentation to establish that they were paid through a share of 
production--for example, by being paid through a portion of a lobster 
or shrimp catch. 

FAS determined that spouses of eligible producers also shared in the 
risk of producing a commodity and could thus separately apply for 
assistance as individual producers. For example, according to the lead 
FAS official for the TAA for Farmers program, a spouse could share in 
the risk by performing the same type of work as a crew member. 
However, unlike crew members, spouses did not need to submit 
documentation showing their contribution to and share in the risk of 
producing a certified commodity. Several FAS officials said the agency 
disapproved the applications of spouses who voluntarily disclosed 
information indicating that they did not contribute to producing a 
certified commodity. The officials said that, because such information 
was not required, they likely approved applications from other spouses 
who did not contribute, but they did not have an estimate of the 
potential number of such spouses. Without requiring spouses applying 
for assistance as individual producers to submit documentation on how 
they contributed to producing a certified commodity, FAS did not have 
assurance that it targeted assistance to individuals who shared in the 
risk of production. 

FAS disapproved about 10 percent of applications from individual 
producers for various reasons, such as when applicants did not provide 
evidence of producing a certified commodity in the year covered by the 
petition. According to an FAS official, the legislative requirement to 
have produced a commodity in the petition year excluded certain 
blueberry growers because the crop is generally harvested every other 
year, and not all Maine growers harvested their crop in the year 
covered by the certification. Other reasons for FAS disapproval of 
applications included individuals not submitting an application within 
the 90-day period following a commodity's certification, not being a 
U.S. citizen or lawful alien, or receiving benefits under another TAA 
for Farmers petition or under one of the TAA programs for workers or 
firms. 

USDA Provided Most Applicants with Technical Assistance Tailored to 
Individual Needs: 

According to Farm Service Agency data, as of April 2012, 7,781 
producers, or about three-quarters of the 9,852 producers approved to 
participate, had fully or partially completed the TAA for Farmers 
technical assistance, including training and the development of 
business plans. Specifically, 5,073 producers had completed the 12 
hours of required training and the development of initial and long-
term business plans. Another 2,708 producers had completed the 
training and submitted an approved initial business plan but had not 
yet submitted an approved long-term business plan. (See appendix III 
for more detail.) 

According to our analysis, the applicants received technical 
assistance tailored to their individual needs. Specifically, NIFA's 
academic partners responsible for coordinating the technical 
assistance took the following steps: 

* Commodity-specific courses. Because of the differences among 
commodities, NIFA's academic partners developed separate courses for 
each certified commodity. For example, courses for lobstermen included 
information on how to harvest more efficiently and reduce fuel 
consumption, and courses for wild blueberry growers included 
fertilizer management practices to optimize inputs and reduce costs. 
In some cases, the courses also provided information on alternatives 
to producing the certified commodity. For example, the courses for 
shrimpers included information on obtaining licenses needed to operate 
a charter fishing boat. Courses could be taken in person and through a 
website. 

* One-on-one business planning assistance. NIFA's academic partners 
assigned business consultants to provide one-on-one assistance to 
approved producers in developing long-term business plans. At a 
meeting of business consultants we attended, the consultants described 
various ways they helped producers develop or improve on their 
business plans--for example, by explaining financial statements and 
helping analyze the financial impact of a business expansion. 

USDA Paid Close to $50 Million in Financial Assistance but Did Not 
Require That Producers Show How Assistance Would Be Used: 

According to USDA summary data, the department obligated $81.1 
million, or 40 percent of the $202.5 million in Trade and 
Globalization Adjustment Assistance Act of 2009 appropriations for the 
TAA for Farmers program, for financial assistance payments to 
producers. As of April 2012, the Farm Service Agency paid close to $50 
million of the $81.1 million obligated for financial assistance 
payments. The remainder of the obligated funds went toward USDA costs 
for administering the program and the cooperative agreement with 
NIFA's lead academic partner for organizing and overseeing the 
program's technical assistance. In addition, USDA did not obligate all 
of the appropriated funds because, for example, FAS did not complete 
regulations for the amended program until March 2010 and thus was not 
able to use fiscal year 2009 funding to make financial assistance 
payments to producers. The funds that were not obligated are no longer 
available for implementation of the program. (See table 1 on USDA's 
use of appropriations for the program.) 

Table 1: USDA's Use of $202.5 Million in Trade and Globalization 
Adjustment Assistance Act of 2009 Appropriations for the TAA for 
Farmers Program: 

Category: Financial assistance payments; 
Amount: $81.1 million; 
Percentage: 40%. 

Category: USDA administrative costs; 
Amount: $12.0 million; 
Percentage: 6%. 

Category: Cooperative agreement for organizing and overseeing 
technical assistance; 
Amount: $34.0 million; 
Percentage: 17%. 

Category: Not obligated; 
Amount: $75.3 million; 
Percentage: 37%. 

Category: Total; 
Amount: $202.5 million; 
Percentage: 100%. 

Source: GAO analysis of USDA data. 

Note: Dollar figures do not add up to $202.5 million due to rounding. 

[End of table] 

The final amount of payments will depend on the number of approved 
business plans that producers complete within the 3-year period 
following FAS's certification of commodities under the 2009 
reauthorization of the program. For plans that do not initially meet 
the criteria for approval, individuals may continue to work on plans 
and resubmit them. The nearly $50 million paid as of April 2012 
included: 

* about $20.2 million to producers who had completed initial business 
plans that met the criteria for approval, 

* about $29.5 million to producers who had completed long-term 
business plans that met the criteria for approval, and: 

* about $60,000 for producers' transportation and related expenses to 
attend an initial orientation to the program. 

Spouses that completed business plans received separate payments. 
According to guidance for the program, a spouse of a producer had to 
complete a separate business plan before receiving a payment, but the 
plans of a spouse and a producer could be nearly identical. 

[Side bar: 
Asparagus and Wild Blueberries: Asparagus and blueberries are examples 
of specialty crops, defined in law as fruits and vegetables, tree 
nuts, dried fruits, and horticulture and nursery crops, including 
floriculture. Unlike wheat, feed grains, cotton, and other 
commodities, specialty crops are not a covered commodity for purposes 
of direct income support under Title I of the 2008 Farm Bill. 
According to USDA, specialty crops represent about half of the total 
value of U.S. crop production. 

Asparagus: Asparagus is a labor-intensive crop grown primarily in 
California, Michigan, and Washington. About 75 percent of asparagus 
produced in the United States in 2009 was intended for the fresh-
market, with the remainder of the crop being canned or frozen. 
According to USDA, the value of the U.S. asparagus crop reached close 
to $97 million in 2011. 

Wild blueberries: Wild blueberries are indigenous to Maine and are 
grown on a 2-year cycle, with new plants emerging the first year after 
mowing or burning of harvested fields and berries being harvested the 
second year. According to USDA, Maine accounts for the vast majority 
of U.S. wild blueberry production, with a preliminary summary for
2011 showing that the crop's value exceeded $71 million. End of side 
bar] 

Some producers received full financial assistance payments of $4,000 
for completion of an initial business plan and an additional $8,000 
for completion of a long-term business plan. Specifically, the fiscal 
year 2010 appropriation for the TAA for Farmers program was sufficient 
to allow full payments to producers approved under certifications from 
the first petition filing period (March through April 2010), which 
included certifications for asparagus, catfish, and shrimp. In 
contrast, FAS determined that it needed to prorate payments to 
producers approved under certifications from the second filing period 
(May through July 2010), which resulted in certifications for lobster 
and wild blueberries, as well as a recertified petition for shrimp. 
These certifications accounted for about 55 percent of producers 
participating in the program. To ensure sufficient funding for all 
individuals approved for assistance under these certifications, FAS 
calculated prorated amounts of about $971 for completion of an initial 
business plan and about $1,943 for completion of a long-term plan, for 
a total of about $2,914. FAS needed to prorate the payments in part 
because it certified the second round of petitions using the first 
quarter fiscal year 2011 appropriation of $22.5 million--one-quarter 
the amount appropriated for each of the 2 previous fiscal years. 
According to an FAS letter to producers, FAS may issue a third payment 
to producers receiving prorated cash benefits at the end of the 
program, depending on the availability of funding and on the number of 
producers who complete technical assistance and are therefore eligible 
for cash benefits. (See appendix III for more detailed data on 
financial assistance payments.) 

According to FAS, NIFA, and Farm Service Agency officials, the Farm 
Service Agency paid producers without the producers being required to 
show that the financial assistance would be used for the intended 
purpose. Under the Trade and Globalization Adjustment Assistance Act 
of 2009, payments for completion of long-term business plans are to be 
used to implement the plans. However, approval of long-term business 
plans was not contingent on producers documenting how payments would 
be used to implement the plans. FAS and NIFA officials cited various 
reasons for not requiring producers to document how payments would be 
used, including that technical assistance was a primary benefit of the 
program. The officials acknowledged, however, that they have received 
feedback that led them to believe that at least some producers used 
payments for expenses unrelated to their business plans, such as to 
cover housing costs. 

USDA's Program Evaluation Approach Relies on Performance Measures and 
Surveys That Do Not Fully Assess Effectiveness: 

FAS is evaluating the effectiveness of the TAA for Farmers program by 
using performance measures and a series of producer surveys that focus 
on technical assistance. These tools provide USDA with data on some 
aspects of the program's effectiveness, but they have several 
limitations that hinder FAS's ability to fully determine the extent to 
which the program as a whole is effective. For example, the 
performance measures do not provide information on long-term program 
effectiveness, and the surveys capture producers' perceptions of 
program effectiveness that FAS has not corroborated through other 
means. 

USDA's Performance Measures Do Not Provide Information on Long-Term 
Effectiveness or All Key Program Areas: 

Measuring performance allows agencies to track progress toward their 
goals and gives managers crucial information on which to base 
decisions. Congress enacted the Government Performance and Results Act 
of 1993 to improve the effectiveness of federal programs, among other 
purposes, and to establish a system for agencies to set goals for 
program performance and to measure results. Federal agencies must 
comply with GPRA requirements, but we have reported that these 
requirements also can serve as leading practices at lower levels 
within federal agencies, such as individual divisions, programs, or 
initiatives. Leading practices embodied in GPRA indicate that outcome-
oriented goals, along with objective and quantifiable performance 
measures, are important performance management tools for agencies. 
[Footnote 5] Performance measures gauge progress in meeting goals to 
determine if a program is achieving intended results. 

FAS, with the input of the Farm Service Agency and NIFA, developed 
five performance measures as part of its approach to evaluating the 
effectiveness of the TAA for Farmers program. The first four measures 
consist of the number of producers completing each stage of the 
program's technical assistance, including: 

* initial orientation, 

* 12 hours of required training, 

* an approved initial business plan, and: 

* an approved long-term business plan. 

The fifth performance measure consists of categorizing the amount of 
assistance provided, such as by certified commodity. NIFA's academic 
partners communicate data on the first four performance measures 
through weekly progress reports, and USDA communicates data on the 
fifth performance measure through its annual report on the program to 
Congress. According to lead FAS program officials, the performance 
measures help FAS understand how effectively the program is operating 
over the short term because they track producers' participation 
throughout the stages of the program and producers' completion of 
program requirements. 

These performance measures do not provide information on the program's 
effectiveness over the long-term, however, because they do not measure 
outcomes. Outcome-oriented goals and performance measures assess the 
results of a program compared to its intended purpose and are 
important for ensuring accountability. For example, the Department of 
Labor's performance measures for the TAA for Workers program include 
several outcome-oriented measures, such as the percentage of 
participants that find jobs after exiting the program. According to 
the lead NIFA official, technical assistance programs such as TAA for 
Farmers are intended to promote changes in producers' knowledge, 
changes in producers' behavior when they act upon what they have 
learned, and ultimately improvements in producers' condition. 
Therefore, appropriate goals and performance measures for this program 
would capture changes in producers' knowledge, behavior, and 
condition. Given the purpose of the program's technical assistance to 
help producers better compete with imports or transition to the 
production of other commodities, such measures might include the 
percentage of producers who are able to remain in business because 
they have become more competitive, or the percentage of producers who 
successfully transition to producing another commodity. 

Moreover, FAS's performance measures focus on the program's technical 
assistance, as opposed to other areas of the program--such as 
producers' use of financial assistance payments. Financial assistance 
is also an important component of the TAA for Farmers program, 
however--both as a benefit to producers and in terms of the programs' 
budget. Because FAS does not have performance measures on all key 
program areas, including financial assistance, FAS cannot 
comprehensively evaluate the program. 

FAS officials said that, because technical assistance is the main 
benefit of the program, they are most interested in tracking progress 
in that area. Nevertheless, FAS and NIFA officials acknowledged that 
the performance measures do not measure outcomes and therefore cannot 
be used to evaluate the long-term effectiveness of the program. The 
officials explained that the reporting requirements of the 2009 
legislation--which focuses on short-term economic stimulus--led them 
to select measures that could be tracked over the short term. The FAS 
officials added that they eventually plan to develop performance 
measures to report on the program's outcomes. However, because outcome 
measures were not selected in advance, the potential to collect 
objective data may be lost. 

Surveys Capture Producers' Perceptions of the Effectiveness of 
Technical Assistance but Do Not Provide a Complete Picture of Program 
Effectiveness: 

Surveys developed by NIFA's academic partners are the other main tool 
that FAS is using to evaluate the effectiveness of the TAA for Farmers 
program. The surveys are to be administered to producers participating 
in the program after each stage of technical assistance, including 
after producers complete each training course and after they complete 
their initial and long-term business plans. As of March 2012, NIFA's 
academic partners developed six producer surveys out of a planned 
seven and were still drafting the seventh. According to our analysis 
of the six developed surveys, including versions adapted to each 
certified commodity, the surveys are well designed and appropriate to 
provide adequate data on producers' perceptions of the program--
including perceived changes in their knowledge, behavior, and 
condition as a result of the technical assistance. 

To provide survey results for our review, NIFA's academic partners 
analyzed the preliminary results of surveys received as of December 
2011 (the survey results may not be representative of all producers 
participating in the program). According to the lead NIFA official, 
the survey results are too preliminary to assess any changes in 
producers' condition--the ultimate goal of the technical assistance--
but the results suggest that producers find the program's technical 
assistance to be effective in helping them improve their knowledge and 
begin to change their behavior. For example, responses from about 
1,800 producers (approximately 19 percent of the producers who were 
approved to participate in the program) surveyed after completion of 
their initial business plans, indicate the following: 

* Knowledge. About 56 percent of producers who responded to the survey 
learned "quite a bit" or "a great deal" from the training that would 
benefit their business. Almost 34 percent said they learned "some," 
almost 9 percent said they learned "a little," and less than 2 percent 
said they learned "nothing." 

* Behavior. Over 57 percent of producers who responded to the survey 
felt that developing an initial business plan was "very" or 
"completely" helpful in assisting them identify changes they could 
make to their business operations. About 28 percent felt it was 
"moderately" helpful, and about 14 percent said it was of "slight" or 
"no" help. 

[Side bar: Lobster, Shrimp, and Catfish: 

[Refer to PDF for image: photograph] 

Source: U.S. Fish and Wildlife Service. 

In the United States, shrimp and lobster are generally harvested from 
the wild, and catfish is raised under controlled conditions (known as 
aquaculture). Fishing businesses comprise a mix of full-time, part-
time, and occasional operators and could be one person on a small 
boat, a family-run operation, or a fleet of trawlers. 

Lobster: The Department of Commerce valued the 2010 U.S. commercial 
harvest of American lobster, which is harvested along the Atlantic 
coast from Maine to Virginia, at nearly $400 million. Most fishermen 
use traps to harvest lobster. 

Shrimp: According to the Department of Commerce, the value of shrimp 
landings totaled close to $417 million in 2010. Shrimp are harvested 
in the South Atlantic and Gulf of Mexico, as well as in Alaska and 
other parts of the country. Commercial shrimpers use trawlers to tow 
nets through the water near the ocean floor. 

Catfish: According to USDA, U.S. catfish growers had sales of $423 
million during 2011. The catfish growing process takes place primarily 
in southern states in several types of ponds, including breeding and 
nursery ponds. End of side bar] 

NIFA's academic partners also collected anecdotes from producers to 
provide specific examples of the TAA for Farmers program's value. For 
example, according to an anecdote from a lobster producer in Maine, 
the direct marketing workshop provided ideas on how to market lobster 
differently from other vendors, such as having lobster certified as 
organic. According to another anecdote from a catfish producer in 
Arkansas, the training helped him understand the need to look at every 
aspect of the cost of his operation and control the spread of disease 
among his stock. 

* The surveys can be used to gather insights into producers' 
perceptions of the program, but limitations in the surveys' design 
will hinder FAS and NIFA's ability to use them as a program evaluation 
tool. In particular, 

* The surveys' time frame is insufficient to gather insights into 
producers' perceptions of long-term effectiveness. According to NIFA's 
academic partners, they will administer the final survey 6 to 12 
months after producers complete the program's technical assistance in 
2013. The lead NIFA official said, however, that technical assistance 
programs require at least 3 years after program completion to begin 
demonstrating results because long-term behavioral changes are not 
easily or quickly adopted. The official added that the academic 
partners would like to administer a final follow-up survey 3 to 5 
years after program completion but said there is currently no funding 
available for such a survey. 

* The surveys provide little information on producers' perceptions of 
the effectiveness of the program's financial assistance. Like USDA's 
performance measures, the surveys focus primarily on the program's 
technical assistance. The lead NIFA official explained that the agency 
tasked its academic partners with evaluating only the program's 
technical assistance. Without evaluating the program's financial 
assistance as well as its technical assistance, however, NIFA and FAS 
cannot know the extent to which the program as a whole is effective in 
helping producers become more competitive. For example, some commodity 
experts we spoke with suggested that the financial assistance for 
producers of capital-intensive commodities, such as catfish, may be 
less effective than such assistance for producers of labor-intensive 
commodities, such as blueberries, because the assistance constitutes a 
smaller percentage of the amount needed to make changes to the 
production of capital-intensive commodities. 

In addition to these limitations, FAS has not corroborated the survey 
results by collecting data to help determine whether improvements in 
producers' conditions are due to the TAA for Farmers program or some 
external factor. In November 2009, we reported that program evaluation 
methods to rule out plausible alternative explanations for outcomes 
that may be influenced by a variety of external factors, such as 
changes in the economy, can help strengthen the evaluations.[Footnote 
6] In practice, it is generally difficult to isolate the causal impact 
of programs from other influences on outcomes, but use of multiple 
sources of data can help address concerns about using only one source. 
FAS officials explained that there were challenges to collecting data 
on producers and their businesses because of privacy and other 
constraints and that FAS did not want to discourage producer 
participation by appearing too invasive. FAS officials also 
acknowledged that there are some types of data they could have 
collected, such as producers' cost structures before they participated 
in the program, and that FAS could have potentially collected this 
information through producers' individual applications. 

Conclusions: 

USDA provided enhanced technical assistance to most producers of 
certified commodities who applied for TAA for Farmers assistance. In 
determining which individual applicants qualified, USDA considered 
certain employees as well as spouses of producers to be eligible on 
the grounds that they shared in the risk of producing the agricultural 
commodities. However, USDA did not require spouses applying for 
assistance to submit documentation on how they contributed to 
producing a certified commodity. As a result, USDA may have approved 
the applications of spouses who did not contribute to producing a 
certified commodity and therefore does not have assurance that it 
targeted assistance to individuals who are intended to benefit from 
the program. In addition, USDA made financial assistance payments to 
producers without the producers being required to show how payments 
would be used to implement their long-term business plans. Under the 
Trade and Globalization Adjustment Assistance Act of 2009, the 
payments for completion of long-term business plans are to be used to 
implement those plans. USDA officials acknowledged that some producers 
likely use the payments for unrelated expenses. 

The performance measures and surveys USDA is using as part of its 
approach to evaluate the TAA for Farmers program are well designed for 
measuring the number of producers completing the program and for 
capturing producer perceptions of the effectiveness of the program's 
technical assistance. However, USDA cannot use its current performance 
measures to fully evaluate the program's effectiveness because they do 
not measure quantifiable outcomes or cover all key areas of the 
program. Furthermore, the surveys have several limitations. For 
example, the time frame for administering the final survey--6 to 12 
months after producers complete the program--is insufficient to gather 
insights into producers' perceptions of the program's long-term 
effectiveness. In addition, USDA has not corroborated the survey 
results to help isolate the impact of the TAA for Farmers program from 
other influences. Because of limitations with USDA's program 
evaluation approach, USDA cannot establish the extent to which the 
program as a whole is ultimately effective. Performing comprehensive 
program evaluations can be difficult for agencies because of resource 
constraints and data collection challenges. Nonetheless, a broader 
program evaluation approach could enable USDA to better evaluate the 
impact of the TAA for Farmers program on producers' competitiveness. 
The TAA for Farmers program as reauthorized in 2009 is almost over, 
and no new funds have been appropriated. If the program receives 
future reauthorizations and funding, USDA will have an opportunity to 
improve the operation and evaluation of the program. 

Recommendations for Executive Action: 

We recommend that the Secretary of Agriculture direct the 
Administrators of FAS and the Farm Service Agency and the Director of 
NIFA, as appropriate, to take the following three actions, as 
applicable under the structure of any future round of trade adjustment 
assistance for farmers and fishermen for which Congress may 
appropriate funds: 

* Require spouses who may be eligible to apply for assistance to 
submit documentation on how they contribute to a commodity's 
production. 

* Take steps to help ensure that any financial assistance payments 
that may be provided under the program are used for the intended 
purpose--for example, by requiring producers to state in their 
business plans how they intend to use the payments. 

* Broaden the program's evaluation approach to help ensure that USDA 
can comprehensively evaluate the effectiveness of the program. Steps 
to broaden the program's evaluation approach could include developing 
quantifiable outcome-oriented performance goals and measures for all 
key areas of the program and collecting data to help isolate the 
impact of the TAA for Farmers program from other influences. 

Agency Comments and Our Evaluation: 

We provided a copy of our draft report to USDA for review and comment. 
In written comments from the department, FAS stated that the 
department generally agrees with our recommendations. In addition, FAS 
stated that, assuming any future TAA for Farmers program has the same 
statutory requirements, the department will make every effort to 
address our recommendations in order to strengthen and improve the 
program. 

We recognize that the statutory requirements for any future TAA for 
Farmers program may differ from current requirements. For example, as 
noted in our report, the Trade and Globalization Adjustment Assistance 
Act of 2009 amended the program, making changes to the program in key 
areas. Given the potential for future changes to the program's 
statutory requirements, we revised our recommendations related to the 
eligibility requirements for spouses and the use of financial 
assistance payments toward implementation of business plans. In 
particular, we revised the wording of these two recommendations to 
account for the potential that a future reauthorization of the program 
may make further changes to the program's eligibility requirements or 
to the technical and financial assistance provided to producers. 

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

If you or your staff have any questions about this report, please 
contact me at (202) 512-3841 or shamesl@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 appendix V. 

Signed by: 

Lisa Shames: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Scope and Methodology: 

To examine the commodities and producers approved for assistance under 
the 2009 reauthorization of the Trade Adjustment Assistance (TAA) for 
Farmers program and the type and amount of assistance provided, we 
reviewed four areas of the program: 

* Commodity certification. We reviewed petitions submitted by groups 
of commodity producers, Economic Research Service analyses, petition 
review committee decision memos with recommendations to the Foreign 
Agricultural Service (FAS) on whether to certify commodities, and FAS 
letters to producer groups and Federal Register notices announcing 
whether commodities had been certified or denied. We analyzed the 
documentation to determine the basis for FAS's determinations and the 
extent to which the 2009 changes to the certification criteria were a 
factor in commodities being certified. 

* Producer application. We reviewed Farm Service Agency documents 
describing the application process and individual eligibility 
requirements, including the requirements for crew members and spouses 
of eligible producers. In addition, we obtained and analyzed Farm 
Service Agency data on the number of applicants for each certified 
commodity, including the number approved and disapproved and the 
reasons for disapproval. 

* Technical assistance. We reviewed documents prepared by the National 
Institute of Food and Agriculture's (NIFA) academic partners for 
organizing and overseeing the program's technical assistance, a list 
of training courses provided to producers, templates for initial and 
long-term business plans, and sample long-term business plans. We also 
analyzed Farm Service Agency data on producers' completion of each 
stage of technical assistance. 

* Financial assistance. We analyzed Farm Service Agency data on 
payments to producers who completed initial and long-term business 
plans, as well as for transportation and related expenses to attend an 
initial orientation to the program. In addition, we reviewed summary 
data from the U.S. Department of Agriculture (USDA) on its use of 
appropriations for the program. 

We assessed the reliability of Farm Service Agency data by checking 
for obvious errors in accuracy and completeness. In addition, we 
assessed the data's consistency with equivalent data maintained by the 
Center for Farm Financial Management on producers' completion of 
technical assistance. We also reviewed documentation describing the 
Farm Service Agency database used to produce the data, and we 
interviewed Farm Service Agency officials who had knowledge of the 
data. We determined that the data were sufficiently reliable for 
reporting on the number of approved and disapproved applicants and the 
amount of technical and financial assistance provided to producers. 

To examine the approach USDA is taking to evaluate the program's 
effectiveness and to identify any limitations in this approach, we 
reviewed USDA's performance measures and producer surveys: 

* Performance measures. We reviewed the performance measures FAS 
selected for program reporting purposes and compared the performance 
measures against guidelines embodied in the Government Performance and 
Results Act of 1993, as amended (GPRA). We also reviewed available 
data on these measures to understand how FAS and NIFA's academic 
partners were tracking and using the performance measures. 

* Producer surveys. We reviewed templates developed by NIFA's academic 
partners for surveys of producers participating in the program. The 
templates included the surveys to be completed after each stage of the 
program's technical assistance. We evaluated the templates and the 
academic partners' survey development methodology against GAO 
guidelines for designing evaluations and the Office of Management and 
Budget's (OMB) Standards and Guidelines for Statistical Surveys to 
understand the extent to which the academic partners incorporated 
generally accepted survey research practices. In addition, we reviewed 
an analysis of preliminary survey results, as of December 2011, that 
NIFA's academic partners prepared for purposes of our audit. 

For further explanation regarding both of our objectives, we 
interviewed USDA officials involved in administering each stage of the 
program, including officials from FAS, the Economic Research Service, 
the TAA for Farmers petition review committee, the Farm Service 
Agency, and NIFA. In addition, we interviewed NIFA's academic partners 
and representatives of the teams established to develop commodity-
specific training courses, and we attended a meeting of TAA of Farmers 
business consultants organized by NIFA's lead academic partner. The 
meeting provided us with the opportunity to obtain business 
consultants' perspectives on various aspects of the program and to 
learn about their experiences working with producers. To better 
understand the type of information contained in long-term business 
plans, we reviewed sample plans (with personal information removed) 
that NIFA's academic partners selected to serve as a basis for 
discussing the criteria for approval of the plans at the meeting of 
business consultants. We also interviewed members of the USDA Office 
of the Inspector General team conducting a review of the TAA for 
Farmers program during the same time we conducted our review. We 
planned our audit to minimize duplication of effort in areas evaluated 
by the Office of Inspector General, such as FAS and Farm Service 
Agency internal controls over the application of eligibility 
requirements for producers of certified commodities. 

To gather additional perspectives, we interviewed a nonprobability 
sample of producer groups that submitted petitions for TAA for Farmers 
assistance. Because we selected a nonprobability sample of producer 
groups to interview, the information we obtained from these interviews 
cannot be generalized to other groups. The interviews instead provided 
us with the perspectives of various producer groups regarding the 
program. We conducted interviews by phone and in person as part of 
fieldwork in Maine and Mississippi, during which we also interviewed 
two producers (a catfish producer and a shrimp producer) regarding the 
impact the program has had on their businesses. We selected these two 
states in order to meet with representatives of producer groups for 
three of the five certified commodities (catfish, lobster, and frozen 
wild blueberries). In addition, Maine accounted for the majority of 
approved lobster producers and all approved wild blueberry producers, 
and Mississippi accounted for the largest number of approved catfish 
producers. 

We conducted this performance audit from September 2011 to July 2012 
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 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Commodities Certified and Denied for TAA for Farmers 
Assistance: 

Table 2 summarizes our analysis of the basis for FAS's certification 
of five commodities under the 2009 reauthorization of the TAA for 
Farmers program, including the Economic Research Service analyses of 
petitions and FAS decision memos. FAS certified four commodities on 
the basis of a decrease in factors added as options (in addition to 
price) for demonstrating harm from imports: quantity of production and 
value of production. None of the certifications were based on a 
decrease in cash receipts (the third factor added for demonstrating 
harm). In its analyses of petitions for lobster, shrimp and frozen 
wild blueberries, the Economic Research Service identified factors 
other than imports that contributed to a decline in the commodity's 
price or other factor. Nevertheless, FAS found that the commodities 
met the requirement for an increase in imports to have contributed 
importantly to the decline. 

Table 2: Commodities Certified for Assistance under the 2009 
Reauthorization of the TAA for Farmers Program: 

Commodity and year covered by the petition: Asparagus (2009); 
Area covered by the certification: Nationwide[B]; 
Basis for FAS's determination[A]: 17 percent decline in quantity of 
production; 
Increase in imports[A]: 17 percent; 
Other contributing factors cited by the Economic Research Service: 
None. 

Commodity and year covered by the petition: Catfish (2009); 
Area covered by the certification: Nationwide; 
Basis for FAS's determination[A]: 16 percent decline in value of 
production; 
Increase in imports[A]: 48 percent; 
Other contributing factors cited by the Economic Research Service: 
None. 

Commodity and year covered by the petition: Lobster (2009)[C]; 
Area covered by the certification: Connecticut, Maine, Massachusetts, 
New Hampshire, and Rhode Island; 
Basis for FAS's determination[A]: State-level declines in the value of 
production ranging from 16 percent to 36 percent; 
Increase in imports[A]: 6 percent; 
Other contributing factors cited by the Economic Research Service: 
Increased domestic production. 

Commodity and year covered by the petition: Shrimp (2008)[D]; 
Area covered by the certification: Alabama, Alaska, Florida, Georgia, 
Louisiana, Mississippi, North Carolina, South Carolina, and Texas; 
Basis for FAS's determination[A]: 22 percent decline in the quantity 
of production; 
Increase in imports[A]: 5 percent; 
Other contributing factors cited by the Economic Research Service: A 
natural variation in harvest and a rapid increase in the price of 
diesel fuel. 

Commodity and year covered by the petition: Wild blueberries, frozen 
(2009); 
Area covered by the certification: Maine; 
Basis for FAS's determination[A]: 56 percent decline in average annual 
price; 
Increase in imports[A]: 3 percent; 
Other contributing factors cited by the Economic Research Service: 
Increased domestic production, high inventory levels from previous 
years, and decreased exports. 

Source: GAO analysis of FAS determinations to certify TAA for Farmers 
petitions. 

[A] Percentage changes are in comparison to the average of the 3 
preceding years. 

[B] FAS received petitions from asparagus producers in California, 
Michigan, Pennsylvania, and Washington. FAS certified producers of 
asparagus nationwide on the basis of data from the top asparagus-
producing states (California, Michigan, and Washington). 

[C] FAS initially denied a nationwide petition for lobster in part 
because imports decreased in 2008. Producer groups from five New 
England states submitted separate petitions during the second filing 
period FAS announced in 2010. The petitions used more recent data that 
had become available for 2009, when imports had increased. 

[D] FAS certified petitions submitted during both the first and second 
filing periods. Recertification of the initial petition extended the 
90-day postcertification period in which individual producers could 
apply for assistance. In addition, producers in Alaska joined the 
second petition. Producers of both wild and pond-raised shrimp and 
prawns were eligible to apply for assistance. 

[End of table] 

Table 3 summarizes our analysis of the basis cited by FAS when denying 
commodities. Reasons for denial included not meeting the requirements 
for both an increase in imports and a decrease in price or another 
factor and not meeting the requirement for an increase in imports to 
have contributed importantly to a commodity's harm. In cases in which 
FAS found that imports had not contributed importantly to a 
commodity's harm, the Economic Research Service identified other 
contributing factors, such as an increase in domestic production. For 
several commodities, including apples, coffee, and cranberries, FAS 
received separate state petitions and cited differing reasons for not 
certifying the commodities in those states. 

Table 3: Basis Cited by FAS for Denying Commodities under the 2009 
Reauthorization of the TAA for Farmers Program: 

Commodity: Apples; 
Area covered by petitions: Maine; 
Basis for FAS's determinations: 
Requirement for greater than 15 percent decline not met; 
Imports decreased in the year covered by the petition. 

Commodity: Apples; 
Area covered by petitions: Michigan and New York; 
Basis for FAS's determinations: 
Factors other than imports contributed to a greater than 15 percent 
decline. 

Commodity: Apples; 
Area covered by petitions: Minnesota; 
Basis for FAS's determinations: 
Imports decreased in the year covered by the petition. 

Commodity: Blue crabs; 
Area covered by petitions: Georgia; 
Basis for FAS's determinations: 
Imports decreased in the year covered by the petition. 

Commodity: Coffee; 
Area covered by petitions: Hawaii; 
Basis for FAS's determinations: Imports decreased in the year covered 
by the petition. 

Commodity: Coffee; 
Area covered by petitions: Puerto Rico; 
Basis for FAS's determinations: 
Requirement for greater than 15 percent decline not met; 
Imports decreased in the year covered by the petition. 

Commodity: Cranberries; 
Area covered by petitions: New Jersey; 
Basis for FAS's determinations: 
Requirement for greater than 15 percent decline not met; 
Imports decreased in the year covered by the petition. 

Commodity: Cranberries; 
Area covered by petitions: Oregon and Washington; 
Basis for FAS's determinations: 
Factors other than imports contributed to a greater than 15 percent 
decline. 

Commodity: Crawfish; 
Area covered by petitions: Louisiana; 
Basis for FAS's determinations: 
Imports decreased in the year covered by the petition. 

Commodity: Cut lilies; 
Area covered by petitions: Georgia, North Carolina, South Carolina, 
and Virginia; 
Basis for FAS's determinations: 
Requirement for greater than 15 percent decline not met. 

Commodity: Lamb; 
Area covered by petitions: Idaho, Montana, Ohio, Utah, and Wyoming; 
Basis for FAS's determinations: 
Requirement for greater than 15 percent decline not met; 
Imports decreased in the year covered by the petition. 

Commodity: Multispecies fish; 
Area covered by petitions: Connecticut, Maine, Maryland, 
Massachusetts, New Hampshire, New Jersey, New York, and Rhode Island; 
Basis for FAS's determinations: Imports decreased in the year covered 
by the petition. 

Commodity: Prunes[A]; 
Area covered by petitions: California; 
Basis for FAS's determinations: 
Factors other than imports contributed to a greater than 15 percent 
decline. 

Commodity: Spiny lobster; 
Area covered by petitions: Florida; 
Basis for FAS's determinations: 
Imports decreased in the year covered by the petition. 

Commodity: Tilapia; 
Area covered by petitions: Arkansas; 
Basis for FAS's determinations: 
Requirement for greater than 15 percent decline not met; 
Imports decreased in the year covered by the petition. 

Commodity: Wild blueberries, fresh; 
Area covered by petitions: New Hampshire; 
Basis for FAS's determinations: 
Requirement for greater than 15 percent decline not met. 

Commodity: Wool; 
Area covered by petitions: Idaho, Kansas, Montana, Ohio, Utah, and 
Wyoming; 
Basis for FAS's determinations: 
Imports decreased in the year covered by the petition. 

Source: GAO analysis of FAS decision memos, letters to petitioners, 
and Federal Register notices. 

[A] FAS received two petitions for California prunes, one during each 
of the two filing periods announced in 2010. For the first petition, 
FAS found, based on partial year data, that imports had declined. For 
the second petition, FAS found that imports had increased but that 
imports were not an important factor in determining the average price. 

[End of table] 

Several commodities for which FAS received TAA for Farmers petitions 
have been the subject of other federal efforts addressing the impact 
of imports. For example, the Food, Conservation and Energy Act of 2008 
appropriated $15 million for USDA to compensate producers of asparagus 
(a commodity certified for TAA for Farmers assistance) for market loss 
and reduced prices resulting from an increase in imports. In addition, 
the U.S. International Trade Commission, an independent federal agency 
that conducts investigations that can lead to the imposition of 
antidumping duties on imports sold at less than fair value, has 
conducted investigations into imports of shrimp and crawfish, two 
commodities for which FAS received petitions for TAA for Farmers 
assistance. The TAA for Farmers certification criteria, however, 
differ from the criteria used by the U.S. International Trade 
Commission to support the imposition of antidumping duties. As a 
result, the outcomes of certification process and commission 
investigations also differed. In particular, FAS certified shrimp but 
denied crawfish even though antidumping duties have been imposed on 
both commodities. 

[End of section] 

Appendix III: Technical and Financial Assistance Provided to Producers 
Approved for TAA for Farmers Assistance: 

Farm Service Agency data on individual applicants under the five 
commodities certified for TAA for Farmers assistance included the 
numbers of approved applicants, disapproved applicants, and applicants 
waiting for a decision on their application or appeal of disapproval 
(see table 4). Shrimp producers included those who applied in the 90-
day period following the commodity's initial certification, as well as 
those who applied in the period following the commodity's 
recertification. 

Table 4: Number of TAA for Farmers Applicants as of April 2012, by 
Certified Commodity and Application Status: 

Commodity: Asparagus; 
Approved: 259; 
Disapproved: 13; 
Pending[A]: 8; 
Total: 280. 

Commodity: Catfish; 
Approved: 743; 
Disapproved: 40; 
Pending[A]: 2; 
Total: 785. 

Commodity: Lobster; 
Approved: 3,842; 
Disapproved: 340; 
Pending[A]: 0; 
Total: 4,182. 

Commodity: Shrimp (initial certification); 
Approved: 3,405; 
Disapproved: 485; 
Pending[A]: 7; 
Total: 3,897. 

Commodity: Shrimp (recertification); 
Approved: 1,349; 
Disapproved: 204; 
Pending[A]: 1; 
Total: 1,554. 

Commodity: Wild blueberries, frozen; 
Approved: 254; 
Disapproved: 24; 
Pending[A]: 0; 
Total: 278. 

Commodity: Total; 
Approved: 9,852; 
Disapproved: 1,106; 
Pending[A]: 18; 
Total: 10,976. 

Source: GAO analysis of Farm Service Agency data. 

[A] Includes applicants waiting for a decision on their application or 
appeal of disapproval. 

[End of table] 

A FAS official estimated that about 80 percent of the approved 
applicants met the eligibility requirement for a decrease in the price 
received for a commodity through a process whereby industry officials 
could submit data for all producers in a state or certain counties 
within a state. For example, FAS allowed all asparagus growers in 
Michigan to rely on such data when applying for assistance rather than 
submit their own price data. According to information from FAS and the 
Farm Service Agency, less than 1 percent of the total number of 
approved applicants did not meet the program's eligibility 
requirements but partially or fully completed the initial training 
requirements after receiving approval letters that were sent in error. 
In consideration of the time such applicants spent on technical 
assistance, the Deputy Under Secretary for Farm and Foreign 
Agricultural Services granted equitable relief to the applicants, 
meaning they were allowed to continue to participate in the program 
and receive cash benefits. According to an official in the Farm 
Service Agency, the agency did not develop software to track 
applicants until after it began accepting applications. As a result, 
staff needed to manually enter applicant data into spreadsheets, which 
led to data entry errors and approval letters being inadvertently sent 
to some applicants who did not meet eligibility requirements. 

Table 5 summarizes Farm Service Agency data on the number and 
percentage of approved producers for each certified commodity who 
completed initial and long-term business plans as of April 2012, as 
well as the total amount of financial assistance payments to the 
producers. 

Table 5: Financial Assistance Provided to Producers as of April 2012, 
by Certified Commodity: 

Commodity: Asparagus; 
Initial business plans: 
Number (percent) of producers with approved plans: 218 (84%); 
Cash benefits: $0.9 million; 
Long-term business plans: 
Number (percent) of producers with approved plans: 73 (28%); 
Cash benefits: $0.6 million; 
Total cash benefits, including transportation and related expenses: 
$1.5 million. 

Commodity: Catfish; 
Initial business plans: 
Number (percent) of producers with approved plans: 668 (90%); 
Cash benefits: $2.7 million; 
Long-term business plans: 
Number (percent) of producers with approved plans: 452 (61%); 
Cash benefits: $3.6 million; 
Total cash benefits, including transportation and related expenses: 
$6.3 million. 

Commodity: Lobster; 
Initial business plans: 
Number (percent) of producers with approved plans: 2,237 (58%); 
Cash benefits: $2.2 million; 
Long-term business plans: 
Number (percent) of producers with approved plans: 1,040 (27%); 
Cash benefits: $2.0 million; 
Total cash benefits, including transportation and related expenses: 
$4.2 million. 

Commodity: Shrimp (initial certification); 
Initial business plans: 
Number (percent) of producers with approved plans: 3,272 (96%); 
Cash benefits: $13.1 million; 
Long-term business plans: 
Number (percent) of producers with approved plans: 2,716 (80%); 
Cash benefits: $21.7 million; 
Total cash benefits, including transportation and related expenses: 
$34.8 million. 

Commodity: Shrimp (recertification); 
Initial business plans: 
Number (percent) of producers with approved plans: 1,180 (87%); 
Cash benefits: $1.1 million; 
Long-term business plans: 
Number (percent) of producers with approved plans: 729 (54%); 
Cash benefits: $1.4 million; 
Total cash benefits, including transportation and related expenses: 
$2.6 million. 

Commodity: Wild blueberries; 
Initial business plans: 
Number (percent) of producers with approved plans: 206 (81%); 
Cash benefits: $0.2 million; 
Long-term business plans: 
Number (percent) of producers with approved plans: 63 (25%); 
Cash benefits: $0.1 million; 
Total cash benefits, including transportation and related expenses: 
$0.3 million. 

Commodity: Total; 
Initial business plans: 
Number (percent) of producers with approved plans: 7,781 (79%); 
Cash benefits: $20.2 million; 
Long-term business plans: 
Number (percent) of producers with approved plans: 5,073 (51%); 
Cash benefits: $29.5 million; 
Total cash benefits, including transportation and related expenses: 
$49.7 million. 

Source: GAO analysis of Farm Service Agency data. 

Note: Column and row totals may not add up due to rounding. In 
addition, the column for total cash benefits includes about $60,000, 
distributed among the certified commodities, for producers' 
transportation and related expenses to attend an initial orientation 
to the program. 

[End of table] 

NIFA's academic partners developed separate templates and approval 
criteria for the initial business plans and long-term business plans. 
The template for the initial business plan is two pages, with space 
for producers to provide brief descriptions of their businesses, key 
challenges, skills gained from the TAA for Farmers training courses, 
plans for applying those skills, changes being considered to improve 
business profitability and the ability to compete with imports, and 
whether producers intend to complete a long-term business plan. 
According to the TAA for Farmers technical assistance procedures 
guide, producers had the option of completing the initial business 
plans during the last 30 minutes of a training course on how to 
develop a long-term business plan. NIFA's academic partners said they 
designed the initial business plan to serve primarily as a starting 
point for developing a long-term plan. They said that, as a result, 
they approved most initial business plans without returning them to 
producers for additional work. 

NIFA's academic partners developed templates for several different 
types of long-term business plans that producers could choose to 
develop to suit their individual needs: a traditional business plan 
with separate versions for farmers and fishermen, a plan to pass a 
business on to successors and plan for retirement, and a career plan 
for producers such as crew members who do not own a business. The 
templates were also translated for the benefit of shrimpers who speak 
Vietnamese as a first language. According to the technical assistance 
procedures guide, the long-term plans are to undergo two levels of 
review before they are approved and producers can receive their 
payments--first by the business consultant assigned to work with a 
producer, and then by NIFA's academic partners. In addition, the 
templates for the long-term business plans are more extensive than the 
template for the initial business plans. For example, the template for 
traditional long-term business plans includes sections for: 

* a business description, including location, facilities, business 
history, and ownership structure. 

* business operations, including management of inventory, product 
quality, customer service, and risk; compliance with regulations; and 
an implementation timeline for any changes. 

* a marketing plan with subsections for an analysis of the market, the 
business's competitive position and market segments to be targeted, 
and pricing, promotion, and distribution plans. 

* management of the business, including new positions to be filled and 
the plan for finding and training people for those positions. 

* a financial plan with subsections for a balance sheet showing 
assets, liabilities, and net worth; historical performance and 
projections; asset management; and capital requests. 

[End of section] 

Appendix IV: Comments from the U.S. Department of Agriculture: 

USDA: 
United States Department of Agriculture: 
Farm and Foreign Agricultural Services: 
Foreign Agricultural Service: 
1400 Independence Ave, SW: 
Stop 1060: 
Washington, DC 20250-1060:  

July 2, 2012: 

Ms. Lisa Shames:
Director, Natural Resources and Environment:
United States Government Accountability Office:
441 G Street, N.W. 
Washington, D.C. 20548: 
 
Dear Ms. Shames: 

The U.S. Department of Agriculture (USDA) appreciates this opportunity 
to review the Government Accountability Office (GAO) draft report 
entitled "Trade Adjustment Assistance: USDA Has Enhanced Technical 
Assistance for Farmers and Fishermen, but  Steps Are Needed to Better 
Evaluate Program Effectiveness" (GA0-12-731). USDA is pleased that the 
GAO noted many positive aspects of the Trade Adjustment Assistance  
(TAA) for Farmers Program, including the program's enhanced technical 
assistance, the reliability of program data for reporting on the 
number of approved and disapproved applicants, and the amounts of 
technical and financial assistance provided, as well as the  
Department's well-designed surveys for capturing producer perceptions 
of the program. 

USDA took several new actions to implement statutory changes for the 
2009-2011 TAA for Farmers Program, some of which were based on 
recommendations made in the GAO report on the previous 2003-2007 TAA 
for Farmers Program (GAO-07-201). Two of the more notable actions 
included broadening the 2009-2011 program's eligibility criteria so 
that more applicants qualify, and modifying the program to further 
emphasize the training and technical assistance component in order to 
help producers adjust to the effects of import competition. 

USDA also notes the GAO recommendations for future TAA for Farmers 
Programs that are found in this draft report. USDA generally agrees 
with these recommendations, and assuming any future program has the 
same statutory requirements, will make every effort to address them as 
follows in order to strengthen and improve any future TAA for Farmers 
Program. 

Documentation Requirement for Spouses: 

The GAO recommends that USDA require spouses applying for program 
assistance to submit documentation on how they contributed to 
producing the program commodity. 

Current legislation requires that all TAA producers, including 
spouses, submit documentation to meet the program's eligibility 
requirements. 

In August 2010, USDA determined that spouses of eligible producers who 
are closely involved in the operation--estimated to be less than 20 
percent of total program applicants--also shared in the risk of 
producing a commodity and could, therefore, apply separately for 
program benefits. This determination applied as long as the spouse met 
the general program eligibility requirements as set forth in 1-SP, 
subparagraph 52A, of the ESA handbook; completed all required 
technical assistance training; and completed and received approval on 
all required business plans. On August 20, 2010, USDA issued a notice 
to FSA county offices that clarified the application guidelines for 
spouses by stating that documentation of a family farming/fishing 
operation could be used by each spouse if both applied separately, and 
that the same documentation of production and prices could be used to 
qualify each spouse. 

In any future TAA for Farmers Program, USDA will consider requiring 
spouses applying for program assistance to submit additional 
documentation of their individual contribution to producing the 
program commodity. This could be achieved by requiring spouses to 
submit their own evidence of how, precisely, they contributed to 
producing a commodity, in keeping with what is already required of 
crewmen on fishing vessels under the program. 

Showing Intended Use of TAA Financial Assistance Payments: 

The GAO recommends that USDA take steps to help ensure that producers 
use the program's financial assistance payments toward implementation 
of their business plans, such as requiring producers to state in their 
business plans how they intend to use the payments. 

The current program expands the training and technical assistance 
component, making it a key benefit of the 2009-2011 program, rather 
than the cash assistance, which was the primary benefit of the 2003-
2007 program. Because of this, less focus was placed on requiring 
producers to report the intended use of their financial assistance, 
even though many producers already included in their business plans, 
under the "Executive Summary's Capital Request" section, how they 
intended to use their financial assistance payments. 

Current TAA applicants also are well-informed of the intended use for 
which the program's financial assistance is provided, as stated in 
USDA press releases, program notices, fact sheets, training courses, 
and other program literature. USDA believes that the vast majority of 
applicants make every effort to use these payments for the intended 
purposes. Because a large number of program applicants are small 
business owners, many with at-home offices or operations, it is not 
uncommon for some of them to use their financial assistance payments 
toward related home office or operation expenses as part of 
implementing their business plans. 

In any future TAA for Farmers Program, USDA will consider developing a 
mechanism to help ensure that producers use the program's financial 
assistance payments toward implementation of their business plans. 
This could be achieved by requiring producers to sign an agreement 
upon which payments are contingent. 

Broadening Evaluation Approach to Measure Program Effectiveness: 
 
The GAO recommends that USDA broaden the program's evaluation approach 
to help ensure that USDA can comprehensively evaluate the 
effectiveness of the program.  

Although current funding restrictions and TAA for Farmers outlay 
requirements present significant challenges, USDA agrees that 
improvements in long-term program evaluation could be beneficial. 
However, it might be appropriate to assess results of program 
participation approximately 3-5 years after completing the training.  

The reporting requirements of the American Recovery and Reinvestment 
Act of 2009 (ARRA), to which the 2009-2011 program is subject, seek to 
measure the short-term economic stimulus provided by that legislation. 
Most ARRA-required performance measures (such as job creation, 
infrastructure investment, energy efficiency and science, assistance 
to the unemployed, and state and local fiscal stabilization) are not 
closely aligned with the purpose of the TAA for Farmers Program, which 
offers training and technical assistance to currently employed 
producers. Therefore, USDA selected performance indicators that can be 
quantified over a short period of time, such as focusing program 
evaluation almost exclusively on the initial training and technical 
assistance component of the program, instead of seeking to measure the 
long-term effectiveness of the 2009-2011 program.  

In any future TAA for Farmers Program, USDA could consider broadening 
the program's evaluation approach and performing a more comprehensive 
evaluation of its long-term effectiveness. This could be achieved by 
establishing a process to analyze applicants' long-term successes as 
indicators of overall program effectiveness.  

USDA would like to thank the GAO for its review and recommendations 
regarding the 2009-2011 TAA for Farmers Program. The Department looks 
forward to addressing these issues in an effort to further improve any 
future TAA for Farmers Program.  

Sincerely,  

Signed by: 

Suzanne Heinen: 
Administrator: 
Foreign Agricultural Service:  

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Lisa Shames, (202) 512-3841 or shamesl@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Mary Denigan-Macauley 
(Assistant Director), Kevin Bray, Joseph Cook, Barbara El Osta, 
Cynthia Norris, Anne Rhodes-Kline, and Heather Salinas made key 
contributions to this report. 

[End of section] 

Footnotes: 

[1] In this report, we refer to both farmers and fishermen as 
producers. 

[2] GAO, Trade Adjustment Assistance: New Program for Farmers Provides 
Some Assistance, but Has Had Limited Participation and Low Program 
Expenditures, [hyperlink, http://www.gao.gov/products/GAO-07-201] 
(Washington, D.C.: Dec. 18, 2006). 

[3] The Trade and Globalization Adjustment Assistance Act of 2009, 
Pub. L. No. 111-5, div. B, tit. I, subtit. I, 123 Stat. 367, 367-423. 

[4] The Omnibus Trade Act of 2010 also appropriated $10.4 million for 
the program for the 6-week period from January 1, 2011, to February 
12, 2011, but USDA did not use this funding because it determined that 
it was not able to certify petitions for assistance within a 6-week 
time frame. 

[5] GAO, Designing Evaluations, [hyperlink, 
http://www.gao.gov/products/GAO-12-208G] (Washington, D.C.: January 
2012). 

[6] GAO, Program Evaluation: A Variety of Rigorous Methods Can Help 
Identify Effective Interventions, [hyperlink, 
http://www.gao.gov/products/GAO-10-30] (Washington, D.C.: Nov. 23, 
2009). 

[End of section] 

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