International School Feeding:

USDA's Oversight of the McGovern-Dole Food for Education Program Needs Improvement

GAO-11-544: Published: May 19, 2011. Publicly Released: May 19, 2011.

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The McGovern-Dole International Food for Education and Child Nutrition Program (MGD Program) provides donations of U.S. agricultural products and financial and technical assistance for school feeding programs in the developing world. According to the U.S. Department of Agriculture (USDA), with about $200 million in funding in fiscal year 2010, the MGD Program served about 5 million beneficiaries in 28 countries. In 2006 and 2007, USDA's Office of the Inspector General (OIG) audited the department's food aid programs and identified significant weaknesses. This report examines (1) USDA's oversight of the MGD Program and (2) the extent to which USDA has addressed the program's internal control weaknesses. GAO conducted field work in Cambodia, Guatemala, and Kenya; reviewed USDA and implementing partners' documents and studies on school feeding; and interviewed officials from U.S. agencies and various organizations..

USDA has established a grant approval process consistent with the MGD Program's objectives of education, nutrition, and sustainability, but weaknesses in its oversight limit its ability to ensure that the program's objectives are met. Specifically, USDA has established criteria for designating priority countries, assessing proposals, and negotiating grant agreements with the United Nations World Food Program and nongovernmental organizations that implement the MGD Program. In addition to providing in-school meals and take-home rations, USDA supports complementary activities such as teacher training, nutrition education, and fostering parental involvement. The oversight weaknesses that GAO identified include: (1) USDA provides weak performance monitoring of the MGD Program's implementation. For example, USDA does not systematically analyze implementing partners' reporting and provides limited feedback. In addition, requirements for implementing partners do not ensure consistent reporting and lack performance indicators directly measuring educational progress, such as learning, and, in some cases, nutrition. GAO's Standards for Internal Control in the Federal Government states that activities need to be established to monitor performance measures and indicators and that these controls could call for comparisons and assessments relating different sets of data to one another so that analysis of the relationships can be made and appropriate actions taken. USDA does not conduct systematic site visits and relies on the implementing partners' performance monitoring, whose rigor varies by implementing partner. (2) USDA has not evaluated completed MGD projects, but is taking steps that will emphasize evaluation in the future. Although USDA now requires implementing partners to conduct evaluations, it has not yet established policies and procedures to guide these evaluations. The American Evaluation Association's An Evaluation Roadmap for a More Effective Government recommends that agencies develop policies and procedures to guide evaluation and assess the strengths and weaknesses of programs to improve their effectiveness. GAO found that USDA is taking steps to improve its financial oversight of MGD projects, but further improvements would help strengthen its internal controls. GAO's Standards for Internal Control in the Federal Government also states that managers need to compare actual performance to planned results and analyze significant differences in a timely manner. USDA has controls in place over project expenditures, but a lack of timely grant closeouts prevents USDA from ensuring that grantees have met all financial requirements and that unused or misused funds are promptly reimbursed to USDA. To date, USDA has collected over $850,000 in unused or misused funds via grant closeouts; however, 15 of 42 (36 percent) of the MGD grants that are eligible to be closed, remain open. Finally, USDA has related outstanding OIG audit recommendations to implement and close. GAO recommends that the Secretary of Agriculture improve oversight of the MGD Program, including issuing monitoring and evaluation guidance for implementing partners, and formalize policies and procedures for closing out grant agreements and establishing guidance to determine when agreements should be closed. USDA agreed with GAO's recommendations and said that it will take steps to address them.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: The Foreign Agricultural Service (FAS) has taken several actions related to this recommendation. In June 2011, FAS issued its monitoring and evaluation (M&E) policy, which was last updated in May 2013. The M&E policy establish a monitoring process, including the requirement for a performance monitoring plan that identifies indicators for monitoring progress in achieving results and present a strategy for collecting performance data. Specifically, for the McGovern-Dole International Food for Education and Child Nutrition Program, in June 2012 FAS developed two results frameworks - one for literacy and the other for health and dietary practices. Under these two results frameworks, FAS defines a list of standard indicators. FAS' monitoring and evaluation policy requires reporting on the indicators and targets semi-annually in project reports. In addition, according to FAS, in March 2011, it launched a new Food Aid Information System, which will serve as the centralized database for all of its monitoring reports and provides the means to systematically track performance measures to better evaluate the performance of individual programs, as well as identify trends across programs.

    Recommendation: To improve USDA's oversight of the MGD Program in the areas of monitoring, evaluation, and financial management, the Secretary of Agriculture should direct the Administrator of the Foreign Agricultural Service to establish a monitoring process that would systematically analyze and report on a preselected set of indicators that directly measures the MGD Program's progress toward achieving its objectives.

    Agency Affected: Department of Agriculture

  2. Status: Closed - Implemented

    Comments: In comments on the draft report, USDA said that it agreed with the GAO recommendation and would take steps to address it. From June 2011 through May 2013, USDA issued and updated a monitoring and evaluation policy that draws significantly from AEA principles. For example, the policy identifies the criteria that guide the evaluation process and stipulates that evaluation plans should address purpose, scope, activities, methodology, and timing, among other things. The May 2013 update added a requirement for interim evaluations versus midpoint evaluations and delineated the administrative steps for planning interim evaluations, such as the timing for submitting terms of reference for the interim evaluation to USDA and for commencing the evaluation. The policy also advises that interim evaluations should recommend mid-course corrections if necessary.

    Recommendation: To improve USDA's oversight of the MGD Program in the areas of monitoring, evaluation, and financial management, the Secretary of Agriculture should direct the Administrator of the Foreign Agricultural Service to develop policies and procedures to guide evaluation of completed projects.

    Agency Affected: Department of Agriculture

  3. Status: Closed - Implemented

    Comments: In commenting on the draft report, USDA said that it agreed with the GAO recommendation and would take steps to address it. In November 2011, USDA issued the Food Assistance Division Program Implementation Guidebook that provides an explanation of the close-out process and includes a checklist for participants to use to prepare their agreements for closeout. In early 2013, USDA released new standard operating procedures for closing out grant agreements. While the procedures cover important changes to Food Assistance Division systems and business processes that impact the closeout process, including a requirement that all agreement closeouts will be conducted through the Food Aid Information System, most of the procedures did not include time frames. Based on GAO's follow-up inquiries, in September 2013, USDA again revised its standard operating procedures for closing out grant agreements; however, it still lacked time frames in several steps, which could result in grant agreements not be closed out in a timely fashion, and it did not have an effective date for implementation. GAO further requested clarification of time frames for these steps, and in July 2015, USDA revised and finalized its standard operating procedures for closing out grant agreements, which addresses GAO's recommendation, as well as established a date when this standard operating procedures became effective.

    Recommendation: To improve USDA's oversight of the MGD Program in the areas of monitoring, evaluation, and financial management, the Secretary of Agriculture should direct the Administrator of the Foreign Agricultural Service to formalize policies and procedures for closing out grant agreements and establish guidance for when agreements should be closed.

    Agency Affected: Department of Agriculture

 

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