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Open Recommendations

School Meal Programs: USDA Could Enhance Implementation of the Buy American Provision
GAO-23-105884
Apr 13, 2023
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1 Open Recommendations
Agency Affected Recommendation Status
Department of Agriculture The Secretary of Agriculture should ensure that the Administrator of FNS develops a standard form that school food authorities can use to document their reasons for using exceptions from the Buy American provision, and disseminates that form through state agencies. (Recommendation 1)
Open
FNS concurred with this recommendation and stated that it will develop a standard template that school food authorities can use to document information related to the Buy American provision when utilizing exceptions. Further, FNS noted that in developing the template, it will consider topical comments on the Buy American provision included in the proposed rule, Child Nutrition Programs: Revisions to Meal Patterns Consistent with the 2020 Dietary Guidelines for Americans, published February 7, 2023. We will monitor the progress of these efforts.

Thrifty Food Plan: Better Planning and Accountability Could Help Ensure Quality of Future Reevaluations
GAO-23-105450
Dec 14, 2022
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8 Open Recommendations
2 Priority
Agency Affected Recommendation Status
Department of Agriculture
Priority Rec.
This is a priority recommendation.
The Secretary of Agriculture should develop and document a process to ensure that TFP reevaluations follow the project management practice of establishing a key document at the start of a project, such as a project charter, that includes an overall assessment of risk and measurable objectives and metrics for success related to project requirements and other expectations for the project. (Recommendation 1)
Open
USDA did not explicitly agree or disagree with this recommendation. USDA did not describe any actions it planned to take to address this recommendation and noted that it plans to respond to each recommendation in detail as part of its required Statement of Action by June 2023.
Department of Agriculture The Secretary of Agriculture should develop and document a process to ensure that TFP reevaluations follow the project management practice of creating a comprehensive project management plan that describes how the project will be executed, monitored, controlled, and closed and, in addition to a project schedule, includes:

  • a risk management plan that manages operational risk and applies controls to ensure the project meets its objectives.
  • a quality management plan that describes how the project will be monitored and controlled based on applicable USDA and other federal quality standards.
  • a stakeholder engagement plan outlining all of the relevant stakeholders that must be included in the reevaluation and their respective roles for achieving quality
  • a requirements management plan that establishes how the project requirements will be analyzed, documented, and managed.
    • (Recommendation 2)
Open
USDA did not explicitly agree or disagree with this recommendation. USDA did not describe any actions it planned to take to address this recommendation and noted that it plans to respond to each recommendation in detail as part of its required Statement of Action by June 2023.
Department of Agriculture The Secretary of Agriculture should develop and document a process to ensure that TFP reevaluations follow the project management practice of designating a project manager, or another member of the project team with project management expertise, to ensure that TFP reevaluations apply generally recognized project management practices, including creating key project documentation. (Recommendation 3)
Open
USDA did not explicitly agree or disagree with this recommendation. USDA did not describe any actions it planned to take to address this recommendation and noted that it plans to respond to each recommendation in detail as part of its required Statement of Action by June 2023.
Department of Agriculture The Secretary of Agriculture should develop and document a process to ensure that TFP reevaluations are subject to formal, comprehensive, and independent peer reviews before publication. (Recommendation 4)
Open
USDA did not explicitly agree or disagree with this recommendation. USDA noted that the Food and Nutrition Service (FNS) will develop formal peer review guidance and clarify which scientific studies will be subject to peer review, how those decisions will be made, and the process for peer review. However, FNS did not specify whether all future TFP reevaluations will be subject to formal, comprehensive, and independent peer reviews before publication. USDA noted that it plans to respond to each recommendation in detail as part of its required Statement of Action by June 2023.
Department of Agriculture The Secretary of Agriculture should consult with the Office of Information and Regulatory Affairs and designate the TFP as a "highly influential scientific assessment" subject to more stringent OMB guidance concerning peer review. (Recommendation 5)
Open
USDA did not explicitly agree or disagree with this recommendation. USDA did not describe any actions it planned to take to address this recommendation and noted that it plans to respond to each recommendation in detail as part of its required Statement of Action by June 2023.
Department of Agriculture
Priority Rec.
This is a priority recommendation.
The Secretary of Agriculture should establish specific quality assurance guidelines for TFP reevaluations that will ensure methodological decisions meet key quality standards for an analysis that will affect public policy and inform policy makers. These guidelines should summarize applicable USDA and other federal quality standards and should describe how such standards will be embedded in future TFPs. These guidelines should ensure that future TFP reports have:

  • clear rationales linked to the objective and scope of the analysis;
  • consideration of alternatives based in evidence, including important economic effects;
  • underlying analysis of economic effects associated with decisions; where important economic effects cannot be quantified, the analysis explains how they affect the comparison of alternatives;
  • transparent description of analytical choices, assumptions and data, including explanation of key limitations in the data and methods used; and
  • adequate documentation included in the analysis; the analysis should document that it complies with a robust quality assurance process.
    • (Recommendation 6)
Open
USDA did not explicitly agree or disagree with this recommendation. USDA stated that, for future Thrifty Food Plan reevaluations, it plans to publish a detailed technical document that describes the methodology and decision points for the reevaluation, along with more detail on the quality assurance processes used. However, the agency did not identify any actions regarding the development of specific quality assurance guidelines for future TFP reevaluations. USDA noted that it plans to respond to each recommendation in detail as part of its required Statement of Action by June 2023.

National School Lunch Program: USDA Could Enhance Assistance to States and Schools in Providing Seafood to Students
GAO-23-105179
Nov 17, 2022
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3 Open Recommendations
Agency Affected Recommendation Status
Department of Agriculture The Secretary of Agriculture should develop a plan to enhance its assistance to states and school food authorities in providing seafood to students through the National School Lunch Program. Actions described in such a plan could build upon information that GAO collected regarding factors that selected states and school food authorities said have affected their efforts to provide more seafood to students through the program. The plan could also incorporate USDA's experience and lessons learned from previous efforts aimed at enhancing the variety and availability of other food products, such as dairy products and unprocessed fruits and vegetables. (Recommendation 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
National Oceanic and Atmospheric Administration The Administrator of the National Oceanic and Atmospheric Administration should work with the Secretary of Agriculture to develop a collaborative mechanism, such as a memorandum of understanding that establishes the sharing of NOAA's list of domestic seafood vendors with USDA. (Recommendation 2)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Department of Agriculture The Secretary of Agriculture should work with the Administrator of the National Oceanic and Atmospheric Administration to develop a collaborative mechanism, such as a memorandum of understanding that establishes the sharing of NOAA's list of domestic seafood vendors with USDA. (Recommendation 3)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Food Safety: FDA Oversight of Substances Used in Manufacturing, Packaging, and Transporting Food Could Be Strengthened
GAO-23-104434
Nov 08, 2022
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2 Open Recommendations
Agency Affected Recommendation Status
Food and Drug Administration The Commissioner of FDA should request specific legal authority to compel companies to provide specific information that they have about food contact substances already on the market. FDA could do so when it submits its report to the House Appropriations Committee on options to systematically reassess the safety of food additives and obtain information on their use. (Recommendation 1)
Open
In May 2023, FDA officials said they were actively considering this recommendation.
Food and Drug Administration The Commissioner of FDA should direct the agency to track the dates of the last pre- and postmarket reviews for all food contact substances in a way that allows FDA to readily identify substances that may warrant postmarket review. (Recommendation 2)
Open
In May 2023, FDA officials said they were working to update FDA's systems to automatically identify and generate reports on substances by date of last review to inform prioritization of post-market review (i.e., reassessment).
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