International Food Assistance: Agencies Should Ensure Timely Documentation of Required Market Analyses and Assess Local Markets for Program Effects
Fast Facts
USAID and USDA provided approximately $1.9 billion of U.S food aid overseas in fiscal year 2015, including about 1.5 million metric tons of commodities such as rice or wheat. Before signing assistance agreements, these agencies are required to document that distributing commodities will not hurt the recipient country's agricultural production or local markets (Bellmon determinations).
We found that USAID and USDA do not consistently document these determinations before distributing food aid.
We recommended that the agencies document Bellmon determinations in a timely manner and also monitor and evaluate markets for negative effects.
Local markets in Malawi (left) and Guatemala (right)
Two photos of markets with vendors and shoppers.
Highlights
What GAO Found
The U.S. Agency for International Development (USAID) and the U.S. Department of Agriculture (USDA) each have a process for prioritizing countries to receive U.S. commodities. USAID's documents lay out its steps to select countries for Food for Peace (FFP) projects in fiscal years 2013 through 2016. However, USDA's documents do not consistently account for decisions to provide commodities to countries that did not meet its prioritization criteria for McGovern-Dole International Food for Education and School Nutrition (McGovern-Dole) and Food for Progress development projects. For example, analysis of USDA documents showed countries that did not meet these criteria received 40 percent of Food for Progress funding in fiscal year 2015; however, the documents do not provide USDA's reasons for these decisions. Better documentation of such decisions would improve transparency and accountability.
USAID and USDA did not consistently document that U.S. commodities would not negatively affect recipient countries' production or markets and that adequate storage was available before providing the commodities. USAID and USDA guidance requires documentation of such “Bellmon determinations” before food aid agreements are signed. In fiscal years 2014 and 2015, USAID and USDA followed this guidance for the 6 FFP emergency projects and 5 of 6 Food for Progress projects GAO reviewed. However, USAID documented determinations before signing agreements for only 5 of 8 FFP development projects, and USDA did so for only 2 of 18 McGovern-Dole projects. As a result, the agencies did not consistently document compliance with a key control.
GAO found lower-than-expected prices 12 percent of the time for key commodities in countries that received commodity-based U.S. food aid at some point in 2015 and 2016. However, neither agency required implementing partners to monitor or evaluate markets during this period. In December 2016, USAID began requiring partners to monitor and evaluate emergency projects for negative market effects, such as unusual price changes. However, USAID does not require this for development projects, and USDA does not require it for either McGovern-Dole or Food for Progress. Yet both agencies require monitoring of project performance and evaluation of project outcomes to identify challenges, ensure projects achieved intended results, and to improve future projects. Monitoring and evaluation for negative market impacts would help identify any needed midcourse corrections and inform future Bellmon determinations.
Delivery of U.S. Department of Agriculture Commodities to a School in Guatemala 
Why GAO Did This Study
In 2015, USAID and USDA provided about $1.9 billion of U.S food aid overseas, including about 1.5 million metric tons of commodities. The Bellmon amendment to the Food for Peace Act requires determining, before distribution of commodities, that the distribution will not cause a substantial disincentive to a country's domestic production and that adequate storage will be available. Agency guidance requires documenting Bellmon determinations before food aid agreements are signed and promotes monitoring and evaluation to improve accountability and performance.
GAO was asked to review USAID's and USDA's provision of U.S. commodities. This report examines the extent to which the agencies have (1) documented their selection of countries for food aid, (2) documented Bellmon determinations before signing project agreements, and (3) monitored and evaluated markets to identify any negative effects during and after project implementation. GAO analyzed agency data, interviewed officials, and visited sites in Malawi and Guatemala where the agencies had projects. GAO also reviewed documentation for 38 projects initiated and 35 final evaluations or reports completed in fiscal years 2014 and 2015.
Recommendations
GAO is making eight recommendations to strengthen USAID's and USDA's provision of U.S. commodities. For example, GAO recommends that both agencies document all Bellmon determinations before signing agreements with partners and require monitoring and evaluation for negative market effects. Both USAID and USDA agreed with our recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| U.S. Agency for International Development | To help ensure that, consistent with the Bellmon amendment, the provision of U.S. in-kind food aid does not result in a substantial disincentive to, or interference with, domestic production or marketing in countries receiving in-kind food aid, the USAID Administrator should ensure that Bellmon determinations are documented for all food assistance projects prior to the provision of commodities, consistent with agency guidance. |
On October 13, 2017 USAID provided a formal response to the Congress on the recommendations included in GAO-17-640. In the response, USAID indicated that it concurred with the recommendations in the report, and USAID reported that it is updating guidance and procedures to address the recommendations. USAID expressed its commitment to ensure that Bellmon determinations are documented for all food assistance projects prior to the provision of U.S. commodities. Additionally, USAID provided documentation that it had completed a Bellmon determination for all applicable food assistance projects in fiscal year 2017.
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| U.S. Agency for International Development | To help ensure that, consistent with the Bellmon amendment, the provision of U.S. in-kind food aid does not result in a substantial disincentive to, or interference with, domestic production or marketing in countries receiving in-kind food aid, the USAID Administrator should update guidance on Bellmon determinations to reflect current policies and procedures. |
On October 13, 2017 USAID provided a formal response to the Congress on the recommendations included in GAO-17-640. In the response, USAID indicated that it concurred with the recommendations in the report, and USAID reported that it is updating guidance and procedures to address the recommendations. USAID updated and reissued the Food for Peace Information Bulletin, which outlines USAID's guidance on Bellmon determinations. USAID distributed the updated guidance to the Food Aid Consultative Group in April, 2018 and uploaded the document to the USAID Food For Peace public-facing website.
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| U.S. Agency for International Development | To help ensure that, consistent with the Bellmon amendment, the provision of U.S. in-kind food aid does not result in a substantial disincentive to, or interference with, domestic production or marketing in countries receiving in-kind food aid, the USAID Administrator should monitor markets during implementation of development projects to identify any potential negative effects, such as unusual changes in prices. |
In response to the GAO recommendation, USAID updated its fiscal year 2018 guidance for Development Awards to require implementing partners to monitor and report on local markets. Specifically, USAID guidance now requires implementing partners to report on price changes in local markets over time, as well as unexpected disincentives or negative effects on markets.
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| U.S. Agency for International Development | To help ensure that, consistent with the Bellmon amendment, the provision of U.S. in-kind food aid does not result in a substantial disincentive to, or interference with, domestic production or marketing in countries receiving in-kind food aid, the USAID Administrator should evaluate markets after development projects are completed to determine whether markets were negatively affected during project implementation or after project completion. |
GAO reported that USAID did not require implementing partners to evaluate markets in 2015 or 2016. In December 2016, USAID began requiring partners to evaluate emergency projects for negative market effects, such as unusual price changes. However, USAID did not require evaluation of markets for development projects. Because the provision of in-kind food aid can distort local markets and displace commercial trade in recipient countries, GAO recommended that USAID evaluate markets after development projects are completed to identify any potential negative effects, such as unusual changes in prices. In response to the GAO recommendation, USAID updated its fiscal year 2018 guidance for Development Awards to require implementing partners to evaluate and report on local markets. Specifically, USAID guidance now requires implementing partners to provide a final evaluation on unexpected market impacts or disincentives to local production upon project completion. Additionally, in December 2018, USAID conducted its own post-completion market evaluation of a development project using the required reporting provided by the implementing partners. Moving forward, USAID indicated it will use market evaluations provided by implementing partners to assess any potential negative market impacts if there were indications of market disruptions during program implementation. By evaluating markets after projects are completed, USAID will improve their ability to determine if any negative market effects resulted from delivery of in-kind food commodities, and therefore would have information that could be used to ensure future projects do not cause disincentives to, or interfere with, domestic production or marketing.
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| Department of Agriculture | To ensure the transparency and accountability of USDA's selection of countries to receive in-kind food aid, the Secretary of Agriculture should develop guidance to require documentation of the reasons for providing funding to countries that were not on the priority list. |
In response to our recommendation, USDA included a requirement in their fiscal year 2021 guidance to document an exception if any countries recommended for funding were not on USDA's priority list. USDA noted that it had not recommended funding to a non-priority country for in-kind food aid since GAO made the recommendation. However, the updated guidance will ensure any future decisions to provide funding to countries not on the priority list will be documented, which will improve transparency and accountability.
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| Department of Agriculture |
Priority Rec.
To help ensure that, consistent with the Bellmon amendment, the provision of U.S. in-kind food aid does not result in a substantial disincentive to, or interference with, domestic production or marketing in countries receiving in-kind food aid, the Secretary of Agriculture should ensure that Bellmon determinations are documented for all food assistance projects prior to the provision of commodities, consistent with agency guidance. |
GAO reported that USDA did not consistently document that U.S. commodities would not negatively affect recipient countries' production or markets and that adequate storage was available before providing the commodities. USDA guidance requires documentation of such "Bellmon determinations" before food aid agreements are signed . In fiscal years 2014 and 2015, USDA documented determinations before signing agreements for only 2 of 18 McGovern-Dole projects. GAO recommended that USDA take action to ensure that Bellmon determinations are documented for all food assistance projects prior to the provision of commodities, consistent with agency guidance. In response to the GAO recommendation, USDA expressed its commitment to ensure that Bellmon determinations are documented for all food assistance projects prior to the provision of U.S. commodities, and USDA updated its guidance to require Bellmon determinations should be documented and approved by USDA management. Additionally, USDA provided documentation that it had completed a Bellmon determination for all applicable food assistance projects in fiscal year 2017.
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| Department of Agriculture | To help ensure that, consistent with the Bellmon amendment, the provision of U.S. in-kind food aid does not result in a substantial disincentive to, or interference with, domestic production or marketing in countries receiving in-kind food aid, the Secretary of Agriculture should monitor markets during implementation of McGovern-Dole projects to identify any potential negative effects, such as unusual changes in prices. |
The agency agreed with our recommendation. In response to GAO's recommendation, USDA provided GAO with updated FY 2020 guidance for McGovern-Dole projects, which requires implementing partners to assess any potential negative effects on markets, such as unusual changes in commodity prices. Implementing partners are required to submit an updated market study to USDA on an annual basis. As a result, USDA and implementing partners will have the ability to identify potential negative effects resulting from the delivery of commodities, and have information that could be useful for making needed midcourse corrections, as well as information that could be used to ensure future projects do not cause disincentives to, or interfere with, domestic production or marketing.
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| Department of Agriculture | To help ensure that, consistent with the Bellmon amendment, the provision of U.S. in-kind food aid does not result in a substantial disincentive to, or interference with, domestic production or marketing in countries receiving in-kind food aid, the Secretary of Agriculture should evaluate markets after the completion of McGovern-Dole and Food for Progress projects to determine whether markets were negatively affected during project implementation or after project completion. |
The agency agreed with our recommendation. In response to GAO's recommendations, USDA provided GAO with updated fiscal year 2020 guidance for McGovern-Dole projects, which requires implementing partners to conduct annual market studies, including the year in which the program ends, of the impacts of commodities on local markets, such as unusual changes in commodity prices. In addition, in January 2021, USDA informed GAO it had updated guidance for Food for Progress projects to require implementing partners to conduct an economic impact assessment of how agricultural commodities can be imported and distributed without resulting in substantial disincentive to, or interference with, agricultural sales within the target country. According to USDA, since 2018, these assessments have been conducted by independent evaluators. The guidance includes a requirement for an impact assessment after the sale of commodities. As a result of these updates to USDA guidance, USDA will have information that could be used to ensure future programs do not cause disincentives to, or interference with, domestic production or marketing.
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