Detailed Information on the
Commodity Supplemental Food Program Assessment

Develop annual and long-term performance measures, and a plan for establishing baselines and targets by June 30, 2005.

Working with Congress to eliminate the program and enroll participants in the WIC and Food Stamp Programs

Develop and implement a revised elderly food package that emphasizes the unique nutritional needs of the elderly by October 1, 2005.

Develop and implement a plan for periodic USDA and State review of CSFP program management by October 1, 2005.

Measure: Percentage of allocated caseload slots utilized

Explanation:FY04 data will be used for the national baseline. The highest avg. participation (not to exceed 100% of assigned caseload) of two periods--the entire FY or the last quarter of the FY--will be used to determine each State's participation/caseload utilization; and subsequently totaling all States' highest avg. participation of the two periods discussed above will yield the national baseline for participation and caseload utilization. Annually, FNS will target a 5% reduction in the gap between total caseload slots utilized and caseload slots allocated.

Measure: Change in Administrative Cost Per Food Package Distributed Relative to the Change in the State and Local Government Price Index

Explanation:

Is the program purpose clear?

Explanation: Through the CSFP, USDA provides nutritious commodities to help State and local agencies meet the nutritional needs of low-income pregnant, postpartum, and breastfeeding women, infants, children ages 1 through 5, and elderly persons. The program is intended to accomplish this purpose while also supporting a plentiful supply of food through the purchase and distribution of agricultural commodities.

Evidence: Description of purpose drawn from proposed 7 CFR Part 247.2, published at 68 FR 62184 (10/31/2003). CSFP's mission is clearly stated in current Program regulations at 7 CFR Part 247.1. The program's agricultural support purpose is found in the Agriculture and Consumer Protection Act of 1973, Section 4(a) and 5, as amended, Public Law 93-86, 7 U.S.C. 612c (note); the Food and Agriculture Act of 1977, as amended, Public Law 95-113, 91 Stat. 980; Public Law 97-98, 95 Stat. 1293; Public Law 98-8, 97 Stat. 35; Public Law 98-92, 97 Stat. 611; the Food Security Act of 1985, Public Law 99-198, 99 Stat. 1590; Public Law 101-624, 104 Stat. 3806; Public Law 104-127, 110 Stat. 888. and, the Farm Security and Rural Investment Act of 2002, Subtitle B, Sec. 4201, Public Law 107-171, 116 Stat. 328.

Does the program address a specific and existing problem, interest or need?

Explanation: CSFP is largely focused on the nutritional needs of low-income elderly households. In 2002, more than 19 percent of these households were food insecure. In elderly persons, food-insecurity has been linked with significantly lower intakes of energy, protein, carbohydrate, niacin, riboflavin, vitamins B-6 and B-12, magnesium, iron and zinc, and impacts on basic quality of life. Such nutrient deficiencies can result in poor memory and cognitive function, impaired immune function, slowed healing of wounds, and heart disease. CSFP provides a supplemental food package to low-income elderly to help them achieve a healthy, balanced diet. CSFP also serves young adult women and children. For this population, food insecurity has been associated with lower intakes of food energy, vitamin B-6, calcium, magnesium, and iron, along with impacts on cognitive, academic and psychological development. Program benefits are tailored to address the specific needs of this population.

Evidence: Lee JS, Frongillo EA. Nutritional and health consequences are associated with food insecurity among U.S. elderly persons. J Nutrition. 2001;131:1503-1509; Cristofar SP, Basiotis PP. Dietary intakes and selected characteristics of women ages 19-50 years and their children ages 1-5 years by reported perception of food sufficiency. J Nutrition Education (1992) 24: 53-58; Alaimo K, Olson CM, Frongillo EA. Food insufficiency and American school-aged children's cognitive, academic and psychosocial development. Pediatrics (2001) 108:44-53; Vailas LI, Nitzke SA, Kecker M & Gast, J. Risk indicators for malnutrition are associated inversely with quality of life for participations in meals programs for older adults. JADA (1991) 91:300-304; Wilde P, Dagata E. Food Stamp Participation by Eligible Older Americans Remains Low. ERS FoodReview No. 25-2. 9/02; Nord M, Andrews M, Carlson S. Household Food Security in the United States, 2002. Food and Rural Economics Division, USDA-ERS, Food Assistance and Nutrition Research Report No. 35; Position of the American Dietetic Association: Nutrition, aging, and the continuum of care.

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: CSFP participants may also be eligible for and are encouraged to participate in the Food Stamp Program. For dual participants, the programs are redundant since both programs provide benefits to help individuals meet their basic nutritional needs. CSFP's 'WIC-like' component partially duplicates WIC. Some CSFP clients are also eligible for WIC, and the programs' purposes for this group do not differ substantially. Regulations prohibit simultaneous participation in both CSFP and WIC. CSFP's 'WIC-like' client group is a small and declining part of the program. In April 2004, 12% of CSFP clients were non-elderly, and many of these individuals may not have been eligible for WIC.

Evidence: On requirement to provide FSP information, see Agriculture and Consumer Protection Act of 1973, Sec. 5 (h)(1). 7 CFR Sec. 246.7(l) and 247.7(j) prohibit simultaneous participation in the WIC Program and the CSFP. Income-eligible children ages 5-6 years and women 6-12 months postpartum are eligible for CSFP but not for WIC; Sec. 246.2 (Definitions) and 247.2 (Definitions) establish categorical eligibility requirements for the WIC Program and the CSFP, respectively. National Databank Version 8.0 participation data retrieved 7/01/04.

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: CSFP's design takes advantage of the Federal government's ability to purchase commodity foods at extremely low cost relative to commercial sources. While USDA must cover the costs of its CSFP program partners to store and distribute these foods, it is able to avoid other costs added through retail channels of trade. However, CSFP's cost effectiveness is reduced by its funding formula which allocates administrative funds to States based on a plan of caseload to be served, rather than on caseload actually served. In addition, while funding for the program does not allow for national coverage, there is no clear rationale for the determination of where the program does and does not operate.

Evidence: Section 5(d)(1) of the Agriculture and Consumer Protection Act of 1973, as amended, establishes the Secretary's authority to determine the types and varieties of commodities distributed through CSFP. Section 5(a) establishes the level of administrative funding per assigned caseload slot to be provided to State operating agencies.

Is the program effectively targeted, so that resources will reach intended beneficiaries and/or otherwise address the program's purpose directly?

Explanation: CSFP serves women, infants, and children who have been determined income eligible under existing Federal, State, or local food, health or welfare programs for low-income persons. For elderly, household income must be at or below 130 percent of the DHHS Federal Poverty Income Guidelines. While the targeted population is clearly defined, there are no national requirements to verify the eligibility of applicants, and only a limited number of program operators undertake such verification. The reliance in most cases on participant attestation of eligibilty represents a risk of erroneous benefit issuances. In addition, the CSFP food package would more directly address the nutritional needs of its elderly participants if it emphasized the nutrients that tend to be lacking in elderly diets.

Evidence: Eligible program beneficiaries are listed at 7 CFR Part 247.7. Program legislation supports the targeting of the intended beneficiaries at those legislative cites listed in the evidentiary response to Question 1.1. CSFP regulations at 7 CFR 247.7(a)(1) require categorical eligibility of all participants, and income requirements for the elderly are provided at 7 CFR 247.7(a)(3). Per Program regulations at 7 CFR 247.7 (a)(2) categorically eligible women, infants, and children, who are considered income eligible for local benefits under existing Federal, State, or local food, health or welfare programs, are considered eligible for CSFP. Representative Elderly CSFP Food Package: Nutritional Values.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: FNS does not track long-term performance measures that track the specific contribution of CSFP to the outcomes that Federal nutrition assistance programs are intended to support. USDA has established a limited number of long-term outcome measures for the 15 programs in the aggregate: the prevalence of hunger among low-income households, the Healthy Eating Index (a measure of dietary quality) for low-income individuals and children, and the rate of obesity among adults, and overweight among adolescents and children.

Evidence: USDA Strategic Goal 4: Improve the Nation's Nutrition and Health, from the Strategic Plan for FY 2002-2007, and its related Objectives (4.1: Improve Access to Nutritious Food, and 4.2: Promote Healthier Eating Habits and Lifestyles) apply to CSFP, as well as all other USDA nutrition assistance programs. (See USDA Strategic Plan 2002-2007, pp. 18-20.)

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: As noted in 2.1, there are no specific long-term performance goals for CSFP. However, overall targets for the hunger, diet quality, and obesity measures represent significant improvements by 2007.

Evidence: USDA Strategic Plan 2002-2007; FNS Strategic Plan 2000-2005.

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: USDA plans to utilize the following two annual efficiency goals and corresponding performance measures. However, these meaures do not demonstrate progress either towards achieving FNS' long-term cross-cutting goals or achieving the purpose of CSFP. The planned efficiency measures are: (1) To reasonably approach 100% caseload utilization by reducing the gap between total caseload slots utilized and caseload slots allocated each fiscal year. (2) To improve food package distribution efficiency by reducing the gap between average administrative funds per food package distributed and the prorated monthly administrative grant per caseload slot assigned per legislative mandate each fiscal year.

Evidence: Program regulations at 7 CFR Part 247.10(a)(2)(ii) establish base caseload determination procedures. 7 CFR 247.10(a)(2)(iii)(A) establishes the criterion of State eligibility to receive expansion caseload. Program legisl. statement based on legisl. cites provided in 1.1. Per Section 5(a) of the Agriculture and Consumer Protection Act of 1973 (7 U.S.C. 612(c) note), as amended, States are allocated an administrative grant per assigned caseload slot. See also 68 FR 62163, the CSFP Plain Language Proposed Rule for proposed changes to the performance measures. Proposed changes to the performance measures are available at proposed 7 CFR Part 247.21. CSFP Food Package Distribution Efficiency Measures were announced in March 2003 and will be initiated upon the release of FY04 closeout data.

Does the program have baselines and ambitious targets for its annual measures?

Explanation: The program does not have baseline data for its annual measures. USDA plans to use FY04 data as the baseline. For measure (1) listed in 2.3, FNS will target a 5% annual reduction in the gap between total caseload slots utilized and caseload slots allocated. For measure (2), FNS will target a 5% annual reduction in the gap between national avg. administrative funds spent per food package distributed and the prorated monthly admin. grant per assigned caseload slot. Without baseline data, the ambitiousness of the annual targets cannot be evaluated. In addition, the long-term targets are basic requirements for sound management, rather than ambitious program goals.

Evidence: Section 247.10(a) established CSFP base caseload assignment procedures. The proposed rule that would alter these procedures was published on October 31, 2003 at 68 FR 62164. Participation/caseload utilization determinations for each State in measure (1) are similar to proposed rule base caseload assignment procedures The administrative grant per slot is mandated by Section 5(a) of the Agriculture and Consumer Protection Act of 1973 (7 U.S.C. 612(c), note), as amended.

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: USDA has not articulated long-term program goals for CSFP. USDA requires States to attain at least 90 percent caseload utilization in order to expand the program in future years, and has proposed increasing this requirement to 95 percent. However, the efficiency measures and annual targets indicated in 2.1 and 2.3 are new and have not yet been presented to States.

Evidence: FNS-153 reports, National Data Bank reports, and budget documents.

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: CSFP has not been evaluated since the 1980's.

Evidence: None.

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: FNS' budget request displays resources for CSFP and other programs in alignment with long-term USDA strategic goals, and fully accounts for all resources by providing a full cost by strategic goal which includes all administrative and overhead expenses allocated to program accounts. It shows the unit cost per CSFP participant. It also includes measures of caseload and participation. However, the budget does not explictly tie the CSFP budget request to the accomplishment of or improvement in annual or long-term performance goals.

Evidence: FNS FY 2005 Explanatory Notes (see especially pp. 26-13, 26-67.)

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: CSFP does not have a stand-alone strategic plan. The program is a part of the USDA Strategic Plan 2002-2007, and the FNS Strategic Plan 2000-2005. USDA has developed two annual efficiency measures to improve the program's cost effectiveness. However, it has not developed long-term outcome nor output goals for the program. USDA is exploring the possibility (contingent on the availability of resources) of analyzing CSFP participant characteristics. This study would enable the Department to better understand the household size and composition, available food preparation facilities, infirmities/disabilities, and other factors that could help to identify program improvements.

Evidence: The CSFP Plain Language, Program Accountability, and Program Flexibility Proposed Rule is available at 68 FR 62163. The proposed changes to the performance measures are available at proposed 7 CFR Part 247.21. The Preamble of the Proposed Rule further explains the performance measures.

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: States report participation data on a monthly basis, and financial data on a quarterly and annual basis. USDA monitors these reports and instructs States to reduce participation or facilitates their efforts to increase participation in accordance with assigned caseloads. While USDA has announced its intention to track average administrative costs per food package, it has not yet begun to collect or use this data to manage the program. CSFP is infrequently the focus of State management evaluations.

Evidence: Section 247.13(c) established the monthly participation reporting requirement, and Section 247.13(b) establishes the quarterly financial reporting requirement. USDA policy memorandum entitle "Commodity Supplemental Food Program (CSFP): Caseload Assignments for the 2003 Caseload Cycle, and Administrative Grants," issued electronically on March 4, 2003.

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: All FNS managers, including those responsible for CSFP, are required to have their performance plans aligned with USDA strategic goals and FNS priorities. Performance plans explicitly tie managers' responsibilities to accomplishment of this designed priority work, and related strategic and annual goals. Commodity vendors are held accountable for compliance with procurement contracts. Regulations and FNS Instructions make State agencies responsible for the commodities they receive, in terms of proper storage, handling, and disposition. Regulatory requirements for State/local agreements, in turn, apply these responsibilities to the local level. FNS is in the process of rulemaking to apply more rigorous performance standards to resource allocation.

Evidence: Memoradum to Subcabinet and Agency Heads from USDA Deputy Secretary on President's Management Agenda and Performance Standads of GS-14s and 15s; Attestation of Under Secretary Bost to compliance with requirements; Sections 250.12, 250.13, 250.14, 250.16, 250.17, 250.20, and 250.24 of Food Distribution Program regulations, FNS Instruction 410-1 (Non-Audit Claims ' Food Distribution Program), FNS Instruction 433-1 (Intra-Agency Commodity Reconciliation), FNS Instruction 709-5 (Shipment and Receipt of Foods), and FNS Instruction 710-1 (Commodities Found Out-of-Condition After Receipt by Distributing Agencies). Section 247.10(a) established CSFP caseload assignment procedures. The proposed rule that would alter these procedures was published on October 31, 2003 at 68 FR 62164.

Are funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: All funds for the CSFP are obligated appropriately and consistently for their intended purpose and in a timely manner. FMFIA reports from 2001 through 2003 and the A-133 Single-Audits have not identified any program-related deficiencies.

Evidence: A-133 Single-Audits, Food and Nutrition Service (2003). Federal Managers' Financial Management Integrity Act (FMFMIA) Report: Fiscal Year 2001-2003.

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: CSFP commodity procurements are conducted competitively to control costs. Examples of strategies to increase efficiency and effectiveness include the shift to purchase of commodities in commercial labels, and to long-term indefinite delivery/indefinite quantity contracting for some products. CSFP local agencies rely heavily on volunteers to augment program services without increasing administrative costs.

Evidence: Copies of procurement documents are available from FNS's commodity procurement agents, the Agricultural Marketing Service for fruits, vegetables, meats, poultry, and fish; and the Farm Service Agency for dairy, grains, and oils. Past compilations of volunteer hours and services by the National CSFP Association are on file in the Food Distribution Division of FNS.

Does the program collaborate and coordinate effectively with related programs?

Explanation: Local CSFP agencies are required to advise participants of the availability and location of health care services. They must also provide written information about Food Stamps, Medicaid, Temporary Assistance for Needy Families (TANF), and the child support enforcement to women, infants and child participants. For the elderly, local agencies must provide written information about Food Stamps, Supplemental Security Income, and medical benefits provided under Title XVI and Title XIX. CSFP and WIC States must enter into agreements to detect and prevent dual participation. Federal CSFP and WIC staff collaborate on memos and guidance materials applicable to both programs. FNS promotes a referral system through which CSFP local agencies recommend WIC to eligible persons; and vice-versa. HHS' Administration on Aging is participating in the review of the CSFP food package.

Evidence: 7 CFR 247.6 provides referral requirements. Regulations at 7 CFR Part 247.5(a)(10) require State agency agreements to detect and prevent dual participation in local areas where both CSFP and WIC operate. The WIC/CSFP joint guidance memorandum dated August 31, 2000, entitled "CSFP: Collaboration Between WIC and CSFP Local Agencies" addresses dual participation issues. The WIC/CSFP joint memorandum also provides guidance on WIC/CSFP cross-program referrals and the sharing of information. A second joint memorandum providing additional guidance on dual participation issues is currently in development, involving collaboration between FDD and SFPD.

Does the program use strong financial management practices?

Explanation: Agency received an unqualified opinion from 1998 through 2000 in its financial statements audit. The Agency has had no reportable conditions in the Department's consolidated financial statements audit in 2001 through 2003. CSFP adheres to a set of established financial policies that are clearly articulated in program directives, Departmental Regulations and OMB Circulars. Program standards require State agencies to maintain a financial management system that provides accurate, current and complete disclosure of CSFP's financial status. However, there are no national requirements to verify the eligibility of applicants; only a limited number of program operators undertake such verification. The reliance on participant attestation of eligibilty represents a risk of erroneous payments.

Evidence: USDA OIG audits of Consolidated Balance Sheet as of September 30, 2001, 2002 and 2003. FNS financial statements audits, 1998 through 2000.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: USDA has proposed to require States to attain 95 percent (rather than 90 percent) caseload utilization in order to expand the program in future years. USDA is in the process of developing guidance for regional office staff to use when conducting management evaluations. USDA plans to review the CSFP food package on the same five-year cycle as the update to the USDA Dietary Guidelines. With this review, USDA plans to increase levels of key nutrients in the food package known to be lacking in the diets of low-income elderly, and decrease the levels of sodium or fat.

Evidence: CSFP Plain Language Proposed Rule (68 FR 62163) contains proposed changes to the minimum requirements for caseload expansion; Draft CSFP Managemetn Evaluation Guide.

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: USDA conducts financial management reviews in all States every 3 to 5 years to obtain reasonable assurance that the financial information reported by State agencies is correct and complete; that it represents proper expenditures of Federal funds; and that States have complied with applicable financial requirements. USDA also conducts management evaluations on a similar cycle. However, CSFP may not be a signficant focus of the review, or not included in the review at all.

Evidence: FNS Financial Management Review (FMR)Guide; Management Evaluation and Reviews; Commodity Supplemental Food Program Regulations.

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: FNS collects program data from States, some of which is published annually, or more frequently, on the FNS web site. However, most of the data on the website is aggregated on a program-wide level. In addition, the website provides data on total program costs, but not detailed by spending category. FNS publishes state-level participation data and updates it monthly. However, it does not publish other state-level data, such as types of participants or program cost.

Evidence: CSFP information on the FNS website may be found at the following links: www.fns.usda.gov/pd/fdpmain.htm; www.fns.usda.gov/fdd/default.htm; and www.fns.usda.gov/fdd/programs/csfp/.

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: CSFP does not have long-term program-specific performance goals. The most recent available data for FNS' long-term cross-cutting performance goals indicates: (1) Rising unemployment and increased poverty have contributed to an increase in the rate of hunger among low-income people between 2000 and 2002; (2) there was no change in the Healthy Eating Index scores between 1996 and 1999-2000.

Evidence: Nord, M., and M. Andrews. Reducing Food Insecurity in the United States: Assessing Progress Toward a National Objective. U.S. Department of Agriculture, Economic Research Service; Basiotis, P., A. Carlson, S. Gerrior, W.Y. Juan, and M. Lino (2002). The Healthy Eating Index: 1999-2000. U.S. Department of Agriculture, Center on Nutrition Policy and Promotion.

Does the program (including program partners) achieve its annual performance goals?

Explanation: USDA plans to implement two new annual efficiency measures, for which it will collect baseline data at the end of FY 04. Achievement of these goals cannot be assessed until baseline data and annual targets are set. USDA has not established measures for CSFP that will demonstrate progress towards the program's long-term goals or purpose.

Evidence: Program regulations at 7 CFR 247.10(a)(2)(ii) contain current requirements for assigning state caseload. Per Public Law 107-171, states are allocated an administrative grant per caseload slot. See 68 FR 51675. The CSFP Plain Language Proposed Rule is available at 68 FR 62163. Proposed changes to the performance measure are available at proposed Part 247.21.

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: USDA plans to implement two new annual efficiency measures, for which it will collect baseline data at the end of FY 04. Achievement of these goals cannot be assessed until baseline data and annual targets are set.

Evidence: FNS's intention to track national total expenditures of administrative funds per food package actually distributed to a participant was announced in a memorandum entitled 'Commodity Supplemental Food Program (CSFP): Caseload Assignments for the 2003 Caseload Cycle, and Administrative Grants,' which was issued electronically on March 4, 2003.

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: CSFP has not been evaluated since the 1980's, and, thus, does not have results that can be compared to other Federal, state or local nutrition assistance programs. Over time, the WIC program has grown, while participation of women, infants and children in CSFP has declined. This trend reflects a significant preference of participants, Federal policy-makers, and state and local program administrators for WIC over CSFP. For elderly individuals, now the majority of CSFP participants, evidence suggests that CSFP may represent a favorable alternative to the Food Stamp Program, and contribute positively to access to food assistance for low-income elderly people in the places where the program operates.

Evidence: FNS FY 2005 Explanatory Notes, showing Federal funding and participation in WIC and CSFP over time. Ponza, et al., Evaluation of the Food Assistance Needs of the Low-income Elderly and their Participation in USDA Programs, 1990, pp. 120-125.

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: There has not been an independent evaluation of CSFP since the 1980's.

Evidence: