International School Feeding: USDA's Oversight of the McGovern-Dole Food for Education Program Needs Improvement

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.

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.

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.