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McGovern-Dole Food for Education Program Needs Improvement' which was 
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United States Government Accountability Office:
GAO: 

Report to Congressional Requesters: 

May 2011: 

International School Feeding: 

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

GAO-11-544: 

GAO Highlights: 

Highlights of GAO-11-544, a report to congressional requesters. 

Why GAO Did This Study: 

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. 

What GAO Found: 

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: 

* 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. 

* 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. 

What GAO Recommends: 

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. 

View [hyperlink, http://www.gao.gov/products/GAO-11-544] or key 
components. For more information, contact Tom Melito at (202) 512-9601 
or melitot@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

USDA Has Established a Grant Approval Process Consistent with the MGD 
Program's Objectives, but Oversight Weaknesses Make It Difficult to 
Determine the Extent to which the Program Is Achieving Its Objectives: 

USDA Has Taken Actions to Address the MGD Program's Internal Control 
Weaknesses, but Improvements Can Be Made: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objective, Scope, and Methodology: 

Appendix II: GAO Analysis of Selected Studies on School Feeding 
Programs: 

Appendix III: Operation of the MGD Program: 

Appendix IV: MGD Program Funding by Year, Country, and Region: 

Appendix V: Methods NGOs Planned to Use to Select MGD Program 
Beneficiaries: 

Appendix VI: MGD Program's Planned Complementary Activities in 
Agreements with Implementing Partners: 

Appendix VII: MGD Program's Performance Indicators in NGOs Agreements 
and WFP Proposals: 

Appendix VIII: Comments from the U.S. Department of Agriculture:
GAO Comments: 

Appendix IX: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: MGD Program Performance Indicators in NGOs Agreements and WFP 
Proposals: 

Table 2: Analyses of Progress Reports Submitted by Implementing 
Partners in Our Fieldwork Countries: 

Table 3: Results of the MGD Program Financial Compliance Reviews as 
Reported by USDA: 

Table 4: Summary of Selected Studies on School Feeding Programs: 

Table 5: Criteria Used to Determine Priority Countries: 

Table 6: Criteria Used to Assess Proposals, Fiscal Years 2008-2010: 

Table 7: Periodic Progress Reporting Required of Implementing Partners: 

Table 8: MGD Program Obligations by Year, Country, and Region, Fiscal 
Years 2003 through 2010 (in millions): 

Table 9: Methods NGOs Planned to Use to Select MGD Program 
Beneficiaries: 

Table 10: MGD Program's Planned Complementary Activities in Agreements 
with Implementing Partners: 

Table 11: MGD Program's Performance Indicators in NGOs Agreements and 
WFP Proposals: 

Figures: 

Figure 1: Evolution of the MGD Program: 

Figure 2: MGD Program Countries Since 2003: 

Figure 3: Key Elements of the Grant Approval, Monitoring, and 
Evaluation Phases: 

Figure 4: The Grant Approval Phase: 

Figure 5: Examples of Complementary Activities in Agreements with 
Implementing Partners: 

Figure 6: The Monitoring Phase: 

Figure 7: Number of MGD Countries Visited and Not Visited, Fiscal 
Years 2004-2010: 

Figure 8: The Evaluation Phase: 

Figure 9: MGD Program Funds Obligated by Region, Fiscal Years 2003 
Through 2010: 

Abbreviations: 

AEA: American Evaluation Association: 

Compliance: Compliance, Security and Emergency Planning Division: 

FAD: Food Assistance Division: 

FAIS: Food Aid Information System: 

FAS: Foreign Agricultural Service: 

MES: Monitoring and Evaluation Staff: 

MGD Program: McGovern-Dole International Food for Education and Child 
Nutrition Program: 

NGO: nongovernmental organization: 

OCFO: Office of the Chief Financial Officer: 

OIG: Office of the Inspector General: 

ROM: results-oriented management: 

UNICEF: United Nations Children's Fund: 

USDA: U.S. Department of Agriculture: 

USAID: U.S. Agency for International Development: 

WFP: World Food Program: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

May 19, 2011: 

Congressional Requesters: 

In 2009, the United Nations World Food Program (WFP)[Footnote 1] 
estimated that about 66 million children in developing countries 
attend school hungry. The McGovern-Dole International Food for 
Education and Child Nutrition Program (MGD Program) was established by 
Congress in 2002 to help address this problem by providing donations 
of U.S. agricultural products, as well as financial and technical 
assistance, for school feeding and maternal and child nutrition 
projects in low-income countries to achieve improvements in education, 
nutrition, and sustainability of school feeding. According to the U.S. 
Department of Agriculture (USDA), with funding of about $200 million 
in fiscal year 2010, the MGD Program served approximately 5 million 
beneficiaries in 28 countries. The program is administered by USDA's 
Foreign Agricultural Service (FAS) and implemented by WFP and 
nongovernmental organizations (NGO). 

In 2002, we identified a number of weaknesses with the pilot program 
that preceded the MGD Program,[Footnote 2] such as a lack of expertise 
and staff resources dedicated to school feeding and a lack of 
performance indicators to monitor and evaluate project results. In 
2006 and 2007, USDA's Office of the Inspector General (OIG) audits of 
FAS food aid programs, including the MGD Program, identified 
significant weaknesses, including the lack of a strategic planning 
process for food aid programs, lack of outcome-based performance 
measures, and poor controls over on-site visits to implementing 
partner projects. As part of our work on international food 
assistance,[Footnote 3] you asked us to review the MGD Program. In 
this report we assessed (1) the extent to which USDA is overseeing the 
MGD Program to ensure it is achieving its objectives, and (2) the 
extent to which USDA has addressed the MGD Program's internal control 
weaknesses. 

To address these objectives, we reviewed USDA and implementing 
partners' program documents and financial information as well as 
numerous studies of school feeding programs. We conducted fieldwork in 
Cambodia, Guatemala, and Kenya and met with representatives of WFP and 
NGOs that implement the program. We also met with staff from U.S. 
missions, host governments, the World Bank, the United Nations 
Children's Fund (UNICEF), and the United Nations Food and Agriculture 
Organization in these countries as appropriate. We visited selected 
schools at which MGD projects are implemented in each country as well 
as food warehouses. In Washington, D.C., we interviewed officials from 
U.S. agencies, including USDA and the U.S. Agency for International 
Development (USAID), as well as private foundations and research 
institutions, such as the Bill and Melinda Gates Foundation, the Delhi 
School of Economics, the Global Child Nutrition Foundation, and 
International Food Policy Research Institute. In Rome, we met with 
representatives of the U.S. Mission to the United Nations Food and 
Agriculture Agencies, WFP, the Food and Agriculture Organization, and 
several bilateral donors. We analyzed USDA's grant approval process, 
including NGOs' grant agreements with USDA, as well as WFP proposals 
and country programs, initiated in fiscal years 2008 through 2010 to 
determine whether the process is consistent with the goals of the MGD 
Program. In addition, we reviewed the NGOs' and WFP's progress reports 
submitted to USDA for the countries we visited to obtain illustrative 
examples of what they reported about their school feeding projects. We 
also reviewed audit reports by the USDA OIG, which highlighted 
relevant internal control weaknesses. We then reviewed various reports 
USDA uses to oversee the MGD Program, and met with USDA officials to 
determine the status of corrective actions to address those internal 
control weaknesses. We did not verify the accuracy of information 
included in the financial and progress reports. Additionally, we 
convened a roundtable of 9 current and former NGO implementing 
partners of the MGD Program and the Global Food for Education 
Initiative pilot to obtain their views on the implementation of the 
program. Finally, we compared USDA's oversight and internal control 
practices to our Standards for Internal Control in the Federal 
Government and the American Evaluation Association's An Evaluation 
Roadmap for a More Effective Government. 

We conducted this performance audit from May 2010 to May 2011 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. (Appendix I 
provides a detailed discussion of our objectives, scope, and 
methodology.) 

Background: 

In recent years, international donors, including the World Bank, and 
national governments in developing countries have increasingly 
embraced school feeding. According to the World Bank, low-income 
countries are expanding school feeding partly in response to United 
Nations Millennium Development Goals addressing hunger and 
education.[Footnote 4] However, views on the benefits and costs of 
school feeding vary. We conducted a review of selected international 
school feeding studies completed over the past 20 years. The studies 
generally found that school feeding programs increase students' total 
food consumption and attendance. However, we found mixed results in 
these studies on the effects of school feeding on enrollment, 
educational progress, and nutrition. The results suggest that school 
feeding programs do not always achieve the same effect, and various 
factors, such as the modality of school feeding (whether the program 
provides in-school meals, take-home rations, or both), gender of the 
beneficiaries, and type of food provided, can influence the programs' 
outcomes. See appendix II for details on our review of studies on 
school feeding programs. 

The MGD Program Has Evolved Since the Inception of the Pilot: 

The MGD Program promotes education, nutrition, and food security for 
poor children in low-income countries that have low literacy and 
primary school completion rates. Specifically, the program provides 
donations of U.S. agricultural commodities,[Footnote 5] as well as 
financial and technical assistance, for school feeding and maternal 
and child nutrition projects in low-income countries. Administered by 
USDA's FAS, the program is implemented by NGOs and WFP which generally 
support school feeding and complementary activities at numerous 
schools in targeted communities. 

The MGD Program was preceded by the pilot known as the Global Food for 
Education Initiative. The Initiative was proposed by President Clinton 
in 2000. As indicated in figure 1, under the pilot, USDA donated $300 
million in U.S. surplus commodities through the Commodity Credit 
Corporation (CCC) to implement the school feeding program for 1 year. 
[Footnote 6] In practice, implementation in some cases took longer, 
and the pilot ended in 2003. The Initiative's objectives were to 
improve student enrollment, attendance, and performance in poor 
countries. Congress authorized the MGD Program in 2002, expanding its 
objectives to include improved maternal and child nutrition and the 
achievement of food security, and reauthorized it in 2008 through 
fiscal year 2012. The program has been subject to annual 
appropriations after fiscal year 2003, and between fiscal years 2003 
and 2010 the annual program funding ranged from $50 million to $210 
million. The total amount of funding provided for the Global Food for 
Education Initiative and the MGD Program from 2000 through 2010 is 
about $1.2 billion. Appropriated funds for the MGD Program are no-year 
appropriations; therefore, the funds are available for obligations 
without fiscal year limitations. In fiscal year 2010, funding for the 
MGD Program constituted less than 10 percent of the U.S. government's 
overall funding for international food aid. 

Figure 1: Evolution of the MGD Program: 

[Refer to PDF for image: timeline] 

Pilot: 

Major Events: 2000: 
Global Food for Education Initiative (pilot) initiated; 
Funded by $300 million in surplus commodities through 2002; 
Funded by Commodity Credit Corporation (CCC) surplus commodity. 
Major Objectives: To carry out an international school feeding program 
to improve student enrollment, attendance, and performance in poor 
countries. 

Major Events: 2001-2002: 
The MGD Program authorized by the Farm Security and Rural Investment 
Act of 2002 with $100 million in CCC funds for 2003; 
Major Objectives: Legislation states to carry out preschool and school 
food for: 
* Education programs in foreign countries to improve literacy
and primary education, particularly with respect to girls; 
* Maternal, infant and child nutrition programs for pregnant women, 
nursing mothers, infants, and children who are 5 years of age or 
younger; 
* Improving food security, and reducing the incidence of hunger. 

Appropriations/funding: 

Major Events: 2003: 
Regulations governing the program published; 
$100 million CCC Funds. 

Major Events: 2004: 
$50 million appropriated. 

Major Events: 2005: 
$87.5 million appropriated. 

Major Events: 2006: 
$100 million appropriated. 

Major Events: 2007: 
$100 million appropriated. 

Major Events: 2008: 
The MGD Program reauthorized by the Food, Conservation, and Energy Act 
of 2008; 
$100 million appropriated. 

Major Events: 2009: 
New regulations require third party interim and final evaluations; 
$100 million appropriated; 
$84 million CCC Funds; 
Major Objectives: Agency guidance outlines six operational objectives:
1. increased enrollment and attendance rates, especially for girls; 
2. improved student achievement levels through improvements in the 
learning environment; 
3. improved maternal, child and student health and nutrition; 
4. attracting non-FAS contributions to development activities; 
5. enabling community support for infrastructure development; 
6. increased government and community support in education. 

Major Events: 2010: 
The appropriation includes $10 million for a micronutrient pilot; 
$209.5 million appropriated. 

Major Events: 2011: 
USDA’s proposal solicitation requires implementing partners to focus on
three broad objectives; 
$199.5 million appropriated; 
Major Objectives: The proposal solicitation has three broad objectives: 
1. improved educational quality; 
2. improved nutrition; 
3. sustainability. 

Source: GAO analysis of legislation and USDA data. 

[End of figure] 

The MGD Program has experienced some changes in recent years. 
Initially, USDA signed single-year agreements with implementing 
partners. In 2006, it began offering three-year agreements, and most 
agreements signed in 2010 were for three years. USDA's guidance 
includes six operational objectives, as indicated in figure 1, which 
in fiscal year 2011 were subsumed into three broad objectives of 
education, nutrition, and sustainability of school feeding. USDA now 
refers to the six operational objectives as intermediate results. 
[Footnote 7] The MGD Program authorizing statute encourages the 
program to focus on girls since they tend to have low school 
attendance rates, and education[Footnote 8] of girls benefits the 
entire family. The program also offers nutrition[Footnote 9] 
assistance to undernourished mothers and their preschool-age children 
to improve the health and learning capacity of the children before 
they enter school.[Footnote 10] In addition to food, the MGD Program 
provides financial assistance to fund complementary school feeding 
activities, such as teacher training, nutrition education, and 
fostering parental involvement. The legislation stresses 
sustainability and requires that all agreements specify a timeline to 
achieve graduation.[Footnote 11] 

Management and Funding of the MGD Program: 

At FAS, the MGD Program is administered by the Food Assistance 
Division (FAD), whose staff in Washington, D.C., manage the program 
and conduct monitoring site visits. Two other units at FAS have some 
oversight responsibilities over USDA's international food assistance 
programs, including the MGD Program--Monitoring and Evaluation Staff 
(MES) and the Compliance, Security and Emergency Planning Division 
(Compliance). MES was established in 2006 to conduct monitoring and 
evaluation of USDA's capacity building and development programs and to 
close out food assistance agreements. With respect to the MGD Program, 
MES has primarily focused on closeout of NGO-implemented agreements. 
Compliance conducts occasional risk-based financial compliance reviews 
of NGO-implemented agreements; these reviews may include visits to NGO 
headquarters or field offices. In addition, FAS's agricultural 
attachés at overseas posts may provide comments on MGD Program 
proposals. 

The MGD Program is implemented by NGOs and WFP. NGOs and WFP submit 
proposals based on criteria established by USDA. See appendix III for 
a discussion of how USDA determines the priority countries and 
establishes criteria for proposal solicitations. USDA requires NGOs 
implementing MGD projects to submit semiannual and annual reports, 
such as project status and audit reports, whereas WFP prepares an 
annual standard project report.[Footnote 12] USDA staff at FAD, MES 
and Compliance review these reports to track program performance and 
compliance with financial rules and regulations. See appendix III for 
a description of the reports implementing partners are required to 
submit to USDA. 

Since 2003, MGD Program funding has supported school feeding and 
related activities in 41 countries, as seen in figure 2. In 2010, the 
program was implemented in 28 countries. From 2003 through 2010, $475 
million (or over 50 percent) of MGD Program funding was directed to 
Africa, $252 million to Asia, $117 million to Latin America and the 
Caribbean, $25 million to the Middle East, and $23 million to Eastern 
Europe. See appendix IV for MGD Program funding by year, country, and 
region. 

Figure 2: MGD Program Countries Since 2003: 

[Refer to PDF for image: illustrated world map] 

41 Countries Have Had School Feeding Programs: 

28 Countries with MGD projects in fiscal year 2010: 
Afghanistan; 
Bangladesh; 
Benin; 
Bolivia; 
Cambodia; 
Cameroon; 
Chad; 
Ethiopia; 
Gambia; 
Guinea-Bissau; 
Guinea; 
Guatemala; 
Honduras; 
Kenya; 
Kyrgyz Republic; 
Laos; 
Liberia; 
Pakistan; 
Senegal; 
Sierra Leone; 
Cameroon; 
Angola; 
Mali; 
Malawi; 
Madagascar; 
Mozambique; 
Niger; 
Republic of Congo. 

13 Countries that no longer had MGD projects in fiscal year 2010: 
Albania; 
Bhutan; 
Dominican Republic; 
Eritrea; 
Ghana; 
Ivory Coast; 
Lebanon; 
Moldova; 
Nepal; 
Nicaragua; 
Tanzania; 
Rwanda; 
Vietnam. 

Sources: USDA (data); Map Resources (map). 

[End of figure] 

Based on USDA's data, since the MGD Program was initially authorized 
in 2002, WFP received 43 percent of the total funding and NGOs 57 
percent. Twenty-two NGOs have implemented the MGD Program since 2003. 
In 2010, WFP invested about $500 million in its school feeding 
program, with the MGD Program contributing about 15 percent of the 
funding. 

USDA Has Established a Grant Approval Process Consistent with the MGD 
Program's Objectives, but Oversight Weaknesses Make It Difficult to 
Determine the Extent to which the Program Is Achieving Its Objectives: 

USDA has established a grant approval process consistent with 
achieving the MGD Program's objectives of education, nutrition, and 
sustainability, but weaknesses in USDA's oversight of the program 
limit its ability to determine the extent to which those objectives 
are actually met. USDA has developed criteria for designating priority 
countries, assessing proposals, and negotiating grant agreements, and 
reports that the MGD Program has fed an annual average of almost 3 
million beneficiaries from fiscal year 2003 to 2010 by providing in- 
school feeding and take-home rations. In addition, USDA supports 
activities that are complementary to school feeding, such as teacher 
training, health and nutrition education, and fostering parental and 
community involvement. However, we identified weaknesses in USDA's 
performance monitoring and evaluation. For example, USDA conducts 
limited monitoring in the field resulting in a reliance on the 
implementing partners' performance monitoring, whose rigor varies by 
implementing partner. In addition, USDA has not prioritized evaluation 
of completed MGD projects to assess the program's strengths and 
weaknesses. 

The MGD Program Includes Three Phases: Grant Approval, Monitoring, and 
Evaluation: 

Our analysis of USDA's oversight of the MGD Program examines three 
broad phases: grant approval, monitoring, and evaluation. Figure 3 
describes the three phases of the program's oversight. Appendix III 
provides a description of the MGD Program's operation, including the 
grant approval process. 

Figure 3: Key Elements of the Grant Approval, Monitoring, and 
Evaluation Phases: 

[Refer to PDF for image: illustration] 

Phase 1: Grant Approval: 
* Designate program objectives and priority countries; 
* Solicit proposals to address program objectives; 
* Review proposals in light of program objectives and other relevant 
criteria; 
* Negotiate agreements based on proposals that were highly rated in 
the review process. 

Phase 2: Monitoring; 
* Ongoing and systematic collection and verification of data to 
determine whether programs are being implemented as intended; 
* Track and report progress using preselected indicators throughout 
the life of the program. 

Phase 3: Evaluation; 
* Develop policies and procedures to guide evaluations; 
* Develop evaluation plans and set priorities; 
* Assess the strengths and weaknesses of programs to improve their 
effectiveness; 
* Use systematic data collection and analysis to address questions 
about how well programs and policies are working, whether they are 
achieving their objectives, and why they are or are not effective. 

Sources: GAO analysis of GAO, USDA, WFP, Committee of Sponsoring 
Organizations of the Treadway Commission, and American
Evaluation Association data. 

Note: 

The standards or sources used include the following: 

* USDA's criteria for designation of priority countries and proposal 
assessments. 

* USDA's regulations governing the McGovern Dole International Food 
for Education and Child Nutrition Program (7 CFR 1599). 

* GAO, Standards for Internal Control in the Federal Government, 
GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999). 

* Committee of Sponsoring Organizations of the Treadway Commission, 
Internal Control - Integrated Framework, Sept. 1992. 

* GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing 
Season Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 
2002). 

* American Evaluation Association, An Evaluation Roadmap for a More 
Effective Government, 2010: 

* GAO, Program Evaluation: Experienced Agencies Follow a Similar Model 
for Prioritizing Research, GAO-11-176 (Washington, D.C.: Jan. 14, 
2011). 

* GAO, International Food Assistance: USAID Is Taking Actions to 
Improve Monitoring and Evaluation of Nonemergency Food Aid, but 
Weaknesses in Planning Could Impede Efforts, GAO-09-980 (Washington, 
D.C.: Sept. 28, 2009). 

* GAO, Performance Measurement and Evaluation: Definitions and 
Relationships, GAO-05-739SP (Washington, D.C.: May, 2005). 

* United Nations World Food Program, Office of Evaluation, Monitoring 
and Evaluation Guidelines. 

Based on the standards and sources cited, GAO determined that the 
points reflected on this graph represent key elements of the grant 
approval, monitoring, and evaluation phases of the MGD Program. 

[End of figure] 

USDA Has Established a Grant Approval Process Consistent with MGD 
Program Objectives: 

USDA established a grant approval process to help ensure that projects 
likely to achieve the MGD Program's objectives of education, 
nutrition, and sustainability are approved. As such, USDA has 
developed criteria for designating priority countries, soliciting 
proposals, assessing proposals, and negotiating grant agreements, as 
shown in figure 4. 

Figure 4: The Grant Approval Phase: 

[Refer to PDF for image: illustration] 

Phase 1: Grant Approval-Key Elements: 
* Designate program objectives and priority countries; 
* Solicit proposals to address program objectives; 
* Review proposals in light of program objectives and other relevant 
criteria; 
* Negotiate agreements based on proposals that were highly rated in 
the review process. 

Grant Approval of the MGD Program: 
* USDA's current MGD objectives are nutrition, education, and 
sustainability; 
* Every year, USDA designates priority countries and issues a 
solicitation for proposals that specifies the criteria for program 
selection; 
* USDA has developed a process to assess the program proposals that
are submitted; 
* The MGD Program agreements generally include activities to address
all program objectives. 

Source: GAO analysis of USDA data. 

Note: Based on USDA's regulations governing the MGD Program (7 CFR 
1599), USDA's criteria for designation of priority countries, proposal 
solicitation, standards for proposal evaluation, and grant 
negotiation, GAO determined that the points reflected on this graph 
are key elements of the grant approval phase for the MGD Program. 

[End of figure] 

MGD Program Grant Approval Process Generally Supports the Objectives 
of the Program: 

Annually, according to FAS, it selects priority countries that would 
most benefit from the MGD Program based on criteria that are intended 
to help ensure that the priority countries are needy and are committed 
to improving their education systems. To help promote sustainability, 
countries with existing projects are also considered priority 
countries. The legislation governing the MGD Program states that an 
agreement with an eligible organization should include provisions to 
sustain the benefits of the program and estimate time frames for 
achieving sustainability, among other things. See appendix III for 
criteria used to determine priority countries. 

Based on USDA's proposal solicitation criteria for fiscal years 2008 
through 2010, the MGD proposals should identify developmental goals 
for improving literacy and primary education (especially for girls). 
For example, USDA criteria stated that the organization should include 
data on the current primary school attendance and completion rates for 
the target population, and explain how the proposed project would help 
to increase these rates. For maternal and child nutrition activities, 
the applicants' proposals are also expected to demonstrate how the 
project will improve the food security and nutritional status of the 
target population. Further, USDA required the NGOs and WFP to 
delineate a plan for achieving sustainability of school feeding 
through the involvement of the government, local institutions, and 
communities.[Footnote 13] For example, the applicant's proposals are 
expected to encourage partnerships via the donation of counterpart 
funding, in-kind materials, and labor and space to sustain project 
activities. Fifteen percent of each proposal's evaluation score is 
based on whether the applicant is able to attract country, community, 
or other donor contributions to the project supported by the MGD 
Program. See appendix III for criteria used to assess the grant 
proposals. 

In assessing the proposals, USDA's program analysts consider various 
factors, such as projects' outcomes, need, and implementation 
capacity. We determined that USDA's program analysts used a standard 
form designed to ensure that the need for the proposed projects was 
justified, the key factors for consideration were rated on a common 
scale, and the strengths and weaknesses of the proposals were 
discussed. From our review of USDA's assessment, we determined that 
the MGD Program's objectives of education, nutrition, and 
sustainability were considered in the assessment, though the education 
and nutrition goals were addressed more generally through discussions 
of program need and overall proposal quality, while sustainability was 
an element that received a specific rating. Our analysis of USDA's 
assessments of the 2010 proposals found that most of the analysts made 
written comments on the MGD Program's sustainability. Seven of the 18 
programs received positive comments about their potential 
sustainability while 4 received negative comments. An additional 4 
programs received mixed comments about their prospects for 
sustainability. Our review of these proposals found that the analysts 
had generally completed the assessments as required and provided 
justifications for funding the projects in question. 

Implementing Partners Provide Specific Details on In-School Feeding 
and Take-Home Rations: 

The next stage of the grant approval process involves negotiating 
agreements between USDA and the NGOs. To obtain an understanding of 
this stage and to determine whether or not the agreements contained 
elements consistent with the MGD Program's stated goals, we reviewed 
all 31 agreements that USDA entered into with NGOs and WFP in fiscal 
years 2008 through 2010.[Footnote 14] Key areas covered in the 
agreements include the food that will be provided to the 
beneficiaries, the methods used to select the beneficiaries, the 
activities that will be undertaken to complement the school feeding 
program, the types of MGD Program performance indicators for measuring 
progress, and coordination with governmental or nongovernmental 
entities. 

USDA allows implementing partners the flexibility to adapt their 
projects to the local context in terms of establishing the type of 
school meals provided, determining appropriate ration sizes, providing 
take-home rations, and choosing which commodities to provide for the 
meals. Our review of NGO and WFP agreements indicate that all but 3 of 
the 31 projects planned to provide in-school feeding.[Footnote 15] The 
implementing partners did not always specify the in-school meals they 
would provide, but when they did, they reported providing breakfasts, 
lunches, or snacks. In addition, 19 of the 31 agreements planned to 
provide take-home rations, most typically to girls, but also to 
teachers and other caregivers in some projects. Further, about half of 
the 19 NGO agreements contained a provision for school feeding for 
preschoolers, and one of the WFP agreements contained such a 
provision.[Footnote 16] 

The Process of Selecting Beneficiaries Varies Between NGOs and WFP: 

Based on our review of the NGOs and WFP's agreements, we found that 
all projects considered nutritional and health needs when selecting 
beneficiaries. NGOs agreed to use a wide range of criteria to select 
beneficiaries while WFP agreed to use a more standardized process. 
USDA does not provide guidance on selecting beneficiaries, allowing 
implementing partners to use a diverse set of criteria to select 
beneficiaries. The NGOs typically rely on the host government and the 
opinions of local stakeholders, as well as a variety of statistics to 
help identify communities and schools for their projects. Examples of 
these statistics are low levels of enrollment and low levels of food 
security. Some of the MGD program agreements for the NGOs planned to 
select schools that required new facilities, teacher training, or the 
development of parent teacher associations or school management 
committees, while others planned to select schools that already had 
existing facilities or community organizations. In some instances, the 
schools that had the existing facilities were ones that already had 
projects, and for which continuations were being requested. See 
appendix V for details on the methods NGOs agreed to use to select 
beneficiaries. According to WFP, its school feeding programs target 
food insecure areas, which tend to be rural, identified through food 
security assessments. Food security information is combined with the 
government-provided education-related information (such as enrollment, 
attendance, retention, and completion rates). WFP includes educational 
indicators into its food security assessments to inform its decisions 
on school feeding and is now trying to standardize this process by 
using a set of targeting guidelines specific for school feeding. 

Implementing Partners Agreed to Undertake Various Complementary 
Activities to Achieve the MGD Program's Objectives: 

The implementing partners agreed to undertake various complementary 
nonfeeding activities to achieve the MGD Program's objectives. For 
example, based on our analysis of all 31 NGO and WFP agreements from 
fiscal years 2008 through 2010, we found that MGD projects planned to 
support an average of 9 complementary activities. Figure 5 provides 
examples of the top three activities that NGOs and WFP agreed to 
undertake for each objective. In addition, appendix VI provides more 
details about the complementary activities that addressed these 
objectives. 

Figure 5: Examples of Complementary Activities in Agreements with 
Implementing Partners: 

[Refer to PDF for image: illustration of three objectives with photos 
for each objective from Cambodia, Guatemala, and Kenya] 

Objective: Education: 

Number of agreements, proposals, or country programs with at least
one activity for this objective: 26. 

Examples of complementary activities: 
Teacher training[A]: 14; 
General school facilities: 13; 
Educational supplies/equipment: 12. 

Objective: Nutrition: 

Number of agreements, proposals, or country programs with at least
one activity for this objective: 29. 

Examples of complementary activities: 
Health/nutrition education: 22; 
School facilities: potable water: 16; 
School facilities: latrines: 14. 

Objective: Sustainability: 

Number of agreements, proposals, or country programs with at least
one activity for this objective: 29. 

Examples of complementary activities: 
Sustainability at the local level: 17; 
Parent and community involvement in the schools: 17; 
Sustainability at host government level: 11. 

Average number of activities per agreement/proposals, or country
programs: 9. 

Sources: GAO analysis of NGOs’ agreements and WFP’s proposals and 
country programs from fiscal years 2008 through 2010. 

Note: These examples are based on our analysis of19 NGO agreements and 
12 WFP agreements, proposals, and country programs. We categorized 
activities into education, nutrition, and sustainability based on our 
analysis of each activity's relevance to each objective. We did not 
categorize activities that either addressed multiple objectives or 
addressed other objectives. 

[A] The numbers in the figure represent the number of NGO agreements 
and WFP agreements, proposals, and country programs that planned to 
undertake those activities. 

[End of figure] 

In order to help countries or projects achieve sustainability, the 
agreements listed other organizations that planned to make 
contributions. Some organizations provided a dollar value for the 
planned contributions from sources other than MGD Program funding. 
Among the 19 NGO agreements we analyzed, 5 reported no dollar amounts 
for additional contributions from other sources; 9 indicated that the 
contributions would be between $10,000 and $600,000; and 5 reported 
that the contributions would be more than $5 million. These 
contributions represented between less than 1 percent and more than 74 
percent of the funds provided by USDA for the projects. Due to 
differences between WFP and NGO projects, and the way that the WFP 
program reported other donor contributions, we were not able to make 
direct comparisons between WFP and NGOs in this regard.[Footnote 17] 

USDA Has Developed a Set of Performance Indicators to Track MGD 
Program Performance by Program Goals: 

Based on our review of the grant agreements, USDA currently has more 
than 30 performance indicators for the MGD Program. USDA's performance 
indicators include both output and outcome measures. Output measures 
track the direct products and services delivered by a program while 
outcome measures track the results of the products and services 
delivered.[Footnote 18] Our analysis of all 31 NGO and WFP agreements 
found that the implementing partners agreed to use an average of 22 of 
these indicators. Table 1 shows the MGD Program's performance 
indicators, and appendix VII lists these indicators along with the 
number of NGO agreements and WFP proposals that include each indicator. 

Table 1: MGD Program Performance Indicators in NGOs Agreements and WFP 
Proposals: 

Performance Indicators: 
* Educational access; 
* Percentage increase in enrollment--boys; 
* Percentage increase in enrollment--girls; 
* Percentage increase in attendance--boys; 
* Percentage increase in attendance--girls; 
* Percentage increase in attendance (gender not specified); 
* Number of take-home rations distributed; 
* Number of food supplements provided. 

Educational progress: 
* Percentage of boys and girls entering grade 1 of primary school who 
reach grade 3 (or grade 5) multiyear agreements (cohort survival to 
grades 3 or 5); 
* Promotion rate; 
* Continuation rate; 
* Percentage of targeted schools with adequate school supplies; 
* Percentage of targeted schools with printed materials to support 
literacy and numeric instruction; 
* Percentage/number of teachers receiving training; 
* Number of communities with adult literacy classes; 
* Number of supply kits provided. 

Nutrition: 
* Number of daily meals provided; 
* Number of take-home rations distributed; 
* Percentage of participating schools implementing health and 
nutrition education for students; 
* Percentage of participating schools with established prophylactic 
programs; 
* Percentage of participating schools with established health care 
provider to the schools including preschools; 
* Percentage of mother and child clinics/health facilities supported; 
* Percentage of children on target with age-to-weight and height 
growth; 
* Percentage of schools that institutionalize health and hygiene 
programs. 

Sustainability: 
* Number of other donors contributing to ancillary projects of 
complementary activities (school infrastructure, immunization program); 
* Dollar amount of donor contributions; 
* Percentage of cost sharing; 
* Percentage of donor support; 
* Implementing partner's/participant's/organization's independent 
contribution; 
* Percentage of schools where parents provide a defined level of 
support; 
* Percentage of schools with parent groups (associations or councils) 
that play a defined role in program management; 
* Number of complementary programs; 
* Number of potable water projects; 
* Number of latrine and/or kitchen repairs and constructions; 
* Number of nutrition and health education classes for adults; 
* Percentage of schools transitioning into parent-teacher association/ 
government-supported feeding program; 
* Percentage of increased government support to education sector; 
* Number of training sessions for capacity building; 
* Percentage of donor support vs. indigenous support; 
* Number of provincial Ministries of Education that received training 
in subjects, such as community mobilization, administration, and 
monitoring. 

Source: GAO analysis of NGOs agreements and WFP proposals from 2008 
through 2010. 

[End of table] 

Implementing Partners Planned to Work with Host Governments but 
Reported Limited Coordination with U.S. Government Agencies: 

As part of the grant approval process, the NGOs and WFP also provide 
information regarding activities that other entities are undertaking 
in the recipient countries to address poverty, hunger, and deficient 
primary education, and whether the proposed project complements or 
duplicates those activities. Based on our analysis of the agreements 
covering fiscal years 2008 through 2010, all the NGOs and WFP reported 
they would work with host government agencies. In particular, 27 of 
the 31 NGOs and WFP agreements indicated they would work with the host 
government's Ministry or Department of Education, and 17 of 31 
indicated they would work with the host government's Ministry of 
Health to further the projects' goals. A few NGOs agreements indicated 
they would work with United Nations organizations, specifically WFP (2 
of 19) and UNICEF (2 of 19). All 12 WFP agreements indicated they 
would work with UNICEF. Five (5) of the 31 NGOs and WFP agreements, 
proposals, and country programs indicated that they would coordinate 
with USAID in some way, for example, through an in-country 
coordinating committee or by working with another partner that was 
funded by USAID.[Footnote 19] 

USAID administers multiple programs whose goals are similar to those 
of USDA's MGD Program and aim to improve food security, maternal and 
child health, education (including food for education), and nutrition 
in developing countries.[Footnote 20] However, USDA's coordination 
with USAID on these programs is limited. USDA obtains input from some 
offices at USAID when it assesses proposals for the MGD Program, but 
it has not systematically considered how it could more effectively 
leverage USAID's extensive overseas presence, or benefit from USAID's 
expertise in basic education. An official at USAID's Office of 
Education informed us that she has never been requested or invited to 
review MGD Program grant proposals or provide input to performance 
indicators. USAID's Office of Education has developed a set of 
learning assessment tools to measure educational progress, but USDA 
has not determined whether these tools can be useful in monitoring 
educational progress for the MGD Program. However, a USDA official 
said that FAS plans to explore the usefulness of these assessment 
tools for the MGD Program. USAID's budget for basic education in 
fiscal year 2010 was about $943 million. In fiscal year 2010, USAID's 
basic education program was implemented in 17 of the 28 countries 
where the MGD Program was implemented. In addition, some officials we 
interviewed during our fieldwork stated that more coordination was 
needed among the donors at the country level. For example, USAID and 
USDA officials noted that even when both agencies had similar programs 
in the same country, their coordination was limited. Moving forward, 
USDA expects greater coordination among host government and U.S. 
government agencies on the MGD Program. In fiscal year 2011, USDA, for 
the first time, reflects coordination as a separate category in its 
solicitation for proposals and has assigned a value of 10 percent to 
this category.[Footnote 21] 

USDA's Performance Monitoring of the MGD Program's Implementation Is 
Weak: 

Our analysis of the monitoring phase includes the review of key 
elements of monitoring, such as ongoing and systematic collection and 
verification of data, as well as the tracking and reporting of 
progress using pre-selected indicators, as shown in figure 6. 

Figure 6: The Monitoring Phase: 

[Refer to PDF for image: illustration] 

Phase 2: Monitoring-Key Elements: 

* Ongoing and systematic collection and verification of data to 
determine whether programs are being implemented as intended. 

* Track and report progress using preselected indicators throughout 
the life of the program. 

Monitoring of Implementation: 

* Reviews implementing partners’ reporting: 
– USDA does not systematically analyze implementing partners' reports; 
– USDA provides limited feedback to implementing partners; 
– Reporting requirements do not ensure implementing partners collect and
submit consistent and complete information; 
– USDA’s plans for improvement: implementing a new information system to
reduce inconsistencies in reporting, providing training and assistance 
to NGO staff, requiring the implementing partners to report on the 
same set of indicators, and introducing the Results-Oriented 
Management process. 

* Performance monitoring in the field: 
– USDA's overseas staff provide limited monitoring support in the 
field; 
– USDA’s headquarters staff do not conduct systematic site visits in 
the field; 
– USDA relies on implementing partners’ performance monitoring in the 
field; 
– USDA has recently increased its headquarters staff and conducted more
sites visits in the field. 

Sources: GAO analysis of GAO, USDA, WFP, Committee of Sponsoring 
Organizations of the Treadway Commission, and American Evaluation 
Association data. 

Note: Based on the standards and sources cited, GAO determined that 
the points reflected on this graph represent key elements of the 
monitoring phase of the MGD Program. 

[End of figure] 

USDA Does Not Systematically Analyze Implementing Partners' Reporting 
and Provides Limited Feedback on the MGD Program's Progress: 

USDA does not systematically analyze implementing partners' reporting 
to help ensure they are taking the actions agreed upon to achieve the 
MGD Program's objectives of education, nutrition, and sustainability. 
In addition, USDA provides limited feedback to implementing partners 
on the progress reports they submit periodically to USDA. Standards 
for Internal Control in the Federal Government[Footnote 22] 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 
analyses of the relationships can be made and appropriate actions 
taken. Beyond tallying MGD Program activities such as the number of 
beneficiaries served or the number of school gardens constructed, USDA 
has not further analyzed the information reported by implementing 
partners. For example, USDA currently does not consolidate and analyze 
the information from separate reports, making it difficult for USDA to 
track the MGD Program's progress at different points over the life of 
the agreement or to make comparisons across agreements. In addition, 
based on USDA's guidance to its staff on reviewing NGOs' reporting, 
the staff's review generally focuses on the financial and logistical 
aspects, and to a lesser extent on tracking whether the MGD Program is 
meeting its objectives. Further, some NGOs reported that USDA provided 
limited communication and feedback on their progress reporting. For 
example, one NGO submitted 50-page reports to USDA but received no 
feedback on its performance indicators. This lack of feedback was also 
reported by other NGOs. 

We analyzed the implementing partners' progress reports in our three 
fieldwork countries of Cambodia, Guatemala, and Kenya since 2004 
[Footnote 23] and found that the implementing partners report 
performance indicators that suggest some progress in achieving the MGD 
Program's objectives of education[Footnote 24] and sustainability but 
less progress on the MGD Program's objective of nutrition. This 
reporting is generated by the implementing partners and the reports 
accuracy were not verified by USDA. We also did not verify the 
accuracy of the data contained in these progress reports. Table 2 
shows information on the indicators reported by the implementing 
partners. 

Table 2: Analyses of Progress Reports Submitted by Implementing 
Partners in Our Fieldwork Countries: 

Objective: Educational access[A]; 
Total number of indicators reported: 74; 
Number (percent) of indicators with targets: 31 (42%); 
Number (percent) of targets met: 19 (61%); 
Number (percent) of indicators that report a baseline value: 67 (91%); 
Number (percent) of indicators with baseline values that report 
increases since baseline: 63 (94%). 

Objective: Educational progress[A]; 
Total number of indicators reported: 42; 
Number (percent) of indicators with targets: 34 (81%); 
Number (percent) of targets met: 21 (62%); 
Number (percent) of indicators that report a baseline value: 26 (62%); 
Number (percent) of indicators with baseline values that report 
increases since baseline: 17 (65%). 

Objective: Nutrition; 
Total number of indicators reported: 55; 
Number (percent) of indicators with targets: 39 (71%); 
Number (percent) of targets met: 16 (41%); 
Number (percent) of indicators that report a baseline value: 18 (32%); 
Number (percent) of indicators with baseline values that report 
increases since baseline: 10 (56%). 

Objective: Sustainability; 
Total number of indicators reported: 87; 
Number (percent) of indicators with targets: 76 (87%); 
Number (percent) of targets met: 46 (61%); 
Number (percent) of indicators that report a baseline value: 44 (51%); 
Number (percent) of indicators with baseline values that report 
increases since baseline: 30 (68%). 

Objective: Total; 
Total number of indicators reported: 258; 
Number (percent) of indicators with targets: 180 (70%); 
Number (percent) of targets met: 102 (57%); 
Number (percent) of indicators that report a baseline value: 155 (60%); 
Number (percent) of indicators with baseline values that report 
increases since baseline: 120 (77%). 

Sources: GAO analysis of NGOs' logistics and monetization reports and 
WFP's standard project reports. 

Note: Our fieldwork countries are Cambodia, Guatemala, and Kenya. 

[A] USDA's performance indicators for educational access include 
attendance and enrollment, and its performance indicators for 
educational progress include promotion and continuation rates, as well 
as teacher training and the number of schools with adequate supplies. 

[End of table] 

USDA's Reporting Requirements Do Not Ensure Implementing Partners 
Collect and Submit Consistent and Complete Information: 

USDA's reporting requirements also contribute to the inconsistent 
information submitted by implementing partners to assess the MGD 
Program's impact. According to internal control standards, program 
managers need operational data to determine whether they are meeting 
their agencies' strategic and annual performance plans and meeting 
their goals for accountability for effective and efficient use of 
resources. For example, our analysis of the NGOs' progress reports in 
our fieldwork countries suggests that the number of performance 
indicators for educational access and progress that NGOs report ranges 
from 0 to 17 by each NGO. We also found that one NGO had 8 indicators 
for nutrition with no targets, and another NGO had 6 indicators for 
nutrition, all of which had targets. USDA officials agreed that the 
quality of the reporting varies by NGO, and they are planning to 
reduce the variation by implementing a new information system (the 
Food Assistance Information System), providing training and assistance 
to NGO staff, and revising the reporting forms required of the NGOs. 

WFP's reporting differs significantly from the NGOs' reporting in our 
fieldwork countries. As a multilateral organization, WFP currently 
submits one annual project report to all of its donors.[Footnote 25] 
The information contained in WFP's annual report differs significantly 
from the reports submitted by NGOs. First, WFP does not report 
separately on the MGD Program but reports in the aggregate on its 
country programs. Its country programs may include other programs and 
funding by other donors. Therefore, it is often not feasible to 
isolate the MGD Program's contribution to the reported progress. 
Second, WFP reported fewer indicators on educational progress and 
nutrition than the NGOs. In the eight NGOs' progress reports we 
analyzed, the NGOs reported a total of 40 indicators on educational 
progress and a total of 39 indicators on nutrition. In comparison, in 
the six WFP progress reports we analyzed, WFP reported 16 indicators 
[Footnote 26] on nutrition and only 2 indicators on educational 
progress, neither of which were reported by NGOs. A senior USDA 
official stated that starting in fiscal year 2012, USDA plans to 
require that WFP report on the same set of indicators as the NGOs. 

USDA does not provide guidance to implementing partners on how to set 
targets, allowing implementing partners to set their own targets. 
While the ability for implementing partners to set their own targets 
may allow them to tailor targets to their specific context, it also 
hinders USDA's ability to compare performance across NGOs, as NGOs may 
use varying methods to set targets. USDA plans to address this lack of 
guidance by developing an indicator handbook that is expected to place 
a greater emphasis on meeting targets. 

USDA's reporting requirements also do not ensure that implementing 
partners collect and submit complete information to assess the MGD 
Program's impact in education and nutrition. Based on our prior work, 
[Footnote 27] the ability of a performance indicator to align with 
program objectives is one key attribute of a successful performance 
indicator. Our analysis of all 31 NGOs and WFP agreements[Footnote 28] 
entered into with USDA from fiscal years 2008 through 2010 found that 
USDA required outcome indicators that measure aspects of educational 
progress such as promotion and continuation rates, but did not require 
outcome indicators that measure learning. For example, the 
implementing partners' progress reports in our fieldwork countries 
include outcome indicators, such as the number of teachers and 
principals with a high number of students passing grade 9, but they do 
not include outcome indicators that directly measure learning, such as 
achievement tests. For nutrition, our analysis of NGOs and WFP 
agreements show that only 5 of the 19 NGOs' agreements and none of the 
WFP proposals and country programs planned to use an outcome measure 
that directly measures nutrition. For example, except for one 
indicator (of a total of 55 indicators) in a progress report for a sub-
recipient of an implementing partner, the implementing partners' 
progress reports include indicators such as the number of meals served 
but did not include any outcome indicators for nutrition, such as 
weight for age and height for age. Without outcome indicators that 
directly link to learning and nutrition, it is difficult for USDA to 
know whether these objectives are being met. 

USDA seeks to establish a Results-Oriented Management (ROM) process to 
develop a more comprehensive approach to align the program with its 
objectives. As part of the ROM, USDA expects to develop a new set of 
performance indicators for the MGD Program, which would include a set 
of outcome and output indicators and set both intermediate goals and 
goals more directly linked to the program's objectives. According to 
USDA officials, the ROM process is not expected to be implemented 
before fiscal year 2012. 

To monitor the MGD Program's progress, USDA requires several reports 
of NGOs, including the logistics and monetization report and the 
project status report. In our analysis of these reports in our 
fieldwork countries, we found that the project status reports 
contained less quantitative information and were generally duplicative 
of the logistics and monetization report. See table 7 in appendix III 
for a detailed description of USDA's various reporting requirements 
for implementing partners. Project status reports generally contain 
narratives on educational progress, nutrition, and sustainability. In 
contrast, the logistics and monetization reports generally contain 
quantitative information on the MGD Program's progress. Of a total of 
78 performance indicators in the project status reports, only 6 
targets (8 percent) were reported. In contrast, of a total of 182 
performance indicators in the logistics and monetization reports, 138 
targets (76 percent) were reported. 

USDA's Limited Performance Monitoring of the MGD Program in the Field 
Hinders Its Ability to Verify Implementing Partners' Reporting: 

USDA has limited field presence to monitor the MGD Program. 
Specifically, USDA's agricultural attachés[Footnote 29]--responsible 
primarily for trade promotion and foreign market development in 
addition to supporting the MGD Program--provide limited support to 
USDA's monitoring of the program in the field. First, the attachés are 
stationed in only 7 of the 28 countries where the MGD Program is being 
implemented.[Footnote 30] In one country, the Republic of Congo, USDA 
does not have any attaché coverage, even though MGD projects were 
implemented in the Republic of Congo in 2004 and 2006 through 2011. 
Other MGD countries without attachés are covered by attachés in other 
countries in the same region. For example, the attaché in Kenya 
provides monitoring support to projects in Malawi, Rwanda, Tanzania, 
and Uganda in addition to Kenya. The agricultural attaché who covers 
one of our fieldwork countries and is based in another country has 
only recently begun to travel to our fieldwork country monthly. While 
in our fieldwork country, the majority of the attaché's time was spent 
on food safety and trade issues. Second, the agricultural attachés in 
our three fieldwork countries have generally received no training on 
how to monitor the MGD Program and conduct limited site visits. In 
addition, since fiscal year 2009, FAS selects the countries to 
implement the program based in part on overseas posts' capacity to 
monitor program implementation. 

FAS staff at headquarters do not conduct systematic site visits in the 
field. FAD staff have visited some programs in recent years, but they 
have not had a systematic approach to monitoring through country site 
visits that relies on a risk assessment. Internal control standards 
define risk assessment as the identification and analysis of relevant 
risks associated with achieving the objectives. Among other things, a 
site visit based on risk assessment would account for the amount of 
MGD Program funding to a country, U.S. policy priorities, and whether 
the implementing partners are new at implementing the MGD Program. 

Figure 7 shows the number of countries FAD staff visited from fiscal 
years 2004 through 2010. From 2004 through 2008, the number of 
countries visited was small relative to the number of the MGD Program 
countries. For 2009 and 2010, figure 7 shows that FAD increased the 
number of visits to nine visits per year. According to a senior USDA 
official, within each country, the MGD Program is generally 
implemented in hundreds of schools; however, USDA's visits generally 
lasted 1 to 2 weeks and included visits to a limited number of 
schools. For example, for Bangladesh, WFP received about $8 million 
per year in MGD Program funding in 2006, 2008, 2009, and 2010, and 
planned to serve 350,000 beneficiaries per year from 2008 through 
2010, making it a top-five country in terms of the MGD Program's 
funding. However, FAD did not conduct a site visit to an MGD project 
in Bangladesh until 2010. Additionally, while on these visits, FAD did 
not provide guidelines for its staff on how to conduct site visits 
until about the end of 2010, when it developed draft monitoring 
guidelines for its headquarters- based staff and attachés. 
Additionally, FAS's MES officials do not conduct site visits but 
instead conduct headquarters-based reviews of the documents the 
implementing partners provide to them. In 2010 and early 2011, FAD 
hired 6 additional staff, for a total of 14. With these new staff, FAD 
officials stated they plan to visit every project at least once every 
2 years. However, they have not developed a plan for these site 
visits, and they select and approve countries for visits on a case-by-
case basis. As a result of the lack of systematic site visits, by both 
USDA staff based in Washington, D.C., and in the field, it is 
difficult for USDA to verify the reporting submitted by implementing 
partners. 

Figure 7: Number of MGD Countries Visited and Not Visited, Fiscal 
Years 2004-2010: 

[Refer to PDF for image: stacked vertical bar graph] 

Year: 2004: 
Number of countries visited by Food Assistance Division staff: 2; 
Number of countries not visited by Food Assistance Division staff: 20; 
Total number of MGD countries[A]: 22. 

Year: 2005: 
Number of countries visited by Food Assistance Division staff: 1; 
Number of countries not visited by Food Assistance Division staff: 24; 
Total number of MGD countries[A]: 25. 

Year: 2006: 
Number of countries visited by Food Assistance Division staff: 5; 
Number of countries not visited by Food Assistance Division staff: 14; 
Total number of MGD countries[A]: 19. 

Year: 2007: 
Number of countries visited by Food Assistance Division staff: 2; 
Number of countries not visited by Food Assistance Division staff: 22; 
Total number of MGD countries[A]: 24. 

Year: 2008: 
Number of countries visited by Food Assistance Division staff: 1; 
Number of countries not visited by Food Assistance Division staff: 22; 
Total number of MGD countries[A]: 23. 

Year: 2009: 
Number of countries visited by Food Assistance Division staff: 9; 
Number of countries not visited by Food Assistance Division staff: 14; 
Total number of MGD countries[A]: 23. 

Year: 2010: 
Number of countries visited by Food Assistance Division staff: 9; 
Number of countries not visited by Food Assistance Division staff: 16; 
Total number of MGD countries[A]: 25. 

Source: GAO based on USDA data. 

[A] The number of countries for fiscal years 2004 through 2010 are 
based on USDA's data and include countries with expenditures over 
$100,000 for the respective year. 

[End of figure] 

USDA Relies on the Implementing Partners' Performance Monitoring in 
the Field: 

Since USDA has not conducted systematic site visits and performs 
primarily headquarters-based document reviews of implementing 
partners' reporting, USDA relies on the implementing partners' 
performance monitoring in the field. However, USDA has not issued 
guidance to the implementing partners on their monitoring efforts. 
This lack of guidance to implementing partners on monitoring has 
contributed to the varying levels of rigor in plans for monitoring 
that we found in our analysis of the 19 NGOs agreements from fiscal 
years 2008 through 2010. In particular, 12 of the 19 agreements did 
not make reference to monitoring, while only 4 of the 19 agreements 
provided detailed plans for data collection. A detailed plan would 
indicate actions such as training staff to collect weight and height 
for age data or monthly spot checks at schools. With regard to WFP, 
all 12 projects outlined monitoring plans in their proposals and/or 
country programs. For example, in Cambodia, the country program 
reported it would follow a ROM approach, using a toolkit that included 
standardized reporting forms for all program components. The two 
programs that did not describe their monitoring activities were 
different types of WFP programs--protracted relief and recovery 
operations--which used a somewhat different reporting format.[Footnote 
31] 

The variation in the implementing partners' plans for monitoring 
contributed to the varying levels of rigor in implementing partners' 
monitoring we encountered in our fieldwork countries. For example, in 
one of our fieldwork countries, one NGO reported that it relied on a 
desk review of progress reports submitted by its local subrecipients 
and 1-week site visits conducted by the NGO's headquarters-based staff 
every quarter, at most. This contrasted with the other NGO operating 
in this country, which reported to have a systematic monitoring system 
that enabled it to make 2 to 3 spot visits to each school every month. 
Finally, WFP has its own monitoring system and has issued guidance 
regarding monitoring of school feeding programs. 

USDA Has Not Developed Policies and Procedures to Guide Evaluation of 
Completed Projects: 

Whereas performance monitoring can address weaknesses that emerge 
during implementation, evaluating completed projects would provide 
USDA with essential evidence for improving the MGD Program's 
effectiveness in education, nutrition, and sustainability, as 
indicated in figure 8. The American Evaluation Association's (AEA) 
Evaluation Roadmap for a More Effective Government recommends that 
each federal agency and its evaluation centers "publish policies and 
procedures and adopt quality standards to guide evaluations within its 
purview." Among other things, the policies should include criteria for 
developing evaluation plans and setting priorities. However, USDA has 
neither developed policies and procedures to guide evaluation of 
completed MGD projects nor established priorities for evaluations. 
[Footnote 32] 

Figure 8: The Evaluation Phase: 

[Refer to PDF for image: illustration] 

Phase 3: Evaluation--Key Elements: 

* Develop policies and procedures to guide evaluations. 

* Develop evaluation plans and set priorities. 

* Assess the strengths and weaknesses of programs to improve their 
effectiveness. 

* Use systematic data collection and analysis to address questions 
about how well programs and policies are working, whether they are 
achieving their objectives, and why they are or are not effective. 

Evaluation of Completed MGD Projects: 

* USDA has not developed policies and procedures to guide evaluation of
completed projects. 

* USDA has not evaluated completed MGD projects. 

* USDA has not disseminated lessons learned from implementation USDA 
is taking steps to emphasize evaluation. 

* In 2009, USDA introduced a requirement for all implementing partners 
to submit an interim and final evaluation for each MGD project. 

* USDA is developing plans to conduct its own evaluations of completed 
MGD projects. 

Source: GAO analysis of GAO, USDA, and American Evaluation Association 
data. 

Note: Based on the standards and sources cited, we determined that the 
points reflected on this graph represent key elements of the 
evaluation phase of the MGD Program. 

[End of figure] 

USDA has not, until recently, required implementing partners to have 
their completed MGD projects evaluated. In addition, it has not 
conducted its own evaluations of these projects. Recognizing the need 
for evaluation, USDA is taking steps that will emphasize this in the 
future. First, in March 2009 USDA issued revised MGD Program 
regulations, which introduced a requirement for all implementing 
partners to submit evaluations, conducted by an independent third 
party, at the middle and final points of the implementation period for 
each MGD Program award.[Footnote 33] According to USDA officials, this 
requirement applies to all multiyear awards beginning in fiscal year 
2010 and USDA expects to receive the first round of final evaluations 
for these awards in fiscal year 2014.[Footnote 34] USDA's FAD and MES 
officials are developing guidance for the required evaluations, which 
USDA plans to release at the International Food Aid and Development 
Conference in Kansas City in June 2011.[Footnote 35] Our analysis of 
USDA NGOs agreements and WFP proposals shows various evaluation 
approaches among MGD Program implementing partners. Most of the NGO 
agreements we reviewed did not include detailed plans for evaluation. 
By comparison, most of the WFP proposals and country programs we 
analyzed discussed evaluation and one WFP proposal included a 
discussion of a planned joint WFP-World Bank impact assessment 
[Footnote 36] of its school feeding program in Laos. 

Second, USDA has not evaluated completed MGD projects, but its MES 
officials are developing plans to evaluate the MGD Program, as part of 
the recently initiated ROM process. However, MES has not identified 
criteria for selecting projects, agency resources available for 
evaluation activities, or specific time frames to conduct the 
evaluations.[Footnote 37] AEA's Evaluation Roadmap recommends that in 
order to develop evaluation plans agencies need to assess what is 
already known about a program's ability to achieve its objectives. 
However, MES officials told us they do not analyze evaluations of WFP 
or NGOs school feeding programs, including assessments of NGO- 
implemented MGD projects.[Footnote 38] Nor does USDA systematically 
identify and disseminate lessons learned from the NGOs' experience in 
implementing the MGD Program. For example, according to NGO 
representatives who participated in our roundtable, USDA does not 
facilitate discussion among NGOs about persistent problems, effective 
practices, or innovative solutions in the MGD Program's implementation. 

Side bar: 
Evaluation of School Feeding at the World Food Program: 

WFP has developed an evaluation policy as well as an evaluation 
quality assurance system. In addition to evaluations of its emergency 
and development programs, some of which include school feeding 
activities, WFP recently initiated a series of impact evaluations of 
its school feeding activities in Bangladesh, Cambodia, the Gambia, Ivory
Coast, and Kenya. The first two studies-—for Cambodia and Kenya, 
countries where WFP’s school feeding is in part supported by the MGD 
Program-—were released in 2010. These evaluations employed both 
quantitative and qualitative methodologies and were conducted by 
independent consultants. Although these impact evaluations reported
that school feeding was associated with higher enrollment, attendance, 
and completion rates, they also discussed serious constraints in 
school feeding’s ability to address nutrition, quality of learning, and
gender parity in education. 

[End of side bar] 

USDA Has Taken Actions to Address the MGD Program's Internal Control 
Weaknesses, but Improvements Can Be Made: 

USDA has established internal controls over cash, commodity, and 
transportation disbursements, including risk-based financial 
compliance reviews to verify that funds were expended as approved. 
However, USDA policies for closing out grant agreements do not include 
time frames for when agreements should be closed. In addition, we 
found that while the FAS Administrator planned corrective actions to 
close out USDA's OIG audit recommendations, the Office of the Chief 
Financial Officer (OCFO) has not received documentation that actions 
have been taken on 10 recommendations, and 1 recommendation concerning 
the implementation of a new information system has not been fully 
implemented. 

USDA Has Established Internal Controls Over Cash, Commodity, and 
Transportation Disbursements, and Conducts Risk-based Financial 
Compliance Site Visits: 

USDA has established internal controls over cash, commodity, and 
transportation disbursements for the MGD Program and conducts risk- 
based financial compliance site visits to verify that funds are spent 
as approved. We interviewed USDA officials and reviewed USDA's 
policies and procedures for cash, commodity, and transportation 
disbursements. We tested the implementation of selected controls 
including testing three grants that were terminated and determined 
that expenditures were within budget. We also traced a judgmental 
sample of key transactions back to the general ledger to verify the 
accuracy of the program's financial information. However, we did not 
trace transactions back to source documents. 

When a MGD Program grant is awarded, USDA negotiates a budget within 
the grant agreement for cash expenses to be incurred by the NGO for 
administrative expenses, internal transportation and shipping 
expenses, and complementary activities such as teacher training, 
latrine building, and deworming activities. In addition, USDA agrees 
to supply commodities up to a negotiated tonnage and ocean transport 
for those commodities. 

USDA may provide the cash component of the grant as either a cash 
advance to the NGO or as a reimbursement after the expenses are 
incurred. In either case, USDA controls seek to ensure funding is 
provided only for approved expenses. When processing a cash advance or 
reimbursement, USDA policies direct USDA officials to compare the 
request for a disbursement against the approved expenses on the grant 
agreement to ensure that the request is within budget. If the NGO 
previously received a cash advance or reimbursement, officials also 
verify that the previous disbursement was properly spent. During this 
review, if officials discover the NGO has incompletely or improperly 
spent previously received funds, USDA will request that the NGO submit 
a reimbursement to USDA. Multiple USDA officials review and sign off 
before a cash advance or reimbursement is approved and funds are 
disbursed to the NGO. Once the NGO receives the funds, it is required 
to obligate all advanced cash within 180 days or return all unused 
funds within 210 days. USDA has similar processes and procedures in 
place to ensure that NGOs receive the correct tonnage of commodities 
and that ocean transport costs are within budget. 

USDA occasionally conducts financial compliance reviews of its food 
aid grants to, among other activities, check receipts and verify that 
the funds were spent as reported to USDA. Site visits are conducted by 
the Compliance, Security and Emergency Planning Division (Compliance). 
[Footnote 39] Using a risk-based approach, USDA selects the MGD 
Program grant to be reviewed from a list of NGOs encountering problems 
and requiring enhanced monitoring. This list is compiled at periodic 
meetings held among FAD, MES, and Compliance. NGOs may be on the list 
for a variety of reasons, including persistent problems with 
reporting, violations of their agreements, or delayed program 
implementation. USDA officials stated that MGD Program grants are less 
likely to have problems than USDA's Food for Progress[Footnote 40] 
food aid grants for reasons including: (1) the Food for Progress 
monetization activities are more complex [Footnote 41] and (2) Food 
for Progress development projects are more varied than MGD projects. 
Consequently, MGD projects are less likely than Food for Progress 
projects to be identified as requiring enhanced monitoring or a 
financial compliance review. 

The financial compliance reviews generally include a site visit to the 
NGO's headquarters in the United States, although sometimes, the 
review is done on-site in the country where the NGO implements the MGD 
project.[Footnote 42] Before beginning the review, Compliance works 
closely with the FAD analyst in charge of the grant to determine the 
NGO's potential compliance problems. As discussed in the previous 
section, during the grant implementation phase, NGOs are required to 
submit various reports to USDA that provide financial and programmatic 
information. Several of the reports have data related to the MGD 
project expenditures, including: logistics and monetization reports, 
financial reports, and A-133 audit reports.[Footnote 43] Before 
carrying out their site reviews, Compliance gives the NGO a 30-to-60- 
day notice and obtains the logistics and monetization reports and any 
correspondence and relevant background information the NGO has 
submitted to FAD. Once on-site at the NGO, Compliance obtains the 
supporting documentation for expenses funded by the MGD Program grant 
and verifies that funds were spent as approved by USDA. At the end of 
the review, Compliance conducts an exit conference with the NGO and 
reports its findings to FAD. 

As of January 25, 2011, of 22 closed MGD Program NGO grants that were 
completed and eligible for financial compliance reviews, Compliance 
had completed 4 reviews and had initiated 3 more. Two of the financial 
compliance reviews had no findings. In one, Compliance determined the 
NGO owed USDA funds because the NGO did not maintain adequate 
supporting documentation for the program expenses. Another found that 
the NGO needed to address commodity handling internal control issues. 
See table 3 for additional information about the 7 financial 
compliance reviews. 

Table 3: Results of the MGD Program Financial Compliance Reviews as 
Reported by USDA: 

Fiscal year review was conducted: FY2005; 
MGD Program country: Bolivia; 
Location where review was conducted: Bolivia; 
Findings/corrective actions recommended: None. 

Fiscal year review was conducted: FY2007; 
MGD Program country: Senegal; 
Location where review was conducted: Washington, DC; 
Findings/corrective actions recommended: Insufficient documentation: 
request for repayment of $2,530.08. 

Fiscal year review was conducted: FY2010; 
MGD Program country: Guatemala; 
Location where review was conducted: Coconut Creek, Florida; 
Findings/corrective actions recommended: None. 

Fiscal year review was conducted: FY2010; 
MGD Program country: Madagascar; 
Location where review was conducted: Madagascar; 
Findings/corrective actions recommended: Commodity handling internal 
control deficiencies: corrective action plan required. 

Fiscal year review was conducted: FY2010; 
MGD Program country: Nicaragua; 
Location where review was conducted: Prattville, Alabama; 
Findings/corrective actions recommended: Review in progress. 

Fiscal year review was conducted: FY2010; 
MGD Program country: Nicaragua; 
Location where review was conducted: Prattville, Alabama; 
Findings/corrective actions recommended: Review in progress. 

Fiscal year review was conducted: FY2011; 
MGD Program country: Afghanistan; 
Location where review was conducted: Washington, DC; 
Findings/corrective actions recommended: Review not yet begun. 

Source: USDA. 

[End of table] 

Although the FAD conducts occasional in-country site visits to assess 
program activities and Compliance conducts occasional site visits to 
assess financial compliance, neither verifies that commodities reach 
the MGD project after arriving at the port of distribution. Currently, 
once the commodities arrive at port via ocean transport, the NGO or 
its representative verifies that the correct tonnage is received. If 
commodities are missing or damaged, the shipping company must 
reimburse USDA. After the NGO takes possession of the commodities, 
USDA relies on the NGO to ensure that the commodities reach the 
intended beneficiaries. FAD officials told us they plan to conduct 
additional programmatic site visits to evaluate program activities in 
the future, and guidance for these site visits includes plans to 
review NGO financial reports to determine whether they accurately 
reflect expenditures for activities in the field, as well as plans for 
examining the quality and receipt of commodities. A Compliance 
official stated that Compliance will continue to use a risk-based 
approach for selecting NGOs for financial compliance reviews and that 
as a result, they cannot predict how many MGD Program-related 
compliance visits will occur per year in the future. 

USDA Policies on How to Close Out Grants Do Not Include Time Frames 
for When Grant Agreements Should Be Closed: 

USDA's draft grant closeout policies do not include time frames for 
when grant agreements should be closed. As a result, USDA is at risk 
that grant agreements will not be closed out in a timely fashion. 
Standards for Internal Control in the Federal Government[Footnote 44] 
states that managers need to compare actual performance, such as 
financial performance, to planned or expected results throughout the 
organization and analyze significant differences. In addition to other 
activities, grant closeouts compare planned and approved expenditures 
to actual NGO expenditures and assist USDA to verify that grantees 
have met financial requirements. 

USDA grant agreement closeouts are to be completed after the MGD 
project activities are complete, and the NGO has submitted its final 
logistics and monetization report. Two divisions in FAS participate in 
grant closeouts: FAD and MES. FAD staff prepare the closeout package 
with the documents necessary to close out the grant and MES officials 
conduct the closeout. MES officials cannot close out a grant until 
they have received the package from FAD. The closeout process is 
guided by draft policies and consists of a financial analysis 
examining reported expenses, as well as a review of the MGD Program's 
grant agreement objectives against reported outputs and outcomes. 
Specifically, during the closeout the USDA official reviews NGO-
provided reports, such as logistics and monetization reports, 
financial reports, and A-133 Single Audits, to verify there were no 
agreement violations and that funds and monetization proceeds were not 
misused.[Footnote 45] Finally, the official creates a closeout 
evaluation report. 

USDA's FAS has been cited by the USDA OIG in the past for having a 
backlog of food aid grant agreements ready to be closed out, and FAS 
has responded by prioritizing certain grant closeouts. For example, in 
response to a 2006 OIG finding, FAS closed the remaining fiscal years 
1998-2001 food aid grants. The OIG report also noted that FAS should 
develop procedures to ensure that agreements for fiscal year 2002 and 
beyond receive timely closeout reviews. In response, USDA set and 
achieved a goal to close out 60 percent of all agreements for fiscal 
years 2002 and 2003. The OIG noted that unless an evaluation or 
closeout review has been conducted for prior agreements, FAS is unable 
to confirm that a NGO has been compliant and FAS cannot fairly judge 
whether the NGO has committed any violations that would preclude a 
favorable consideration for new grants. 

USDA has made progress in closing out backlogged grants; however, we 
found that of the 42 MGD Program grants awarded before 2008, 15 (36 
percent) have completed program activities but have not been closed. 
Two of the 15 grants remain open because USDA terminated the grant 
agreements and is in the process of investigating how much of the 
grant the NGOs must reimburse to USDA. For 7 of the 15, USDA has all 
the necessary documentation, but has not closed out the grant. For the 
remaining 6 open grants, which were awarded in 2005 and 2006, USDA is 
still organizing the paperwork received from the NGOs that is 
necessary to conduct the closeout. According to an OIG report, USDA 
has set a goal to close 80 percent of grant agreements within 6 years 
of signing; however, a senior FAD official told us FAD had no official 
goal or policy governing the time frame within which closeouts should 
be completed. 

Closeouts are an important grant management procedure because they are 
the final point of accountability for grantees.[Footnote 46] 
Additionally, during the closeout process, USDA officials reported 
that sometimes they discover that NGOs owe USDA funds. Funds returned 
from NGOs can be used by USDA to ensure it meets its obligations to 
other NGOs. For instance, in cases where commodity or transportation 
costs rise unexpectedly during the course of a grant agreement, USDA 
can use the reimbursed funds to cover unanticipated cost increases and 
to help ensure delivery of commodities to MGD projects. As of February 
15, 2011, 15 NGOs that were awarded grants between 2003 and 2006, 
reimbursed USDA over $852,000 in unspent or misused funds. We found 
one instance in which a NGO retained $23,500 of USDA funds for 53 
months, well after its grant activities had been completed, before 
USDA received the reimbursement. In general, the funds returned to 
USDA make up a small proportion of the overall funding advanced to the 
NGO--on average 3.6 percent--however, in some cases, the amount can be 
significant. For example, two NGOs returned approximately $249,000 to 
USDA, or over 34 percent of the total USDA funding they had received. 
NGOs are not required to pay interest on unspent or misused funds that 
they return to USDA if the NGO returns the funds within 30 days of 
being notified by USDA that funds are due. Timely closeouts provide 
valuable information to USDA as it decides whether or not to fund 
future NGO activities, and USDA officials told us that closeouts 
provide information that informs their future grant decisions. 

USDA Has Not Fully Implemented and Completed All USDA OIG Audit 
Recommendations: 

USDA has not fully implemented and completed all USDA OIG audit 
recommendations. The OIG released audits on FAS's food aid programs in 
2006 and 2007.[Footnote 47] Sixteen of the OIG audit findings and 
related recommendations pertained to the MGD Program, and 11 of 16 
recommendations remain open, including the implementation of a new 
Food Aid Information System (FAIS) that will integrate financial 
management components and has been partially implemented, according to 
USDA officials.[Footnote 48] The FAS Administrator has developed 
corrective actions to close out USDA OIG audit recommendations; 
however, the OCFO has not received and/or reviewed documentation that 
the corrective actions have been taken and therefore the 
recommendations are not considered complete. Office of Management and 
Budget Circular A-50 states that agencies are responsible for ensuring 
that corrective actions are taken on audit recommendations. In order 
for FAS to fully implement and officially close an audit 
recommendation, FAS must present appropriate evidence to the OCFO that 
planned corrective actions have been taken on the finding. The OCFO 
then needs to review and approve this documentation before closing the 
recommendation as fully implemented. 

According to a FAS official, USDA has taken action on all 16 OIG MGD 
Program-related recommendations and has completed 5 of them. For 
example, the OIG recommended that USDA review NGO reports to track 
problems, such as incomplete reports. Recognizing the need for early 
detection of problems in grant agreements, USDA agreed with the 
recommendation, and during fiscal year 2006 a staff member was 
assigned to review each report and quickly note any obvious problems. 
Additionally, USDA stated that it would give priority to reviewing 
reports from NGOs already experiencing problems. Subsequently, the 
OCFO closed this OIG recommendation. However, of the 11 remaining open 
recommendations, 10 are still open because the OCFO has not received 
documentation from the FAS Administrator demonstrating that planned 
corrective actions have actually been taken. For example, the OIG 
determined that FAS did not have a system to identify problematic NGO 
agreements and perform regular reviews of these agreements. FAS agreed 
with this finding and, in response, set the following criteria to 
identify problematic agreements: monetization problems; high-risk 
country; inconsistent reporting; unexplained program delays; and 
warnings from in-country USDA staff, anonymous whistleblowers, or 
other sources. However, USDA has not provided the OCFO with 
documentation to close this recommendation. Additionally, USDA has not 
provided documentation on corrective actions taken related to new 
procedures for on-site reviews and revised procedures for establishing 
timely closeouts of food aid agreement operations. 

The last open recommendation concerns the implementation of FAIS. This 
new system is expected to address security control weaknesses and 
other internal control issues. FAS had originally told the OIG that it 
hoped to have the system implemented by January 2009, however USDA 
officials stated that the system implementation was delayed due to 
budget, contracting, and other delays. FAS has not yet completed 
implementation of FAIS, but it has taken other interim steps to 
address financial management weaknesses. For example, according to 
USDA officials, the current financial management system has internal 
control weaknesses related to tracking expenditures at the grant 
agreement level. USDA's accounting functions for the MGD Program are 
performed by USDA's Farm Service Agency, which previously did not 
report individual transactions at the grant agreement level, thus 
preventing USDA from closely monitoring grant financial transactions. 
As an interim solution, the Farm Service Agency created a series of 
manual spreadsheets that enable USDA officials to track financial and 
nonfinancial transactions at the grant agreement level. These 
spreadsheets compile data including expenditures and remaining amounts 
authorized for disbursements. FAIS is expected to strengthen internal 
controls, including automating these manual financial processes. In 
addition, FAIS will result in improvements in the reconciliation and 
reporting of unobligated balances. Further, FAIS is expected to result 
in improved oversight of NGOs and food aid agreements. 

The new FAIS system will contain information related to the grant 
process, including: program budgets, project proposals, and 
agreements. It will also capture information related to grant 
implementation, including: commodity and freight purchases, commodity 
shipments, and payments. Additionally, FAIS will capture financial 
management information from NGO logistics and monetization reports and 
financial reports. FAS plans to implement FAIS in three phases: March 
2011, July 2011, and September 2011. FAS met its deadline to commence 
implementation in March 2011 and agency officials state the system is 
scheduled to be fully implemented by September 2011 as planned. 

Conclusions: 

Although USDA has established a grant approval process consistent with 
the MGD Program's goals of education, nutrition, and sustainability, 
weaknesses in USDA's oversight of the program limit its ability to 
ensure that those objectives are actually met. Specifically, USDA's 
inadequate monitoring of implementing partners' performance raises 
concerns about its capacity to identify critical operational problems 
and take real-time corrective action. Moreover, the lack of an 
evaluation system, including policies and procedures, limits USDA's 
ability to identify the strengths and weaknesses of the MGD Program, 
take appropriate actions, and identify and disseminate lessons learned. 

USDA is taking steps to improve its financial oversight of MGD Program 
grants. However, further improvements would help strengthen internal 
controls. Appropriate financial internal controls are essential for 
ensuring taxpayer dollars are spent as intended. USDA has controls in 
place over MGD Program 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. 

Recommendations for Executive Action: 

To improve USDA's oversight of the MGD Program in the areas of 
monitoring, evaluation, and financial management, we recommend that 
the Secretary of Agriculture direct the Administrator of the Foreign 
Agricultural Service to implement the following three recommendations: 

* 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. 

* Develop policies and procedures to guide evaluation of completed 
projects. 

* Formalize policies and procedures for closing out grant agreements 
and establish guidance for when agreements should be closed. 

Agency Comments and Our Evaluation: 

We requested and received comments on a draft of this report from the 
Secretary of Agriculture. The USDA agreed with our recommendations and 
said that it will take steps to address them. USDA acknowledged that 
proper monitoring and evaluation are essential to improving the 
quality and measuring the results of the MGD Program. For example, 
USDA said that it will identify a common set of indicators on which 
all program participants will be required to report, beginning in 
fiscal year 2012 program cycle, in order to permit more effective 
program management and an assessment of program impact, among other 
things. In addition, USDA said that it will finalize its monitoring 
and evaluation policy by September 2011. USDA also acknowledged the 
importance of closing out grant agreements in a timely manner to 
ensure full accountability of all projects and stated that it has set 
a goal of closing 65 percent of 2003 and 2004 agreements by September 
30, 2011. Although USDA stated that it has never had a backlog of MGD 
Program agreements awaiting closeout, we found that 15 of 42 (36 
percent) of MGD Program grants awarded before 2008 have completed 
program activities but have not yet been closed by USDA. USDA stated 
that it expects to close out agreements within 180 days of the receipt 
of the final reports and documents and that it will revisit its 
closeout procedures to seek additional improvements, including 
establishing timeframes for organizations to submit required documents 
and holding those who do not meet deadlines accountable. USDA's 
comments, along with our response, are reprinted in appendix VIII. 
USDA, USAID, and WFP also provided technical comments, which were 
incorporated in the report, as appropriate. 

We are sending copies of this report to interested members of 
Congress; the Secretary of Agriculture; the Administrator of the 
Foreign Agricultural Service; the Administrator of USAID, and relevant 
agency heads. The report is also available at no charge on the GAO Web 
site at [hyperlink, http://www.gao.gov. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-9601 or melitot@gao.gov. Contact points for 
our Office of Congressional relations and Public Affairs may be found 
on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix IX. 

Signed by: 

Thomas Melito, Director: 
International Affairs and Trade: 

List of Requesters: 

The Honorable Debbie Stabenow: 
Chairwoman: 
The Honorable Pat Roberts: 
Ranking Member: 
Committee on Agriculture, Nutrition, and Forestry: 
United States Senate: 

The Honorable Frank D. Lucas: 
Chairman: 
The Honorable Collin C. Peterson: 
Ranking Member: 
Committee on Agriculture: 
House of Representatives: 

The Honorable Robert P. Casey: 
Chairman: 
The Honorable Richard G. Lugar: 
Ranking Member: 
Subcommittee on Nutrition, Specialty Crops, Food and Agricultural 
Research: 
Committee on Agriculture, Nutrition, and Forestry: 
United States Senate: 

The Honorable Donald M. Payne: 
Ranking Member: 
Subcommittee on Africa, Global Health, and Human Rights: 
Committee on Foreign Affairs: 
House of Representatives: 

The Honorable Sherrod Brown: 
United States Senate: 

The Honorable Saxby Chambliss: 
United States Senate: 

The Honorable James P. McGovern: 
House of Representatives: 

[End of section] 

Appendix I: Objective, Scope, and Methodology: 

We examined (1) the extent to which the U.S. Department of Agriculture 
(USDA) is overseeing the McGovern-Dole International Food for 
Education and Child Nutrition Program (MGD Program) to ensure it is 
meeting its objectives; and (2) the extent to which USDA has addressed 
the MGD Program's internal control weaknesses. 

To examine the extent to which USDA is overseeing the MGD Program to 
ensure it is meeting its objectives of education, nutrition, and 
sustainability, we analyzed three phases of the program: (1) the grant 
approval phase, including agreements USDA signed with nongovernmental 
organizations (NGO) and the World Food Program (WFP), as well as WFP's 
proposals and country programs; (2) the monitoring of implementation 
phase, including NGO and WFP progress reports to USDA for our 
fieldwork countries--Cambodia, Guatemala, and Kenya, and (3) the 
evaluation phase, including progress in evaluating completed projects. 
Our discussion of the three phases considered recognized standards and 
principles, including USDA's criteria for designation of priority 
countries and proposal assessments; GAO's Standards for Internal 
Control in the Federal Government[Footnote 49]; Committee of 
Sponsoring Organizations of the Treadway Commission, Internal 
Control - Integrated Framework; the American Evaluation Association's 
Evaluation Roadmap for a More Effective Government, United Nations 
World Food Program, Monitoring and Evaluation Guidelines, as well as 
GAO's prior work in this are[Footnote 50]a. Based on standards and 
sources cited, GAO determined the key elements of the grant approval, 
monitoring, and evaluation phases of the MGD Program. 

To analyze the grant approval phase, we reviewed the priority country 
designation and solicitations for proposals (program considerations) 
for fiscal years 2008 through 2010, as well as the program analysts' 
assessment of the accepted grant proposals for fiscal year 2010. In 
addition, we analyzed all the MGD Program agreements that USDA's 
Foreign Agricultural Service (FAS) initiated with the NGOs and WFP in 
fiscal years 2008, 2008, and 2010. During this period 19 NGOs[Footnote 
51] and 12 WFP agreements were initiated, representing funding of 
about $370 million. We examined the planned school feeding and take-
home rations, the methods implementing partners planned to use for 
selecting beneficiaries, the complementary activities to achieve 
program goals, other donors' planned contributions, planned 
coordination, discussions of monitoring and evaluation, and the 
performance indicators selected. As WFP provided most of this 
information in its program proposals and country program documents, we 
also reviewed those documents for WFP programs. 

We used a data collection instrument to collect consistent information 
from the agreements, proposals, and country program documents, and to 
develop comprehensive lists of categories for each area we examined. 
For example, we developed more than 20 broad categories for the 
complementary activities and more than 40 broad categories for the 
targeting methods. However, we relied on the lists of more than 30 
indicators that the MGD Program provided for the performance 
indicators. In our review, we determined how many implementing 
partners' programs had planned to use each category of complementary 
activities, targeting methods, performance indicators, and other 
elements of interest. In addition, we determined the average numbers 
of complementary activities the implementing partners' planned to use 
and the performance indicators they selected. Appendix V provides 
information on the methods NGOs agreed to use to select MGD 
beneficiaries. Appendix VI provides some planned complementary 
activities that NGOs and WFP agreed to implement. Appendix VII lists 
the performance indicators along with the number of NGO agreements and 
WFP proposals that include each indicator. 

To analyze the monitoring of implementation phase of the MGD Program 
in achieving its objectives, we reviewed the NGOs' logistics and 
monetization reports and project status reports, as well as WFP's 
standard project reports, for our fieldwork countries--Cambodia, 
Guatemala, and Kenya. These reports were submitted to USDA from 2004 
to 2010. We did not verify the accuracy of information contained in 
these progress reports. We limited this analysis to our fieldwork 
countries because conducting fieldwork in these countries allowed us 
to compare the reporting of the implementing partners in these 
countries to our observations and the testimonial evidence provided 
during our site visits. The fieldwork provided context for our 
analysis of implementing partners' reporting. We also limited our 
analysis to these three fieldwork countries due to budgetary and time 
constraints; therefore, our findings are not generalizable to the 
universe of all countries where the MGD Program is implemented. Our 
fieldwork country selections were based on a range of criteria, 
including: (1) geographical dispersion, (2) amount of funding 
(commodity and financial assistance) recipient countries received, (3) 
number of beneficiaries served, (4) length of time receiving MGD 
Program funding, (5) diversity of the implementing partners, and (6) 
logistics and budget constraints. Further, to determine staff 
available to monitor the MGD Program, we reviewed information on staff 
in Washington, D.C., and overseas posts. We believe the staffing data 
are reasonably reliable for the purposes of this report. To compare 
the number of countries USDA staff visited to the total number of MGD 
countries, we used USDA's data on staff visits to determine the number 
of countries visited and USDA's expenditure data to determine the 
total number of MGD countries with expenditures over $100,000 for each 
fiscal year between 2004 and 2010. We determined that these two sets 
of data were sufficiently reliable for this purpose. We also 
determined that USDA's data on obligations by country, region, and 
year for fiscal years 2003 through 2010 were sufficiently reliable for 
our purposes. 

To examine USDA's evaluation phase of the MGD Program, we reviewed the 
MGD Program's regulations, interviewed relevant USDA officials, and 
analyzed evaluations of school feeding programs that had been 
conducted by MGD Program implementing partners. We also used the data 
collection instrument described above to analyze whether the 2008 
through 2010 NGOs agreements and WFP proposals and country programs 
outlined or discussed how implementing partners would monitor and 
evaluate the MGD Program and whether implementing partners planned to 
conduct any evaluation as part of complementary activities. In 
addition, we considered recognized standards, such as the American 
Evaluation Association's Evaluation Roadmap for a More Effective 
Government that is intended to promote the integration of evaluation 
with program management. We also reviewed GAO's prior work in this 
area. 

To assess the extent to which school feeding programs can improve 
education and nutrition, we conducted a search for studies examining 
the impacts of school feeding programs in developing countries, 
narrowing the search to studies that evaluated the impacts of programs 
most similar to the MGD Program. We reviewed the resulting 21 studies 
for their description of the program, the study's design, methodology, 
limitations, and findings. The review covered studies from 1989 to 
2010 (see appendix II for our review of selected studies on school 
feeding). 

To determine the extent to which USDA has implemented internal 
controls for the MGD Program, we reviewed the design of financial 
management controls in place and compared those controls to our 
Standards for Internal Control in the Federal Government.[Footnote 52] 
We then tested the implementation of selected controls. We tested all 
three MGD Program grants that were terminated and determined that 
expenditures for these grants were within budget. The results of our 
testing are not generalizable to the universe of all MGD grants. We 
also reviewed policies and procedures and interviewed financial 
management personnel about controls in place to ensure that cash, 
commodities, and transportation expenditures for MGD Program grants 
remain within budget. We also interviewed officials about procedures 
used to monitor MGD Program disbursements at the grant agreement 
level, and then analyzed spreadsheets being used to track these MGD 
Program disbursements. In particular, we traced a judgmental sample of 
key transactions back to the general ledger to verify the accuracy of 
financial information in the spreadsheets. We did not trace 
transactions back to source documents. We also used the spreadsheets 
to analyze USDA obligation and expenditure data from 2003 through 2010 
to determine the extent to which NGOs have reimbursed USDA for unspent 
or misspent MGD Program funds. We then reviewed other financial and 
nonfinancial documents used by USDA officials to oversee the MGD 
Program, including NGO financial reports, WFP Standard Project 
Reports, and USDA closeout reports for our case study countries for 
fiscal years 2002 to 2003 and 2009. We chose these years because they 
represent the earliest program years and the most recently completed 
program fiscal year. We did not verify the accuracy of information 
included in these reports. We also examined NGOs A-133 audit reports 
for our case study countries for fiscal years 2002 to 2003 and 2009 to 
determine whether the USDA officials followed up on reported control 
problems, and whether the MGD Program had ongoing or systemic internal 
control problems. We then reviewed policies and procedures for closing 
out grant agreements, and interviewed USDA officials responsible for 
conducting closeouts. We assessed grant agreements awarded between 
2003 and 2010 to determine their closeout status. We also reviewed 
policies and procedures and met with officials to determine the extent 
to which USDA conducts financial compliance reviews of the NGOs 
implementing the MGD Program. We also obtained the results of MGD 
Program compliance reviews from fiscal years 2005 through 2010 
reported to us by USDA officials. Finally, we evaluated internal USDA 
assessments of financial management control weaknesses, as well as 
recent USDA Office of the Inspector General's audits of FAS's food aid 
programs to identify findings relevant to the MGD Program[Footnote 
53]. We then met with USDA officials and reviewed documentation to 
identify the status of corrective actions taken in response to these 
audits. 

To address both our objectives, we reviewed USDA and implementing 
partners' program documents and financial information, and numerous 
studies of school feeding programs. We conducted fieldwork in 
Cambodia, Guatemala, and Kenya and met with representatives of WFP and 
NGOs who implement the program. We also met with staff from U.S. 
missions, host governments, the World Bank, UNICEF, and the United 
Nations Food and Agriculture Organization in these countries as 
appropriate. We visited selected schools at which the MGD projects are 
implemented in each country as well as food warehouses. In Washington, 
D.C., we interviewed officials from U.S. agencies, including USDA, the 
U.S. Agency for International Development (USAID), and the Departments 
of State and the Treasury, as well as private foundations and research 
institutions, such as the Bill and Melinda Gates Foundation, the Delhi 
School of Economics, Global Child Nutrition Foundation, International 
Food Policy Research Institute, and Tufts University. In Rome, we 
interviewed representatives of the U.S. Mission to the United Nations 
Food and Agriculture Agencies, WFP, the Food and Agriculture 
Organization, and several bilateral donors. Finally, we convened a 
roundtable of 9 former and current NGO implementing partners of the 
MGD Program and the Global Food for Education Initiative pilot to 
obtain their views on the program's implementation. 

We conducted this performance audit from May 2010 to May 2011 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: GAO Analysis of Selected Studies on School Feeding 
Programs: 

To assess the extent to which school feeding programs can improve 
education and nutrition, we conducted a search for studies examining 
the impacts of school feeding programs in developing countries, 
narrowing the search to studies that evaluated the impacts of programs 
most similar to the MGD Program[Footnote 54]. We reviewed the 
resulting 21 studies for their description of the program, the study's 
design, methodology, limitations, and findings. The review covered 
studies from 1989 through 2010.[Footnote 55] Table 4 lists the results 
of this review. 

Education: 

Based on our review, we found school feeding programs improve 
attendance, especially the attendance of those students already 
enrolled in school before the program. However, the studies did not 
have consistent findings for enrollment. Five of eight studies showed 
improvements in enrollment with one study that found evidence that 
implied that students may be switching from schools without the 
program to schools with the program. 

Our review of the studies also showed mixed results on the impact of 
school feeding on educational progress. Although six of nine studies 
showed improvements in achievement and cognitive tests, the 
improvements were not consistent across subject matters or 
subpopulations. For example, one study found improvements in 
vocabulary test scores but not math tests scores for heavier students 
and another study found improvements in arithmetic test scores but not 
reading test scores in younger children. 

Nutrition: 

Five of five studies showed that school feeding programs increased 
food intake, meaning that when students were provided school feeding, 
households generally did not reduce the students' food intake at home 
enough to nullify the effect of the food they receive from school. 

Our review also found five studies that showed school feeding 
increased weight; two of these five studies showed improvements in 
height and other anthropometric measures. 

Further, there were three studies that measured micronutrient status 
with blood, urine, or stool testing. Of these three studies, two 
showed that some but not all micronutrient outcomes were improved. 

Sustainability: 

Our review of studies did not include studies that examined the 
sustainability of school feeding programs. 

Table 4: Summary of Selected Studies on School Feeding Programs: 

Study authors, title, publication, and year: Adelman, Sarah, Harold 
Alderman, Daniel O. Gilligan, and Kim Lehrer, "The Impact of School 
Feeding Programs on Cognitive Development and Learning: Experimental 
Evidence on the Role of Nutrition and Schooling from Northern Uganda," 
unpublished working paper, 2009; 
Setting: Internally displaced people camps, Uganda; 
Food provided: In-school feeding: snack of corn-soya blend, sugar, 
water and lunch of maize and beans; Take-home rations: similar in size 
and composition; 
Findings: The study used a randomized evaluation that allowed for 
identification of impacts on achievement and cognitive tests of in-
school feeding and take-home rations, respectively. However, the study 
found that the impacts of the programs varied by age, subject, and 
statistical method, and thus the evidence on improvements in 
achievement and cognitive tests was mixed. 

Study authors, title, publication, and year: Afridi, Farzana, "The 
Impact of School Meals on School Participation: Evidence from Rural 
India," Indian Statistical Institute Discussion Paper 10-02, 2010; 
Setting: Poor rural district in Madhya Pradesh, India; 
Food provided: In-school feeding: wheat or rice porridge; Take-home 
rations: raw wheat or rice; 
Findings: The study used school level data from two different time 
periods and a staggered program start to compare attendance and 
enrollment for villages that began providing cooked meals to villages 
that continued to provide take-home rations. It found that switching 
from take-home rations to in-school feeding improved attendance for 
grade 1 girls. However, it found no significant increases for other 
grades or for boys and no significant effects on enrollment. 

Study authors, title, publication, and year: Afridi, Farzana, "Child 
Welfare Programs and Child Nutrition: Evidence from a Mandated School 
Meal Program in India," Journal of Development Economics 92 (2010): 
152-165; 
Setting: Poor rural district in Madhya Pradesh, India; 
Food provided: In-school feeding: wheat or rice porridge; Take-home 
rations: raw wheat or rice; 
Findings: The study used household and student level data from two 
different time periods, a staggered program start, and dietary recall 
to compare the difference in food intake during school days versus non-
school days and then to compare this difference among students who 
received in-school meals versus students who received take-home 
rations. The study found that in-school meals substantially improved 
calorie, carbohydrate, and protein intake when compared to take-home 
rations. The study found less consistent evidence for improvements in 
iron intake and almost no evidence for improvements in calcium intake. 

Study authors, title, publication, and year: Agarwal, DK, KN Agarwal, 
and SK Upadhyay, "Effect of Mid-day Meal Programme on Physical Growth 
and Mental Function," Indian Journal of Medical Research 90 (1989): 
163-74; 
Setting: Rural Tamil Nadu, India; 
Food provided: Unspecified meals; 
Findings: The study randomly chose treatment schools to compare to the 
outcomes of control schools. However, the study did not explicitly 
state that the study was planned as a randomized evaluation that can 
identify the impacts of the program. Nonetheless, the study found that 
the meals improved weight, cognitive test scores, and math test 
scores. However, the evidence for cognitive performance differed 
across the statistical method of analysis and were not consistent 
across all cognitive tests. The study also found no evidence for 
improvements in height or nutritional status. 

Study authors, title, publication, and year: Alderman, Harold, Daniel 
O. Gilligan, and Kim Lehrer, "The Impact of Food for Education 
Programs on School Participation in Northern Uganda," unpublished 
working paper, 2010; 
Setting: Internally displaced people camps, Uganda; 
Food provided: In-school feeding: snack of corn-soya blend, sugar, 
water and lunch of maize and beans; Take-home rations: similar in size 
and composition; 
Findings: The study used a randomized evaluation that allowed for 
identification of impacts on attendance and enrollment of in-school 
feeding and take-home rations, respectively. The study found that in-
school feeding and take-home rations improve attendance, age of entry, 
and grade repetition. The study also showed that in-school feeding 
increased the enrollment of out-of-school children. Finally, the study 
found an unintended negative impact on students' promotion rates to 
secondary school as hungry children may have delayed completing 
primary school to continue receiving the meals. 

Study authors, title, publication, and year: Du, Xueqin, Kun Zhu, 
Angelika Trube, Qian Zhang, Guansheng Ma, Xiaoqi Hu, David R. Fraser, 
and Heather Greenfield, "School-milk Intervention Trial Enhances 
Growth and Bone Mineral Accretion in Chinese Girls Aged 10-12 Years in 
Beijing," British Journal of Nutrition 92 (2004):159-168; 
Setting: Beijing, China; 
Food provided: Calcium milk and milk supplemented with Vitamin D; 
Findings: The study used a randomized evaluation that allowed for 
identification of impacts of providing two different kinds of milk to 
primary school-aged girls. The study found that providing milk to 10 
year old girls significantly increased their changes in height, 
weight, and bone mineral content and density. The study also found 
that dietary recall showed increases in the intake of milk and calcium 
and in the intake of vitamin D for the study group that received 
vitamin D supplemented milk. Providing milk also led to changes in 
urine and blood tests for one of four micronutrient measures and 
providing vitamin D supplemented milk led to changes in urine and 
blood tests for two of four micronutrient measures. 

Study authors, title, publication, and year: Grillenberger, Monika, 
Charlotte G. Neumann, Suzzanne P. Murphy, Nimrod O. Bwibo, Pieter 
van't Veer, Joseph G. A. J. Hautvast, and Clive E. West, "Food 
Supplements Have a Positive Impact on Weight Gain and the Addition of 
Animal Source Foods Increases Lean Body Mass of Kenyan 
Schoolchildren," The Journal of Nutrition 133 (2003): 3957S-3964S; 
Setting: Rural area in Eastern Province, Kenya; 
Food provided: Githeri (maize, beans, vegetables, and fat) with meat, 
githeri with milk, githeri with more fat; 
Findings: The study used a randomized evaluation that allowed for the 
identification of impacts on anthropometric measures of providing 
meals that were supplemented with one of three different nutrients. 
The study found that supplements of meat, energy, or milk to the meal 
improved weight, middle upper arm circumference, and mid upper arm 
muscle area when compared to providing no food supplements. However, 
the study found no improvements on six other anthropometric measures, 
including height. 

Study authors, title, publication, and year: He, Fang,[A] "School 
Feeding Programs and Enrollment: Evidence from Sri Lanka," unpublished 
working paper, 2009; 
Setting: Sri Lanka; 
Food provided: Two in-school feeding programs: (1) provided corn-soya 
blend and (2) provided local food products; 
Findings: The study used school level enrollment and administrative 
data that was collected annually and a staggered program start to 
compare two differences: (1) the difference across time before and 
after a school meal program was implemented and (2) the difference 
across schools and grades with and without a school meal program. The 
study showed that enrollment increased for one of the school meal 
programs examined, but that this increase disappeared when the study 
looked at areas with varying intensities of program coverage. The 
study also found evidence that areas with higher percentages of 
schools and grades with the program were associated with decreases in 
enrollment for those schools and grades without the program in those 
areas. The study suggested that these results may have resulted from 
students switching from schools and grades without the program to 
schools and grades with the program. 

Study authors, title, publication, and year: Jacoby, Enrique, Santiago 
Cueto, and Ernesto Pollitt, "Benefits of a School Breakfast Programme 
Among Andean Children in Huaraz, Peru," Food and Nutrition Bulletin 17 
No. 1 (1996): 54-64; 
Setting: Rural, mountainous area, Peru; 
Food provided: Four cookies and an instant drink (sometimes cake and 
drinks were provided); 
Findings: The study used a randomized evaluation that allowed for 
identification of impacts of providing cookies and an instant drink. 
Dietary recall was used to measure food intake. The study found that 
providing breakfast increased intake of energy, protein, and iron and 
improved attendance. However, the study did not find evidence that the 
program significantly improved scores on cognitive tests, reading, 
vocabulary, or math tests. Finally, the study found some evidence that 
breakfast improved vocabulary test scores for heavier students. 

Study authors, title, publication, and year: Jacoby, Hanan G, "Is 
There an Intrahousehold 'Flypaper Effect'? Evidence from a School 
Feeding Programme," The Economic Journal 112 (January 2002): 196-221; 
Setting: Metropolitan Cebu area, Phillipines; 
Food provided: Morning or afternoon snack (most had sweetened porridge 
of bulgur wheat, others had rice, vegetables, milk); 
Findings: The study used administrative data and student level data 
and dietary recall to compare the difference in food intake during 
school days to non-school days and then to compare this difference 
among students who received in-school meals to students who did not. 
Even though the study found that poorer households are more likely to 
give students less food at home in response to the school snack that 
was provided, overall, the study found evidence that providing a 
school snack increased total caloric intake. 

Study authors, title, publication, and year: Kazianga, Harounan, 
Damien de Walque, and Harold Alderman, "Educational and Child Labor 
Impacts of Two Food for Education Schemes: Evidence from a Randomzied 
Trial in Rural Burkina Faso," unpublished working paper, 2010; 
Setting: Sahel region (rural area), Burkina Faso; 
Food provided: In-school feeding: unspecified food; Take-home rations: 
10 kg of cereal flour; 
Findings: The study used a randomized evaluation that allowed for 
identification of impacts of providing in-school feeding and take-home 
rations. The study found evidence that in-school feeding and take-home 
rations improved new enrollment for younger girls. The study did not 
find impacts on achievement or cognitive tests. The study also found a 
worsening overall attendance rate that could be due to the fact that 
new children from households with low child labor supplies (fewer 
siblings) were enrolled who would have been working - these new 
children attended school at a low rate and therefore drove down the 
overall attendance rate. 

Study authors, title, publication, and year: Meng, Xin, and Jim Ryan, 
"Does a Food for Education Program Affect School Outcomes? The 
Bangladesh Case," Journal of Population Economics 23 (2010): 415-447; 
Setting: Bangladesh; 
Food provided: Take-home rations: monthly rations of wheat (15-20 kg) 
or rice (12-16 kg); 
Findings: The study used data from a survey of schools, households, 
communities, and food grain dealers and matching techniques to compare 
four groups: (1) those that enroll into the program in program areas, 
(2) those that do not enroll into the program in program areas, (3) 
those that would have enrolled into the program in non-program areas, 
and (4) those that would not have enrolled into the program in non-
program areas. The study found evidence that the take-home rations 
improved enrollment and duration of school, particularly for girls. 

Study authors, title, publication, and year: Murphy, Suzanne P., 
Constance Gewa, Li-Jung Liang, Monika Grillenberger, Nimrod O. Bwibo, 
and Charlotte G. Neumann, "School Snacks Containing Animal Source 
Foods Improve Dietary Quality for Children in Rural Kenya," The 
Journal of Nutrition 133 (2003): 3950S-3956S; 
Setting: Rural area in Eastern Province, Kenya; 
Food provided: Githeri (maize, beans, vegetables, and fat) with meat, 
githeri with milk, githeri with more fat; 
Findings: The study used a randomized evaluation that allowed for the 
identification of impacts of providing meals that were supplemented 
with one of three different nutrients. The study used dietary recall 
to measure food intake. The study found evidence that a supplement of 
meat to the meal improved total caloric intake. However, the study 
found that supplements of energy and milk did not improve total 
caloric intake due to decreased caloric intake at home relative to the 
control group. The study also found that the meat supplement increased 
intake of protein, vitamins B-12 and A, calcium, iron, and zinc, that 
the milk supplement increased intake of vitamin B-12 and A, 
riboflavin, and calcium, and that the energy supplement increased 
intake of iron and no other outcomes. 

Study authors, title, publication, and year: Nielsen, Nicolai Steen, 
Kate Godden, Pierre Leguéné, Daniela Ruegenberg, and Jesper Rüdiger, 
"WFP Cambodia School Feeding 2000-2010: A Mixed Method Impact 
Evaluation," WFP Impact Evaluation, 2010; 
Setting: Prey Veng and Siem Reap provinces, Cambodia; 
Food provided: In-school feeding: early morning meal of rice, oil, 
salt, fish, and yellow split pea; Take-home rations: rice, oil, salt, 
fish, and yellow split pea; 
Findings: The study used school level data collected annually to 
examine the effects on enrollment, promotion, continuation, and drop-
out rates and cross- sectional data on students to examine the effects 
on attendance, achievement tests, anthropometry, and nutritional 
status. Control schools were chosen to be similar to program schools. 
The study found evidence showing improvements in enrollment, drop-out 
rates (3 of 6 grades), promotion (1 of 6 grades), and continuation 
rates (1 of 6 grades). The study also used cross-sectional data to 
find evidence that take-home rations improved attendance and that in-
school feeding increased girls' weight, but the study did not find 
significant evidence showing increases in girls' height and no 
evidence showing increases in girls' mid upper arm circumference. The 
study did not find any evidence showing increases in boys' 
anthropometric measures. The only evidence that the study found for 
improving achievement test scores was for girls' math tests scores in 
one of the two provinces. The study found that the improvements in 
enrollment and attendance were stronger for girls. The study also 
found evidence on reducing illness for girls and on improving dietary 
diversity for boys and girls. The study did not find that school 
feeding improved hemoglobin levels or reduced vitamin A deficiencies 
significantly. 

Study authors, title, publication, and year: Powell, Christine A., 
Susan P. Walker, Susan M. Chang, and Sally M. Grantham-McGregor, 
"Nutrition and Education: A Randomized Trial of the Effects of 
Breakfast in Rural Primary School Children," The American Journal of 
Clinical Nutrition 68 (1998): 873-9; 
Setting: Rural, mountainous area, Jamaica; 
Food provided: Breakfast (cheese sandwich or spiced bun and cheese and 
flavored milk), orange slice; 
Findings: The study used a randomized evaluation that allowed for the 
identification of impacts of providing breakfast versus providing an 
orange slice. The study found evidence showing that providing 
breakfast improved attendance, height, weight, and body mass index. As 
for the achievement tests, the study found that breakfast improved 
arithmetic test scores for young children but not spelling or reading 
test scores. 

Study authors, title, publication, and year: Ravallion, Martin and 
Quentin Wodon, "Evaluating a Targeted Social Program When Placement is 
Decentralized," unpublished working paper, 1998; 
Setting: Rural Bangladesh; 
Food provided: Take-home rations: monthly rations of wheat or rice 15 
kg for one child, 30 kg for more than two children in household; 
Findings: The study used household level data and implemented a 
methodology to address the likely bias in estimating the program's 
impact that was a result of differences between households that 
participate in the program and households that do not. Thus the study 
used an instrumental variables methodology with the program area as 
the instrument since the selection of the program (geographic) area 
was based on specified area characteristics. The study used this 
methodology to find evidence that showed that take-home rations 
improved attendance rates. 

Study authors, title, publication, and year: Ravallion, Martin and 
Quentin Wodon, "Does Child Labour Displace Schooling? Evidence on 
Behavioural Responses to an Enrollment Subsidy," The Economic Journal 
110 No. 462 (March 2000): C158-C175; 
Setting: Rural Bangladesh; 
Food provided: Take-home rations: monthly rations of rice that total 
on average 114 kg per year per household; 
Findings: The study used household level data and implemented a 
methodology to address the likely bias in estimating the program's 
impact that was a result of differences between households that 
participate in the program and households that do not. Thus the study 
used an instrumental variables methodology with the program area as 
the instrument since the selection of the program (geographic) area 
was based on specified area characteristics. The study used this 
methodology to find evidence that showed that take-home rations 
improved enrollment and reduced child labor. However, only part of the 
increase in enrollment was accounted for by a reduction in child labor. 

Study authors, title, publication, and year: Rogers, Beatrice Lorge, 
Jennifer Coates, and Akoto Kwame Osei, "WFP Bangladesh School Feeding 
Programme Mid-term Evaluation Final Report," unpublished working 
paper, 2004; 
Setting: Rural areas and urban slums, Bangladesh; 
Food provided: Biscuits; 
Findings: The study used school level data from two time periods to 
compare two differences: (1) the difference across time before and 
after take-home rations were provided and (2) the difference between 
those that received the take-home rations and those that did not. The 
study found evidence, albeit not consistent across all statistical 
methods, that take-home rations increased attendance. However, the 
study found weak or no evidence that take-home rations improved 
enrollment, grade repetition, drop-out rates, or achievement tests. 
The study did find that the enrollment at schools without the program 
decreased during the study period. 

Study authors, title, publication, and year: Siekmann, Jonathan H., 
Lindsay H. Allen, Nimrod O. Bwibo, Montague W. Demment, Suzanne P. 
Murphy, and Charlotte G. Neumann, "Kenyan School Children Have 
Multiple Micronutrient Deficiencies, but Increased Plasma Vitamin B-12 
is the Only Detectable Micronutrient Response to Meat or Milk 
Supplementation," The Journal of Nutrition 133 (2003): 3972S-3980S; 
Setting: Rural area in Eastern Province, Kenya; 
Food provided: Githeri (maize, beans, vegetables, and fat) with meat, 
githeri with milk, githeri with more fat; 
Findings: The study used a randomized evaluation that allowed for the 
identification of impacts of providing meals that were supplemented 
with one of three different nutrients. The study used clinical exams, 
blood tests, and stool samples to assess the impacts on micronutrient 
outcomes and disease prevalence rates. The study found evidence that 
showed that 1 of 9 micronutrient outcomes (plasma vitamin B-12) were 
improved for supplements of meat and milk to the meal. The study did 
not find evidence that a supplement of energy to the meal improved 
micronutrient outcomes. The study also showed that the meat supplement 
improved prevalence rates for 5 of 10 diseases, the milk supplement 
improved prevalence rates for 2 of 10 diseases, and the energy 
supplement improved prevalence rates of 1 of 10 diseases. 

Study authors, title, publication, and year: Tan, Jee-Peng, Julia 
Lane, and Gerard Lassibille, "Student Outcomes in Philippine 
Elementary Schools: An Evaluation of Four Experiments," The World Bank 
Economic Review 13 No. 3 (September 1999): 493-508; 
Setting: 10 provinces, Philippines; 
Food provided: Unspecified meals; 
Findings: The study used a randomized evaluation that allowed for the 
identification of impacts of providing school feeding compared to 
providing learning materials and providing nothing. The school feeding 
and learning materials program was also paired with providing parent-
teacher partnerships. The study also looked at the cost of the 
different programs. However, we focused on the study's findings on 
school feeding since that is the focus of this review. The study did 
not find evidence that school feeding improved the drop-out rate from 
1st to 5th grade. The study also did not find consistent evidence 
(across different model specifications) of improvements in math, 
Filipino, or English achievement test scores. Finally, despite being a 
randomized evaluation, the study had differences between the study 
groups that led to different results for different statistical models. 

Study authors, title, publication, and year: Whaley, Shannon E., 
Marian Sigman, Charlotte Neumann, Nimrod Bwibo, Donald Guthrie, Robert 
E. Weiss, Susan Alber, and Suzanne P. Murphy, "The Impact of Dietary 
Intervention on the Cognitive Development of Kenya School Children," 
The Journal of Nutrition 133 (2003): 3965S-3971S; 
Setting: Rural area in Eastern Province, Kenya; 
Food provided: Githeri (maize, beans, vegetables, and fat) with meat, 
githeri with milk, githeri with more fat; 
Findings: The study used a randomized evaluation that allowed for the 
identification of impacts on cognitive test scores of providing meals 
that were supplemented with one of three different nutrients. The 
study found evidence that showed that providing a supplement of meat 
to the meal improved scores on two of three cognitive tests (Raven's 
matrices and arithmetic). The study also showed that providing a 
supplement of energy to the meal improved arithmetic test scores. 
However, the study did not find that providing a supplement of milk to 
the meal improved any cognitive test scores. 

Source: GAO analysis of selected studies on school feeding. 

[A] Fang He, an economist at GAO, completed this study prior to his 
current employment at GAO. His preparation of the summary of selected 
studies on school feeding programs was independently reviewed by two 
other GAO economists who concurred with the analysis presented here. 

[End of table] 

[End of section] 

Appendix III: Operation of the MGD Program: 

The MGD Program Grant Approval Process Begins with the Designation of 
Priority Countries: 

USDA has established a grant approval process to help ensure that only 
programs that are likely to achieve the MGD Program's objectives of 
education, nutrition, and sustainability are approved. As such, USDA 
has developed criteria for designating priority countries, evaluating 
proposals, and negotiating grant agreements. Annually, according to 
FAS, it selects the MGD Program's priority countries that would most 
benefit from U.S. food assistance based on criteria that are intended 
to help ensure that the priority countries are needy and are committed 
to improving their education systems. Table 5 lists the criteria that 
a country had to meet to be considered a priority country. In order to 
help ensure sustainability, countries with existing programs were also 
considered priority countries. 

Table 5: Criteria Used to Determine Priority Countries: 

Fiscal Year 2008: Per capita incomes below $3,465 (based on World Bank 
statistics); 
Fiscal Years 2009 and 2010: Per capita income below $3,595 (based on 
World Bank statistics) and a population greater than 1 million; 
Fiscal Year 2011: Low-and lower-middle income countries (based on 2008 
World Bank statistics). 

Fiscal Year 2008: A net food importer with a greater-than-20-percent 
prevalence of undernourishment as a proportion of the total population 
(Food and Agricultural Organization); 
Fiscal Years 2009 and 2010: A net food importer with a greater-than-20-
percent prevalence of undernourishment as a proportion of the total 
population (Food and Agricultural Organization); 
Fiscal Year 2011: Greater than 20-percent prevalence of stunted growth 
(World Health Organization). 

Fiscal Year 2008: Adult literacy rate below 75 percent; 
Fiscal Years 2009 and 2010: Adult literacy rate below 75 percent; 
Fiscal Year 2011: Adult literacy rate below 80 percent. 

Fiscal Year 2008: Government support for education; 
Fiscal Years 2009 and 2010: Government commitment for education; 
Fiscal Year 2011: Government support for education. 

Fiscal Year 2008: Has no or limited civil conflict that could impede 
implementation of the program; 
Fiscal Years 2009 and 2010: No security, market, and/or capacity 
issues exist; 
Fiscal Year 2011: Absence of civil conflict. 

Fiscal Years 2009 and 2010: Fiscal Year 2008Fiscal Years 2009 and 
2010: FAS post coverage and FAS ability to monitor program 
implementation; 
Fiscal Year 2011: Fiscal Year 2008Fiscal Year 2011: FAS overseas 
presence to provide oversight of program activities. 

Source: GAO analyses of FAS's program considerations (solicitations 
for proposals) for fiscal years 2008 through 2011. 

Note: In fiscal year 2009, FAS solicited proposals for two fiscal 
years: 2009 and 2010. 

[End of table] 

Entities Submit Proposals Based on USDA's Criteria: 

Once USDA identifies and announces priority countries, it invites 
NGOs, foreign governments, and international organizations, such as 
WFP, to submit proposals. The proposals are evaluated based on 
criteria that are designed to address the MGD Program's three broad 
objectives of education, nutrition, and sustainability. Food 
Assistance Division analysts review every proposal and evaluate them 
by assessing the quality of the proposal, such as how the applicants 
plan to implement the program to achieve its goals, the applicants' 
organizational capabilities, the project's graduation or 
sustainability plan, the appropriateness of the requested commodities 
for the beneficiaries, and the need for the program. Table 6 describes 
the criteria the Food Assistance Division used to assess each proposal 
and the weight assigned each criteria for fiscal years 2008 to 2010. 

Table 6: Criteria Used to Assess Proposals, Fiscal Years 2008-2010: 

Proposal criteria: Proposal quality; This section addresses three 
program issues: implementation, costs, and situational analysis: 
1. How will the applicant implement the program, specifically, will 
the applicant contribute its own or outside resources to achieve 
program goals? How will the applicant use program funds to implement 
and monitor the target goals of the program? How does the proposed 
commodity provide a food for targeted beneficiaries that augments 
calories or nutrients? How will monetization or barter be conducted 
and by whom, and is monetization or barter more appropriate than a 
cash outlay? Has the applicant addressed the customs exemption issue 
in the case of a direct feed program? 
2. Does the proposal indicate a cost ratio that can effectively 
achieve a direct feeding, education, or maternal health care program? 
Is the proposal cost efficient in reaching a large number of 
recipients with the requested resources? If USDA resources are 
requested, do these funds effectively support an experienced 
management team which can implement, evaluate, and monitor projected 
goals? Are the requested USDA funds appropriate for the proposed 
technical assistance, storage, distribution, or other pertinent 
program activities? 
3. Does the proposal provide country information that explains and 
justifies the need for the proposed food aid programming? Do the 
targeted beneficiaries have a need that is not being met currently or 
sufficiently? Are there clear criteria and a persuasive rationale for 
the selection of a particular region, country and beneficiaries? Are 
the beneficiary baseline and target goals clear? Does the proposal 
target areas of a recipient country with the highest levels of 
poverty, hunger and low primary school enrollment rates, particularly 
of girls? Are the ideas in the proposal well developed and articulated? 
Weight: 38 percent. 

Proposal criteria: Experience and organizational capacity factors; 
Does the proposal show the organization's capability and effectiveness 
in implementing previous food aid programs, particularly school 
feeding, maternal child health (MCH), or other developmental 
activities related to education in schools or MCH? FAS looks at the 
experience of the organization and evaluates the organization 
favorably if it has experience in providing food aid with its own 
resources, or, more importantly, those from other donors. FAS 
considers the experiences of providing food aid regardless of the 
source of funding. Past experiences with USDA, USAID, or other donors 
will be viewed positively. FAS also reviews lists of known terrorists 
to ensure no organization, nor recipient agency, is participating in 
or funding terrorist activities. A review of non-profit websites is 
also conducted to ensure the financial and technical capability of 
program applicants. Finally, FAS ensures that organizations new to the 
program have a fair chance in competing for funds; 
Weight: 20 percent. 

Proposal criteria: Graduation/Sustainability--Country, community, or 
other donor contribution to program; Is there a plan for the host or 
local government to provide sufficient space and teachers for targeted 
schools? Does the local community provide food, space, labor, and 
involvement in education or nutrition programs? Does the applicant 
commit resources that demonstrate a continuance of the program after 
FAS ends funding? Does the proposal contain a graduation plan with 
methods and timeline to sustain activities and achievements? Do 
governments or other donors provide financial or in-kind support of 
the proposed activity that helps continue the program beyond the years 
of the proposed program? Does the proposal describe what other 
stakeholders are doing to address poverty, hunger and deficient 
primary education in the recipient country, what needs remain, and how 
the proposed program complements and does not duplicate those 
activities? 
Weight: 15 percent. 

Proposal criteria: Commodity or USDA funds appropriateness; Has the 
organization identified commodities and tonnages appropriate for the 
country? Is adequate information provided about the distribution 
process, storage and handling of commodities? Has the organization 
clearly identified how the requested USDA funds will be used and how 
they will complement the distribution of the commodities and lead to 
sustainability? 
Weight: 15 percent. 

Proposal criteria: Need for program; Is the program need clearly 
substantiated with statistics on food deficits, malnutrition, 
literacy, and information regarding education resources? Does the 
recipient country demonstrate commitment to improving its quality of 
education and nutrition of school-aged or children under 5 years old? 
Weight: 12 percent. 

Source: FAS's Fiscal Years 2008 through 2010 Program Considerations 
(solicitation for proposals). 

[End of table] 

Once USDA makes the final decisions on the proposals, the proposals 
are sent to the appropriate FAS overseas office for review and shared 
with other U.S. agencies, such as USAID, the U.S. State Department, 
and the Office of Management and Budget. After the awards are made, 
the agreements are negotiated with the implementing partners. 

Implementing Partners Are Required to Submit Various Progress Reports 
to Monitor and Evaluate the MGD Program: 

Food Assistance Division analysts monitor and evaluate the MGD 
Program's projects while they are active. The implementing partners 
are required to provide several periodic progress reports to FAS. 
Table 7 lists the types of reports, examples of information required, 
frequency, and party responsible for preparing them. 

Table 7: Periodic Progress Reporting Required of Implementing Partners: 

Required reports: Financial report; 
Examples of information required: 
The NGO report provides amounts for administrative expenses, such as 
salaries and office rent, and spending on shipping, handling, and 
warehousing of the commodities; 
Frequency of required reports: At least annually but not more than 
quarterly; 
Quarterly; 
Implementing partner: NGO; 
The WFP report will provide information regarding expenditures related 
to a project agreement, such as cash disbursements, federal share of 
expenditures, and recipient share of expenditures; 
Frequency of required reports: 
Quarterly; 
Implementing partner: WFP will comply beginning in fiscal year 2012. 

Required reports: Logistics and monetization report; 
Examples of information required: Examples of information covered in 
the report: 
* the commodities, the amounts received, when received, the commodity 
balance; 
* commodity losses or damages, and problems encountered in the 
delivery, and warehousing of the commodity; 
* the amount of commodity distributed to each project and the number 
of beneficiaries served; 
* school performance by several performance indicators, including 
enrollment and attendance; 
* information on monitoring procedures; and; 
* if applicable, the amount of food aid monetized, the amount 
generated from the sale of the commodity, and the use of the funds; 
Frequency of required reports: Semiannual; 
Implementing partner: NGO. 

Required reports: Project status report; 
Examples of information required: Examples of information covered in 
the report: 
* the number, frequency, and average size of the meal provided each 
month for in-school meals and take-home rations; 
* monthly enrollment, dropout, and attendance by gender for each 
school; 
* the establishment of any school infrastructure; and; 
* the establishment of any parent-teacher associations; 
Frequency of required reports: Semiannual; 
Implementing partner: NGO; WFP will comply beginning in fiscal year 
2012. 

Required reports: Single Audit (A-133); 
Examples of information required: NGOs that expend $500,000 or more in 
federal awards in a year are to obtain an audit in accordance with the 
requirements of the Single Audit Act (codified at 311 U.S.C. 7501 et 
seq). A Single Audit consists of "(1) an audit and opinions on the 
fair presentation of the financial statements and the Schedule of 
Expenditures of Federal Awards; 
(2) gaining an understanding of and testing internal control over 
financial reporting and the entity's compliance with laws, 
regulations, and contract or grant provisions that have a direct and 
material effect on certain federal programs (i.e., the program 
requirements); 
and (3) an audit and an opinion on compliance with applicable program 
requirements for certain federal programs;" 
Frequency of required reports: Annual; 
Implementing partner: NGO. 

Required reports: Standard project report; 
Examples of information required: WFP provides a standard report that 
covers its country projects, including school feeding activities. 
Examples of the information covered in the report are: 
* the operational objectives of the country program; 
* the project's results, including beneficiaries targeting, outputs, 
outcomes, sustainability, and capacity development and handover; 
* inputs, including resources from donors, governments, and partners; 
food purchases, and food transport, delivery, and handling; 
* management, including WFP's partnerships with other entities and 
lessons learned; and; 
* the financial section provides details of financial activity 
relating to the project throughout the reporting period and a summary 
of the project's financial status at the end of the reporting period; 
Frequency of required reports: Annual; 
Implementing partner: WFP. 

Required reports: Ad hoc reporting; 
Examples of information required: For each project agreement, WFP will 
be required to report on collected, established baseline indicators 
about: 
* the number of meals served; 
* access to, entry into and continuation of school (e.g., enrollment 
levels, total attendance numbers, including female attendance levels); 
* educational progress; 
* nutrition and child health interventions; 
* other donor support; 
* community development; and; 
* sustainability for activities supported by the project agreement; 
Frequency of required reports: Annual; 
Implementing partner: WFP will comply beginning in fiscal year 2012. 

Required reports: Interim and final evaluations; 
Examples of information required: Implementing partners are required 
to have evaluations conducted by an independent third party that: 
* is financially and legally separate from the participant's 
organization; 
* has staff with demonstrated knowledge, analytical capability, 
language skills, and experience in conducting evaluation of 
development programs involving agriculture, education, and nutrition; 
* uses acceptable analytical frameworks such as comparison with non-
project areas, surveys, involvement of stakeholders in the evaluation, 
and statistical analyses; 
* uses local consultants, as appropriate, to conduct portions of the 
evaluation; and; 
* provides a detailed outline of the evaluation, major tasks, and 
specific schedules prior to initiating the evaluation; 
Frequency of required reports: Midpoint and end point of the project 
implementation period; 
Implementing partner: NGO and WFP. 

Sources: USDA's Foreign Agricultural Service and GAO analysis. 

Notes: 

The semiannual reports are due in November and May of each year that 
the project is active. 

WFP currently provides the annual standard project report to FAS. 
Based on a framework agreement between FAS and WFP signed in June 
2010, WFP is required to comply with the other reporting requirements 
beginning in 2012. 

Implementing partners are expected to submit the first round of mid- 
point evaluations for multi-year agreements in fiscal year 2012 and 
the first round of end-point evaluations in fiscal year 2014. 

[End of table] 

FAS Staff Perform Closeouts of Completed Grant Agreements: 

FAS staff are required to closeout grant agreements after the MGD 
project activities are completed. Both the Food Assistance Division 
and the Monitoring and Evaluation Staff analysts participate in grant 
closeouts. Using a checklist, the Food Assistance Division program 
analysts compile a folder for the Monitoring and Evaluation staff that 
consists of the necessary documents, including final logistics and 
monetization reports, cumulative financial reports, and final audits. 
The Monitoring and Evaluation Staff first conducts a financial 
analysis by comparing the reported expenditures to the budgeted 
amounts in the agreement. The analysis consists of determining whether 
money is owed and ensuring that line item expenditures did not exceed 
the agreement, etc. The logistics and monetization reports are 
reviewed to assess whether excessive loss in commodities occurred, and 
results of the A- 133 audit are reviewed to determine the financial 
integrity of the NGOs. If expenditure reports indicate that all 
advanced cash has not been used, the NGO is required to reimburse USDA. 

USDA occasionally conducts financial compliance review site visits of 
USDA food aid grants to verify that the funds were spent as approved 
by USDA. Site visits are conducted by the Compliance, Security, and 
Emergency Planning Division within USDA. 

[End of section] 

Appendix IV: MGD Program Funding by Year, Country, and Region: 

The total amount of funds appropriated by Congress for the MGD Program 
from fiscal years 2003 through 2010 is $931 million.[Footnote 56] 
Table 8 shows that, based on USDA's data, the total amount obligated 
for MGD projects through fiscal year 2010 is approximately $892 
million. Of that amount, approximately $638 million has been spent as 
of October 31, 2010. Of the total obligated, the five countries that 
received the most funding are Guatemala ($74.6 million), Pakistan 
($67.3 million), Kenya ($62.6 million), Mozambique ($51.1 million), 
and Afghanistan ($50.7 million). 

Table 8: MGD Program Obligations by Year, Country, and Region, Fiscal 
Years 2003 through 2010 (in millions): 

Country: Angola; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: $29.5; 
2010: [Empty]; 
Grand total: $29.5. 

Country: Benin; 
2003: $5.4; 
2004: [Empty]; 
2005: [Empty]; 
2006: $2.9; 
2007: $1.7; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $9.9. 

Country: Cameroon; 
2003: $1.6; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: $3.9; 
2009: $2.9; 
2010: $2.7; 
Grand total: $11.1. 

Country: Chad; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: $5.1; 
2007: [Empty]; 
2008: $5.6; 
2009: $5.6; 
2010: $5.6; 
Grand total: $22.0. 

Country: Republic of Congo; 
2003: [Empty]; 
2004: $2.5; 
2005: [Empty]; 
2006: $7.1; 
2007: $6.9; 
2008: $4.7; 
2009: [Empty]; 
2010: $3.6; 
Grand total: $24.8. 

Country: Eritrea; 
2003: [Empty]; 
2004: $4.5; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $4.5. 

Country: Ethiopia; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: $4.5; 
2009: $4.5; 
2010: $4.5; 
Grand total: $13.4. 

Country: Gambia; 
2003: [Empty]; 
2004: $0.5; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $0.5. 

Country: Ghana; 
2003: $4.4; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $4.4. 

Country: Guinea; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: $11.4; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $11.4. 

Country: Guinea-Bissau; 
2003: [Empty]; 
2004: [Empty]; 
2005: $2.1; 
2006: $3.2; 
2007: $5.0; 
2008: [Empty]; 
2009: $18.8; 
2010: $0.1; 
Grand total: $29.1. 

Country: Ivory Coast; 
2003: $4.7; 
2004: $3.1; 
2005: $4.7; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $12.5. 

Country: Kenya; 
2003: [Empty]; 
2004: $5.3; 
2005: $10.3; 
2006: $7.7; 
2007: $10.0; 
2008: $10.0; 
2009: $10.0; 
2010: $9.4; 
Grand total: $62.6. 

Country: Liberia; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: $2.3; 
2008: [Empty]; 
2009: $9.0; 
2010: $11.4; 
Grand total: $22.8. 

Country: Madagascar; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: $5.4; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $5.4. 

Country: Malawi; 
2003: $4.2; 
2004: $3.4; 
2005: [Empty]; 
2006: [Empty]; 
2007: $6.5; 
2008: $6.5; 
2009: $6.5; 
2010: $8.3; 
Grand total: $35.6. 

Country: Mali; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: $14.0; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $14.0. 

Country: Mozambique; 
2003: $3.3; 
2004: $3.5; 
2005: [Empty]; 
2006: [Empty]; 
2007: $5.4; 
2008: $7.1; 
2009: $7.8; 
2010: $24.0; 
Grand total: $51.1. 

Country: Niger; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: $13.2; 
2010: [Empty]; 
Grand total: $13.2. 

Country: Rwanda; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: $9.1; 
2009: $9.1; 
2010: $9.1; 
Grand total: $27.3. 

Country: Senegal; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: $7.3; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $7.3. 

Country: Sierra Leone; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: $2.9; 
2009: $2.9; 
2010: $2.3; 
Grand total: $8.1. 

Country: Tanzania; 
2003: $3.9; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: $9.7; 
Grand total: $13.6. 

Country: Uganda; 
2003: $2.5; 
2004: [Empty]; 
2005: $6.8; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: $19.0; 
2010: $12.7; 
Grand total: $40.9. 

Country: Africa total; 
2003: $30.0; 
2004: $22.8; 
2005: $23.9; 
2006: $33.3; 
2007: $68.5; 
2008: $54.4; 
2009: $138.7; 
2010: $103.5; 
Grand total: $475.1. 

Country: Afghanistan; 
2003: $9.0; 
2004: $6.7; 
2005: $10.0; 
2006: $25.0; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $50.7. 

Country: Bangladesh; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: $8.1; 
2007: [Empty]; 
2008: $7.8; 
2009: $7.9; 
2010: $8.0; 
Grand total: $31.8. 

Country: Bhutan; 
2003: $1.0; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $1.0. 

Country: Cambodia; 
2003: $1.3; 
2004: [Empty]; 
2005: [Empty]; 
2006: $5.0; 
2007: $8.8; 
2008: $1.3; 
2009: $1.2; 
2010: $18.1; 
Grand total: $35.9. 

Country: Kyrgyzstan; 
2003: $3.0; 
2004: $3.0; 
2005: $6.6; 
2006: [Empty]; 
2007: [Empty]; 
2008: $2.4; 
2009: [Empty]; 
2010: $3.2; 
Grand total: $18.2. 

Country: Laos; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: $3.3; 
2007: [Empty]; 
2008: $6.9; 
2009: $3.0; 
2010: $7.3; 
Grand total: $20.5. 

Country: Nepal; 
2003: $5.4; 
2004: [Empty]; 
2005: $6.2; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $11.6. 

Country: Pakistan; 
2003: $6.9; 
2004: [Empty]; 
2005: $7.5; 
2006: $7.3; 
2007: $9.5; 
2008: $9.9; 
2009: $10.0; 
2010: $16.3; 
Grand total: $67.3. 

Country: Vietnam; 
2003: $8.0; 
2004: [Empty]; 
2005: $6.8; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $14.8. 

Country: Asia total; 
2003: $34.7; 
2004: $9.7; 
2005: $37.1; 
2006: $48.8; 
2007: $18.3; 
2008: $28.3; 
2009: $22.1; 
2010: $52.9; 
Grand total: $251.8. 

Country: Albania; 
2003: $3.2; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $3.2. 

Country: Moldova; 
2003: $9.0; 
2004: $6.6; 
2005: $4.6; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $20.2. 

Country: Eastern Europe total; 
2003: $12.2; 
2004: $6.6; 
2005: $4.6; 
2006: $0.0; 
2007: $0.0; 
2008: $0.0; 
2009: $0.0; 
2010: $0.0; 
Grand total: $23.4. 

Country: Bolivia; 
2003: $3.4; 
2004: $3.0; 
2005: $3.7; 
2006: $1.8; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: $7.0; 
Grand total: $18.9. 

Country: Dominican Republic; 
2003: [Empty]; 
2004: $3.4; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $3.4. 

Country: Guatemala; 
2003: $4.8; 
2004: [Empty]; 
2005: $4.0; 
2006: $10.5; 
2007: $11.2; 
2008: $13.7; 
2009: $14.2; 
2010: $16.1; 
Grand total: $74.6. 

Country: Honduras; 
2003: [Empty]; 
2004: [Empty]; 
2005: $9.7; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $9.7. 

Country: Nicaragua; 
2003: $5.4; 
2004: [Empty]; 
2005: $2.7; 
2006: $0.7; 
2007: [Empty]; 
2008: $1.2; 
2009: [Empty]; 
2010: $0.1; 
Grand total: $10.1. 

Country: Latin America and the Caribbean total; 
2003: $13.6; 
2004: $6.4; 
2005: $20.2; 
2006: $12.9; 
2007: $11.2; 
2008: $14.9; 
2009: $14.2; 
2010: $23.2; 
Grand total: $116.7. 

Country: Lebanon; 
2003: $7.9; 
2004: [Empty]; 
2005: $7.8; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: [Empty]; 
2010: [Empty]; 
Grand total: $15.7. 

Country: Yemen; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: $9.1; 
2010: [Empty]; 
Grand total: $9.1. 

Country: Middle East total; 
2003: $7.9; 
2004: [Empty]; 
2005: $7.8; 
2006: [Empty]; 
2007: [Empty]; 
2008: [Empty]; 
2009: $9.1; 
2010: [Empty]; 
Grand total: $24.8. 

Country: Grand total; 
2003: $98.4; 
2004: $45.5; 
2005: $93.6; 
2006: $95.0; 
2007: $98.0; 
2008: $97.6; 
2009: $184.1; 
2010: $179.6; 
Grand total: $891.8. 

Source: USDA, Farm Service Agency. 

Note: The funds for Yemen were obligated, but the MGD project was 
never implemented. 

[End of table] 

Of the total funds obligated, according to USDA, Africa received the 
most, 53 percent, followed by Asia, Latin America and the Caribbean, 
Middle East, and Eastern Europe, as reflected in figure 9. 

Figure 9: MGD Program Funds Obligated by Region, Fiscal Years 2003 
Through 2010: 

[Refer to PDF for image: pie-chart] 

Africa: $475.1 million (53.3%); 
Asia: $251.8 million (28.2%); 
Latin America and the Caribbean: $116.7 million (13.1%); 
Middle East: $24.8 million (2.8%); 
Eastern Europe: $23.4 million (2.6%). 

Sources: USDA, Farm Service Agency. 

[End of figure] 

[End of section] 

Appendix V: Methods NGOs Planned to Use to Select MGD Program 
Beneficiaries: 

We analyzed all 19 NGO agreements from fiscal years 2008 through 2010 
to determine how NGOs select their beneficiaries for the MGD Program. 
Table 9 shows the methods NGOs agreed to use in selecting their 
beneficiaries and the number of NGO agreements that include each 
method. Some of the MGD program agreements for the NGOs planned to 
select schools that required new facilities, teacher training, or the 
development of parent teacher associations or school management 
committees, while others planned to select schools that already had 
existing facilities or community organizations. According to WFP, its 
school feeding programs target food insecure areas, which tend to be 
rural, and identified through food security assessments. Food security 
information is combined with the government-provided education-related 
information (such as enrollment, attendance, retention, and completion 
rates). WFP has been including educational indicators into its food 
security assessments to inform its decisions on school feeding and is 
now trying to standardize this process by using a set of targeting 
guidelines specific for school feeding. 

Table 9: Methods NGOs Planned to Use to Select MGD Program 
Beneficiaries: 

Opinions of need: 

NGOs' methods of selecting beneficiaries: Host government agencies 
opinions' of need; 
Number of agreements/proposals: 4. 

NGOs' methods of selecting beneficiaries: Local teachers and education 
officials opinions' of need; 
Number of agreements/proposals: 2. 

NGOs' methods of selecting beneficiaries: Local provincial and 
regional officials opinions' of need; 
Number of agreements/proposals: 5. 

NGOs' methods of selecting beneficiaries: Village elders or other 
community representatives' opinions of need; 
Number of agreements/proposals: 1. 

Data collection to indicate need: 

NGOs' methods of selecting beneficiaries: On-site observation and 
interviews to determine needs; 
Number of agreements/proposals: 1. 

NGOs' methods of selecting beneficiaries: Field surveys conducted by 
NGO or others to determine needs (including lists created for earlier 
programs); 
Number of agreements/proposals: 8. 

NGOs' methods of selecting beneficiaries: Government registries of 
educational institutions in a region; 
Number of agreements/proposals: 4. 

NGOs' methods of selecting beneficiaries: Official host government 
statistics; 
Number of agreements/proposals: 13. 

NGOs' methods of selecting beneficiaries: WFP, other United Nations 
agency or other donor's (such as USAID) statistics; 
Number of agreements/proposals: 7. 

Indicators of need: 

NGOs' methods of selecting beneficiaries: High rates of poverty; 
Number of agreements/proposals: 5. 

NGOs' methods of selecting beneficiaries: Low levels of literacy; 
Number of agreements/proposals: 3. 

NGOs' methods of selecting beneficiaries: High rates of malnutrition; 
Number of agreements/proposals: 5. 

NGOs' methods of selecting beneficiaries: High levels of food 
insecurity and vulnerability; 
Number of agreements/proposals: 6. 

NGOs' methods of selecting beneficiaries: Low levels of school 
enrollment/underenrollment; 
Number of agreements/proposals: 7. 

NGOs' methods of selecting beneficiaries: Low levels of school 
enrollment for girls; 
Number of agreements/proposals: 3. 

NGOs' methods of selecting beneficiaries: High rates of absenteeism 
from school/low rates of attendance; 
Number of agreements/proposals: 4. 

NGOs' methods of selecting beneficiaries: Low retention rates; 
Number of agreements/proposals: 2. 

NGOs' methods of selecting beneficiaries: High drop out rates for 
girls, esp. between primary and secondary school; 
Number of agreements/proposals: 1. 

NGOs' methods of selecting beneficiaries: Other evidence of gender 
inequality; 
Number of agreements/proposals: 2. 

Location: 

NGOs' methods of selecting beneficiaries: Rural or remote location; 
Number of agreements/proposals: 3. 

NGOs' methods of selecting beneficiaries: Regions not receiving 
coverage by other school feeding program; 
Number of agreements/proposals: 5. 

NGOs' methods of selecting beneficiaries: Area(s) where NGO works; 
Number of agreements/proposals: 3. 

Community willingness to participate and contribute: 

NGOs' methods of selecting beneficiaries: Community agrees to 
participate and contribute; 
Number of agreements/proposals: 9. 

NGOs' methods of selecting beneficiaries: Community agrees to provide 
firewood and cooking fuel; 
Number of agreements/proposals: 1. 

NGOs' methods of selecting beneficiaries: Local government willingness 
to contribute financially; 
Number of agreements/proposals: 1. 

NGOs' methods of selecting beneficiaries: Parent Teacher Association 
(PTA) or School Management Committee (SMC) indicates willingness to 
participate and contribute; 
Number of agreements/proposals: 7. 

School willingness to participate and contribute: 

NGOs' methods of selecting beneficiaries: Teachers agree to 
participate and/or contribute (including by participating in teacher 
training by the NGO and contributing time to distribution activities); 
Number of agreements/proposals: 2. 

NGOs' methods of selecting beneficiaries: Schools demonstrate or agree 
to adhere to program policies and conditions (including regulations 
for storage and handling, distribution, data collection, monitoring 
and tracking by the NGO, reporting, etc.); 
Number of agreements/proposals: 4. 

NGOs' methods of selecting beneficiaries: Schools participate or agree 
to participate in related NGO programs; 
Number of agreements/proposals: 1. 

NGOs' methods of selecting beneficiaries: Schools willing to adopt 
innovative practices related to sustainability; 
Number of agreements/proposals: 7. 

School can demonstrate necessary capacity: 

NGOs' methods of selecting beneficiaries: Schools have staff capacity 
and experience in school feeding programs (e.g., sufficient teachers 
and support staff, staff with experience in school feeding programs 
and management); 
Number of agreements/proposals: 1. 

NGOs' methods of selecting beneficiaries: Schools have necessary 
facilities (e.g., trucks, safe water supply, functioning kitchens, 
secure storage, disposal facilities, etc.); 
Number of agreements/proposals: 5. 

NGOs' methods of selecting beneficiaries: PTA or SMC or Education 
Development Committee exists and is capable of helping run program; 
Number of agreements/proposals: 5. 

NGOs' methods of selecting beneficiaries: Schools participated in 
previous school feeding program; 
Number of agreements/proposals: 6. 

Other: 

NGOs' methods of selecting beneficiaries: Schools currently closed but 
could be re-opened to meet local needs; 
Number of agreements/proposals: 1. 

NGOs' methods of selecting beneficiaries: Other; 
Number of agreements/proposals: 25. 

Source: GAO analysis of NGO agreements from 2008 through 2010. 

[End of table] 

[End of section] 

Appendix VI: MGD Program's Planned Complementary Activities in 
Agreements with Implementing Partners: 

We analyzed all 19 NGO agreements and all 12 WFP proposals and country 
programs from fiscal years 2008 through 2010 to determine the types of 
activities that implementing partners agreed to implement in their 
agreements with USDA. The implementing partners agreed to these 
activities as part of the MGD Program's objectives to improve 
education, nutrition, and sustainability. Table 10 shows some planned 
complementary activities that NGOs and WFP have agreed to implement 
and the number of NGO agreements and WFP proposals and country 
programs that include each activity. 

Table 10: MGD Program's Planned Complementary Activities in Agreements 
with Implementing Partners: 

Education-related activities: 

Activity name: Teacher Training; 
Description of activities: Train teachers to improve education quality; 
includes training trainers, working with the host government Ministry 
of Education on teacher training curriculum and issues; advanced 
teacher training; training the trainers; 
Number of agreements/proposals: 14. 

Activity name: School Facilities: General; 
Description of activities: Improve school infrastructure, facilities, 
or environment through construction projects or grants (includes 
furniture, classrooms, storage rooms, and canteens--but not latrines 
or wells, see below); 
Number of agreements/proposals: 13. 

Activity name: Educational Supplies/Equipment; 
Description of activities: Provide school supplies and educational 
materials (including school or classroom kits); 
Number of agreements/proposals: 12. 

Activity name: School Awareness; 
Description of activities: Conduct school awareness campaigns and/or 
training emphasizing the value of education; 
Number of agreements/proposals: 7. 

Activity name: Teacher Residences; 
Description of activities: Provide or rehabilitate residences for 
teachers; 
Number of agreements/proposals: 2. 

Nutrition-related activities: 

Activity name: Health/Nutrition Education; 
Description of activities: Provide health, nutrition, hygiene 
sessions, and/or advice in schools and the community. Includes 
providing health advice/education/training for parents (esp. mothers), 
children (school and preschool), teachers, caregivers, others in the 
community; training municipal government, parents on health, 
nutrition, hygiene, etc. Also includes advice on preparation of food; 
Number of agreements/proposals: 22. 

Activity name: School Facilities: Potable water; 
Description of activities: Drill and/or rehabilitate boreholes and 
water wells, or provide other methods (and training) to ensure potable 
water; 
Number of agreements/proposals: 16. 

Activity name: School Facilities: Latrines; 
Description of activities: Construct school latrines; 
Number of agreements/proposals: 14. 

Activity name: Health: De-worming; 
Description of activities: Distribute and administer deworming 
medication either by WFP/NGO itself of in collaboration with other 
donors, such as UNICEF or local health officials; 
Number of agreements/proposals: 14. 

Activity name: Health Supplies; 
Description of activities: Provide health supplies (such as medicines) 
and supplies/equipment to promote health; 
Number of agreements/proposals: 7. 

Activity name: Nutrition Interventions; 
Description of activities: Provide rations and/or nutrients to 
mothers/families or others; 
distribute micronutrients and/or vitamin supplements to schoolchildren 
(and pregnant nursing mothers); 
purchase salt or other commodities locally to add to the rations; 
Number of agreements/proposals: 6. 

Activity name: Health Screening; 
Description of activities: Screen children for ailments/perform simple 
examinations and follow up as appropriate; 
perform simple interventions; 
Number of agreements/proposals: 3. 

Activity name: Health: Anti-malaria; 
Description of activities: Conduct antimalaria programs (informational 
materials, provision of nets and sprays); 
Number of agreements/proposals: 1. 

Sustainability-related activities: 

Activity name: Sustainability: Local Level; 
Description of activities: Train local government employees, community 
planners, parent-teacher associations, and other stakeholders to focus 
on sustainability. Includes, training parents to help with educational 
activities; training teachers, community leaders, and parent-teacher 
associations or school management committees to implement project 
activities; training in budget management techniques possibly with 
special reference to school feeding programs; adult literacy courses 
for local community; training in farming techniques; 
Number of agreements/proposals: 17. 

Activity name: Parent and Community Involvement in the Schools; 
Description of activities: Form or develop partnerships with parents 
and the community/create or support parent-teacher associations or 
school management committees; 
Number of agreements/proposals: 17. 

Activity name: Sustainability: Host Governments; 
Description of activities: Work with host government Ministry of 
Education to develop national school feeding program. Includes: 
working with host government Ministry of Education and Ministry of 
Health to develop their capacity to run and monitor education and 
health programs; encouraging/supporting changes in the education 
system, establishing national education management information system, 
developing monitoring and evaluation capacity; training national 
managers; 
Number of agreements/proposals: 11. 

Activity name: Sustainability: Civil Society/General; 
Description of activities: Training/seminars/workshops for 
implementing partners, other nongovernmental officials; 
general and other capacity building and sustainability activities 
where the level of government is not specified; 
Number of agreements/proposals: 4. 

Source: GAO analysis of NGO agreements and WFP proposals and country 
programs from fiscal years 2008 through 2010. 

Note: Table 10 is not meant to be a comprehensive list of 
complementary activities in NGOs' agreements and WFP's proposals and 
country programs. We categorized the list of activities into 
education, nutrition, and sustainability-related activities, based on 
our analysis of each activity's relevance to each objective. The 
implementing partners also agreed to perform a range of activities 
that either addressed multiple objectives, or addressed other 
objectives. For these activities that could not be categorized under 
these three objectives or that may have fallen under more than one 
objective, we omitted them from the table. 

[End of table] 

[End of section] 

Appendix VII: MGD Program's Performance Indicators in NGOs Agreements 
and WFP Proposals: 

USDA has developed over 30 performance indicators for the MGD Program. 
These indicators are based on the program's objectives of education, 
nutrition, and sustainability. We analyzed all 19 NGOs agreements and 
all 12 WFP proposals and country programs from fiscal years 2008 
through 2010 to identify the indicators on which each implementing 
partner agreed to report. Table 11 shows a full list of the indicators 
implementing partners agreed to report and the number of NGOs 
agreements and WFP proposals that include each indicator. 

Table 11: MGD Program's Performance Indicators in NGOs Agreements and 
WFP Proposals: 

Educational access: 

Performance indicators: Percentage increase in enrollment - boys; 
Number of agreements/proposals: 28. 

Performance indicators: Percentage increase in enrollment - girls; 
Number of agreements/proposals: 31. 

Performance indicators: Percentage increase in attendance - boys; 
Number of agreements/proposals: 27. 

Performance indicators: Percentage increase in attendance - girls; 
Number of agreements/proposals: 29. 

Performance indicators: Percentage increase in attendance (gender not 
specified); 
Number of agreements/proposals: 0. 

Performance indicators: Number of take-home rations distributed; 
Number of agreements/proposals: 0. 

Performance indicators: Number of food supplements provided; 
Number of agreements/proposals: 0. 

Performance indicators: Other; 
Number of agreements/proposals: 1. 

Educational progress: 

Performance indicators: Percentage of boys and girls entering grade 1 
of primary school who reach grade 3 (or grade 5) multiyear agreements 
(cohort survival to grades 3 or 5); 
Number of agreements/proposals: 24. 

Performance indicators: Promotion rate; 
Number of agreements/proposals: 26. 

Performance indicators: Continuation rate; 
Number of agreements/proposals: 24. 

Performance indicators: Percentage of targeted schools with adequate 
school supplies; 
Number of agreements/proposals: 21. 

Performance indicators: Percentage of targeted schools with printed 
materials to support literacy and numeric instruction; 
Number of agreements/proposals: 15. 

Performance indicators: Percentage/number of teachers receiving 
training; 
Number of agreements/proposals: 23. 

Performance indicators: Number of communities with adult literacy 
classes; 
Number of agreements/proposals: 1. 

Performance indicators: Number of supply kits provided; 
Number of agreements/proposals: 0. 

Performance indicators: Other; 
Number of agreements/proposals: 2. 

Nutrition: 

Performance indicators: Number of daily meals provided; 
Number of agreements/proposals: 27. 

Performance indicators: Number of take-home rations distributed; 
Number of agreements/proposals: 17. 

Performance indicators: Percentage of participating schools 
implementing health and nutrition education for students; 
Number of agreements/proposals: 24. 

Performance indicators: Percentage of participating schools with 
established prophylactic programs; 
Number of agreements/proposals: 21. 

Performance indicators: Percentage of participating schools with 
established health care provider to the schools including preschools; 
Number of agreements/proposals: 7. 

Performance indicators: Percentage of mother and child clinics/health 
facilities supported; 
Number of agreements/proposals: 2. 

Performance indicators: Percentage of children on target with age-to- 
weight and height growth; 
Number of agreements/proposals: 5. 

Performance indicators: Percentage of schools that institutionalized 
health and hygiene programs; 
Number of agreements/proposals: 1. 

Performance indicators: Other; 
Number of agreements/proposals: 0. 

Sustainability: 

Performance indicators: Number of other donors contributing to 
ancillary projects of complementary activities (school infrastructure, 
immunization program); 
Number of agreements/proposals: 26. 

Performance indicators: Dollar amount of donor contributions; 
Number of agreements/proposals: 15. 

Performance indicators: Percentage of cost sharing; 
Number of agreements/proposals: 16. 

Performance indicators: Percentage of donor support; 
Number of agreements/proposals: 13. 

Performance indicators: Implementing partner/participant's/ 
organization's independent contribution; 
Number of agreements/proposals: 14. 

Performance indicators: Percentage of schools where parents provide a 
defined level of support; 
Number of agreements/proposals: 27. 

Performance indicators: Percentage of schools with parent groups 
(associations or councils) that play a defined role in program 
management; 
Number of agreements/proposals: 30. 

Performance indicators: Number of complementary programs; 
Number of agreements/proposals: 29. 

Performance indicators: Number of potable water projects; 
Number of agreements/proposals: 24. 

Performance indicators: Number of latrine and/or kitchen repairs and 
constructions; 
Number of agreements/proposals: 25. 

Performance indicators: Number of nutrition and health education 
classes for adults; 
Number of agreements/proposals: 21. 

Performance indicators: Percentage of schools transitioning into 
parent-teacher association/government-supported feeding program; 
Number of agreements/proposals: 19. 

Performance indicators: Percentage of government increased support to 
education sector; 
Number of agreements/proposals: 25. 

Performance indicators: Number of training sessions for capacity 
building; 
Number of agreements/proposals: 28. 

Performance indicators: Percentage of donor support vs. of indigenous 
support; 
Number of agreements/proposals: 16. 

Performance indicators: Number of provincial Ministries of Education 
that received training (in subjects like community mobilization, 
administration, and monitoring); 
Number of agreements/proposals: 0. 

Performance indicators: Other; 
Number of agreements/proposals: 0. 

Source: GAO analysis of NGO agreements and WFP proposals from fiscal 
years 2008 through 2010. 

Note: The MGD Program provides its prospective implementing partners 
with a list of more than 30 possible indicators they can use to track 
performance. For this analysis, we recorded the indicators that the 
implementing partners had selected in the NGO agreements and WFP 
proposals for fiscal years 2008 through 2010. Some of the indicators 
have zeros because no implementing partners selected them during that 
time period. 

[End of table] 

[End of section] 

Appendix VIII: Comments from the U.S. Department of Agriculture: 

Note: GAO comments supplementing those in the report text appear at 
the end of this appendix. 

USDA: 
United States Department of Agriculture:	
Farm and Foreign Agricultural Service: 
Foreign Agricultural Service: 
1400 Independence Ave, SW: 
Washington, DC 20250-1034: 

May 4, 2011: 

Mr. Thomas Melito: 
Director, International Affairs and Trade Team: 
United States Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

Dear Mr. Melito: 

The U.S. Department of Agriculture (USDA) appreciates this opportunity 
to review the Government Accountability Office (GAO) draft report on 
"International School Feeding: USDA's Oversight of the McGovern-Dole 
Food for Education Program Needs Improvement" (GAO-11-544). USDA is 
pleased that the GAO noted our positive results in the grant approval 
and agreement negotiation processes, financial oversight, and 
performance indicators. The Department also notes the GAO's 
recommendations that oversight of the McGovern-Dole program continue 
to improve, and that internal controls he strengthened to ensure that 
program funds arc used as intended. USDA agrees with these 
recommendations and will work to address them. 
	
USDA takes program management very seriously and recognizes the 
essential role that the proper monitoring and evaluation of projects 
plays in providing Oversight of current programs, improving the 
quality of Entire programs, and measuring results. USDA has taken 
several actions over the past four years to make improvements. These 
actions include new hires, increasing the number of site visits by 
three-fold, requiring mid-term and final evaluations of projects. 
incorporating results-oriented management (ROM) procedures, and 
improving technology to better capture and analyze performance data. 
USDA appreciates the GAO's acknowledgment of the steps USDA already 
has taken to improve program management. 

Establishing an Improved Monitoring Process: 

The GAO recommends that USDA establish a systematic monitoring process 
that includes analyzing and reporting on a pre-selected set of 
indicators that directly measure the program's progress towards its 
objectives. During the past two years USDA has hired additional staff 
to review project reports and conduct site visits. As a result, USDA 
has increased the number of site visits substantially and has 
established a target of assessing each project in the field at least 
once every two years. USDA also has developed a field monitoring guide 
for staff in order to standardize the results of field monitoring 
trips. USDA will institute a systematic process for choosing which 
projects to visit and will finalize its monitoring guidance. 
	
USDA includes a set of pre-selected indicators in its McGovern-Dole 
program agreements but is currently working through a ROM process to 
improve the measurement of results for learning and health. USDA will 
identify a common set of indicators on which all program participants 
will be required to report. These common indicators will permit more 
effective program management, an assessment of program impact. and 
allows USDA to compare performance across programs. USDA also will 
require performance monitoring plans front program participants. All 
this will he implemented in the FY2012 program cycle. 

Finally, in March USDA launched its new Food Aid Information System 
(FAIS), an integrated online application through which USDA manages 
its food assistance programs and coordinates with program 
participants. Future program participants will he required to submit 
all required reports in FAIS. The new FAIS allows USDA to more easily 
compare and contrast different elements of McGovern-Dole program 
reporting to facilitate discussions regarding project challenges. 
opportunities. and corrective actions. 

Prioritizing Evaluations of Projects: 

USDA is committed to building a sustainable culture of program 
accountability and transparency that fosters learning from experience. 
To support this the Department changed its regulations to require mid-
term and final evaluations on protects. USDA also has drafted a 
monitoring and evaluation policy. That policy outlines the purpose of 
monitoring and evaluation. the range of methods used to monitor and 
evaluate programs (including experimental and quasi-experimental 
methods, roles and responsibilities of USDA and program stakeholders). 
and the ways in which evaluations will he used and disseminated to 
inform decisions regarding program management and implementation. This 
policy will be released by September 2011. 

USDA currently reviews evaluation reports received from McGovern-Dole 
program participants during the closeout process. However, the 
evaluation policies and procedures currently being developed will 
apply to all implementing partners. All evaluation reports will be 
monitored and reviewed by USDA. 

Formalizing Procedures for Closing Out Grants: 

USDA agrees that closing out agreements in a timely manner is 
important to ensure full accountability in all projects. USDA expects 
to close most agreements within 180 days of the receipt of final 
reports and documents. The closeout process does take longer in the 
limited number of cases where it latent issue with an agreement, or a 
return of funds is required. USDA has improved its tracking of the 
closeout process to continue to improve on timeliness. [See comment 1] 

USDA also has set a goal or closing 65 percent of 2003 and 2004 
agreements his September 30, 2011, and is on track to meet this goal.	
In addition, the Monitoring and Evaluation Staff continues to close 
more recent agreements as they are submitted and ready for closure to 
ensure there is no backlog of agreements. USDA will take another look 
at its closeout procedures to seek additional improvements including 
establishing timeframes for organizations to submit required 
documents, and holding those that don't meet deadlines accountable. 
USDA notes that it has never had a backlog of McGovern-Dole agreements 
awaiting closeout. 

USDA thanks GAO for its review of the McGovern-Dole program. All 
comments and recommendations will he taken into account and USDA will 
work to finalize all needed policies and procedures. 

Sincerely. 

Signed by: 

John Brewer: 
Administrator: 
Foreign Agricultural Service: 

The following is GAO's comment on the USDA's letter dated May 4, 2011. 

GAO Comments: 

1. USDA stated that it has never had a backlog of McGovern-Dole 
Program agreements awaiting closeout; however, we found that 15 of 42 
(36 percent) of MGD Program grants awarded before 2008 have completed 
program activities but have not yet been closed by USDA. USDA 
acknowledged the importance of closing out grant agreements in a 
timely manner in order to ensure full accountability in projects, and 
stated that it expects to close out agreements within 180 days of the 
receipt of the final reports and documents. 

[End of section] 

Appendix IX: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Thomas Melito, (202) 512-9601 or melitot@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Phillip Thomas, Assistant 
Director; Barbara Shields, Analyst-in-Charge; Sada Aksartova; Ming 
Chen; Debbie Chung; Martin De Alteriis; Marissa Dondoe; Tanya Doriss; 
Mark Dowling; Daniel Egan; Etana Finkler; Fang He; Glenn Slocum, and 
Adam Vogt made key contributions to this report. Other contributors 
include Kenneth Bulle, Lynn Cothern, Karen Deans, Julie Hirshen, Joy 
Labez, Jeremy Latimer, Armetha Liles, Taylor Nelson, Julia Roberts, 
Cristina Ruggiero, Ellery Scott, Cynthia Taylor, Celia Thomas, and 
Melissa Zoock. 

[End of section] 

Related GAO Products: 

International Food Assistance: Better Nutrition and Quality Control 
Can Further Improve U.S. Food Aid. [hyperlink, 
http://www.gao.gov/products/GAO-11-491]. Washington, D.C.: May 12, 
2011. 

Global Food Security: U.S. Agencies Progressing on Governmentwide 
Strategy, but Approach Faces Several Vulnerabilities. [hyperlink, 
http://www.gao.gov/products/GAO-10-352]. Washington, D.C.: March 11, 
2010. 

International Food Assistance: A U.S. Governmentwide Strategy Could 
Accelerate Progress toward Global Food Security. [hyperlink, 
http://www.gao.gov/products/GAO-10-212T]. Washington, D.C.: October 
29, 2009. 

International Food Assistance: Key Issues for Congressional Oversight. 
[hyperlink, http://www.gao.gov/products/GAO-09-977SP]. Washington, 
D.C.: September 30, 2009. 

International Food Assistance: USAID Is Taking Actions to Improve 
Monitoring and Evaluation of Nonemergency Food Aid, but Weaknesses in 
Planning Could Impede Efforts. [hyperlink, 
http://www.gao.gov/products/GAO-09-980]. Washington, D.C.: September 
28, 2009. 

International Food Assistance: Local and Regional Procurement Provides 
Opportunities to Enhance U.S. Food Aid, but Challenges May Constrain 
Its Implementation. [hyperlink, 
http://www.gao.gov/products/GAO-09-757T]. Washington, D.C.: June 4, 
2009. 

International Food Assistance: Local and Regional Procurement Can 
Enhance the Efficiency of U.S. Food Aid, but Challenges May Constrain 
Its Implementation. [hyperlink,
http://www.gao.gov/products/GAO-09-570]. Washington, D.C.: May 29, 
2009. 

USAID Acquisition and Assistance: Challenges Remain in Developing and 
Implementing a Strategic Workforce Plan. [hyperlink, 
http://www.gao.gov/products/GAO-09-607T]. Washington, D.C.: April 28, 
2009. 

Foreign Aid Reform: Comprehensive Strategy, Interagency Coordination, 
and Operational Improvements Would Bolster Current Efforts. 
[hyperlink, http://www.gao.gov/products/GAO-09-192]. Washington, D.C.: 
April 17, 2009. 

Foreign Assistance: State Department Foreign Aid Information Systems 
Have Improved Change Management Practices but Do Not Follow Risk 
Management Best Practices. [hyperlink, 
http://www.gao.gov/products/GAO-09-52R]. Washington, D.C.: November 
21, 2008. 

USAID Acquisition and Assistance: Actions Needed to Develop and 
Implement a Strategic Workforce Plan. [hyperlink, 
http://www.gao.gov/products/GAO-08-1059]. Washington, D.C.: September 
26, 2008. 

International Food Security: Insufficient Efforts by Host Governments 
and Donors Threaten Progress to Halve Hunger in Sub-Saharan Africa by 
2015. [hyperlink, http://www.gao.gov/products/GAO-08-680]. Washington, 
D.C.: May 29, 2008. 

Somalia: Several Challenges Limit U.S. International Stabilization, 
Humanitarian, and Development Efforts. [hyperlink, 
http://www.gao.gov/products/GAO-08-351]. Washington, D.C.: February 
19, 2008. 

Foreign Assistance: Various Challenges Limit the Efficiency and 
Effectiveness of U.S. Food Aid. [hyperlink, 
http://www.gao.gov/products/GAO-07-905T]. Washington, D.C.: May 24, 
2007. 

Foreign Assistance: Various Challenges Impede the Efficiency and 
Effectiveness of U.S. Food Aid. [hyperlink, 
http://www.gao.gov/products/GAO-07-560]. Washington, D.C.: April 13, 
2007. 

Foreign Assistance: U.S. Agencies Face Challenges to Improving the 
Efficiency and Effectiveness of Food Aid. [hyperlink, 
http://www.gao.gov/products/GAO-07-616T]. Washington, D.C.: March 21, 
2007. 

Darfur Crisis: Progress in Aid and Peace Monitoring Threatened by 
Ongoing Violence and Operational Challenges. [hyperlink, 
http://www.gao.gov/products/GAO-07-9]. Washington, D.C.: November 9, 
2006. 

Results-Oriented Government: Practices That Can Help Enhance and 
Sustain Collaboration among Federal Agencies. [hyperlink, 
http://www.gao.gov/products/GAO-06-15]. Washington, D.C.: October 21, 
2005. 

Maritime Security Fleet: Many Factors Determine Impact of Potential 
Limits of Food Aid Shipments. [hyperlink, 
http://www.gao.gov/products/GAO-04-1065]. Washington, D.C.: September 
13, 2004. 

United Nations: Observations on the Oil for Food Program and Iraq's 
Food Security. [hyperlink, http://www.gao.gov/products/GAO-04-880T]. 
Washington, D.C.: June 16, 2004. 

Foreign Assistance: Lack of Strategic Focus and Obstacles to 
Agricultural Recovery Threaten Afghanistan's Stability. [hyperlink, 
http://www.gao.gov/products/GAO-03-607]. Washington, D.C.: June 30, 
2003. 

Foreign Assistance: Sustained Efforts Needed to Help Southern Africa 
Recover from Food Crisis. [hyperlink, 
http://www.gao.gov/products/GAO-03-644]. Washington, D.C.: June 25, 
2003. 

Food Aid: Experience of U.S. Programs Suggest Opportunities for 
Improvement. [hyperlink, http://www.gao.gov/products/GAO-02-801T]. 
Washington, D.C.: June 4, 2002. 

Foreign Assistance: Global Food for Education Initiative Faces 
Challenges for Successful Implementation. [hyperlink, 
http://www.gao.gov/products/GAO-02-328]. Washington, D.C.: February 
28, 2002. 

Foreign Assistance: U.S. Food Aid Program to Russia Had Weak Internal 
Controls. [hyperlink, 
http://www.gao.gov/products/GAO/NSIAD/AIMD-00-329]. Washington, D.C.: 
September 29, 2000. 

Foreign Assistance: U.S. Bilateral Food Assistance to North Korea Had 
Mixed Results. [hyperlink, 
http://www.gao.gov/products/GAO/NSIAD-00-175]. Washington, D.C.: June 
15, 2000. 

Managing for Results: Barriers to Interagency Coordination. 
[hyperlink, http://www.gao.gov/products/GAO/GGD-00-106]. Washington, 
D.C.: March 29, 2000. 

Foreign Assistance: Donation of U.S. Planting Seed to Russia in 1999 
Had Weaknesses. [hyperlink, 
http://www.gao.gov/products/GAO/NSIAD-00-91]. Washington, D.C.: March 
9, 2000. 

Foreign Assistance: North Korea Restricts Food Aid Monitoring. 
[hyperlink, http://www.gao.gov/products/GAO/NSIAD-00-35]. Washington, 
D.C.: October 8, 1999. 

Food Security: Factors That Could Affect Progress Toward Meeting World 
Food Summit Goals. [hyperlink, 
http://www.gao.gov/products/GAO/NSIAD-99-15]. Washington, D.C.: March 
22, 1999. 

Food Security: Preparations for the 1996 World Food Summit. 
[hyperlink, http://www.gao.gov/products/GAO/NSIAD-97-44]. Washington, 
D.C.: November 7, 1996. 

[End of section] 

Footnotes: 

[1] WFP is a part of the United Nations system and is the world's 
largest humanitarian agency addressing hunger worldwide. 

[2] GAO, Foreign Assistance: Global Food for Education Initiative 
Faces Challenges for Successful Implementation, [hyperlink, 
http://www.gao.gov/products/GAO-02-328] (Washington, D.C.: Feb. 28, 
2002). 

[3] This work includes a recently issued GAO report International Food 
Assistance: Better Nutrition and Quality Control Can Further Improve 
U.S. Food Aid, [hyperlink, http://www.gao.gov/products/GAO-11-491] 
(Washington, D.C.: May 12, 2011) and an ongoing review of the 
monetization of U.S. food aid. See page 13 of ]hyperlink, 
http://www.gao.gov/Products/Gao-11-491] for an interactive graphic 
with video illustrating the 3-stage supply chain required to deliver 
U.S. food aid from vendor to village. 

[4] The Millennium Development Goals are eight international 
development goals that United Nations member states agreed in 2000 to 
achieve by 2015. The eight goals are to (1) eradicate extreme poverty 
and hunger; (2) achieve universal primary education; (3) promote 
gender equality and empower women; (4) reduce child mortality rate; 
(5) improve maternal health; (6) combat HIV/AIDS, malaria, and other 
diseases; (7) ensure environmental sustainability; and (8) develop a 
global partnership for development. 

[5] The commodities includes bulgur, vegetable oil, dry beans, corn 
soy blend, rice, canned salmon, cornmeal, flour, wheat, wheat soy 
blend, and soybean meal. 

[6] CCC is a funding mechanism for U.S. farm income support and 
disaster assistance programs. Its activities, including acquisition, 
storage, and disposition of surplus commodities, are carried out 
primarily by personnel of USDA's Farm Service Agency. 

[7] USDA defines an intermediate result as any result below the 
highest level result in the MGD results framework that contributes to 
the achievement of the highest level result. 

[8] USDA defines its education objective as: (1) access, entry, and 
continuation, which includes enrollment and attendance rates; and (2) 
educational progress, which includes student achievement levels 
through improvements in the learning environment, such as teacher 
training, materials and books, etc. 

[9] USDA defines nutrition as the improvement in the food security and 
nutritional status of the target population. 

[10] The international donor community and experts have been placing a 
stronger emphasis on early childhood nutrition and maternal health. 
USDA has also initiated a micronutrient pilot as part of the MGD 
Program to test new products with a potential to improve the health 
and nutrition of school-age children, preschoolers, and mothers. 

[11] USDA defines sustainability/graduation as activities that involve 
host country, community, and other donor contributions that enable the 
project to continue after MGD Program funding ceases. 

[12] USDA regulations allow the agency discretion to exclude United 
Nations agencies from relevant reporting requirements. See 7 CFR 
1599.13, 7 CFR 3019.2(cc). Based on a framework agreement between FAS 
and WFP signed in June 2010, beginning in fiscal year 2012, WFP is 
required to comply with reporting requirements similar to those of the 
NGOs. 

[13] See 7 U.S.C. 1736o-1(j). 

[14] FAS initiated a total of 19 agreements with the NGOs and 12 with 
the WFP during fiscal years 2008 through 2010. To analyze comparable 
information for the WFP and the NGOs, we also reviewed the WFP's 
proposals and country programs for the same period. These agreements 
represent total funding of about $202 million for all years of the 
NGOs' programs and $170 million for the WFP's program. 

[15] The programs in Pakistan planned to provide take-home rations to 
girls and did not have an in-school feeding component. 

[16] WFP indicated that it feeds preschoolers in some additional 
countries even if it has not specified in the agreements and proposals. 

[17] In fiscal year 2006, USDA began funding multiyear agreements that 
enable most of the MGD Program-supported projects to operate for up to 
3 years, without reapplying for funding, providing more time in which 
implementing partners can conduct activities intended to advance the 
projects' sustainability. 

[18] In this case, performance indicators refers to outputs, such as 
number of beneficiaries served, number of meals served, etc., and to 
outcomes, such as the changes in enrollment and attendance that are 
reported by the implementing partners. 

[19] USAID may not have related programs in all the MGD countries; 
therefore, coordination with USAID may not be possible for all 
projects. One implementing partner indicated that it may not report 
all of its coordination with USAID in the documents we reviewed. 

[20] USAID's budget for maternal and child health and nutrition was 
about $549 million in fiscal year 2010. USAID also spent about $7 
million on food for education development programs in 5 countries, 
including 2 MGD Program countries, in fiscal year 2010. 

[21] In May 2010, the administration announced a global food security 
initiative, Feed the Future, which is designed to provide a framework 
for greater interagency coordination. 

[22] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[23] These progress reports include logistics and monetization reports 
submitted by the NGOs and the standard project reports submitted by 
WFP but do not include the project status reports submitted by the 
NGOs, which are discussed below. These reports are also reviewed by 
USDA to verify that the NGO spent the funds as approved in the NGO's 
agreement with USDA. See appendix III for a description of the reports 
implementing partners are required to submit to FAS. We analyzed 8 NGO 
and 6 WFP reports beginning in 2004. 

[24] Education includes educational access and progress. According to 
USDA, indicators for educational access include attendance and 
enrollment. Indicators for educational progress include the number of 
school supplies, the number of teacher trainings, and promotion rates. 

[25] Based on a framework agreement between FAS and WFP signed in June 
2010, beginning in fiscal year 2012, WFP is required to comply with 
reporting requirements similar to those of the NGOs. See appendix III 
for detailed information on implementing partners' reporting 
requirements. 

[26] Based on USDA's categorization, and to be consistent with our 
analysis of NGOs progress reporting, we included output indicators for 
nutrition, such as the number of take-home rations and the number of 
children receiving deworming treatment. 

[27] [hyperlink, http://www.gao.gov/products/GAO-03-143]. 

[28] We examined the 19 agreements that FAS initiated with NGOs and 12 
that it initiated with WFP during fiscal years 2008 through 2010. For 
our analysis of indicators, we reviewed the NGOs' agreements and WFP's 
proposals. 

[29] Agricultural attachés and counselors are USDA foreign 
agricultural service officers stationed in foreign countries to 
provide direction and oversight to all FAS programs and to provide 
support and counsel to other USDA agencies. Their duties include: 
commodity analysis and reporting; strategic results and market access; 
agricultural trade, market promotion, and development; supervision and 
management; and mission support, coordination, and representation. 

[30] Mozambique's USDA FAS staff consists of a locally-hired 
agricultural specialist rather than an attaché. 

[31] WFP funds school feeding in emergency settings of protracted 
relief and recovery operations. 

[32] According to AEA, "such policies and procedures should identify 
the kinds of evaluations to be performed and the criteria and 
administrative steps for developing evaluation plans and setting 
priorities, selecting evaluation approaches and methods to use, 
consulting subject matter experts, ensuring evaluation product 
quality, publishing evaluation reports, ensuring independence of the 
evaluation function, using an appropriate mix of staff and outside 
consultants and contractors, appropriately focusing evaluation designs 
and contracts, and promoting the professional development of 
evaluation staff." See AEA, An Evaluation Roadmap for a More Effective 
Government, 2010. 

[33] USDA officials currently estimate that the required evaluations 
will cost about $50,000 per award. 

[34] According to USDA, single-year MGD Program awards do not require 
an interim evaluation. 

[35] This annual conference, jointly sponsored by USDA and USAID, is 
the largest food aid and agricultural development conference in the 
United States with participants representing the food and agriculture 
industries, maritime and rail transportation, ports, NGOs, as well as 
U.S. and foreign governments. 

[36] WFP defines impact evaluation as an assessment of whether a 
program or an intervention has contributed to lasting and/or 
significant change (positive and/or negative) for individuals, gender 
and age-groups, households, communities and institutions. See WFP, 
Impact Evaluations Concept Note 2010-2011. 

[37] For a discussion of evaluation planning at federal agencies with 
mature evaluation capacity, see [hyperlink, 
http://www.gao.gov/products/GAO-11-176]. 

[38] In the past USDA provided funding for evaluations that were 
proposed by NGOs as part of their MGD Program-supported activities. 
For example, USDA funded third-party assessments of Project Concern 
International's MGD project in Bolivia in 2006 and Catholic Relief 
Services' MGD project in Benin in 2009. While these assessments 
concluded that the NGOs were achieving the MGD Program's goals, they 
varied in their methodological rigor. Whereas the Bolivia study relied 
exclusively on focus groups and interviews with a range of 
stakeholders, the Benin study complemented qualitative findings with 
analyses of quantitative data on a number of indicators, such as 
attendance and enrollment. 

[39] Compliance is responsible for: (1) protecting FAS resources 
against fraud, waste, and abuse; (2) verifying compliance with all 
laws, regulations, and policies controlling FAS programs and 
administration; (3) promoting maximum economy and effectiveness 
throughout FAS; and (4) administering FAS's Security and Emergency 
Preparedness Programs. 

[40] The Food for Progress program, authorized by the Food for 
Progress Act of 1985, provides for the donation or credit sale of U.S. 
commodities to developing countries and emerging democracies to 
support democracy and the expansion of private enterprise. The 
commodities donated through Food for Progress may be sold in the 
recipient country and the proceeds may be used to support 
agricultural, economic, or infrastructure development programs. 

[41] Monetization is the practice of selling commodities to generate 
cash resources for development projects. Some MGD Program grant 
agreements allow the NGO to sell USDA-provided commodities to generate 
revenue for program implementation. 

[42] Financial compliance reviews are separate from programmatic 
monitoring visits and therefore are not counted in the visits 
discussed in the earlier section on monitoring. 

[43] The Single Audit Act requires states, local governments, and 
nonprofit organizations expending $500,000 or more in federal awards 
in a year to obtain an audit in accordance with the requirements set 
forth in the act. A Single Audit consists of (1) an audit and opinions 
on the fair presentation of the financial statements and the Schedule 
of Expenditures of Federal Awards; (2) gaining an understanding of and 
testing internal control over financial reporting and the entity's 
compliance with laws, regulations, and contract or grant provisions 
that have a direct and material effect on certain federal programs 
(i.e., the program requirements); and (3) an audit and an opinion on 
compliance with applicable program requirements for certain federal 
programs. For a description of these reports, see appendix III. 

[44] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[45] See appendix III for a description of the reports that 
implementing partners are required to submit to USDA. As noted 
previously, WFP does not submit the same reports to USDA as the NGOs. 
Thus, the closeout procedure for WFP is different. USDA closes out a 
WFP agreement when all budgeted funds are spent or when WFP notifies 
USDA that no further payments under the agreement are required. 

[46] GAO, Grants Management: Attention Needed to Address Undisbursed 
Balances in Expired Grant Accounts, [hyperlink, 
http://www.gao.gov/products/GAO-08-432] (Washington, D.C.: Aug. 29, 
2008). 

[47] Foreign Agricultural Service Private Voluntary Organization Grant 
Fund Accountability: no. 07016-1-At (issued March 2006) and Foreign 
Agricultural Service Implementation of the Trade Title of the 2002 
Farm Bill and the 2002 President's Management Agenda: no. 50601-12-At 
(issued March 2007). 

[48] In response to the OIG's reports, USDA engaged a public 
accounting firm to conduct a review of FAS's internal controls. The 
firm's report was released in July 2009 and corroborated the OIG's 
findings. 

[49] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: Nov. 1999). 

[50] GAO, Performance Measurement and Evaluation: Definitions and 
Relationships, [hyperlink, http://www.gao.gov/products/GAO-05-739SP] 
(Washington, D.C.: May, 2005). GAO, Tax Administration: IRS Needs to 
Further Refine Its Tax Filing Season Performance Measures, [hyperlink, 
http://www.gao.gov/products/GAO-03-143], (Washington, D.C.: Nov. 22, 
2002). GAO, Program Evaluation: Experienced Agencies Follow a Similar 
Model for Prioritizing Research, [hyperlink, 
http://www.gao.gov/products/GAO-11-176] (Washington, D.C.: Jan. 2011). 
GAO, International Food Assistance: USAID Is Taking Actions to Improve 
Monitoring and Evaluation of Nonemergency Food Aid, but Weaknesses in 
Planning Could Impede Efforts, [hyperlink, 
http://www.gao.gov/products/GAO-09-980] (Washington, D.C.: Sept. 28, 
2009). 

[51] We combined the NGO agreements for Liberia in fiscal years 2009 
and 2010 because we determined that the 2010 agreement represented a 
modification of the prior agreement. 

[52] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[53] Foreign Agricultural Service Private Voluntary Organization Grant 
Fund Accountability: no. 07016-1-At (issued March 2006) and Foreign 
Agricultural Service Implementation of the Trade Title of the 2002 
Farm Bill and the 2002 President's Management Agenda: no. 50601-12-At 
(issued March 2007). 

[54] These studies evaluated programs focused on primary school aged 
children in developing countries in field settings and examined the 
effect of these programs on education and/or health and/or 
sustainability outcomes. In addition, these studies also focused on 
programs that provided either in-school meals or take-home rations. 
Studies only assessing the impact of micronutrient fortification were 
not included. 

[55] The summary of selected studies on school feeding was conducted 
by one economist at GAO and then independently reviewed by two other 
economists at GAO who concurred with the analysis presented here. 

[56] The total amount appropriated for the MGD Program ($931 million) 
includes amounts funded through the Commodity Credit Corporation since 
2003. 

[End of section] 

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