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International Food Assistance: USAID Has Controls for Implementation and Support Costs but Should Strengthen Financial Oversight

GAO-17-224 Published: Mar 09, 2017. Publicly Released: Apr 10, 2017.
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Fast Facts

USAID spent about $1.4 billion in fiscal year 2016 on international food aid projects under the Food for Peace Act. These funds have traditionally been used to buy food in the United States and transport it abroad. In addition, USAID also spends some of this money on implementation and support costs, such as storing food in warehouses and—in recent years—providing cash and food vouchers to individuals.

We found that USAID could enhance its financial oversight of these implementation and support costs. We recommended that the agency conduct financial reviews, collect monitoring data, and assess risks to ensure that these funds are used properly.

Warehouse Workers Packaging Food Aid for Beneficiaries in Haiti

Two photos of food aid workers in Haiti.

Two photos of food aid workers in Haiti.

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Highlights

What GAO Found

The U.S. Agency for International Development (USAID) has used most of the 2014 Farm Bill's increase in authorized funding for section 202(e) of the Food for Peace Act to provide cash transfers, food vouchers, and locally or regionally procured food—modalities not previously supported through Title II. Of the additional authorized funding that the agency utilized, USAID obligated 75 percent in fiscal year 2014 and 96 percent in fiscal year 2015 for these modalities. In addition, to better meet beneficiaries' needs, USAID has increasingly used funds from accounts authorized by the Foreign Assistance Act, along with 202(e) funding, to implement and support projects—costs that 202(e) funding has typically covered. Also, in some cases, USAID has used funds from those accounts along with 202(e) funding to provide cash transfers, food vouchers, or local or regional procurement in a single project.

Warehouse Workers Packaging Food Aid for Beneficiaries in Haiti

Warehouse Workers Packaging Food Aid for Beneficiaries in Haiti

USAID and its partners have various controls for financial oversight of Title II funding used for implementation and support costs; however, GAO found certain deficiencies in USAID's oversight. USAID reviews partners' detailed planned budgets for these costs and high-level quarterly financial reports, according to USAID officials, but it generally has not conducted systematic, targeted financial reviews of partners' actual spending on these costs. While GAO found that partners' internal controls generally included policies and procedures to help ensure proper use of funds, GAO's limited, nongeneralizable financial transactions testing identified instances of misspending, such as charging a 202(e) cost to one project that should have been charged to another. Also, USAID has not obtained key monitoring data from partners related to these costs that could identify areas needing additional financial oversight. Moreover, USAID does not require partners to conduct comprehensive assessments of financial and fraud risks for cash transfers and food vouchers in development projects, although it requires risk assessments for emergency projects. GAO found that partners for selected development projects provided broad discussions of risk to USAID but did not provide comprehensive risk assessments. As a result, USAID is limited in its ability to ensure that partners are spending funds as planned.

Why GAO Did This Study

In recent years, USAID has awarded about $1.4 billion annually for international food assistance projects under Title II of the Food for Peace Act (Title II). This funding has traditionally been used to provide U.S.-purchased commodities to food-insecure beneficiaries overseas. Section 202(e) of the Food for Peace Act authorizes USAID to also provide funding to cover project implementation costs, which have typically included administrative expenses such as implementing partner staff salaries. The Agricultural Act of 2014 (2014 Farm Bill) increased the amount of 202(e) funding USAID can use for implementation costs from 13 to 20 percent of the annual Title II appropriation and also expanded the eligible uses of these funds. USAID's utilization of these new authorities presents potential oversight challenges.

GAO was asked to review Title II implementation costs. This report examines (1) any changes in USAID's use of Title II funding to implement and support projects since the 2014 Farm Bill and (2) USAID's financial oversight of this funding for selected projects. GAO analyzed USAID funding data for fiscal years 2012 through 2015 (the most recent available), reviewed USAID and partner documents, and interviewed officials. GAO conducted financial reviews of a nongeneralizable sample of seven Title II projects, selected on the basis of project funding and implemented modalities.

Recommendations

GAO is making five recommendations to USAID—for example, to conduct financial reviews, collect monitoring data, and assess risks. USAID concurred with the recommendations.

Recommendations for Executive Action

Agency Affected Recommendation Status
U.S. Agency for International Development
Priority Rec.
To enhance USAID's financial oversight of implementing partners' spending to implement and support Title II development and emergency projects, the USAID Administrator should develop, document, and implement a process for periodically conducting systematic, targeted financial reviews of Title II development and emergency projects. Such reviews should include efforts to verify that actual costs incurred for these projects align with planned budgets.
Closed – Implemented
USAID agreed with the recommendation and has implemented corrective actions to resolve the cited deficiency. In response to the recommendation, December 2017, USAID informed us that it planned to conduct a limited number of systematic, targeted financial reviews in FY 2018, and that it planned to establish a compliance/review team to undertake these reviews in an ongoing basis in the future. In April 2019, USAID informed us that it had hired a grants auditor who will lead the financial review efforts. Between March 2019 and March 2020, USAID provided documentation of its procedures for selecting projects and for conducting these reviews, as well as evidence, including final reports, for four reviews that it had conducted for Title II development and emergency projects in fiscal years 2018 and 2019.
U.S. Agency for International Development To enhance USAID's financial oversight of implementing partners' spending to implement and support Title II development and emergency projects, the USAID Administrator should ensure that its requirements for implementing partners to provide monitoring data on an ongoing basis on the use of 202(e) funding for cash transfers, food vouchers, and local and regional procurement are consistent for Title II development and emergency projects.
Closed – Implemented
In March 2017, GAO reported that the U.S. Agency for International Development (USAID) lacked consistent requirements for development and emergency project partners to report monitoring data on their use of Section 202(e) funding-which may be used to implement and support food aid projects-for cash transfers, food vouchers, and local and regional procurement under Title II of the Food for Peace Act. GAO recommended that the USAID Administrator establish consistent requirements for Title II development and emergency projects. USAID agreed with the recommendation and has implemented corrective actions to resolve the cited deficiencies. In particular, in response to GAO's recommendation, USAID developed a revised cooperative agreement template in fiscal year 2017 for Title II development projects that includes required reporting on cash transfers, food vouchers, and local and regional procurement. In addition, USAID developed a new award template with similar monitoring reporting requirements for Title II emergency projects implemented by the World Food Program. USAID also provided support that it incorporated the new reporting requirements into cooperative agreements for implementing partners for two Title II development projects and into a Title II award for the World Food Program in fiscal year 2018. Taking these steps will provide USAID with more complete and consistent information across projects, to inform budget decisions and financial oversight of the Title II program.
U.S. Agency for International Development
Priority Rec.
To enhance USAID's financial oversight of implementing partners' spending to implement and support Title II development and emergency projects, the USAID Administrator should take steps to ensure that it collects complete and consistent monitoring data from implementing partners for Title II development and emergency projects on the use of 202(e) funding for cash transfers, food vouchers, and local and regional procurement as well as data on the use of Title II funding for internal transportation, storage, and handling (ITSH) costs, in accordance with established requirements.
Closed – Implemented
USAID developed a revised cooperative agreement template in fiscal year 2017 for Title II development awards, which requires programs to provide quarterly performance reports on actual cash transfers, food vouchers, and local and regional procurement activities, as well as to report on ITSH costs. USAID also developed a new World Food Program (WFP) emergency award template with similar reporting requirements. In response to our recommendation, in October 2017 and February 2018, USAID provided support that it had developed training and updated oversight staff roles and responsibilities to help ensure that complete and consistent monitoring data is collected for Title II development and emergency projects. Since then, USAID provided documentation to support that it has collected complete and consistent data, in accordance with its requirements, for two Title II development projects. USAID also provided documentation to support that it has collected required data for emergency projects implemented by the WFP. This monitoring data can be used to help inform USAID's budget decisions and identify any areas needing additional financial oversight for implementation and support costs within and across Title II food assistance projects.
U.S. Agency for International Development To enhance USAID's financial oversight of implementing partners' spending to implement and support Title II development and emergency projects, the USAID Administrator should update key guidance and systems to consistently reflect allowable uses of ITSH funds in Title II development and emergency projects.
Closed – Implemented
USAID agreed with the recommendation and has implemented corrective actions to resolve the cited deficiencies. In response to GAO?s recommendation, USAID updated its guidance and Food for Peace Management Information System (FFPMIS) to align with allowable uses of ITSH funds. For example, in December 2017 USAID finalized and distributed updated information bulletins outlining eligible uses of ITSH funds, specifying that costs related to local and regional procurement are not permitted to be paid for with ITSH funds. Additionally, USAID updated FFPMIS to prevent ITSH funds from being requested to support local or regional procurement cots costs and to allow for implementing partners to request funding specifically for transportation, storage, and distribution costs through other sources.
U.S. Agency for International Development To enhance USAID's financial oversight of implementing partners' spending to implement and support Title II development and emergency projects, the USAID Administrator should establish a requirement for Title II development project partners to conduct and document comprehensive risk assessments and mitigation plans for cash transfers and food vouchers funded by 202(e), and take steps to ensure that implementing partners adhere to the requirement.
Closed – Implemented
In March 2017, GAO reported that the U.S. Agency for International Development (USAID) does not require implementing partners for Title II development food aid projects to conduct and document comprehensive risk assessments and mitigation plans for cash transfer and food vouchers funded by Section 202(e) in Title II of the Food for Peace Act, despite requiring risk assessments for these modalities in emergency food aid projects implemented by NGOs. GAO recommended that the USAID Administrator establish a requirement for Title II development project partners to conduct and document comprehensive risk assessments and mitigation plans for cash transfers and food vouchers funded by 202(e), and take steps to ensure that implementing partners adhere to the requirement. USAID agreed with the recommendation and has implemented corrective actions to resolve the cited deficiencies. In response to GAO's recommendation, USAID established a requirement for Title II development project partners to conduct and document comprehensive risk assessments and mitigations plans for cash transfers and food vouchers, and has taken steps to ensure that implementing partners adhere to the requirement. For example, in April 2017 USAID issued a request for applications for a Title II development food aid project which required partners to complete an analysis of risks and mitigation measures, including those related to cash transfers and food vouchers. The awardee included such assessments and plans in its application. In addition, in September 2018, USAID entered into a cooperative agreement for a Title II development project with another implementing partner, which provided a comprehensive risk assessments and mitigation plan to address potential cash transfer and food voucher misuse.

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Topics

BeneficiariesFederal fundsForeign assistanceInternal controlsInternational food programsCommoditiesCompliance oversightFederal spendingFood assistance programsInternational food assistance