NCA Response – USDA Reorganization Plan

NCA’s Response to USDA Plan to Relocate Staff from DC Area to Five Hubs

NCA appreciates USDA’s goal to bring USDA closer to the people they serve and create more opportunity for Child Nutrition Program operators to communicate directly with USDA. However, NCA is concerned that USDA will not be able to maintain the same level of staffing and support through the reorganization process. By relocating over half of USDA’s NCR staff (65%), there will also be a high risk of attrition among long-time FNS employees with critical institutional knowledge and programmatic expertise. It is crucial that FNS maintain current staffing levels in order to ensure key functions of FNS go uninterrupted, such as USDA rulemaking, guidance and resource creation, and timely technical assistance.

The Secretary’s memorandum states that the department has already lost over 15,364 employees through the deferred resignation process. This significant loss of staff is already placing a strain on existing USDA employees which has resulted in a delay in responses to State agencies and Child Nutrition Program operators. Any further reduction in staff, as a result of relocation, could be harmful to the integrity of Child Nutrition Programs.

In 2019, USDA relocated the Economic Research Service (ERS) and the National Institute of Food and Agriculture (NIFA) from the NCR to Kansas City, Missouri. A report from the United States Government Accountability Office (GAO) describes how this relocation affected ERS and NIFA human resources and productivity. The report states that, “the agencies lost over half of their staff, with vacancies in key positions,” following their relocation. GOA also reported that the decline in managerial roles impacted the agencies’ ability to make hiring decisions. In addition, GAO outlines how the relocation of the agencies resulted in a loss of experienced staff, creating a shift in institutional knowledge. Prior to relocation, GAO estimates that 84% of ERS staff and 82% of NIFA staff had been permanently employed for more than 2 years, however after relocation only 34% of ERS and 21% of NIFA had been employed for more than 2 years. As a result, the vast majority of staff were new to the agencies, which likely caused a lag in historical and programmatic knowledge within the agencies.

The GAO also reported that after two years, the “agencies’ workforce size and productivity had largely recovered.” However, from NCA’s experience, it takes two years for a person to learn all of the intricacies and truly understand the CACFP. Therefore, if this relocation results in a two year lag in hiring, followed by two years of training for staff to be fully versed in Child Nutrition Programs, FNS will be lacking a comprehensive staff with programmatic knowledge for up to four years.

The relocation of ERS and NIFA in 2019 is a clear case study that can be a map for what will potentially happen should USDA move forward with its Agency-wide relocation plan. USDA cannot risk the potential loss of half its staff, subsequent lag in hiring, and major loss of institutional and programmatic knowledge. This could have negative effects on the successful operation of Child Nutrition Programs.

 

NCA’s Response to USDA Plan to Reduce Regions from Seven to Five

FNS Regional Offices (FNSRO) are key to the success of Child Nutrition Programs, by working directly with States in their region to provide technical assistance and support and communicating with the USDA national office to enforce and provide guidance on federal program requirements. FNSROs are also responsible for approving State requests to add State-level regulations and flexibilities, as well as ensuring that States do not create overly burdensome administrative requirements for Child Nutrition Programs.

By reducing FNS regions from seven to five, each FNSRO will be responsible for the oversight of a larger number of States. As regions are redrawn, there will likely be a significant lag in communication between FNSROs and State agencies as staff are reallocated, leadership structures are recreated, new communication channels are set up and points of contact are redetermined. This relocation also poses the threat of further attrition of FNSRO staff which will result in a larger workload on remaining staff members – limiting their availability to provide timely responses and technical assistance to State agencies.

The suggested hub locations for the five regional offices are also of concern. Only one of the five hubs is in a State where a current FNSRO is located, meaning that nearly all FNSRO staff will have to relocate to a different State. Relocation of such magnitude will be costly and time-consuming and could result in further delays in communication between FNSROs and State agencies. There will also likely be a reduction in FNSRO workforce as staff choose not to uproot their families. This attrition will result in a loss of institutional knowledge and expertise. The process for replacing these staff could also take a long time, leaving key rolls empty and putting Child Nutrition Program integrity at risk.

In addition, the five hub locations are not sufficiently distributed across the United States. Multiple of the current USDA regions will no longer have an office in their area. For instance, there will be no hubs in the current Northeast, Mid-Atlantic, or Western regions – which represent 13%, 10%, and 19% of CACFP operators respectively. On the other hand, there will be two hubs in the current Mountain Plains Region (representing 7% of CACFP operators), and one in each of the Southeast, Midwest Region, and Southwest Regions. The States selected for the regional hubs are not States with the highest number of CACFP operators: North Carolina ranks 12th, Indiana 19th, Missouri 24th, Colorado 30th, and Utah ranks 31st (see Appendix A). If USDA is true to its goal of “ensuring USDA is located closer to the people it serves,” then these hub locations do not achieve this goal in regard to Child Nutrition Programs which are more dispersed throughout the country.