TRADE 

ADJUSTMENT

ASSISTANCE

USDA Has Enhanced 

Technical Assistance 

for Farmers and 

Fishermen, but Steps 

Are Needed to Better 

Evaluate Program 

Effectiveness

Report to Congressional Committees

July 2012

GAO-12-731

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-731, a report to 

congressional committees 

July 2012 

TRADE ADJUSTMENT ASSISTANCE 

USDA Has Enhanced Technical Assistance for 

Farmers and Fishermen, but Steps Are Needed to 

Better Evaluate Program Effectiveness

Why GAO Did This Study

Agricultural imports—including imports 

of fruit, vegetables, seafood, and other 

commodities that directly compete with 

U.S. products—have more than 

doubled over the last decade, 

according to data from USDA. The 

department’s TAA for Farmers 

program provides technical and 

financial assistance to producers of 

commodities certified by USDA as 

eligible for assistance. The Trade and 

Globalization Adjustment Assistance 

Act of 2009 reauthorized and amended 

the program and directed GAO to 

prepare and submit a report on the 

operation and effectiveness of the 

amendments. In particular, GAO 

examined (1) the commodities and 

producers USDA approved for 

assistance and the type and amount of 

assistance it provided, and (2) the 

approach USDA is taking to evaluate 

the program’s effectiveness and 

limitations, if any, in this approach. 

GAO analyzed USDA data and 

documents; interviewed USDA 

officials, their academic partners, 

producer groups, and commodity 

experts; and conducted fieldwork in 

two states to meet with producer 

groups for certified commodities. 

What GAO Recommends

GAO recommends that, as part of any 

future TAA for Farmers program 

funding, USDA require spouses 

applying for assistance to submit 

documentation on how they contribute 

to producing a commodity, take steps 

to help ensure the program’s financial 

assistance is used for the intended 

purpose, and broaden its program 

evaluation approach. USDA generally 

agreed with the recommendations.

What GAO Found

The U.S. Department of Agriculture (USDA) certified relatively few commodities 

under its Trade Adjustment Assistance (TAA) for Farmers program, as 

reauthorized by the Trade and Globalization Adjustment Assistance Act of 2009, 

but provided assistance to most individual farmers and fishermen who produced 

certified commodities and applied for assistance. Specifically, USDA certified 5 of 

the 18 commodities for which it received petitions. As of April 2012, USDA 

approved 9,852, or about 90 percent, of the applicants who produced a certified 

commodity to participate in the program. In addition, out of the $202.5 million in 

appropriations for the reauthorized program, USDA paid nearly $50 million in 

financial assistance to help producers implement long-term business plans in 

order to become more competitive. GAO identified two issues regarding USDA’s 

process for approving applications from spouses of producers and providing 

financial assistance: 

• USDA determined that producers’ spouses also shared in the risk of 

producing a commodity and could thus separately apply for assistance as 

individual producers. However, unlike other producers, spouses did not need 

to submit documentation showing how they contributed to and shared in the 

risk of production. USDA officials said they disapproved applications if 

spouses voluntarily disclosed that they did not contribute to producing a 

commodity but they likely approved applications from other spouses who 

similarly did not contribute. As a result, USDA did not have assurance that it 

targeted assistance to individuals who shared in the risk of production.

• USDA made financial assistance payments without requiring producers to 

show that the assistance would be used for the intended purpose. Under the 

2009 legislation, payments for completion of approved long-term business 

plans are to be used to implement the plans, but approval of plans was not 

contingent on producers documenting how payments would be used. USDA

officials said they received feedback that led them to believe that some 

producers used payments for unrelated expenses, such as housing costs. 

USDA’s approach to evaluating the TAA for Farmers program relies on 

performance measures and a series of surveys administered to producers. This 

approach provides USDA with data on producers’ completion of program 

requirements and perceptions of effectiveness, but the approach has several 

limitations that hinder USDA’s ability to fully determine the extent to which the 

program as a whole is effective. In particular, the performance measures do not 

measure outcomes, such as the percentage of producers who are able to remain 

in business. Leading practices indicate that outcome-oriented goals and 

quantifiable performance measures are important tools to determine if a program 

is achieving intended results. In addition, the time frame for administering the 

surveys is too short to gather producers’ perceptions of long-term effectiveness. 

Moreover, the surveys provide little information on producer perceptions of the 

program’s financial assistance, and USDA has not corroborated survey results by 

collecting data to help determine whether improvements in producers’ conditions 

are due to the program or some external factor. It can be difficult to isolate the 

causal impact of programs from other influences on outcomes, but the use of 

multiple sources of data can help overcome this challenge. 

View GAO-12-731. For more information, 

contact Lisa Shames at (202) 512-3841 or 

shamesl@gao.gov. 
Page i GAO-12-731 Trade Adjustment Assistance

Letter 1 

Background 4

USDA Certified Relatively Few Commodities but Has Provided 

Assistance to Most Covered Applicants 8

USDA’s Program Evaluation Approach Relies on Performance 

Measures and Surveys That Do Not Fully Assess Effectiveness 16

Conclusions 20

Recommendations for Executive Action 21

Agency Comments and Our Evaluation 22

Appendix I Scope and Methodology 24

Appendix II Commodities Certified and Denied for TAA for Farmers Assistance 27

Appendix III Technical and Financial Assistance Provided to Producers 

Approved for TAA for Farmers Assistance 30

Appendix IV Comments from the U.S. Department of Agriculture 33

Appendix V GAO Contact and Staff Acknowledgments 36

Tables

Table 1: USDA’s Use of $202.5 Million in Trade and Globalization 

Adjustment Assistance Act of 2009 Appropriations for the 

TAA for Farmers Program 14

Table 2: Commodities Certified for Assistance under the 2009 

Reauthorization of the TAA for Farmers Program 27

Table 3: Basis Cited by FAS for Denying Commodities under the 

2009 Reauthorization of the TAA for Farmers Program 28

Table 4: Number of TAA for Farmers Applicants as of April 2012, 

by Certified Commodity and Application Status 30

Table 5: Financial Assistance Provided to Producers as of April 

2012, by Certified Commodity (Dollars in Millions) 31

Contents
Page ii GAO-12-731 Trade Adjustment Assistance

Figures

Figure 1: USDA Agency Roles in TAA for Farmers Program 7

Figure 2: Commodities and Geographic Areas Certified as Eligible 

for or Denied TAA for Farmers Assistance 9

Abbreviations

FAS Foreign Agricultural Service 

GPRA Government Performance and Results Act of 1993, as 

amended

NIFA National Institute of Food and Agriculture 

Recovery Act American Recovery and Reinvestment Act of 2009 

TAA Trade Adjustment Assistance 

USDA U.S. Department of Agriculture

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-12-731 Trade Adjustment Assistance

United States Government Accountability Office 

Washington, DC 20548

July 12, 2012

The Honorable Max Baucus

Chairman

The Honorable Orrin G. Hatch

Ranking Member

Committee on Finance

United States Senate

The Honorable Dave Camp

Chairman

The Honorable Sander Levin

Ranking Member

Committee on Ways and Means

House of Representatives

Data from the U.S. Department of Agriculture (USDA) show that 

agricultural imports have more than doubled over the last decade. 

According to these data, the imports include fruit, vegetables, seafood, 

and other commodities that directly compete with U.S. agricultural 

products. USDA’s Trade Adjustment Assistance (TAA) for Farmers 

program offers assistance to farmers and fishermen hurt by competition 

from such imports. In particular, the program provides help to individual 

producers of raw agricultural commodities, such as farmers and 

fishermen, to become more competitive in producing their current 

commodity or transitioning to a different commodity.1

Producers apply for TAA for Farmers assistance through a two-step 

process, which USDA publicizes through its website, news releases, and 

other means when funding to implement the program is available. First, a 

group of producers of a particular commodity, or an association that 

represents producers, must submit a petition for certification of eligibility 

for assistance. Petitions cover all producers of that commodity in the 

United States or in one or more specifically identified states. Petitions 

must be submitted within the filing period announced by USDA and 

provide supporting information, such as national data showing that the 

commodity’s price declined in the most recent year for which such data 

 

1

In this report, we refer to both farmers and fishermen as producers.

 
 

Page 2 GAO-12-731 Trade Adjustment Assistance

are available. Second, after USDA certifies a commodity as eligible, any 

producer of the commodity who is interested in participating in the 

program must apply for assistance within 90 days of the certification. The 

benefits of the program include both technical and financial assistance. 

The technical assistance, which must be completed within the 3-year 

period following a commodity’s certification, includes a minimum of 12 

hours of training geared toward improving producers’ competitiveness, as 

well as assistance in developing business plans. Individuals who 

complete approved business plans are entitled to receive payments of up 

to $12,000 to help them implement the plans.

The TAA for Farmers program was established by the Trade Act of 2002, 

which appropriated funding for the program at $90 million per year for 

fiscal years 2003 through 2007. In December 2006, we reported that the 

criteria for program eligibility were difficult for many producers to meet 

and that USDA spending for the program was well below the amount 

provided for by the Trade Act.2

The Trade and Globalization Adjustment Assistance Act of 2009, which 

was enacted as part of the American Recovery and Reinvestment Act of 

2009 (Recovery Act), reauthorized and amended the program.

We also reported that the program’s 

technical and financial assistance appeared to assist producers in 

adjusting to the effects of import competition on a limited, short-term 

basis. Funding for the program lapsed in fiscal year 2008.

3

 

Appropriations for the reauthorized program were $90 million per year in 

fiscal years 2009 and 2010 and $22.5 million for the first quarter of fiscal 

year 2011.4

 

2

GAO, Trade Adjustment Assistance: New Program for Farmers Provides Some 

Assistance, but Has Had Limited Participation and Low Program Expenditures, 

USDA accepted petitions and certified commodities under the 

reauthorized program in 2010 and later that year began providing 

assistance to producers of certified commodities. These producers have 

until 2013 to complete the program’s technical assistance. The Trade 

Adjustment Assistance Extension Act of 2011 reauthorized the program 

GAO-07-201 (Washington, D.C.: Dec. 18, 2006).

3

The Trade and Globalization Adjustment Assistance Act of 2009, Pub. L. No. 111-5, div. 

B, tit. I, subtit. I, 123 Stat. 367, 367-423. 

4

The Omnibus Trade Act of 2010 also appropriated $10.4 million for the program for the 6-

week period from January 1, 2011, to February 12, 2011, but USDA did not use this 

funding because it determined that it was not able to certify petitions for assistance within 

a 6-week time frame.
 

Page 3 GAO-12-731 Trade Adjustment Assistance

through the first quarter of fiscal year 2014 but did not appropriate funds. 

USDA is continuing to spend funds to complete the program as 

reauthorized in 2009 but does not have funding to accept additional 

petitions for certification of commodities and continue the program.

The 2009 legislation mandated that GAO prepare and submit a report on 

the operation and effectiveness of the amendments to the TAA for 

Farmers program. In response, we examined (1) the commodities and 

producers that USDA approved for assistance under the program as 

reauthorized in 2009 and the type and amount of assistance it provided 

and (2) the approach USDA is taking to evaluate the program’s 

effectiveness and limitations, if any, in this approach.

To examine the commodities and producers USDA approved for 

assistance and the type and amount of assistance it provided, we 

reviewed four key areas of the TAA for Farmers program as amended: 

the commodity certification process, the producer application process, 

technical assistance, and financial assistance. In particular, for 

commodity certification, we reviewed the criteria established by the 2009 

legislation for USDA to use when certifying commodities, petitions 

submitted by groups of commodity producers, and USDA’s 

documentation explaining the basis for its decisions to certify or deny 

commodities. We examined the producer application process by 

reviewing eligibility requirements for individual producers of certified 

commodities and USDA data on applications from individual producers, 

including the numbers approved and disapproved and the reasons for 

disapproval. We examined the amount of technical and financial 

assistance USDA provided to approved producers by reviewing data from 

USDA. We assessed the reliability of USDA data by checking for obvious 

errors in accuracy and completeness and through other means. We 

determined that the data were sufficiently reliable for reporting on the 

number of approved and disapproved applicants and the amount of 

technical and financial assistance provided to producers.

To examine the approach USDA is taking to evaluate the program’s 

effectiveness and to identify any limitations in this approach, we reviewed 

USDA’s performance measures for the program, and we analyzed 

surveys of producers participating in the program and preliminary survey 

results as of December 2011. We compared USDA’s approach to 

principles for evaluating the effectiveness of programs, such as those 

embodied in the Government Performance and Results Act of 1993, as 

amended (GPRA), GAO guidance on designing evaluations, and federal 

standards for internal control.
 

Page 4 GAO-12-731 Trade Adjustment Assistance

For further explanation regarding both of our objectives, we interviewed 

USDA officials, USDA’s academic partners for organizing and overseeing 

the program’s technical assistance, and a nonprobability sample of 

producer groups that submitted petitions. Because we selected a 

nonprobability sample of producer groups to interview, the information we 

obtained from these interviews cannot be generalized to other groups. 

The interviews instead provided us with the perspectives of various 

producer groups about the program. We also interviewed the USDA 

Office of the Inspector General team conducting a separate review of the 

TAA for Farmers program. We planned our audit to minimize duplication 

in areas evaluated by the Office of Inspector General, such as USDA 

internal controls over the application of eligibility requirements for 

individual producers. Appendix I presents a more detailed description of 

the scope and methodology of our review.

We conducted this performance audit from September 2011 to July 2012 

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.

In its amendments to the TAA for Farmers program, the Trade and 

Globalization Adjustment Assistance Act of 2009 changed the program in 

four key areas:

• Commodity certification. The act changed the criteria for groups of 

commodity producers to demonstrate they had been harmed by import 

competition and for USDA to certify commodities. Prior to the 

amendments, USDA certified a commodity if (1) imports of a “like or 

directly competitive” commodity—that is, imports that are substantially 

identical in inherent or intrinsic characteristics or substantially 

equivalent for commercial purposes—had increased and (2) the 

average price of the commodity submitted for certification decreased by 

more than 20 percent compared to the average of the previous 5 years. 

If these two criteria were met, USDA had to determine that the imports 

contributed importantly to the decrease in price, with “contributed 

importantly” defined by the TAA for Farmers legislation as a cause that 

is important but not necessarily more important than any other cause. 

Under the 2009 reauthorization, imports must have increased 

compared to the average of the previous 3 years. In addition, the act 

Background
 

Page 5 GAO-12-731 Trade Adjustment Assistance

lowered the threshold for a decrease in price to more than 15 percent 

compared to the average of the previous 3 years. Furthermore, the act 

allowed groups of commodity producers to demonstrate harm on the 

basis of a more than 15 percent decrease in any one of three factors 

other than price: quantity of production, value of production, and cash 

receipts. The act retained the criterion for an increase in imports to 

have contributed importantly to a commodity’s harm.

• Producer application. The act eliminated a requirement that a 

producer of a certified commodity experience a decline in net farm 

income. The act instead required a producer to have produced the 

commodity in the year covered by a certification and in at least 1 of 

the 3 years preceding the certification. In addition, the act required a 

producer to demonstrate a decrease in the individual producer’s 

production quantity, or a decrease in the commodity’s price—either 

the actual price received by the producer or the average price at the 

local level. Moreover, the act required that individual producers’ 

applications for assistance include sufficient information to establish 

that a producer is not receiving benefits under another TAA for 

Farmers petition or under related TAA programs for workers or firms.

• Technical assistance. The act modified the technical assistance 

benefit that the program provides to eligible producers, which 

previously consisted of a workshop and counseling to improve 

competitiveness and profitability. Specifically, the act provided for a 

series of courses to help producers become more competitive in 

producing their current commodity or to transition to producing 

another commodity, and it required that eligible producers complete 

initial and long-term business plans before receiving financial 

assistance. The act specified that for an initial business plan to be 

approved, it must reflect the skills producers gained through the 

program’s courses and demonstrate how those skills are to be applied 

to the circumstances of the producer. The act also specified criteria 

for approval of long-term business plans, including that plans 

incorporate steps to adjust to changing market conditions, take into 

consideration the interests of workers employed by producers, and 

demonstrate sufficient resources to implement the plans.

• Financial assistance. The act eliminated a formula that USDA was 

previously required to use to calculate the amount of financial 

assistance to a producer. The act instead entitled producers who 

complete an approved initial business plan to receive payments of up 

to $4,000 to implement the plan or develop a long-term business plan. 

The act further entitled producers who complete an approved long-
 

Page 6 GAO-12-731 Trade Adjustment Assistance

term business plan to receive additional payments of up to $8,000 to 

implement the plan.

The Foreign Agricultural Service (FAS), which works to improve foreign 

market access for U.S. products, is the lead USDA agency for 

administering the TAA for Farmers program and is responsible for 

accepting petitions for assistance from groups or associations of 

commodity producers and certifying or denying commodities. After the 

reauthorization of the program in February 2009, FAS began developing 

regulations for the program, as amended, and completed the regulations 

in March 2010. FAS accepted petitions under the reauthorized program 

during two filing periods, first under the program’s fiscal year 2010 

appropriation of $90 million and then under the fiscal year 2011 

appropriation of $22.5 million. Both filing periods occurred in 2010 after 

FAS completed regulations for the program—the first from March 11 

through April 14, and the second from May 21 through July 16. The 

second filing period presented producer groups with an opportunity to 

resubmit petitions filed during the first period, either to provide additional 

supporting information (for denied commodities) or to petition for 

recertification of a commodity and thereby extend the 90-day 

postcertification period in which individual producers could apply for 

assistance (for certified commodities).

In addition to FAS, several other USDA agencies play or have played a 

role in implementing the program. The Economic Research Service, 

which conducts economic research and provides information related to 

agriculture, conducted analyses after FAS received petitions to verify the 

decline in the price, quantity of production, value of production, or cash 

receipts for petitioned commodities and to assess possible causes, 

including imports. A petition review committee with representatives from 

four USDA agencies—the Office of the Chief Economist, the Farm 

Service Agency, the Agricultural Marketing Service, and FAS—reviewed 

the analyses and made recommendations to FAS to certify or deny 

commodities. For commodities that FAS certified, the Farm Service 

Agency, which administers programs for farmers and ranchers, drew on 

its network of state and county offices to establish a system for accepting 

and approving individual applications for assistance and distributing 

payments to approved producers who have completed relevant program 

requirements. The National Institute of Food and Agriculture (NIFA), 

which supports state and local research and education efforts related to 

agriculture, administers the program’s technical assistance component. 

After the 2009 reauthorization of the program, NIFA entered into a 

cooperative agreement with a lead academic partner—the Center for 
 

Page 7 GAO-12-731 Trade Adjustment Assistance

Farm Financial Management at the University of Minnesota, which had 

been involved in implementing the initial TAA for Farmers program—to 

organize and oversee the program’s technical assistance. The Center for 

Farm Financial Management established relationships with other 

academic partners across the country to promote the availability of 

assistance to producer groups and individual producers of certified 

commodities and to coordinate the delivery of technical assistance. 

Figure 1 depicts the roles of these agencies in administering the program.

Figure 1: USDA Agency Roles in TAA for Farmers Program

a

The petition review committee includes representatives from four USDA agencies: the Office of the 

Chief Economist, the Farm Service Agency, the Agricultural Marketing Service, and FAS. 

b

The Farm Service Agency approves applications, and FAS decides whether to disapprove 

applications that do not meet eligibility requirements and whether to approve or deny appeals. 

The TAA for Farmers program is one of four trade adjustment assistance 

programs; the other three provide assistance for workers, firms, and 

communities harmed by international trade. Under the TAA for Workers 

program, the Department of Labor provides services and benefits, such 
 

Page 8 GAO-12-731 Trade Adjustment Assistance

as training and re-employment services and income support, to eligible 

workers in manufacturing and service industries. The Department of 

Commerce administers a TAA program that provides funds for 

manufacturing and other types of firms to develop and implement a 

business recovery plan. Under a TAA program to assist trade-affected 

communities, the Department of Labor awards grants to institutions of 

higher education for expanding or improving education and career 

training programs for persons eligible for training under the TAA for 

Workers program, and the Department of Commerce provides technical 

assistance to trade-affected communities and awards and oversees 

strategic planning and implementation grants. In addition to mandating 

that GAO report on the TAA for Farmers program, the Trade and 

Globalization Adjustment Assistance Act of 2009 mandated that GAO 

report on the other TAA programs. Our reports on the other TAA 

programs are forthcoming.

USDA certified relatively few commodities as eligible for assistance under 

the reauthorized TAA for Farmers program, but it has provided technical 

and financial assistance to most individual applicants who produced a 

certified commodity. Specifically, FAS, the lead agency for administering 

the program, certified 5 of the 18 commodities for which it received 

petitions under the reauthorized program. For the 5 certified commodities, 

the Farm Service Agency approved most applications from individual 

producers, including from producers’ spouses, who were not required to 

show how they contributed to production. Producers who were approved 

to participate in the program received technical assistance that was 

tailored to their individual needs. In addition, as of April 2012, the Farm 

Service Agency paid close to $50 million in financial assistance to 

producers who completed initial and long-term business plans. The Trade 

and Globalization Adjustment Assistance Act of 2009 specifies that 

producers are to use payments for long-term business plans to implement 

those plans; however, approval of long-term business plans was not 

contingent on producers documenting how payments would be used to 

implement the plans.

FAS certified 5 of the 18 commodities for which it received petitions under 

the reauthorized program (see fig. 2). The commodities for which FAS 

received petitions included seafood and specialty crops, such as fruits 

and vegetables, as opposed to commodities such as grains. Two of the 5 

certifications—for asparagus and catfish—covered producers nationwide. 

All other petitions covered producers of a commodity in a particular state 

USDA Certified 

Relatively Few 

Commodities but Has 

Provided Assistance 

to Most Covered 

Applicants

FAS Certified Relatively 

Few Commodities
 

Page 9 GAO-12-731 Trade Adjustment Assistance

or group of states. (See app. II for further information on the certified and

denied commodities.)

Figure 2: Commodities and Geographic Areas Certified as Eligible for or Denied 

TAA for Farmers Assistance

a

Multispecies fish includes various species of fish, such as cod and halibut. 

The 2009 changes to the TAA for Farmers program’s certification criteria 

were a factor in the decision to support 4 of the 5 commodity certifications, 

according to our review of the Economic Research Service’s analyses of 

petitions under the reauthorized program and FAS’s decision memos. For 

example, FAS would likely not have been able to certify asparagus or 

shrimp on the basis of a decrease in price—a requirement under the 

previous certification criteria—because the analysis of petitions for both 
 

Page 10 GAO-12-731 Trade Adjustment Assistance

commodities indicated that their prices had increased from the average of 

the 3 previous years. Under the modified certification criteria, FAS was 

instead able to certify these two commodities on the basis of a factor other 

than price, specifically a decrease in the quantity of production. For 

example, the Economic Research Service found that asparagus producers 

had reduced the number of acres harvested to adjust to the rapidly rising 

volume of imports.

The most common reason FAS cited for denying commodities was that the 

petitions for such commodities did not meet the criteria for both an increase 

in imports and a decrease in price or another factor. For example, the 

Economic Research Service found that Hawaiian coffee met the criterion 

for a decrease in price, but FAS denied the commodity because coffee 

imports had declined. FAS also denied several commodities that it 

determined did not meet the criterion for imports to have contributed 

importantly to a decline in price or another factor. For example, according 

to FAS’s documentation explaining the basis for its determination, the 

agency found that California prunes met the criteria for both an increase in 

imports and a decrease in price but that imports were not an important 

factor in determining the price. FAS instead determined that the price 

decline had been affected by an increase in domestic production and other 

factors. To support such determinations on whether imports contributed 

importantly to a commodity’s harm, the Economic Research Service 

conducted qualitative analyses that examined the impact of other factors, 

such as domestic production, consumption, and exports.

Through our interviews and analyses, we identified additional factors that 

contributed to FAS’s denial of commodities. Because the certification 

criteria take into account a number of factors, it is difficult to identify these 

factors as the direct cause for a commodity being denied:

• The time frame over which import competition had occurred. Under 

the certification criteria, a commodity can face competition from 

imports over a long time frame but still be denied if, in the year 

covered by the petition, imports that compete with the commodity do 

not increase compared to the average of the 3 previous years. For 

example, an FAS official said that Florida fishermen of spiny lobsters 

had competed against imports over a long time frame but that FAS 

denied the commodity because imports that compete with such 

lobsters declined in 2009, the year covered by the petition and the 

most recent calendar year for which data were available during the 

period FAS accepted petitions under the reauthorized program. The 

FAS official attributed the decline in these imports to the economic 
 

Page 11 GAO-12-731 Trade Adjustment Assistance

recession. According to data compiled by the U.S. International Trade 

Commission, overall imports of agricultural products declined in 

2009—a year characterized by a significant economic downturn. A 

USDA official who was a member of the committee that made 

recommendations to FAS to certify or deny petitions said that the 

certification criteria favor commodities that have experienced a surge 

in imports, as opposed to slow, steady erosion that occurs over time 

as a result of sustained competition from imports.

• Information presented by producer groups in their petitions. The 

outcome of the certification process depended in part on information 

producer groups presented in their petitions, such as which states to 

include in a petition and whether to submit a petition for a commodity 

that is frozen or fresh. For example, FAS certified frozen wild 

blueberries from Maine on the basis of an Economic Research 

Service analysis showing that the commodity met the criteria for a 

decrease in price and an increase in imports. In contrast, FAS denied 

fresh wild blueberries from New Hampshire in part because the 

quantity of production—the factor cited in the petition for 

demonstrating harm from import competition—had increased rather 

than decreased.

In contrast to the relatively small proportion of commodities that were 

certified as eligible for TAA for Farmers assistance, most applications 

submitted by individual producers of certified commodities were 

approved. Specifically, as of April 2012, the Farm Service Agency had 

approved 9,852, or about 90 percent, of the approximately 11,000 

applications from individual producers.

The shrimp and lobster certifications accounted for 8,596 (87 percent) of 

the approved applications, and the asparagus, catfish, and frozen wild 

blueberry certifications accounted for the remaining 1,256 (13 percent). 

The distribution reflects the relative numbers of fishing or farming 

operations for the certified commodities. For example, according to data 

collected by the Maine Department of Marine Resources, in 2011 there 

were 4,341 active commercial lobster harvesters in the state (one of the 

five states covered by the certification for lobster). In contrast, according 

to USDA data, in 2011 there were 389 catfish operations in Alabama, 

Arkansas, and Mississippi, which are the three major catfish producing 

states. (See app. III for additional detail on individual applications.)

USDA Approved Most 

Individual Applications, 

Including from Spouses 

Who Were Not Required to 

Show They Contributed to 

Producing a Commodity
 

Page 12 GAO-12-731 Trade Adjustment Assistance

FAS officials said the agency took steps to broaden the scope of 

individuals eligible to apply for assistance in order to implement the 

program as reauthorized in 2009 and to increase program participation. 

For example, FAS determined that certain employees of eligible 

producers of certified commodities, such as crew members helping to 

harvest lobster or shrimp, met the definition of agricultural commodity 

producers as sharing in the risk of producing a commodity and could thus 

separately apply for assistance as individuals. To be approved for 

assistance, such individuals needed to provide sufficient documentation 

to establish that they were paid through a share of production—for 

example, by being paid through a portion of a lobster or shrimp catch.

FAS determined that spouses of eligible producers also shared in the risk 

of producing a commodity and could thus separately apply for assistance 

as individual producers. For example, according to the lead FAS official 

for the TAA for Farmers program, a spouse could share in the risk by 

performing the same type of work as a crew member. However, unlike 

crew members, spouses did not need to submit documentation showing 

their contribution to and share in the risk of producing a certified 

commodity. Several FAS officials said the agency disapproved the 

applications of spouses who voluntarily disclosed information indicating 

that they did not contribute to producing a certified commodity. The 

officials said that, because such information was not required, they likely 

approved applications from other spouses who did not contribute, but 

they did not have an estimate of the potential number of such spouses. 

Without requiring spouses applying for assistance as individual producers 

to submit documentation on how they contributed to producing a certified 

commodity, FAS did not have assurance that it targeted assistance to 

individuals who shared in the risk of production.

FAS disapproved about 10 percent of applications from individual 

producers for various reasons, such as when applicants did not provide 

evidence of producing a certified commodity in the year covered by the 

petition. According to an FAS official, the legislative requirement to have 

produced a commodity in the petition year excluded certain blueberry 

growers because the crop is generally harvested every other year, and 

not all Maine growers harvested their crop in the year covered by the 

certification. Other reasons for FAS disapproval of applications included 

individuals not submitting an application within the 90-day period following 

a commodity’s certification, not being a U.S. citizen or lawful alien, or 

receiving benefits under another TAA for Farmers petition or under one of 

the TAA programs for workers or firms.
 

Page 13 GAO-12-731 Trade Adjustment Assistance

According to Farm Service Agency data, as of April 2012, 7,781 

producers, or about three-quarters of the 9,852 producers approved to 

participate, had fully or partially completed the TAA for Farmers technical 

assistance, including training and the development of business plans. 

Specifically, 5,073 producers had completed the 12 hours of required 

training and the development of initial and long-term business plans. 

Another 2,708 producers had completed the training and submitted an 

approved initial business plan but had not yet submitted an approved 

long-term business plan. (See app. III for more detail.)

According to our analysis, the applicants received technical assistance 

tailored to their individual needs. Specifically, NIFA’s academic partners 

responsible for coordinating the technical assistance took the following 

steps:

• Commodity-specific courses. Because of the differences among 

commodities, NIFA’s academic partners developed separate courses 

for each certified commodity. For example, courses for lobstermen 

included information on how to harvest more efficiently and reduce 

fuel consumption, and courses for wild blueberry growers included 

fertilizer management practices to optimize inputs and reduce costs. 

In some cases, the courses also provided information on alternatives 

to producing the certified commodity. For example, the courses for 

shrimpers included information on obtaining licenses needed to 

operate a charter fishing boat. Courses could be taken in person and 

through a website.

• One-on-one business planning assistance. NIFA’s academic partners 

assigned business consultants to provide one-on-one assistance to 

approved producers in developing long-term business plans. At a 

meeting of business consultants we attended, the consultants 

described various ways they helped producers develop or improve on 

their business plans—for example, by explaining financial statements 

and helping analyze the financial impact of a business expansion.

According to USDA summary data, the department obligated $81.1 

million, or 40 percent of the $202.5 million in Trade and Globalization 

Adjustment Assistance Act of 2009 appropriations for the TAA for 

Farmers program, for financial assistance payments to producers. As of 

April 2012, the Farm Service Agency paid close to $50 million of the 

$81.1 million obligated for financial assistance payments. The remainder 

of the obligated funds went toward USDA costs for administering the 

USDA Provided Most 

Applicants with Technical 

Assistance Tailored to 

Individual Needs

USDA Paid Close to $50 

Million in Financial 

Assistance but Did Not 

Require That Producers 

Show How Assistance 

Would Be Used
 

Page 14 GAO-12-731 Trade Adjustment Assistance

program and the cooperative agreement with NIFA’s lead academic 

partner for organizing and overseeing the program’s technical assistance. 

In addition, USDA did not obligate all of the appropriated funds because, 

for example, FAS did not complete regulations for the amended program 

until March 2010 and thus was not able to use fiscal year 2009 funding to 

make financial assistance payments to producers. The funds that were 

not obligated are no longer available for implementation of the program. 

(See table 1 on USDA’s use of appropriations for the program.)

Table 1: USDA’s Use of $202.5 Million in Trade and Globalization Adjustment 

Assistance Act of 2009 Appropriations for the TAA for Farmers Program

Category

Amount 

(millions) Percentage

Financial assistance payments $81.1 40

USDA administrative costs $12.0 6 

Cooperative agreement for organizing and overseeing 

technical assistance

$34.0 17

Not obligated $75.3 37

Total $202.5 100

Source: GAO analysis of USDA data.

Note: Dollar figures do not add up to $202.5 million due to rounding. 

The final amount of payments will depend on the number of approved 

business plans that producers complete within the 3-year period following 

FAS’s certification of commodities under the 2009 reauthorization of the 

program. For plans that do not initially meet the criteria for approval, 

individuals may continue to work on plans and resubmit them. The nearly 

$50 million paid as of April 2012 included

• about $20.2 million to producers who had completed initial business 

plans that met the criteria for approval,

• about $29.5 million to producers who had completed long-term 

business plans that met the criteria for approval, and

• about $60,000 for producers’ transportation and related expenses to 

attend an initial orientation to the program.

Spouses that completed business plans received separate payments. 

According to guidance for the program, a spouse of a producer had to 
 

Page 15 GAO-12-731 Trade Adjustment Assistance

complete a separate business plan before receiving a payment, but the 

plans of a spouse and a producer could be nearly identical.

Some producers received full financial assistance payments of $4,000 for 

completion of an initial business plan and an additional $8,000 for 

completion of a long-term business plan. Specifically, the fiscal year 2010 

appropriation for the TAA for Farmers program was sufficient to allow full 

payments to producers approved under certifications from the first petition 

filing period (March through April 2010), which included certifications for 

asparagus, catfish, and shrimp. In contrast, FAS determined that it needed 

to prorate payments to producers approved under certifications from the 

second filing period (May through July 2010), which resulted in 

certifications for lobster and wild blueberries, as well as a recertified petition 

for shrimp. These certifications accounted for about 55 percent of 

producers participating in the program. To ensure sufficient funding for all 

individuals approved for assistance under these certifications, FAS 

calculated prorated amounts of about $971 for completion of an initial 

business plan and about $1,943 for completion of a long-term plan, for a 

total of about $2,914. FAS needed to prorate the payments in part because 

it certified the second round of petitions using the first quarter fiscal year 

2011 appropriation of $22.5 million—one-quarter the amount appropriated 

for each of the 2 previous fiscal years. According to an FAS letter to 

producers, FAS may issue a third payment to producers receiving prorated 

cash benefits at the end of the program, depending on the availability of 

funding and on the number of producers who complete technical 

assistance and are therefore eligible for cash benefits. (See app. III for 

more detailed data on financial assistance payments.)

According to FAS, NIFA, and Farm Service Agency officials, the Farm 

Service Agency paid producers without the producers being required to 

show that the financial assistance would be used for the intended 

purpose. Under the Trade and Globalization Adjustment Assistance Act of 

2009, payments for completion of long-term business plans are to be 

used to implement the plans. However, approval of long-term business 

plans was not contingent on producers documenting how payments 

would be used to implement the plans. FAS and NIFA officials cited 

various reasons for not requiring producers to document how payments 

would be used, including that technical assistance was a primary benefit 

of the program. The officials acknowledged, however, that they have 

received feedback that led them to believe that at least some producers 

used payments for expenses unrelated to their business plans, such as to 

cover housing costs.
 

Page 16 GAO-12-731 Trade Adjustment Assistance

FAS is evaluating the effectiveness of the TAA for Farmers program by 

using performance measures and a series of producer surveys that focus 

on technical assistance. These tools provide USDA with data on some 

aspects of the program’s effectiveness, but they have several limitations 

that hinder FAS’s ability to fully determine the extent to which the program 

as a whole is effective. For example, the performance measures do not 

provide information on long-term program effectiveness, and the surveys 

capture producers’ perceptions of program effectiveness that FAS has not 

corroborated through other means.

Measuring performance allows agencies to track progress toward their 

goals and gives managers crucial information on which to base decisions. 

Congress enacted the Government Performance and Results Act of 1993 

to improve the effectiveness of federal programs, among other purposes, 

and to establish a system for agencies to set goals for program 

performance and to measure results. Federal agencies must comply with 

GPRA requirements, but we have reported that these requirements also 

can serve as leading practices at lower levels within federal agencies, 

such as individual divisions, programs, or initiatives. Leading practices 

embodied in GPRA indicate that outcome-oriented goals, along with 

objective and quantifiable performance measures, are important 

performance management tools for agencies.5

FAS, with the input of the Farm Service Agency and NIFA, developed five 

performance measures as part of its approach to evaluating the 

effectiveness of the TAA for Farmers program. The first four measures 

consist of the number of producers completing each stage of the 

program’s technical assistance, including

Performance measures 

gauge progress in meeting goals to determine if a program is achieving 

intended results.

• initial orientation,

• 12 hours of required training,

 

5

GAO, Designing Evaluations, GAO-12-208G (Washington, D.C.: January 2012).

USDA’s Program 

Evaluation Approach 

Relies on 

Performance 

Measures and Surveys 

That Do Not Fully 

Assess Effectiveness

USDA’s Performance 

Measures Do Not Provide 

Information on Long-Term 

Effectiveness or All Key 

Program Areas
 

Page 17 GAO-12-731 Trade Adjustment Assistance

• an approved initial business plan, and

• an approved long-term business plan.

The fifth performance measure consists of categorizing the amount of 

assistance provided, such as by certified commodity. NIFA’s academic 

partners communicate data on the first four performance measures 

through weekly progress reports, and USDA communicates data on the 

fifth performance measure through its annual report on the program to 

Congress. According to lead FAS program officials, the performance 

measures help FAS understand how effectively the program is operating 

over the short term because they track producers’ participation 

throughout the stages of the program and producers’ completion of 

program requirements.

These performance measures do not provide information on the 

program’s effectiveness over the long-term, however, because they do 

not measure outcomes. Outcome-oriented goals and performance 

measures assess the results of a program compared to its intended 

purpose and are important for ensuring accountability. For example, the 

Department of Labor’s performance measures for the TAA for Workers 

program include several outcome-oriented measures, such as the 

percentage of participants that find jobs after exiting the program. 

According to the lead NIFA official, technical assistance programs such 

as TAA for Farmers are intended to promote changes in producers’ 

knowledge, changes in producers’ behavior when they act upon what 

they have learned, and ultimately improvements in producers’ condition. 

Therefore, appropriate goals and performance measures for this program 

would capture changes in producers’ knowledge, behavior, and condition. 

Given the purpose of the program’s technical assistance to help 

producers better compete with imports or transition to the production of 

other commodities, such measures might include the percentage of 

producers who are able to remain in business because they have become 

more competitive, or the percentage of producers who successfully 

transition to producing another commodity.

Moreover, FAS’s performance measures focus on the program’s technical 

assistance, as opposed to other areas of the program—such as 

producers’ use of financial assistance payments. Financial assistance is 

also an important component of the TAA for Farmers program, however—

both as a benefit to producers and in terms of the programs’ budget. 

Because FAS does not have performance measures on all key program 
 

Page 18 GAO-12-731 Trade Adjustment Assistance

areas, including financial assistance, FAS cannot comprehensively 

evaluate the program.

FAS officials said that, because technical assistance is the main benefit of 

the program, they are most interested in tracking progress in that area. 

Nevertheless, FAS and NIFA officials acknowledged that the performance 

measures do not measure outcomes and therefore cannot be used to 

evaluate the long-term effectiveness of the program. The officials 

explained that the reporting requirements of the 2009 legislation—which 

focuses on short-term economic stimulus—led them to select measures 

that could be tracked over the short term. The FAS officials added that 

they eventually plan to develop performance measures to report on the 

program’s outcomes. However, because outcome measures were not 

selected in advance, the potential to collect objective data may be lost.

Surveys developed by NIFA’s academic partners are the other main tool 

that FAS is using to evaluate the effectiveness of the TAA for Farmers 

program. The surveys are to be administered to producers participating in 

the program after each stage of technical assistance, including after

producers complete each training course and after they complete their 

initial and long-term business plans. As of March 2012, NIFA’s academic 

partners developed six producer surveys out of a planned seven and 

were still drafting the seventh. According to our analysis of the six 

developed surveys, including versions adapted to each certified 

commodity, the surveys are well designed and appropriate to provide 

adequate data on producers’ perceptions of the program—including 

perceived changes in their knowledge, behavior, and condition as a result 

of the technical assistance.

To provide survey results for our review, NIFA’s academic partners 

analyzed the preliminary results of surveys received as of December 

2011 (the survey results may not be representative of all producers 

participating in the program). According to the lead NIFA official, the 

survey results are too preliminary to assess any changes in producers’ 

condition—the ultimate goal of the technical assistance—but the results 

suggest that producers find the program’s technical assistance to be 

effective in helping them improve their knowledge and begin to change 

their behavior. For example, responses from about 1,800 producers 

(approximately 19 percent of the producers who were approved to 

participate in the program) surveyed after completion of their initial 

business plans, indicate the following:

Surveys Capture 

Producers’ Perceptions of 

the Effectiveness of 

Technical Assistance but 

Do Not Provide a 

Complete Picture of 

Program Effectiveness
 

Page 19 GAO-12-731 Trade Adjustment Assistance

• Knowledge. About 56 percent of producers who responded to the 

survey learned “quite a bit” or “a great deal” from the training that 

would benefit their business. Almost 34 percent said they learned 

“some,” almost 9 percent said they learned “a little,” and less than 2 

percent said they learned “nothing.” 

• Behavior. Over 57 percent of producers who responded to the survey 

felt that developing an initial business plan was “very” or “completely” 

helpful in assisting them identify changes they could make to their 

business operations. About 28 percent felt it was “moderately” helpful, 

and about 14 percent said it was of “slight” or “no” help.

NIFA’s academic partners also collected anecdotes from producers to 

provide specific examples of the TAA for Farmers program’s value. For 

example, according to an anecdote from a lobster producer in Maine, the 

direct marketing workshop provided ideas on how to market lobster 

differently from other vendors, such as having lobster certified as organic. 

According to another anecdote from a catfish producer in Arkansas, the 

training helped him understand the need to look at every aspect of the 

cost of his operation and control the spread of disease among his stock.

The surveys can be used to gather insights into producers’ perceptions of 

the program, but limitations in the surveys’ design will hinder FAS and 

NIFA’s ability to use them as a program evaluation tool. In particular,

• The surveys’ time frame is insufficient to gather insights into 

producers’ perceptions of long-term effectiveness. According to 

NIFA’s academic partners, they will administer the final survey 6 to 12 

months after producers complete the program’s technical assistance 

in 2013. The lead NIFA official said, however, that technical 

assistance programs require at least 3 years after program completion 

to begin demonstrating results because long-term behavioral changes 

are not easily or quickly adopted. The official added that the academic 

partners would like to administer a final follow-up survey 3 to 5 years 

after program completion but said there is currently no funding 

available for such a survey.

• The surveys provide little information on producers’ perceptions of the 

effectiveness of the program’s financial assistance. Like USDA’s 

performance measures, the surveys focus primarily on the program’s 

technical assistance. The lead NIFA official explained that the agency 

tasked its academic partners with evaluating only the program’s 

technical assistance. Without evaluating the program’s financial 
 

Page 20 GAO-12-731 Trade Adjustment Assistance

assistance as well as its technical assistance, however, NIFA and 

FAS cannot know the extent to which the program as a whole is 

effective in helping producers become more competitive. For 

example, some commodity experts we spoke with suggested that the 

financial assistance for producers of capital-intensive commodities, 

such as catfish, may be less effective than such assistance for 

producers of labor-intensive commodities, such as blueberries, 

because the assistance constitutes a smaller percentage of the 

amount needed to make changes to the production of capitalintensive commodities.

In addition to these limitations, FAS has not corroborated the survey 

results by collecting data to help determine whether improvements in 

producers’ conditions are due to the TAA for Farmers program or some 

external factor. In November 2009, we reported that program evaluation 

methods to rule out plausible alternative explanations for outcomes that 

may be influenced by a variety of external factors, such as changes in the 

economy, can help strengthen the evaluations.6 In practice, it is generally 

difficult to isolate the causal impact of programs from other influences on 

outcomes, but use of multiple sources of data can help address concerns 

about using only one source. FAS officials explained that there were 

challenges to collecting data on producers and their businesses because 

of privacy and other constraints and that FAS did not want to discourage

producer participation by appearing too invasive. FAS officials also 

acknowledged that there are some types of data they could have 

collected, such as producers’ cost structures before they participated in 

the program, and that FAS could have potentially collected this 

information through producers’ individual applications.

USDA provided enhanced technical assistance to most producers of 

certified commodities who applied for TAA for Farmers assistance. In 

determining which individual applicants qualified, USDA considered 

certain employees as well as spouses of producers to be eligible on the 

grounds that they shared in the risk of producing the agricultural 

commodities. However, USDA did not require spouses applying for 

assistance to submit documentation on how they contributed to producing 

a certified commodity. As a result, USDA may have approved the 

 

6

GAO, Program Evaluation: A Variety of Rigorous Methods Can Help Identify Effective 

Interventions, GAO-10-30 (Washington, D.C.: Nov. 23, 2009).

Conclusions
 

Page 21 GAO-12-731 Trade Adjustment Assistance

applications of spouses who did not contribute to producing a certified 

commodity and therefore does not have assurance that it targeted 

assistance to individuals who are intended to benefit from the program. In 

addition, USDA made financial assistance payments to producers without 

the producers being required to show how payments would be used to 

implement their long-term business plans. Under the Trade and 

Globalization Adjustment Assistance Act of 2009, the payments for 

completion of long-term business plans are to be used to implement 

those plans. USDA officials acknowledged that some producers likely use 

the payments for unrelated expenses.

The performance measures and surveys USDA is using as part of its 

approach to evaluate the TAA for Farmers program are well designed for 

measuring the number of producers completing the program and for 

capturing producer perceptions of the effectiveness of the program’s 

technical assistance. However, USDA cannot use its current performance 

measures to fully evaluate the program’s effectiveness because they do 

not measure quantifiable outcomes or cover all key areas of the program. 

Furthermore, the surveys have several limitations. For example, the time 

frame for administering the final survey—6 to 12 months after producers 

complete the program—is insufficient to gather insights into producers’ 

perceptions of the program’s long-term effectiveness. In addition, USDA 

has not corroborated the survey results to help isolate the impact of the 

TAA for Farmers program from other influences. Because of limitations 

with USDA’s program evaluation approach, USDA cannot establish the 

extent to which the program as a whole is ultimately effective. Performing 

comprehensive program evaluations can be difficult for agencies because 

of resource constraints and data collection challenges. Nonetheless, a 

broader program evaluation approach could enable USDA to better 

evaluate the impact of the TAA for Farmers program on producers’ 

competitiveness. The TAA for Farmers program as reauthorized in 2009

is almost over, and no new funds have been appropriated. If the program 

receives future reauthorizations and funding, USDA will have an 

opportunity to improve the operation and evaluation of the program.

We recommend that the Secretary of Agriculture direct the Administrators 

of FAS and the Farm Service Agency and the Director of NIFA, as 

appropriate, to take the following three actions, as applicable under the 

structure of any future round of trade adjustment assistance for farmers 

and fishermen for which Congress may appropriate funds: 

Recommendations for 

Executive Action
 

Page 22 GAO-12-731 Trade Adjustment Assistance

• Require spouses who may be eligible to apply for assistance to 

submit documentation on how they contribute to a commodity’s 

production.

• Take steps to help ensure that any financial assistance payments that 

may be provided under the program are used for the intended 

purpose—for example, by requiring producers to state in their 

business plans how they intend to use the payments.

• Broaden the program’s evaluation approach to help ensure that USDA 

can comprehensively evaluate the effectiveness of the program. 

Steps to broaden the program’s evaluation approach could include 

developing quantifiable outcome-oriented performance goals and 

measures for all key areas of the program and collecting data to help 

isolate the impact of the TAA for Farmers program from other 

influences.

We provided a copy of our draft report to USDA for review and comment. 

In written comments from the department, FAS stated that the department 

generally agrees with our recommendations. In addition, FAS stated that, 

assuming any future TAA for Farmers program has the same statutory 

requirements, the department will make every effort to address our 

recommendations in order to strengthen and improve the program.

We recognize that the statutory requirements for any future TAA for 

Farmers program may differ from current requirements. For example, as 

noted in our report, the Trade and Globalization Adjustment Assistance 

Act of 2009 amended the program, making changes to the program in key 

areas. Given the potential for future changes to the program’s statutory 

requirements, we revised our recommendations related to the eligibility 

requirements for spouses and the use of financial assistance payments 

toward implementation of business plans. In particular, we revised the 

wording of these two recommendations to account for the potential that a 

future reauthorization of the program may make further changes to the 

program’s eligibility requirements or to the technical and financial 

assistance provided to producers.

Agency Comments 

and Our Evaluation
 

Page 23 GAO-12-731 Trade Adjustment Assistance

We are sending copies of this report to the Secretary of Agriculture, the 

appropriate congressional committees, and other interested parties. In 

addition, the report is available at no charge on GAO’s website at 

http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-3841 or shamesl@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix V.

Lisa Shames

Director, Natural Resources 

and Environment
Appendix I: Scope and Methodology

Page 24 GAO-12-731 Trade Adjustment Assistance

To examine the commodities and producers approved for assistance 

under the 2009 reauthorization of the Trade Adjustment Assistance (TAA) 

for Farmers program and the type and amount of assistance provided, we 

reviewed four areas of the program:

• Commodity certification. We reviewed petitions submitted by groups 

of commodity producers, Economic Research Service analyses, 

petition review committee decision memos with recommendations to 

the Foreign Agricultural Service (FAS) on whether to certify 

commodities, and FAS letters to producer groups and Federal 

Register notices announcing whether commodities had been certified 

or denied. We analyzed the documentation to determine the basis for 

FAS’s determinations and the extent to which the 2009 changes to the 

certification criteria were a factor in commodities being certified.

• Producer application. We reviewed Farm Service Agency documents 

describing the application process and individual eligibility 

requirements, including the requirements for crew members and 

spouses of eligible producers. In addition, we obtained and analyzed 

Farm Service Agency data on the number of applicants for each 

certified commodity, including the number approved and disapproved 

and the reasons for disapproval.

• Technical assistance. We reviewed documents prepared by the 

National Institute of Food and Agriculture’s (NIFA) academic partners 

for organizing and overseeing the program’s technical assistance, a 

list of training courses provided to producers, templates for initial and 

long-term business plans, and sample long-term business plans. We 

also analyzed Farm Service Agency data on producers’ completion of 

each stage of technical assistance.

• Financial assistance. We analyzed Farm Service Agency data on 

payments to producers who completed initial and long-term business 

plans, as well as for transportation and related expenses to attend an 

initial orientation to the program. In addition, we reviewed summary 

data from the U.S. Department of Agriculture (USDA) on its use of 

appropriations for the program.

We assessed the reliability of Farm Service Agency data by checking for 

obvious errors in accuracy and completeness. In addition, we assessed 

the data’s consistency with equivalent data maintained by the Center for 

Farm Financial Management on producers’ completion of technical 

assistance. We also reviewed documentation describing the Farm 

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 25 GAO-12-731 Trade Adjustment Assistance

Service Agency database used to produce the data, and we interviewed 

Farm Service Agency officials who had knowledge of the data. We 

determined that the data were sufficiently reliable for reporting on the 

number of approved and disapproved applicants and the amount of 

technical and financial assistance provided to producers.

To examine the approach USDA is taking to evaluate the program’s 

effectiveness and to identify any limitations in this approach, we reviewed 

USDA’s performance measures and producer surveys:

• Performance measures. We reviewed the performance measures 

FAS selected for program reporting purposes and compared the 

performance measures against guidelines embodied in the 

Government Performance and Results Act of 1993, as amended 

(GPRA). We also reviewed available data on these measures to 

understand how FAS and NIFA’s academic partners were tracking 

and using the performance measures.

• Producer surveys. We reviewed templates developed by NIFA’s 

academic partners for surveys of producers participating in the 

program. The templates included the surveys to be completed after 

each stage of the program’s technical assistance. We evaluated the 

templates and the academic partners’ survey development 

methodology against GAO guidelines for designing evaluations and 

the Office of Management and Budget’s (OMB) Standards and 

Guidelines for Statistical Surveys to understand the extent to which 

the academic partners incorporated generally accepted survey 

research practices. In addition, we reviewed an analysis of preliminary 

survey results, as of December 2011, that NIFA’s academic partners 

prepared for purposes of our audit.

For further explanation regarding both of our objectives, we interviewed 

USDA officials involved in administering each stage of the program, 

including officials from FAS, the Economic Research Service, the TAA for 

Farmers petition review committee, the Farm Service Agency, and NIFA. 

In addition, we interviewed NIFA’s academic partners and representatives 

of the teams established to develop commodity-specific training courses, 

and we attended a meeting of TAA of Farmers business consultants 

organized by NIFA’s lead academic partner. The meeting provided us 

with the opportunity to obtain business consultants’ perspectives on 

various aspects of the program and to learn about their experiences 

working with producers. To better understand the type of information 

contained in long-term business plans, we reviewed sample plans (with 
Appendix I: Scope and Methodology

Page 26 GAO-12-731 Trade Adjustment Assistance

personal information removed) that NIFA’s academic partners selected to 

serve as a basis for discussing the criteria for approval of the plans at the 

meeting of business consultants. We also interviewed members of the 

USDA Office of the Inspector General team conducting a review of the 

TAA for Farmers program during the same time we conducted our review. 

We planned our audit to minimize duplication of effort in areas evaluated 

by the Office of Inspector General, such as FAS and Farm Service 

Agency internal controls over the application of eligibility requirements for 

producers of certified commodities.

To gather additional perspectives, we interviewed a nonprobability 

sample of producer groups that submitted petitions for TAA for Farmers 

assistance. Because we selected a nonprobability sample of producer 

groups to interview, the information we obtained from these interviews 

cannot be generalized to other groups. The interviews instead provided 

us with the perspectives of various producer groups regarding the 

program. We conducted interviews by phone and in person as part of 

fieldwork in Maine and Mississippi, during which we also interviewed two 

producers (a catfish producer and a shrimp producer) regarding the 

impact the program has had on their businesses. We selected these two 

states in order to meet with representatives of producer groups for three 

of the five certified commodities (catfish, lobster, and frozen wild 

blueberries). In addition, Maine accounted for the majority of approved 

lobster producers and all approved wild blueberry producers, and 

Mississippi accounted for the largest number of approved catfish 

producers.

We conducted this performance audit from September 2011 to July 2012 

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 II: Commodities Certified and Denied 

for TAA for Farmers Assistance

Page 27 GAO-12-731 Trade Adjustment Assistance

Table 2 summarizes our analysis of the basis for FAS’s certification of five 

commodities under the 2009 reauthorization of the TAA for Farmers 

program, including the Economic Research Service analyses of petitions 

and FAS decision memos. FAS certified four commodities on the basis of 

a decrease in factors added as options (in addition to price) for 

demonstrating harm from imports: quantity of production and value of 

production. None of the certifications were based on a decrease in cash 

receipts (the third factor added for demonstrating harm). In its analyses of 

petitions for lobster, shrimp and frozen wild blueberries, the Economic 

Research Service identified factors other than imports that contributed to 

a decline in the commodity’s price or other factor. Nevertheless, FAS 

found that the commodities met the requirement for an increase in 

imports to have contributed importantly to the decline.

Table 2: Commodities Certified for Assistance under the 2009 Reauthorization of the TAA for Farmers Program

Commodity and 

year covered by 

the petition

Area covered by the 

certification

Basis for FAS’s 

determinationa Increase in 

importsa

Other contributing factors cited 

by the Economic Research 

Service

Asparagus (2009) Nationwideb 17 percent decline in 

quantity of production

17 percent None

Catfish (2009) Nationwide 16 percent decline in value 

of production

48 percent None

Lobster (2009)c Connecticut, Maine, 

Massachusetts, New 

Hampshire, and Rhode Island

State-level declines in the 

value of production ranging 

from 16 percent to 36 

percent

6 percent Increased domestic production

Shrimp (2008)d Alabama, Alaska, Florida, 

Georgia, Louisiana, 

Mississippi, North Carolina, 

South Carolina, and Texas

22 percent decline in the 

quantity of production

5 percent A natural variation in harvest and 

a rapid increase in the price of 

diesel fuel

Wild blueberries, 

frozen (2009)

Maine 56 percent decline in 

average annual price

3 percent Increased domestic production, 

high inventory levels from previous 

years, and decreased exports

Source: GAO analysis of FAS determinations to certify TAA for Farmers petitions.

a

Percentage changes are in comparison to the average of the 3 preceding years. 

b

FAS received petitions from asparagus producers in California, Michigan, Pennsylvania, and 

Washington. FAS certified producers of asparagus nationwide on the basis of data from the top 

asparagus-producing states (California, Michigan, and Washington). 

c

FAS initially denied a nationwide petition for lobster in part because imports decreased in 2008. 

Producer groups from five New England states submitted separate petitions during the second filing 

period FAS announced in 2010. The petitions used more recent data that had become available for 

2009, when imports had increased. 

d

FAS certified petitions submitted during both the first and second filing periods. Recertification of the 

initial petition extended the 90-day postcertification period in which individual producers could apply 

for assistance. In addition, producers in Alaska joined the second petition. Producers of both wild and 

pond-raised shrimp and prawns were eligible to apply for assistance. 

Appendix II: Commodities Certified and 

Denied for TAA for Farmers Assistance
Appendix II: Commodities Certified and Denied 

for TAA for Farmers Assistance

Page 28 GAO-12-731 Trade Adjustment Assistance

Table 3 summarizes our analysis of the basis cited by FAS when denying 

commodities. Reasons for denial included not meeting the requirements for 

both an increase in imports and a decrease in price or another factor and 

not meeting the requirement for an increase in imports to have contributed 

importantly to a commodity’s harm. In cases in which FAS found that 

imports had not contributed importantly to a commodity’s harm, the 

Economic Research Service identified other contributing factors, such as 

an increase in domestic production. For several commodities, including 

apples, coffee, and cranberries, FAS received separate state petitions and 

cited differing reasons for not certifying the commodities in those states.

Table 3: Basis Cited by FAS for Denying Commodities under the 2009 Reauthorization of the TAA for Farmers Program

Basis for FAS’s determinations

Commodity Area covered by petitions

Requirement for 

greater than 15 

percent decline 

not met

Imports 

decreased in the 

year covered by 

the petition

Factors other than 

imports contributed 

to a greater than 15 

percent decline

Apples Maine X X 

Michigan and New York X 

Minnesota X 

Blue crabs Georgia X 

Coffee Hawaii X 

Puerto Rico X X 

Cranberries New Jersey X X 

Oregon and Washington X 

Crawfish Louisiana X 

Cut lilies Georgia, North Carolina, South Carolina, 

and Virginia

X 

Lamb Idaho, Montana, Ohio, Utah, and Wyoming X X 

Multispecies fish Connecticut, Maine, Maryland, 

Massachusetts, New Hampshire, New 

Jersey, New York, and Rhode Island

X 

Prunesa California X 

Spiny lobster Florida X 

Tilapia Arkansas X X 

Wild blueberries, fresh New Hampshire X 

Wool Idaho, Kansas, Montana, Ohio, Utah, and 

Wyoming

X 

Source: GAO analysis of FAS decision memos, letters to petitioners, and Federal Register notices.

a

FAS received two petitions for California prunes, one during each of the two filing periods announced 

in 2010. For the first petition, FAS found, based on partial year data, that imports had declined. For 

the second petition, FAS found that imports had increased but that imports were not an important 

factor in determining the average price. 
Appendix II: Commodities Certified and Denied 

for TAA for Farmers Assistance

Page 29 GAO-12-731 Trade Adjustment Assistance

Several commodities for which FAS received TAA for Farmers petitions 

have been the subject of other federal efforts addressing the impact of 

imports. For example, the Food, Conservation and Energy Act of 2008 

appropriated $15 million for USDA to compensate producers of 

asparagus (a commodity certified for TAA for Farmers assistance) for 

market loss and reduced prices resulting from an increase in imports. In 

addition, the U.S. International Trade Commission, an independent 

federal agency that conducts investigations that can lead to the imposition 

of antidumping duties on imports sold at less than fair value, has 

conducted investigations into imports of shrimp and crawfish, two 

commodities for which FAS received petitions for TAA for Farmers 

assistance. The TAA for Farmers certification criteria, however, differ from 

the criteria used by the U.S. International Trade Commission to support 

the imposition of antidumping duties. As a result, the outcomes of 

certification process and commission investigations also differed. In 

particular, FAS certified shrimp but denied crawfish even though 

antidumping duties have been imposed on both commodities.
Appendix III: Technical and Financial 

Assistance Provided to Producers Approved 

for TAA for Farmers Assistance

Page 30 GAO-12-731 Trade Adjustment Assistance

Farm Service Agency data on individual applicants under the five 

commodities certified for TAA for Farmers assistance included the 

numbers of approved applicants, disapproved applicants, and applicants 

waiting for a decision on their application or appeal of disapproval (see 

table 4). Shrimp producers included those who applied in the 90-day 

period following the commodity’s initial certification, as well as those who 

applied in the period following the commodity’s recertification.

Table 4: Number of TAA for Farmers Applicants as of April 2012, by Certified 

Commodity and Application Status

Commodity Approved Disapproved Pendinga Total

Asparagus 259 13 8 280

Catfish 743 40 2 785

Lobster 3,842 340 - 4,182

Shrimp (initial certification) 3,405 485 7 3,897 

Shrimp (recertification) 1,349 204 1 1,554

Wild blueberries, frozen 254 24 - 278

Total 9,852 1,106 18 10,976

Source: GAO analysis of Farm Service Agency data.

a

Includes applicants waiting for a decision on their application or appeal of disapproval. 

A FAS official estimated that about 80 percent of the approved applicants 

met the eligibility requirement for a decrease in the price received for a 

commodity through a process whereby industry officials could submit data 

for all producers in a state or certain counties within a state. For example, 

FAS allowed all asparagus growers in Michigan to rely on such data when 

applying for assistance rather than submit their own price data. According 

to information from FAS and the Farm Service Agency, less than 1 

percent of the total number of approved applicants did not meet the 

program’s eligibility requirements but partially or fully completed the initial 

training requirements after receiving approval letters that were sent in 

error. In consideration of the time such applicants spent on technical 

assistance, the Deputy Under Secretary for Farm and Foreign Agricultural 

Services granted equitable relief to the applicants, meaning they were 

allowed to continue to participate in the program and receive cash 

benefits. According to an official in the Farm Service Agency, the agency 

did not develop software to track applicants until after it began accepting 

applications. As a result, staff needed to manually enter applicant data 

into spreadsheets, which led to data entry errors and approval letters 

being inadvertently sent to some applicants who did not meet eligibility 

requirements.

Appendix III: Technical and Financial 

Assistance Provided to Producers Approved 

for TAA for Farmers Assistance 
Appendix III: Technical and Financial 

Assistance Provided to Producers Approved 

for TAA for Farmers Assistance

Page 31 GAO-12-731 Trade Adjustment Assistance

Table 5 summarizes Farm Service Agency data on the number and 

percentage of approved producers for each certified commodity who 

completed initial and long-term business plans as of April 2012, as well as 

the total amount of financial assistance payments to the producers.

Table 5: Financial Assistance Provided to Producers as of April 2012, by Certified Commodity (Dollars in Millions)

Initial business plans Long-term business plans

Commodity

Number (percent) 

of producers with 

approved plans Cash benefits

Number (percent) 

of producers with 

approved plans

Cash 

benefits

Total cash benefits, 

including transportation 

and related expenses 

Asparagus 218 (84%) $0.9 73 (28%) $0.6 $1.5

Catfish 668 (90%) $2.7 452 (61%) $3.6 $6.3

Lobster 2,237 (58%) $2.2 1,040 (27%) $2.0 $4.2

Shrimp (initial certification) 3,272 (96%) $13.1 2,716 (80%) $21.7 $34.8

Shrimp (recertification) 1,180 (87%) $1.1 729 (54%) $1.4 $2.6

Wild blueberries 206 (81%) $0.2 63 (25%) $0.1 $0.3

Total 7,781 (79%) $20.2 5,073 (51%) $29.5 $49.7

Source: GAO analysis of Farm Service Agency data.

Note: Column and row totals may not add up due to rounding. In addition, the column for total cash 

benefits includes about $60,000, distributed among the certified commodities, for producers’ 

transportation and related expenses to attend an initial orientation to the program. 

NIFA’s academic partners developed separate templates and approval 

criteria for the initial business plans and long-term business plans. The 

template for the initial business plan is two pages, with space for 

producers to provide brief descriptions of their businesses, key 

challenges, skills gained from the TAA for Farmers training courses, plans 

for applying those skills, changes being considered to improve business 

profitability and the ability to compete with imports, and whether 

producers intend to complete a long-term business plan. According to the 

TAA for Farmers technical assistance procedures guide, producers had 

the option of completing the initial business plans during the last 30 

minutes of a training course on how to develop a long-term business plan. 

NIFA’s academic partners said they designed the initial business plan to 

serve primarily as a starting point for developing a long-term plan. They 

said that, as a result, they approved most initial business plans without 

returning them to producers for additional work.

NIFA’s academic partners developed templates for several different types 

of long-term business plans that producers could choose to develop to 

suit their individual needs: a traditional business plan with separate 

versions for farmers and fishermen, a plan to pass a business on to 
Appendix III: Technical and Financial 

Assistance Provided to Producers Approved 

for TAA for Farmers Assistance

Page 32 GAO-12-731 Trade Adjustment Assistance

successors and plan for retirement, and a career plan for producers such 

as crew members who do not own a business. The templates were also 

translated for the benefit of shrimpers who speak Vietnamese as a first 

language. According to the technical assistance procedures guide, the 

long-term plans are to undergo two levels of review before they are 

approved and producers can receive their payments—first by the 

business consultant assigned to work with a producer, and then by 

NIFA’s academic partners. In addition, the templates for the long-term 

business plans are more extensive than the template for the initial 

business plans. For example, the template for traditional long-term 

business plans includes sections for

• a business description, including location, facilities, business history, 

and ownership structure.

• business operations, including management of inventory, product 

quality, customer service, and risk; compliance with regulations; and 

an implementation timeline for any changes.

• a marketing plan with subsections for an analysis of the market, the 

business’s competitive position and market segments to be targeted, 

and pricing, promotion, and distribution plans.

• management of the business, including new positions to be filled and 

the plan for finding and training people for those positions.

• a financial plan with subsections for a balance sheet showing assets, 

liabilities, and net worth; historical performance and projections; asset 

management; and capital requests.
Appendix IV: Comments from the U.S. 

Department of Agriculture

Page 33 GAO-12-731 Trade Adjustment Assistance

Appendix IV: Comments from the U.S. 

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

Department of Agriculture

Page 34 GAO-12-731 Trade Adjustment Assistance
Appendix IV: Comments from the U.S. 

Department of Agriculture

Page 35 GAO-12-731 Trade Adjustment Assistance
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 36 GAO-12-731 Trade Adjustment Assistance

Lisa Shames, (202) 512-3841 or shamesl@gao.gov

In addition to the contact named above, Mary Denigan-Macauley 

(Assistant Director), Kevin Bray, Joseph Cook, Barbara El Osta, Cynthia 

Norris, Anne Rhodes-Kline, and Heather Salinas made key contributions 

to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(361338)
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