GAO 

United States Government Accountability Office

Report to Congressional Committees

INTERNATIONAL 

FOOD ASSISTANCE 

USAID Is Taking 

Actions to Improve 

Monitoring and 

Evaluation of 

Nonemergency Food 

Aid, but Weaknesses in 

Planning Could Impede 

Efforts

September 2009 

GAO-09-980 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 2009

INTERNATIONAL FOOD ASSISTANCE

USAID Is Taking Actions to Improve Monitoring and 

Evaluation of Nonemergency Food Aid, but 

Highlights of GAO-09-980, a report to Weaknesses in Planning Could Impede Efforts

congressional committees 

In passing the Food for Peace Act 

in 2008, Congress authorized up to 

$22 million annually for fiscal years 

2009 to 2012 to the U.S. Agency for 

International Development 

(USAID) to improve, monitor, and 

evaluate the effectiveness and 

efficiency of nonemergency food 

aid programs. Congress also 

required USAID to report on its 

oversight of these programs and 

the Comptroller General to review 

and report to Congress on USAID’s 

report. Through analysis of agency 

documents; interviews with agency 

officials, experts, and partners; and 

visits to Bangladesh and Haiti, this 

mandated report reviews 

(1) USAID’s plans and actions to 

improve its monitoring and 

evaluation of nonemergency food 

aid programs and (2) the extent to 

which USAID has integrated its 

monitoring and evaluation of 

nonemergency food aid with 

program management. 

What GAO Recommends

GAO recommends that the USAID 

Administrator (1) develop a 

concept of operations document to 

help reduce the risks associated 

with upgrading FFP’s information 

technology system and (2) develop 

an integrated monitoring and 

evaluation plan to better oversee 

nonemergency food aid programs. 

USAID agreed with the first 

recommendation, but disagreed 

with the second recommendation, 

asserting that GAO did not fully 

consider its planning processes. 

GAO believes the recommendation 

remains valid in view of current 

findings. 

USAID’s actions to improve its monitoring and evaluation of these programs 

could be hindered by weak planning. Monitoring is essential to ensuring that 

USAID’s nonemergency food aid programs in developing countries are 

implemented as intended, and evaluation helps to assure that these programs 

achieve their goal of reducing global food insecurity. First, with funding from 

the Food for Peace Act, USAID’s Office of Food for Peace (FFP) plans to 

increase the number of field staff responsible for the monitoring of 

nonemergency food aid programs, has provided funding for the Famine Early 

Warning Systems Network, and has initiated an upgrade of its information 

technology system. However, FFP’s plans for the information technology 

upgrade lack a concept of operations document, which describes system 

characteristics for a proposed system from a user’s point of view and includes 

high-level descriptions of information systems, their interrelationships, and 

information flows. Second, with funding from other sources, USAID plans to 

carry out additional actions in an effort to improve its oversight of food aid, 

including the expansion of a computerized system for monitoring the 

implementation and management of nonemergency food aid programs. 

However, USAID has not determined a stable source of funding for these 

initiatives beyond the first year of operations due to legal restrictions that 

preclude the agency from using the newly authorized funding for grants and 

cooperative agreements. 

USAID’s monitoring and evaluation of its nonemergency food aid programs 

are consistent to varying degrees with some of the principles established by 

the American Evaluation Association’s Task Force on Evaluation Policy to 

integrate evaluation into program management. GAO found that (1) FFP’s 

actions were generally consistent with the principles for policies and 

procedures and for independence. For example, FFP has issued policies and 

procedures for monitoring and evaluating food aid programs and generally 

uses external evaluators to assess its multiyear assistance programs. 

(2) FFP’s actions were partially consistent with the principles for scope and 

coverage, dissemination of results, professional competence, and resources. 

For example, FFP relies on a range of staff to perform its monitoring and 

evaluation, but does not have reliable data on the numbers of field staff who 

have competencies in monitoring and evaluation, or their specific skills. 

(3) FFP’s actions were not consistent with the principles for monitoring and 

evaluation plans. While FFP plans some of its monitoring and evaluation 

activities—such as final evaluations for multiyear assistance programs—it 

lacks an integrated plan to ensure that monitoring and evaluation results will 

be used to improve program management. 

View GAO-09-980 or key components.

For more information, contact Thomas Melito 

at (202) 512-9601 or melitot@gao.gov. 
Page i GAO-09-980 International Food Assistance 

Contents 

Letter 1

Results in Brief 5 

Background 8 

Weaknesses in Planning Could Hinder USAID’s Actions to Improve 

Monitoring and Evaluation of Nonemergency Food Aid 

Programs 15 

USAID’s Monitoring and Evaluation of Nonemergency Food Aid 

Are Not Fully Integrated with Program Management 26 

Conclusions 35 

Recommendations for Executive Action 35 

Agency Comments and Our Evaluation 36 

Appendix I Objectives, Scope, and Methodology 39 

Appendix II USAID Report to Congress 42 

Appendix III Examples of Activities Supported with 

Nonemergency Food Aid 48 

Appendix IV Comments from USAID 49 

Appendix V GAO Contact and Staff Acknowledgments 55 

Related GAO Products 56 

Table 

Table 1: Types of Monitoring and Evaluation Activities Performed 

by FFP Staff, Implementing Partners, and External 

Evaluators 14 
Figures 

Figure 1: Countries That Received U.S. Nonemergency Food Aid in 

Fiscal Year 2008 9 

Figure 2: A Framework for Program Management of 

Nonemergency Food Aid That Integrates Monitoring and 

Evaluation 12 

Figure 3: USAID Allocations of the Food for Peace Act Funding for 

Monitoring and Evaluation in Fiscal Year 2009 and 

Implementation Timelines 16 

Figure 4: FFP Priority Countries and Locations of New Positions 

for the Monitoring of Nonemergency Food Aid Programs 18 

Figure 5: Examples of Activities Supported with Nonemergency 

Food Aid 48 

Page ii GAO-09-980 International Food Assistance 
Abbreviations 

ADS Automated Directives System 

AEA American Evaluation Association 

AED Academy for Educational Development 

BEST Bellmon Estimation for Title II 

DA Development Assistance 

DAP Development Assistance Program 

DEC Development Experience Clearinghouse 

EFP emergency food product 

FANTA-2 Food and Nutrition Technical Assistance II Project 

FAO Food and Agriculture Organization 

FEWS NET Famine Early Warning Systems Network 

FFP Office of Food for Peace 

FFPMS Food for Peace Management System 

IEEE Institute of Electrical and Electronics Engineers 

MYAP Multiyear Assistance Program 

NGO nongovernmental organization 

OFDA Office of Foreign Disaster Assistance 

PDA personal data assistant 

PM2A Preventing Malnutrition in Children Under 2 Approach 

SYAP Single-Year Assistance Program 

UN United Nations 

USAID U.S. Agency for International Development 

WFP World Food Program 

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 iii GAO-09-980 International Food Assistance 
Page 1 GAO-09-980 International Food Assistance 

 

United States Government Accountability Office

Washington, DC 20548 

 

September 28, 2009 

The Honorable Blanche Lambert Lincoln 

Chair 

The Honorable Saxby Chambliss 

Ranking Minority Member 

Committee on Agriculture, Nutrition, and Forestry 

United States Senate 

The Honorable Collin C. Peterson 

Chair 

The Honorable Frank D. Lucas 

Ranking Member 

Committee on Agriculture 

House of Representatives 

The Honorable Howard L. Berman 

Chair 

The Honorable Ileana Ros-Lehtinen 

Ranking Member 

Committee on Foreign Affairs 

House of Representatives 

The number of undernourished people worldwide has been growing and 

now exceeds 1 billion, according to the estimates of the United Nations 

(UN) Food and Agriculture Organization (FAO). This calls into question 

the feasibility of attaining the 1996 World Food Summit target of reducing 

the number of hungry people by half to no more than 420 million by 2015. 

The United States is the world’s largest donor of food aid, and the U.S. 

Agency for International Development (USAID) Office for Food for Peace 

(FFP) administers the largest nonemergency food aid program funded 

under the Food for Peace Act.1

 FFP has adopted as its strategic objective 

the reduction of food insecurity in vulnerable populations. Specifically, 

FFP’s Strategic Plan for 2006-2010 identifies two intermediate results: 

1

Section 3001 of Pub. L. No. 110-246, the Food, Conservation, and Energy Act of 2008 

changed the title of the underlying legislation from the Agricultural Trade Development 

Assistance Act of 1954, also known as Pub. L. 480, to the Food for Peace Act. Title II of the 

Food for Peace Act addresses donation of agricultural commodities for humanitarian 

purposes. 
 

(1) enhancing FFP’s global leadership in reducing global food insecurity 

and (2) increasing FFP’s program impact in the field.2

Monitoring3

 and evaluation4 of nonemergency food aid—one of the largest 

sources of U.S. funding focused on food security—are critical oversight 

and program management tools that would help to ensure that FFP meets 

its strategic objective. The size and scope of FFP’s activities are 

substantial—in fiscal year 2008, FFP supported 20 grantees that 

implemented 92 activities in 28 countries—but a number of recent reviews 

have found that monitoring and evaluation of these activities have been 

insufficient. In 2007, we found that the USAID Inspector General had 

previously reported that monitoring had not been regular and systematic 

and that, in some cases, intended recipients had not received food aid or 

the number of recipients could not be verified. In April 2007, we reported 

that USAID had only 23 Title II-funded staff assigned to missions and 

regional offices in just 10 countries to monitor programs that cost about 

$1.7 billion in 55 countries in the previous fiscal year. Our audit work also 

indicated that monitoring had been insufficient due to various factors 

including limited staff, competing priorities, and legal restrictions on the 

use of food aid resources. To ensure the effective use of food aid, we 

recommended that USAID improve its monitoring of food aid programs to 

strengthen proper management and implementation of these programs.5

USAID agreed, noting that monitoring of all its grant programs is required 

and that its implementing partners are legally required to monitor and 

report their findings to USAID. Like monitoring, evaluation is crucial to 

ensuring that best practices and lessons learned are considered in the 

 

2

USAID FFP, Bureau for Democracy, Conflict, and Humanitarian Assistance, Strategic Plan 

for 2006-2010 (Washington, D.C.: May 2005). 

3

For the purposes of this report, we consider whether agencies are monitoring (1) that the 

necessary inputs for programs (equipment, supplies, and personnel) are in place and that 

programs are being implemented as intended and (2) that programs are achieving their 

expected outputs and targets by regularly tracking performance indicators. See appendix I 

for more details. 

4

For the purposes of this report, we consider whether agencies are evaluating on a periodic 

or ad hoc basis (1) the extent to which program objectives were achieved as well as the 

factors that influenced outcome achievement and (2) the degree to which outcomes and 

impacts can be attributed directly to programs, and the cost effectiveness of the programs. 

These studies are often considered cross-cutting because they look across projects, 

programs, and countries, among other things. See appendix I for more details. 

5

This recommendation was also addressed to the U.S. Department of Agriculture. See GAO, 

Foreign Assistance: Various Challenges Impede the Efficiency and Effectiveness of U.S. 

Food Aid, GAO-07-560 (Washington, D.C.: Apr. 13, 2007). 

Page 2 GAO-09-980 International Food Assistance 
 

management and implementation of existing programs and in designing 

new ones. However, for many years, USAID did not place a great deal of 

importance or invest many resources in evaluation. In a June 2009 speech, 

the Secretary of State, whose department coordinates U.S. development 

assistance, recognized that “...too often, program evaluation is treated as 

an afterthought, and sometimes is overlooked entirely.” To rectify this 

situation, the Secretary announced that the Department of State (State) 

had for the first time developed a policy for integrating evaluation into its 

work worldwide.6

In passing the Food for Peace Act in 2008, Congress authorized up to $22 

million annually in funding for fiscal years 2009 through 2012 to USAID for 

program oversight to improve, monitor, and evaluate the effectiveness and 

efficiency of nonemergency food aid programs—and, consistent with our 

2007 recommendation, required the USAID Administrator to submit an 

implementation report on the agency’s efforts in these areas.7

 Congress 

also required the Comptroller General of the United States to review 

USAID’s report and provide recommendations for improvement. To 

address this congressional mandate, we reviewed (1) USAID’s plans and 

actions to improve its monitoring and evaluation of nonemergency food 

aid programs provided under the Food for Peace Act and (2) the extent to 

which USAID has integrated its monitoring and evaluation of 

nonemergency food aid with program management, particularly with 

regard to established principles. In this review, we focused on oversight 

practices of FFP, not of USAID as a whole. 

To address these objectives, we examined USAID’s December 2008 report 

to Congress, which outlines FFP’s plans to improve its monitoring and 

evaluation of nonemergency food aid programs, and actions FFP has taken 

to date. We interviewed USAID officials, including FFP field staff 

responsible for monitoring the implementation of nonemergency food aid 

programs, and implementing partners such as nongovernmental 

organizations (NGO) and the World Food Program (WFP). We considered 

established principles for monitoring and evaluation—especially the 

 

6

In the same speech, the Secretary of State also noted that U.S. diplomacy and development 

demand “our best efforts and deepest commitment to achieving sustainable results” and 

called for an evidence-based approach to foreign policy. 

7

See appendix II for USAID’s report to Congress issued on December 31, 2008. 

Page 3 GAO-09-980 International Food Assistance 
 

“Roadmap” principles of the American Evaluation Association (AEA),8

which have been developed to integrate monitoring and evaluation with 

program management; GAO standards and prior GAO work; USAID 

guidance; and guidelines that the Institute of Electrical and Electronics 

Engineers (IEEE) has established for information technology.9

 We 

conducted fieldwork in Bangladesh and Haiti,10 where we met with U.S. 

mission officials, host government officials, bilateral and multilateral 

donor representatives, and NGO representatives. In Bangladesh and Haiti, 

we also visited various WFP and USAID project sites supported by 

nonemergency food aid and food aid logistics facilities. 

We conducted this performance audit from March 2009 to September 2009, 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. (Appendix I provides a detailed 

discussion of our objectives, scope, and methodology.) 

 

8

AEA is an international professional association of evaluators devoted to the application 

and exploration of program evaluation, personnel evaluation, technology, and other forms 

of evaluation. In February 2009, AEA’s Task Force on Evaluation Policy issued An 

Evaluation Roadmap for a More Effective Government, which recommended a framework 

for each federal agency to guide the development and implementation of its evaluation 

programs. The framework offers a set of guiding principles intended to facilitate the 

integration of monitoring and evaluation activities with program management. We used the 

AEA framework in considering the extent to which USAID’s practices for monitoring and 

evaluation are consistent with established principles. Additionally, GAO has issued 

guidance on aspects of monitoring and evaluation over the years in reports including 

Performance Measurement and Evaluation: Definitions and Relationships, 

GAO-05-739SP (Washington, D.C.: May 2005); The Results Act: An Evaluator’s Guide to 

Assessing Agency Annual Performance Plans, GAO/GGD-10.1.20 (Washington, D.C.: April 

1998); and Designing Evaluations, GAO/PEMD-10.1.4 (Washington, D.C.: March 1991). 

9

IEEE is a nonprofit, technical professional association that develops standards for a broad 

range of global industries including the information technology and information assurance 

industries and is a leading source for defining best practices. 

10We selected Bangladesh and Haiti based on the size and scope of USAID’s nonemergency 

food aid programs, the presence of field monitoring staff, and the differences in how food 

aid programs are monitored in these countries (For example, Layers, a computerized 

monitoring system for quality assurance, is used in Haiti but not in Bangladesh). 

Page 4 GAO-09-980 International Food Assistance 
 

USAID’s actions to improve its monitoring and evaluation of 

nonemergency food aid programs could be hindered by weak planning. 

First, with funding from the Food for Peace Act, USAID’s FFP (1) plans to 

use $5 million to increase the number of field staff responsible for the 

monitoring of food aid programs, but it does not have a systematic process 

in place to determine appropriate staffing levels for effective monitoring 

and evaluation; (2) has provided $7.6 million in funding for the Famine 

Early Warning Systems Network (FEWS NET) operational budget in fiscal 

year 2009; and (3) has issued a contract for $637,000 to begin upgrading its 

information technology system, which is expected to fully capture food 

commodity management data and have the capability to interface with 

USAID’s core financial system. However, FFP’s plans for the information 

technology upgrade lack a concept of operations document, which 

describes characteristics for a proposed system from a user’s point of view 

and includes high-level descriptions of information systems, their 

interrelationships, and information flows. Second, with funding from other 

sources, FFP (1) plans to expand the use of Layers—a computerized 

system for monitoring the implementation and management of 

nonemergency food aid programs—from 3 pilot countries to 20 countries 

by the end of 2012; (2) has commissioned several cross-cutting evaluations 

of nonemergency food aid projects through USAID’s cooperative 

agreement with the Food and Nutrition Technical Assistance (FANTA-2) 

Project of the Academy for Educational Development (AED) and plans to 

improve the quality of assessments and targeting approaches for FFP 

programs; and (3) has launched a 3-year pilot project intended to improve 

the market analysis required before food aid programs are approved in 

recipient countries. In May 2009, however, USAID’s General Counsel 

determined that the agency does not have the legal authority to use Food 

for Peace Act funding for the cooperative agreement required to 

implement Layers and the cross-cutting evaluations, which are essential to 

improving monitoring and evaluation of USAID’s nonemergency food aid 

programs. USAID has not made provisions for alternative sources of 

funding for these initiatives beyond the cost of the start-up and first year 

of operations. 

Results in Brief 

USAID’s monitoring and evaluation of its nonemergency food aid 

programs are consistent to varying degrees with some of the “Roadmap” 

principles established by AEA to integrate evaluation into program 

management. We found that USAID’s actions were (1) generally 

consistent with the AEA principles for policies and procedures and for 

independence; (2) partially consistent with the principles for scope and 

coverage, dissemination of results, professional competence, and 

Page 5 GAO-09-980 International Food Assistance 
 

resources; and (3) not consistent with the principles for monitoring and 

evaluation plans, as discussed below: 

• Policies and procedures. In accordance with AEA’s recommendation for 

established and published policies for monitoring and evaluation, USAID’s 

guidance—which applies to FFP— details the agency’s monitoring and 

evaluation requirements. In addition, FFP has issued several information 

bulletins for staff and implementing partners that explain policies and 

requirements regarding monitoring and evaluation, reporting, and 

performance indicators. 

• Independence. To help ensure independence as outlined in AEA’s 

“Roadmap” principles, FFP requires that each multiyear assistance 

program’s final evaluation be performed by external evaluators. In 

addition, it generally uses external entities to perform cross-cutting 

evaluations with funding from the Food for Peace Act and other sources. 

• Scope and coverage. In accordance with AEA’s principle that monitoring 

should be conducted for most of an agency’s programs and throughout the 

programs’ life cycle, FFP requires the monitoring and evaluation of all of 

its multiyear assistance programs and has published policies and 

procedures to guide their oversight. However, in recent years, FFP has 

conducted only a few periodic, cross-cutting evaluations that examined 

the relative effectiveness of a range of its programs, projects, and 

activities. 

• Dissemination of results. AEA recommends that agencies disseminate the 

results of their monitoring and evaluation activities on easily accessible 

Web sites. However, FFP does not routinely and consistently disseminate 

evaluation results. Although an FFP requirement states that project 

evaluations should be posted in a central electronic clearinghouse, FFP 

has not ensured that implementing partners routinely comply with it. 

• Professional competence. AEA recommends that agencies should have 

competent and qualified staff to perform monitoring and evaluation. FFP 

relies on a range of staff to perform its monitoring and evaluation, 

including field staff, implementing partners’ monitoring and evaluation 

staff, and FANTA-2 staff. However, it does not have reliable data on the 

numbers of field staff who have monitoring and evaluation competencies, 

or their specific skills. 

• Resources. AEA recommends that agencies should have sufficient resources 

for monitoring and evaluation. Although the 2008 Food for Peace Act grants 

USAID up to $22 million in new funding annually in fiscal years 2009 through 

Page 6 GAO-09-980 International Food Assistance 
 

2012 to improve, monitor, and evaluate the effectiveness and efficiency of 

nonemergency food aid programs, it is difficult to determine whether FFP’s 

level of funding for proper oversight of nonemergency food aid is sufficient 

because FFP does not know exactly how much it spends on monitoring and 

evaluation and has not done an evaluation of its resource needs. 

• Monitoring and evaluation plans. AEA recommends that agencies should 

have multiyear plans, updated annually, that take into account evaluation 

results for program budgeting, as well as ongoing program development and 

management. While FFP plans some of its monitoring and evaluation 

activities, such as final evaluations for multiyear assistance programs, it 

lacks an integrated plan for all of its oversight activities that takes into 

account the need for evaluation results as well as risk-based policy-making 

and management needs. In addition, FFP neither systematically prioritizes 

its monitoring and evaluation needs nor links resources to risk-based needs. 

To reduce the risks associated with upgrading FFP’s information technology 

system, we are recommending that the Administrator of USAID develop a 

concept of operations document. Such a document should adhere to 

industry best practices and include key elements such as major system 

components, interfaces to external systems, and performance 

characteristics. It would also describe system characteristics for a proposed 

system from the user’s point of view and include high-level descriptions of 

information systems, their interrelationships, and information flows. 

In view of USAID’s new authority to direct up to $88 million over a 4-year 

period to improve, monitor, and evaluate the effectiveness and efficiency 

of nonemergency food aid programs, we also recommend that USAID 

develop an integrated monitoring and evaluation plan for its 

nonemergency food aid programs. Such a plan should, among other things, 

(1) link monitoring and evaluation to key USAID and FFP goals; 

(2) establish a systematic process for determining appropriate budget 

levels and staff resources for monitoring and evaluation based on an 

analysis of factors such as the nature, scope, and size of the programs; 

(3) examine all available options for funding monitoring and evaluation at 

headquarters and in recipient countries; and (4) establish time frames for 

implementing and evaluating the plan. 

USAID concurred with our first recommendation, but disagreed with the 

second recommendation, asserting that we did not adequately take into 

account documents that detail its planning processes. We considered all 

the documents that USAID cited and found that they did not constitute a 

plan, but only provided guidance for planning. Furthermore, the 

Page 7 GAO-09-980 International Food Assistance 
 

weaknesses we identified in FFP’s monitoring and evaluation efforts, 

including in the areas of resources and professional competence, 

demonstrate the need for a comprehensive monitoring and evaluation 

plan. USAID provided written comments on a draft of this report. We 

believe this recommendation remains valid. 

We have reprinted USAID’s comments in appendix IV, along with our 

responses. Additionally, USAID provided technical comments on a draft 

of this report, which we have addressed as appropriate. 

Background 

FFP is shifting to larger programs in fewer countries in order to leverage 

nonemergency food aid resources more effectively. FFP’s Strategic Plan 

for 2006-2010 concentrates on a single objective of reducing food 

insecurity in vulnerable populations with an aim to fund programs that can 

be modified when circumstances change. In fiscal year 2008, under the 

Food for Peace Act, the United States provided $354 million in 

nonemergency food aid and FFP administered nonemergency food aid 

programs in 28 countries. Beginning in fiscal year 2010, FFP will limit its 

nonemergency food aid programs to 20 priority countries.11 Of these, 16 

are in sub-Saharan Africa (Burkina Faso, Burundi, Chad, the Democratic 

Republic of Congo, Ethiopia, Liberia, Madagascar, Malawi, Mali, 

Mauritania, Mozambique, Niger, Sierra Leone, Sudan, Uganda, and 

Zambia), 2 are in Central and South Asia (Afghanistan and Bangladesh), 

and 2 are in Latin America and the Caribbean (Guatemala and Haiti). 

Figure 1 lists the countries that received nonemergency food aid in fiscal 

year 2008 and the most recent available statistics on the number of 

undernourished people and the prevalence of undernourishment in these 

countries, respectively. 

USAID Plans to Administer 

Larger Nonemergency 

Food Aid Programs in 

Fewer Priority Countries 

 

11According to FFP, the selection of the 20 priority countries for nonemergency food aid 

programs, completed in 2009, was based on a weighted average of the country’s ranking 

under three food insecurity indicators: (1) percentage of children stunted (utilization), 

(2) percentage of population living under $1 a day (access), and (3) percentage of 

population undernourished (availability). The utilization indicator contributes 60 percent to 

the needs-based country rank, whereas the access indicator and the availability indicator 

contribute 30 and 10 percent, respectively. 

Page 8 GAO-09-980 International Food Assistance 
 

Figure 1: Countries That Received U.S. Nonemergency Food Aid in Fiscal Year 2008 

0 10 20 30 40 50

Mali

Guinea

Senegal

Chad

Burundi

Mauritania

Ghana

Sierra Leone

Liberia

Bolivia

Zambia

Nicaragua

Kenya

Democratic Republic of Congo

Afghanistan

Burkina Faso

Honduras

Rwanda

Madagascar

Niger

India

Guatemala

Malawi

Mozambique

Ethiopia

Uganda

Haiti

Bangladesh

Countries that received nonemergency food aid in 

fiscal year 2008

(U.S. dollars in millions)

Number of

undernourished people

2003-2005

(in millions)

47.8

34.2

26.4

23.2

19.9

17.9

13.9

13.5

12.8

11.8

11.4

10.2

10.0

9.9

9.8

9.4

9.3

9.1

9.0

7.7

6.9

6.9

5.0

4.9

4.5

4.1

3.0

2.0

40.1

5.3

4.1

35.2

7.5

3.8

2.0

230.5

3.7

6.6

3.6

0.8

1.3

not available

43.0

11.0

1.2

5.1

2.0

1.3

2.5

1.9

0.2

4.8

3.8

3.0

1.5

1.2

Percentage of 

population that was

undernourished in 

2003-2005

27

58

15

46

38

29

16

21

29

37

40

12

10

not available

76

32

22

45

22

40

47

9

8

63

39

26

17

11

Sources: GAO analysis of USAID and Food and Agriculture Organization of the United Nations data.

Page 9 GAO-09-980 International Food Assistance 
 

FFP provides food aid funding under the Food for Peace Act using two 

primary funding mechanisms—Single-Year Assistance Programs (SYAP) 

and Multiyear Assistance Programs (MYAP). SYAPs address emergency 

needs and are used for direct distribution of food aid in emergency 

contexts.12 MYAPs, long-term programs with duration of 3 to 5 years, are 

used to implement development activities that target chronically foodinsecure populations.13 In carrying out nonemergency programs through 

its implementing partners, FFP uses a combination of Food for Peac

commodities for direct distribution, local currency generated through 

monetization,

e 

 

14 and cash resources to implement activities that target 

chronic food insecurity. (For illustrative examples of the types of 

activities supported by nonemergency food aid, such as project activities 

we observed in Bangladesh and Haiti, see app. III.) 

Food for Peace 

Nonemergency Food Aid 

Programs Are 

Implemented through 

Grants for Single-Year and 

Multiyear Assistance 

Programs 

12On a case-by-case basis, SYAPs may be extended beyond the initial 12 months approved 

for the program. 

13These development projects are typically supported by implementing partners that sell 

food aid commodities as a means to generate cash to fund these projects. Food-insecure 

populations, as defined in FFP’s Strategic Plan for 2006-2010, are people at risk of food 

insecurity because of physiological, socioeconomic, and political status, physical security, 

and limited or weak governance or a population whose ability to cope has been temporarily 

hindered by a shock. Beginning in 2006, multiyear assistance programs, MYAPs, replaced 

Development Assistance Programs (DAP). DAPs focused on increasing food security, 

whereas MYAPs—reflecting FFP’s main strategic objective for 2006-2010—focus on 

reducing food insecurity. 

14Monetization is a practice that involves the sale in a recipient country of food aid 

commodities that have been purchased in and shipped from the United States. 

Page 10 GAO-09-980 International Food Assistance 
 

Monitoring and evaluation perform two separate but related functions. 

Monitoring is the collection of data to determine whether programs are 

being implemented as intended and the tracking of progress using 

preselected indicators throughout the life of the program. Evaluation 

consists of periodic or ad hoc studies to assess how and whether programs 

achieved their expected goals. It can also consider what outcomes can be 

attributed to the program, as well as program cost-effectiveness. 

Evaluations can rely on a range of quantitative and qualitative measures as 

well as preselected indicators, comprehensive research designs, and the 

use of appropriate statistical analysis of the data. Figure 2 outlines a 

framework based on our review of Food for Peace nonemergency 

programs, as well as AEA and WFP guidance that illustrates how 

monitoring and evaluation could be integrated with program 

management15 of nonemergency food aid. 

Monitoring and Evaluation 

Are Essential to Effective 

Program Management 

 

15Following the AEA guidance, we are defining program management as the management of 

a program’s key stages, from planning and initial development through start up, ongoing 

implementation, and reauthorization. 

Page 11 GAO-09-980 International Food Assistance 
 

Figure 2: A Framework for Program Management of Nonemergency Food Aid That Integrates Monitoring and Evaluation 

Sources: GAO analysis, adapted from WFP information; GAO and USAID (photos).

Program Management 

Assessment and 

analysis

• Assess the context, 

extent, and magnitude 

of needs arising from 

current or impending 

food insecurity.

• Prioritize assistance 

for affected population 

groups and 

geographical areas.

Focus on the extent to 

which program 

objectives were 

achieved and what 

outcomes can be 

directly attributed to 

programs.

• Direct distribution 

programs may 

consider how the 

ration is affecting the 

health and nutritional 

status of beneficiaries.

• Food-for-work 

programs may focus

on how the activity is

addressing temporary 

food insecurity and 

developing a

sustainable 

community asset.

• Identify characteristics

and needs of target 

population.

• Develop objectives.

• Select food distribution 

and/or development 

activity.

Early childhood development 

Income generating activities Mother and child health and nutrition

Income generating activities

Implementation Evaluation

Planning

Monitoring

• Determine if necessary inputs (equipment, 

supplies, and personnel) are in place. 

 – Ensure that food is properly stored.

 – Check to see if health clinics are sufficiently

stocked for intended beneficiaries.

• Determine if programs are achieving their 

expected outputs by tracking performance 

indicators.

• Ensure that target number of beneficiaries are 

receiving food and attending clinics.

Page 12 GAO-09-980 International Food Assistance 
 

FFP relies on a range of staff to perform its monitoring and evaluation— 

including FFP officers in the field, implementing partners, contractors, 

and FANTA-2 staff.16 According to FFP, field staff visit project sites to 

ensure that programs are being implemented as expected. They also 

approve and oversee the implementing partners’ selection of performance 

indicators and data collection. In addition to regularly collecting 

performance data, the implementing partners perform baseline studies and 

midterm evaluations for their multiyear programs and hire external 

evaluators to conduct the final evaluations for the multiyear programs. In 

addition, FFP relies on appropriately credentialed consultants and 

researchers for some cross-cutting evaluations, which, for example, 

consider the agency’s exit strategies for nonemergency food aid programs 

in Bolivia, Honduras, and Kenya. 

FFP Relies on a Range of 

Staff to Perform Various 

Types of Monitoring and 

Evaluation Activities 

Conducting evaluations can present many challenges, such as obtaining 

reliable data and employing qualified evaluators. These challenges can be 

compounded in developing countries, where local conditions may be 

difficult and local capacity is often limited. For example, a recent review 

of evaluations conducted by an international NGO cited numerous 

challenges in-country including climate, poor economic status, civil unrest, 

migration of beneficiaries, cultural biases, poor recordkeeping, and 

turnover in government and NGO staff.17

Table 1 summarizes the various types of monitoring and evaluation 

activities that FFP performs. The table also indicates which staff have 

primary responsibility for the activities, briefly describes the activities, and 

provides examples of them. 

 

16The FANTA-2 project was established through a cooperative agreement between USAID 

and AED. Under subagreements, FANTA-2 staff collaborate with partner organizations 

such as Cornell University, Tufts University, Food Aid Management, the International Food 

Policy Research Institute, Technical Assistance to NGOs International, and the World 

Health Organization. 

17See Michael Bamberger, Jim Rugh, and Linda Mabry, Real World Evaluation: Working 

under Budget, Time, and Data and Political Constraints (Thousand Oaks, Calif.: Sage, 

2006). The authors reviewed evaluations of CARE International programs and projects. 

Page 13 GAO-09-980 International Food Assistance 
 

Table 1: Types of Monitoring and Evaluation Activities Performed by FFP Staff, Implementing Partners, and External 

Evaluators 

Types of monitoring 

and evaluation 

activities 

Staff with primary 

responsibility Description of activities Examples 

Monitoring of project 

sites and activities 

USAID mission staff Field staff visit project sites to check 

on inputs and program 

implementation. 

Field staff checks on, for example: 

• storage conditions of food aid 

warehouses, and 

• whether clinics for mothers and 

children offer the required services. 

Tracking of performance 

measures 

Implementing 

partners with 

oversight from FFP 

and the USAID 

mission 

Implementing partners select 

performance measures used by 

FFP, State/F,a

 and the mission. 

USAID headquarters staff review 

and approve the indicators. 

Implementing partners collect data 

on the measures. 

USAID and implementing partners track, 

for example: 

• FFP indicators (e.g., the number of 

farmers who received extension 

services), and 

• State/F indicators (e.g., the number 

of beneficiaries of agricultural 

assistance). 

Evaluating program 

outcomes 

External evaluators Implementing partners hire external 

evaluators to conduct the projects’ 

final evaluations, and determine 

whether the goals were achieved. 

One final evaluation reported a 

reduction in acute malnutrition in 

children aged 6-59 months during the 

life of the project. 

The evaluations generally also provided 

reasons that goals were or were not 

met, and lessons learned. 

Evaluating program 

impacts 

FANTA-2, its partner 

organizations, and 

contractors to FFP 

FFP has commissioned several 

cross-cutting studies designed to 

evaluate what impacts can be 

attributed to its programs and to 

analyze the relative effectiveness of 

alternative delivery mechanisms. 

One evaluation examined the impact 

and cost-effectiveness of two 

approaches to prevent malnutrition in 

infants, using randomly selected 

comparison groups to judge the impacts 

and effectiveness of each approach. 

Related studies FANTA-2, its partner 

organizations, and 

contractors to FFP 

Studies that are intended to help 

understand and improve aspects of 

program management. 

FFP plans another full review of all its 

multiyear projects. The last such review 

recommended a series of improvements 

in, for example, program design and 

results reporting. 

Sources: GAO analysis of AED/FANTA-2 and USAID documents. 

a

In June 2006, the Office of the Director of Foreign Assistance (State/F) was created at State to carry 

out the Director of Foreign Assistance’s responsibilities and focus the use of foreign assistance on 

achieving the Secretary’s transformational diplomacy goal: “to help build and sustain democratic, 

well-governed states that will respond to the needs of their people, reduce widespread poverty, and 

conduct themselves responsibly in the international system.” State/F was given responsibility for 

developing, among other things (1) a coherent, coordinated U.S. government foreign assistance 

strategy; (2) multiyear country-specific assistance strategies and annual country specific operational 

plans; (3) consolidated policy, planning, budget, and implementation mechanisms and staff functions 

required to provide leadership to USAID and State foreign assistance; and (4) guidance for foreign 

assistance delivered through other U.S. government agencies. 

Page 14 GAO-09-980 International Food Assistance 
 

USAID has begun taking a series of actions to improve its monitoring and 

evaluation of nonemergency food aid programs, as mandated by the Food 

for Peace Act passed in July 2008. These efforts include (1) increasing the 

number of field staff responsible for the monitoring of nonemergency food 

aid programs; (2) expanding FEWS NET; (3) upgrading FFP’s information 

technology system; (4) expanding the use of Layers, a computerized 

monitoring system for quality assurance; (5) improving the quality of 

evaluations, assessments, and targeting approaches; and (6) launching a 

pilot project to improve market analysis in countries receiving U.S. 

nonemergency food aid. Weaknesses in planning could hinder USAID’s 

ability to effectively implement these actions, but it is too early to assess 

impact because the agency’s efforts are still in progress. As of August 2009, 

USAID estimated that, in fiscal year 2009, it will have spent about $13 

million of the $22 million authorized for monitoring and evaluation of 

nonemergency food aid under the Food for Peace Act. Figure 3 

summarizes the allocation of the funds and the implementation timelines. 

Weaknesses in 

Planning Could 

Hinder USAID’s 

Actions to Improve 

Monitoring and 

Evaluation of 

Nonemergency Food 

Aid Programs 

Page 15 GAO-09-980 International Food Assistance 
 

Figure 3: USAID Allocations of the Food for Peace Act Funding for Monitoring and Evaluation in Fiscal Year 2009 and 

Implementation Timelines 

Source: GAO analysis of USAID data.

Total = $22,000,000

Implementation timelines

Fiscal year

Allocation of Food for Peace Act funding

23%

35%

40%

2008 2009 2010 2011

Information technology upgrade

Monetization study

FEWS NET

New FFP field staff positions

FEWS NET, $7,600,000

New FFP field staff positions, $5,000,000a

3%

Information technology upgrade, $637,000

.02%

Monetization study, $5,000

Unused funding, $8,758,000

Late Early Mid Late Early Mid Late Early

a

As of August 2009, USAID had filled 9 of the 21 new positions and will therefore not spend the full $5 

million it planned to spend within the fiscal year. 

Page 16 GAO-09-980 International Food Assistance 
 

USAID has announced plans to increase the number of field staff 

responsible for the monitoring of food aid programs, which would provide 

minimal FFP presence in all priority countries. The agency plans to use 

approximately $5 million of its new Food for Peace Act funding to add 21 

full-time field staff whose responsibilities include the monitoring of 

nonemergency food aid programs. According to USAID, 1 of the new 

positions is located in USAID’s Southern Africa Regional Office in Pretoria 

(South Africa) while the other 20 new positions are or will be located in 

designated priority countries for nonemergency food aid programs 

(including 19 in sub-Saharan Africa and 1 in Guatemala). As of August 

2009, all 21 of the new positions had been established, of which 9 had been 

filled.18 Figure 4 shows the location of the new positions, including those 

filled, in FFP’s 20 priority countries for nonemergency food aid. 

USAID Has Allocated New 

Funding to Increase 

Staffing Levels and 

Upgrade Information 

Systems but Has Not 

Developed Key Processes 

and Plans in These Areas 

Staffing Levels 

 

18The 9 filled positions are as follows: 1 in Burundi, 3 in Madagascar, 1 in Malawi, 1 in Mali, 

1 in Niger, 1 in Zambia, as well as 1 position in the Southern Africa Regional Office. 

Page 17 GAO-09-980 International Food Assistance 
 

Figure 4: FFP Priority Countries and Locations of New Positions for the Monitoring of Nonemergency Food Aid Programs 

Sources: GAO analysis of USAID data; Map Resources (map).

20 priority countries for 

nonemergency food aid 

programs

Zambia

Uganda

Sudan

Niger

Mozambique

Mali

Malawi

Madagascar

Ethiopia

Chad

Burundi

Dem. Republic

of Congo

Southern 

Africa 

Regional 

Office

Mauritania

Sierra Leone

Liberia

Burkina Faso

1

Haiti

Guatemala

Haiti

Bangladesh

Afghanistan

New Food for Peace-funded positions

Filled

To be filled

Page 18 GAO-09-980 International Food Assistance 
 

We found that USAID does not have a systematic process in place to 

determine appropriate staffing levels for effective monitoring and 

evaluation. According to USAID officials, creating new positions in field 

missions where FFP has lacked staff was the primary consideration for 

their allocation. Hence, 17 of the new positions are in countries where 

USAID runs nonemergency food aid programs but has lacked FFP 

program management staff to date, namely: Burkina Faso, Burundi, 

Liberia, Madagascar, Malawi, Mali, Mauritania, Niger, Sierra Leone, and 

Zambia.19 The remaining 4 new positions augment existing FFP program 

management staff in the Democratic Republic of Congo, Guatemala, 

Sudan, and the Southern Africa Regional Office in Pretoria. 

USAID plans to replace its current Food for Peace Information System 

with a new Food for Peace Management System (FFPMS) that it expects 

will address several of FFP’s current information technology issues, 

including the collection, tracking, and interfacing of food aid program 

data. According to USAID’s December 2008 report to Congress, the new 

FFPMS is expected to involve collaboration and testing with users in each 

business area in which the system is used. These areas include budgeting, 

proposal, document management, commodity purchase, commodity 

booking and shipping, tracking, monitoring and evaluation, reporting, 

closeout, and interface with internal and external information systems. In 

addition, USAID officials explained that, unlike FFPIS, FFPMS is intended 

to be an all-inclusive system that will fully capture the movement of U.S. 

food aid commodities, used for both emergency and nonemergency 

purposes, from the initial transfer authorization to the commodity’s final 

distribution site. FFPMS is also expected to (1) capture implementing 

partners’ data on Food for Peace resources, including revenues from 

monetization transactions as well as costs incurred; (2) allow FFP to 

aggregate information for its implementing partners’ annual results 

reports; and (3) have the capability to interface with USAID internal 

systems—such as USAID’s core financial system, known as Phoenix, 

which captures all USAID transactions—as well as with external agency 

information systems with which FFP conducts business to allow the 

collection and sharing of information among and between agencies. With 

systematic and electronic collection of information, USAID anticipates 

being able to monitor the relative efficiency of its nonemergency food aid 

Information Technology 

System 

 

19According to USAID, 4 new positions in Madagascar include 1 administrative staff 

member and 1 driver. 

Page 19 GAO-09-980 International Food Assistance 
 

programs and adequately monitor the degree to which monetization 

revenues cover costs. 

USAID is in the initial stages of this planned information systems upgrade. 

In June 2009, USAID awarded a contract for $637,000 to develop a 

management strategy and framework for implementing FFPMS by the end 

of fiscal year 2010. The contractor’s responsibilities, as defined in the 

contract, are to revalidate assumptions made within the 2005 requirements 

and architecture diagram;20 revalidate FFP’s technical environment; and 

update the requirements, documents, and architectural design. The 

contractor is also expected to make a recommendation to USAID by 

December 2009 for a commercial off-the-shelf software package that 

would best fit FFP’s needs. 

A concept of operations document is a critical element in developing 

information system requirements and testing activities. However, USAID 

has not developed such a document for this initiative. This document is 

normally one of the first documents produced during a disciplined 

development effort because it describes system characteristics for a 

proposed system from a user’s point of view.21 The key elements that 

should be included in the document are major system components, 

interfaces to external systems, and performance characteristics, such as 

speed and volume. A concept of operations document defines how an 

organization’s day-to-day activities will be carried out to meet mission 

needs and includes high-level descriptions of information systems, their 

interrelationships, and information flows. It also describes the operations 

that must be performed, who must perform them, and where and how the 

operations will be carried out. 

To provide timely and rigorous early warning and vulnerability 

information on emerging food security issues, USAID is making a 

contribution to the FEWS NET fiscal year 2009 operational budget. FEWS 

NET monitors and analyzes relevant data, using multiple technologies 

such as satellites and field observations, to identify threats to food security 

Famine Early Warning Systems 

Network 

 

20The term “architectural diagram” includes a description of an organization’s current or “as 

is” information technology environment and its target or “to be” information technology 

environment. The architecture also includes a transition or sequencing plan, which is based 

on an analysis of the gaps between the “as is” and “to be” environments. 

21IEEE Guide for Information Technology—System Definition—Concept of Operations 

Document, Std. 1362-1998. 

Page 20 GAO-09-980 International Food Assistance 
 

and their impacts on livelihoods and markets. Chemonics, the private firm 

responsible for implementing FEWS NET along with several U.S. 

government agencies, currently maintains 20 national and 3 regional field 

offices in sub-Saharan Africa, Central America, Haiti, and Afghanistan. 

Anticipating an increase in food insecurity in countries where there is no 

FEWS NET presence, Chemonics plans to implement three remote 

monitoring pilot projects—in Burundi, Pakistan, and Yemen—that are 

expected to be completed by the end of fiscal year 2010.22

In fiscal year 2009, USAID is providing $7.6 million of the newly authorized 

Food for Peace Act funding to support FEWS NET. This funding is not 

designated to support the remote monitoring pilot projects but is a 

contribution to FEWS NET’s operational budget of $20 million, with the 

remaining $12.4 million coming from the Development Assistance (DA), 

the Office of Foreign Disaster Assistance (OFDA), and other sources. 

Legal Restrictions on 

Usage of Food for Peace 

Act Funding Could 

Hamper USAID’s Plans to 

Expand FFP’s New 

Monitoring System and 

Improve Evaluations 

Legal restrictions on the allowable uses of Food for Peace Act funding 

could hamper USAID’s plans to expand FFP’s new monitoring system for 

quality assurance. USAID plans to expand the use of Layers—a 

computerized system using personal data assistant (PDA) devices for 

monitoring the implementation and management of nonemergency food 

aid programs—from 3 pilot countries to 20 countries by the end of 2012, 

through its multiyear cooperative agreement with AED.23 The purpose of 

Layers is to help FFP staff responsible for the monitoring of food aid 

Plans to Expand FFP’s 

Computerized Monitoring 

System for Quality Assurance 

 

22Remote monitoring will be based upon a regular assessment of (1) a livelihoods-based 

analytic food security framework of food security, (2) weather and crop monitoring and 

assessment, and (3) markets and trade monitoring and assessment. 

23Layers was developed as part of the FANTA-2 project. FANTA staff conduct initial 

training on the use of Layers for FFP field staff and provide continuing technical assistance 

to FFP staff after Layers is introduced. 

Page 21 GAO-09-980 International Food Assistance 
 

programs to collect data to assess the quality of implementing partner 

operations in the field. Layers can be used to monitor a wide range of 

programs and activities, including the conditions of storage in commodity 

warehouses and the quality of services delivered by FFP’s implementing 

partners, such as food-for-work activities, provision of community health 

services, and maternal and child health and nutrition. Prior to 2009, Layers 

was piloted in Haiti, Ethiopia, and Madagascar. USAID estimates the onetime cost for the start-up to introduce Layers to a new country to be 

approximately $144,000. It began rolling out the system in Guatemala, 

Mali, and Uganda in 2009 and plans to do so in all the remaining priority 

countries by the end of 2012 as their multiyear assistance programs are 

approved. However, in May 2009, USAID’s General Counsel determined 

that the Food for Peace Act precludes the agency from using the newly 

authorized funding for nonemergency food aid monitoring and evaluation 

for grants and cooperative agreements.24 Section 3012(f)(5) of the Food for 

Peace Act authorizes USAID to enter into personal services contracts to 

carry out monitoring and evaluation but does not refer to grants or 

cooperative agreements.25 As a result, FFP cannot move forward with its 

original plans to use Food for Peace Act funding to expand the 

implementation of Layers and will instead need to use other sources of 

funding that could be made available for this purpose.26 According to FFP 

officials, the current plan is to use other funding streams, such as the DA 

account, to fund the costs of the start-up of Layers and the first year of the 

system’s operation. However, these officials noted that due to competing 

priorities for DA, it cannot be relied upon as a stable source of funding. 

 

24Federal grants and cooperative agreements are used to accomplish a public purpose of 

support or stimulation authorized by the federal statute. The award mechanisms of grants 

and cooperative agreements are the largest components of awards made by USAID. 

25Personal services contracts are characterized by the employer-employee relationship that 

exists between the government and the contractor. The contractor is treated very much 

like the civil service staff, frequently performing the same or similar work. USAID hires 

personal services contractors to work in a variety of fields both in USAID/Washington and 

in USAID missions worldwide. 

26In addition, the viability of Layers will depend on USAID missions’ willingness to use their 

own funds to provide ongoing support for Layers—estimated by FFP at $60,000 annually—

after the first year. FFP and FANTA-2 are optimistic that missions will want to do so both 

because the cost is small relative to improvements in the monitoring of the implementing 

partners’ programs and because the system can be easily adapted for nonfood aid 

programs. 

Page 22 GAO-09-980 International Food Assistance 
 

USAID plans to improve the quality of evaluations through a number of 

ongoing and future studies. Using $5,000 of the newly authorized funding 

for monitoring and evaluation, the agency has signed a contract with 

Michigan State University for a study of monetization that is expected to 

be available for release in December 2009. It has also commissioned 

several cross-cutting evaluations and related studies that are expected to 

improve the quality of assessments, targeting approaches, design, and 

evaluation of nonemergency food aid programs. For example, through a 

cooperative agreement with AED, USAID is funding the FANTA-2 project 

to initiate the following multiyear studies in 2009: 

Plans to Improve the Quality of 

Evaluations 

• a study of exit strategies in Bolivia, Honduras, and Kenya, which will 

produce recommendations for effective ways to sustain program benefits 

after U.S. nonemergency food aid programs have been phased out; 

• a study to identify key components of success in Preventing Malnutrition 

in Children Under 2 Approach (PM2A) programs in Guatemala and 

Burundi; 

• a study to improve the early warning and response capacity in FFP’s 

multiyear assistance programs in Haiti, Niger, and Uganda; 

• an update of the 2002 Food Aid and Food Security Assessment, which will 

evaluate progress made under FFP’s Strategic Plan for 2006-2010; and 

• a study testing the efficacy and safety of emergency food products (EFP) 

that is co-funded by USAID’s Bureau for Global Health and FFP. 

In addition to these cross-cutting evaluations and studies, FANTA-2 

prepared four food security country frameworks—for Bangladesh, 

Burkina Faso, Liberia, and Sierra Leone—in 2009.27 Food security country 

frameworks are assessments that provide country-specific guidance to 

partners developing new MYAP proposals and describe how Food for 

Peace resources should be programmed and integrated with other U.S. 

government funds by defining objectives, approaches, regions, and 

institutional partnerships for effective use of U.S. government resources 

dedicated to reducing food insecurity. FFP estimates the cost of FANTA2’s work on the cross-cutting evaluations, related studies, and food 

security country frameworks in fiscal year 2009 to be $4.4 million. 

 

27Prior to 2009, food security country frameworks had been prepared for Madagascar, 

Malawi, and Mozambique. 

Page 23 GAO-09-980 International Food Assistance 
 

To improve the quality of assessments and targeting approaches, FFP is 

also initiating a new cooperative agreement to identify best practices that 

will increase the efficiency and effectiveness of Food for Peace food aid 

program management and capacity building. The aim is to promote the 

broader adoption of best practices and collaboration among FFP’s 

implementing partners. As of August 2009, FFP had issued a Request for 

Applications seeking to identify potential partners’ interests, priorities, 

and capacities and estimates the cost of the award at $3.5 million. 

However, USAID has determined that the Food for Peace Act precludes 

the agency from using the newly authorized funding for monitoring and 

evaluation of nonemergency food aid for grants and cooperative 

agreements. As a result, the completion of the multiyear cross-cutting 

evaluations, as well as future food security country frameworks and “best 

practices” assessments is not assured. FFP’s current plan is to fund these 

studies from the DA account. 

USAID Is Using Other 

Funding to Improve 

Assessments Conducted 

Prior to Approving U.S. 

Food Aid Programs in 

Recipient Countries but 

Faces Implementation 

Challenges 

In August 2008, USAID launched a 3-year Bellmon Estimation for Title II 

(BEST) pilot project intended to improve the market analysis required 

before food aid programs are approved in recipient countries—commonly 

referred to as the Bellmon analysis.28 The project is funded through 

resources other than the newly authorized Food for Peace Act funding for 

monitoring and evaluation of nonemergency food aid. It aims to improve 

how nonemergency food aid data are collected and analyzed, to determine 

the appropriate level of food aid, as well as the appropriate commodities 

that can be distributed and monetized in each country. 

The pilot project reduces the potential for conflict of interest because the 

organization that does the analysis is no longer the same organization whose 

interest is directly affected by the outcome of the analysis. In the past, 

USAID’s implementing partners for nonemergency food aid distribution or 

monetization conducted and submitted the Bellmon analysis to USAID. 

However, the outcome of the analysis affected whether they could conduct 

 

28In 1977, Congress passed the Bellmon Amendment to Pub. L. No. 480 (Pub. L. No. 480 was 

renamed the Food for Peace Act in 2008). As required by the Bellmon Amendment, before 

food aid can be supplied, the U.S. government must determine that (1) adequate storage 

facilities are available in the recipient country at the time of export of the commodity to 

prevent waste or spoilage and (2) the distribution of the commodities will not result in a 

substantial disincentive or interference with domestic production or marketing in that 

country. 

Page 24 GAO-09-980 International Food Assistance 
 

monetization and, if so, how much food aid they could monetize—which, in 

turn, directly affected their operating budgets. Under the pilot project, USAID 

will have one organization, Fintrac, carry out the initial market analysis for all 

20 of USAID’s priority countries. According to Fintrac, having one 

organization do the analysis for all countries could help to improve 

consistency in analytical methodology, reporting structure, and format. 

BEST is still in its early stage of implementation. It encountered some 

difficulties in its first year of implementation and has yet to address some 

additional methodological challenges. One key challenge is ensuring the 

quality and consistency of the analysis, which can be impaired by a lack of 

reliable and up-to-date data. For example, Fintrac was able to use data 

from a recent livelihoods survey done by the World Food Program and 

FEWS NET in the Malawi assessment but had to conduct additional 

research and trips to Guatemala because it had no comparable updated 

data for that country. In addition, Fintrac officials told us that they have 

not developed quantifiable measures and thresholds agreed upon by 

USAID and its implementing partners to help guide USAID’s programming 

decisions on levels of monetization. Without quantifiable measures and 

thresholds, implementing partners could challenge USAID’s determination 

of monetization levels in a country. Finally, the law requires that the 

distribution of commodities will not result in a substantial disincentive or 

interference with domestic production or marketing in a recipient 

country—but the information Fintrac uses for its analysis, such as the 

historic levels of monetization relative to a country’s imports or 

production, does not directly answer the question of whether U.S. food aid 

will cause such disincentives. USAID and Fintrac officials acknowledged 

that additional research is needed in this area. As of July 2009, Fintrac had 

completed analyses for 7 priority countries: Burundi, Ethiopia, Guatemala, 

Madagascar, Malawi, Sudan, and Uganda, with plans to complete analyses 

for the remaining 13 priority countries through 2011. 

Page 25 GAO-09-980 International Food Assistance 
 

USAID’s monitoring and evaluation of its nonemergency food aid 

programs are consistent to varying degrees with some of the principles 

established by AEA to integrate evaluation into program management. We 

found that USAID’s actions were (1) generally consistent with the AEA 

principles for policies and procedures and for independence; (2) partially 

consistent with the principles for scope and coverage, dissemination of 

results, professional competence, and resources; and (3) not consistent

with the principles for monitoring and evaluation plans. 

USAID’s Monitoring 

and Evaluation of 

Nonemergency Food 

Aid Are Not Fully 

Integrated with 

Program Management 

USAID’s Actions Were 

Generally Consistent with 

the AEA Principles for 

Policies and Procedures 

and for Independence 

FFP has established policies and procedures for monitoring and 

evaluation that are contained primarily in several information bulletins for 

staff and implementing partners.29 Guidance can also be found in the FFP 

Process and Procedures Manual, which outlines field and headquarters 

staff’s roles and responsibilities for monitoring and evaluation. In addition, 

FFP has issued a series of technical papers by FANTA-2 that discuss the 

methodological standards and techniques that can be used for many 

aspects of monitoring and evaluation, such as statistical sampling for 

surveys of beneficiaries and preparing survey questions for key indicators. 

For example, one technical paper discusses in detail a key FFP indicator, 

household dietary diversity, and explains how to collect data through a 

questionnaire, tabulate the responses, and set appropriate targets to track 

progress over time. FFP’s policies and procedures, in conjunction with 

USAID’s official guidance, cover the types of evaluations that can be 

performed, methodologies that can be employed, ways to plan evaluations, 

the means to disseminate studies, and the independence of the staff 

performing the evaluations. 

FFP Has Issued Policies and 

Procedures for Monitoring and 

Evaluation 

Policies and Procedures

Principles:

• Agency should publish policies and 

procedures and adopt quality standards to 

guide the conduct of evaluations.

• Policies and procedures should identify 

the kinds of evaluations to be performed 

and the criteria and administrative steps

for developing evaluation plans and setting 

priorities; selecting the appropriate 

evaluation approaches and methods to be 

used; consulting subject matter experts; 

ensuring the quality of the evaluation 

products; publishing evaluation reports; 

and ensuring the independence of the 

evaluation function.

Source: AEA, An Evaluation Roadmap for a More Effective 

Government.

 

29These bulletins explain requirements regarding monitoring and evaluation, reporting, and 

performance indicators and reinforce the Automated Directives System (ADS), chapter 

203, which details the agency’s monitoring and evaluation requirements. 

Page 26 GAO-09-980 International Food Assistance 
 

USAID’s new central evaluation office collaborated with State’s Office of 

the Director of Foreign Assistance (State/F) to develop evaluation 

guidelines and standards that were placed on the United States Foreign 

Assistance Web site in March 2009. These standards and guidance 

elaborate on the official USAID and FFP guidance, and they specifically 

address some elements that are not directly addressed in the official 

guidance, most notably the standards for quality. Collectively, the FFPspecific, USAID-wide, and Foreign Assistance policies and procedures are 

generally consistent with the AEA principles. 

To help ensure independence as outlined in the AEA principle, FFP 

requires that each multiyear assistance program’s final evaluation be 

performed by external evaluators. It also relies on external entities to 

perform cross-cutting evaluations using the Food for Peace Act and other 

funding sources.30

FFP Requires External 

Evaluations to Help Ensure 

Independence 

Independence

Principle:

Evaluation managers should be independent

with respect to the design, conduct, and

results of their evaluation studies.

Source: AEA, An Evaluation Roadmap for a More Effective 

Government.

Independence in the context of final evaluations for FFP multiyear 

assistance programs means that the key evaluation experts, the team 

leader, and sectoral leads, should be external consultants hired by the 

project. Our review of the 16 final evaluations that we found on USAID’s 

Development Experience Clearinghouse (DEC) Web site determined that 

external consultants were generally listed as the prime authors.31 In some 

instances, the external evaluators were affiliated with a particular 

consulting firm and, in other instances, several external evaluators formed 

a team to perform the final evaluation. 

In addition, the cross-cutting evaluations and other FFP-funded studies are 

to be conducted by FANTA-2 and external consultants. FANTA-2 is part of 

AED, a nonprofit organization that cites integrity as one of its core 

 

30According to guidance issued by State’s Office of the Director of Foreign Assistance in 

March 2009, independent evaluations tend to have a high degree of credibility because the 

evaluators conducting them are not responsible to managers in the projects that are being 

evaluated. However, USAID’s capacity to perform independent evaluations in recent years 

has been limited because it lacked a central evaluation unit between 2006 and 2008. 

31In one instance, we were unable to determine whether the lead evaluator was 

independent due to a lack of information in the evaluation and, in another instance, it was 

not clear whether the external evaluators had worked as a team with the implementing 

partners. In addition to the 16 final evaluations we found in DEC, we looked at a final 

evaluation that the USAID mission in Bangladesh provided to us in hard copy and found 

that it had been conducted by an external evaluator. 

Page 27 GAO-09-980 International Food Assistance 
 

values.32 Our review of selected task orders, signed and made available by 

FANTA-2, found them in line with the AEA principle for independence. For 

example, not only did its task order for a subrecipient of a new 3-year 

cross-cutting evaluation describe the project’s phases, activities, and 

methodologies, but it also clearly specified that the subrecipient’s staff 

would develop preliminary conclusions based on the collected data, draft 

interim reports, and submit a final report to USAID.33

USAID’s Actions Were 

Partially Consistent with 

the AEA Principles for 

Scope and Coverage, 

Dissemination of Results, 

Professional Competence, 

and Resources 

In line with the AEA principles, FFP requires that all of its MYAPs be 

monitored and evaluated at all stages of their life cycle—its guidance 

specifies the activities that are required from proposal writing onward. 

The implementing partners must 

USAID Requires Few CrossCutting Evaluations 

Scope and Coverage

Principles:

• Evaluation should span the life cycle of 

programs and policies, making it integral 

to planning, developing, and managing 

government programs at all stages of their 

development.

• In general, federal programs and policies

should be subject to evaluation, which is a

responsible and necessary part of good 

management.

Source: AEA, An Evaluation Roadmap for a More Effective 

Government.

• perform a baseline survey at the beginning of each MYAP; 

• submit annual reports, including annual results reports that present 

performance indicators and a narrative regarding progress made; 

• submit annual questionnaires that respond to questions about FFP’s 

food security indicators; and 

• submit midterm and final project evaluations. 

In addition, USAID project officers must review the evaluation plans and 

final reports. Finally, the final evaluation must include questionnaires that 

 

32AED defines “integrity” as striving for the highest ethical standards, transparency, and 

accountability in all aspects of its work as an independent organization free of political 

influence. 

33Tufts University, an approved subrecipient under the FANTA-2 cooperative agreement, 

recently received a 3-year task order to assess the success of exit strategies for FFP’s food 

aid programs in Bolivia. 

Page 28 GAO-09-980 International Food Assistance 
 

are comparable to the baseline surveys, along with information about 

sample design, universe, methods of analysis, and sampling frame. 

During our fieldwork in Bangladesh and Haiti, we saw several examples of 

FFP’s implementing partners following these directives. For example, we 

visited a project in Bangladesh that had collected baseline data on a wide 

range of indicators that measured aspects of land ownership, height and 

weight-for-age measures, maternal and child health practices, access to 

water and sanitation, household food security, and disaster preparedness. 

In addition, we visited a project in Haiti that had produced a quarterly 

report including targets for more than 50 measures, along with data on 

whether or not those targets had been achieved, and reasons why some 

targets had not been met. 

FFP’s required monitoring and evaluation of the multiyear programs focus 

on whether the programs are achieving their expected outcomes—but 

they do not assess program impacts, or the effectiveness and efficiency, of 

particular approaches. To achieve this, FFP would need to conduct 

periodic, cross-cutting evaluations that compare what actually happened 

with what would have happened in the absence of the program or 

activity.34 While FFP has commissioned some of these studies, according 

to USAID officials, it has no requirements to do so35 and has conducted 

only a relatively small number over the last 5 years.36 In contrast, FFP 

required every one of more than 100 multiyear projects concluded over the 

last 5 years to be evaluated for outcomes. 

 

34According to USAID officials, there is an example of a cross-cutting evaluation that was 

funded in part by FFP and compared two approaches to prevent malnutrition in infants in 

Haiti. The first approach targeted the interventions on all children aged between 6 and 23 

months (the “preventive” model) and the second approach targeted underweight children 

aged between 6 and 60 months (the “recuperative” model). By the use of carefully selected 

comparison groups, the study concluded that the preventive early intervention model 

yielded the greatest benefits. However, the only other example FFP provided of a recent 

cross-cutting study was a FANTA Report on Food Aid and Food Security Assessment: A 

Review of the Title II Development Food Aid Program issued in 2002. 

35Guidance recently issued by FFP describes evaluation as answering the “why,” “why not” 

and the “what else” of performance and states that it is used on a periodic basis to assess 

effects and impacts, as well as efficiency and effectiveness. However, the guidance only 

requires evaluations of the extent to which Food for Peace programs are meeting outcomes 

and objectives. 

36FFP plans for conducting future cross-cutting impact evaluations and other studies were 

discussed in this report. 

Page 29 GAO-09-980 International Food Assistance 
 

Although USAID policy requires final evaluations of its nonemergency 

food aid programs to be posted on a special Web site known as DEC, the 

implementing partners responsible for these evaluations often do not 

adhere to this requirement. The DEC Web site is accessible to the general 

public and contains both simple and more advanced search engines. For 

example, a user interested in Food for Peace nonemergency programs 

could perform a search for “agriculture,” “maternal and child health,” or 

“food security” final evaluations conducted in recent years. A user could 

also search for final evaluations sponsored by FFP. However, FFP officials 

told us that the MYAP implementing partners often do not submit their 

final evaluations to DEC, even though this is a program requirement. 

According to these officials, there is no penalty if the implementing 

partners do not submit their reports to DEC. We were unable to find in 

DEC a final evaluation of an integrated food security program that FFP 

staff in Bangladesh provided to us in hard copy. In addition, more than 100 

FFP-sponsored final evaluations of multiyear programs should have been 

conducted from 2004 to 2009, according to FFP staff, but our search in 

DEC found only 16. 

Implementing Partner 

Evaluation Results Are Not 

Routinely and Widely 

Disseminated 

Dissemination of Results

Principles:

• The results of all evaluations related to 

public accountability should be made 

available publicly and in a timely manner.

• Evaluations should be easily accessible 

through the Internet with user friendly 

search and retrieval technologies.

• Evaluations of promising and effective 

program practices should be 

systematically and broadly disseminated 

to potential users.

Source: AEA, An Evaluation Roadmap for a More Effective 

Government.

Although the entities that USAID has selected to perform cross-cutting 

evaluations have staff with appropriate professional training and 

experience, questions have been raised about the technical skills of some 

staff that perform monitoring and evaluation for the implementing 

partners. As FFP does not have reliable data on the number of its field 

staff that perform monitoring and evaluation functions, and the specific 

skills and competencies of those staff, it is not possible to determine their 

overall competence. In addition, as FFP’s ability to hire monitoring and 

evaluation specialists in Washington, D.C., is limited, and as USAID has 

only recently reestablished its central evaluation unit, there has been an 

absence of skilled evaluators in headquarters that could assist FFP’s 

officers in the field and implementing partners’ staff. 

Professional Competence 

Varies among the Different 

Groups of Staff Who Monitor 

and Evaluate FFP Programs 

Professional Competence

Principles:

• Evaluations should be performed by 

professionals with evaluation training and 

experience appropriate to the evaluation 

activity in which they are engaged.

• Federal agencies should be encouraged to 

recognize the multidisciplinary nature of 

evaluation and assure that the diversity of 

disciplines is appropriately represented in 

both internal and independent consulting 

teams.

Source: AEA, An Evaluation Roadmap for a More Effective 

Government.

FFP’s Partners Have Training and Experience Consistent with the 

AEA Principles 

The partner organizations that FFP relies on to provide technical 

assistance and support and to conduct cross-cutting evaluations have 

training and expertise that are consistent with the AEA principles for 

professional competence. The AED FANTA-2 project, with which USAID 

has a cooperative agreement for various types of technical assistance, 

employs staff experienced in monitoring and evaluation, with backgrounds 

in economics, sociology, nutrition, anthropology, public health, and 

epidemiology. In addition, FANTA-2 has partnered with universities and 

Page 30 GAO-09-980 International Food Assistance 
 

research institutes, such as Tufts University and the International Food 

Policy Research Institute, for particular evaluations and other research 

projects. 

Concerns Have Been Raised about Certain Aspects of 

Implementing Partners’ Monitoring and Evaluation Skills 

FFP’s implementing partners’ staff perform important monitoring and 

evaluation functions, such as gathering data on performance indicators 

and tracking these indicators. Yet FFP officials in Washington, D.C., and in 

the field, as well as some external evaluators, have expressed concerns 

about the competency of these staff to perform certain aspects of 

monitoring and evaluation, as follows: 

• Staff can lack key evaluation skills. Implementing partners’ staff can lack 

key evaluation skills, according to an AED employee who provided 

training and support to FFP’s implementing partners and several external 

evaluators. According to the AED employee, implementing partners’ staff 

could execute research designs adequately but often were not capable of 

designing the research themselves, or of taking responsibility for key 

aspects of data collection, such as developing surveys or selecting 

statistical samples. FFP officials stated that they recognize the need to 

build capacity among the implementing partners, and are providing 

monitoring and evaluation training in the field for these FFP and 

implementing partner staff. 

• Difficulties in hiring and retaining qualified staff. Adequacy of staffing 

levels and staff turnover have been cited as a concern in some countries. 

For example, the implementing partners in Haiti told us that it was 

difficult to attract and retain technically qualified staff. They stated that 

Haiti has only a limited supply of people with the appropriate skills and 

training for monitoring and evaluation. To address the shortage, one 

implementing partner recently hired a new monitoring and evaluation 

program officer from an African country who had appropriate 

methodological skills but did not speak either French or Creole, Haiti’s 

official languages, at the time of his arrival in-country. 

Page 31 GAO-09-980 International Food Assistance 
 

FFP Lacks Data on the Monitoring and Evaluation Competencies of 

Its Field Staff 

FFP does not have the data necessary to assure that it has enough staff 

with the right skills. According to FFP officials, USAID does not collect an 

inventory of its staff’s skills and abilities,37 which would help the agency to 

determine whether it has staff with sufficient training and skills in 

monitoring and evaluation. Furthermore, neither USAID nor FFP have 

data that can indicate which staff spend the majority of their time on 

monitoring and evaluation, or how much staff time is spent on various 

monitoring and evaluation activities, such as checking on warehouses, 

advising implementing partners on performance indicators, or 

participating in evaluation designs. While FFP attempted to gather some 

data for us on its field staff who perform monitoring and evaluation, these 

data were not reliable. 

In Haiti, for example, FFP officials initially told us that nine staff acted as 

field monitors. However, we found that this number included staff 

members who did not spend much of their time involved in routine 

monitoring and evaluation, such as the FFP officer, his deputy, and two 

secretaries. Of the FFP staff in country, only four appeared to spend 

substantial parts of their time on specific monitoring activities, such as 

performing routine checks of warehouses or health clinics and giving 

implementing partners advice on indicators. 

One reason that it is difficult for FFP to determine which staff spend the 

majority of their time on monitoring is that definitions of this function 

vary. For example, while a recent FFP bulletin defined monitoring as the 

regular tracking of program implementation, FFP guidance to field staff 

defined monitoring more broadly, to include activities such as reviewing 

contracts and ensuring that financial audits are performed.38 If the broader 

 

37According to USAID’s most recent workforce plan, the agency has created competency 

models and conducts annual competency assessments for the human resources, 

information technology, and acquisitions occupations. It projects that it will complete 

competency models for the foreign service in fiscal year 2010, civil service in fiscal year 

2011, and foreign service nationals and U.S. personal services contractors in fiscal year 

2013. USAID, USAID Five-Year Workforce Plan FY 2009-FY 2013. 

38During our fieldwork in Bangladesh and Haiti, we found that the number of staff devoted 

to monitoring and evaluation, and the amount of time they dedicated to those activities, 

varied considerably between the two missions. FFP in Haiti dedicated more staff to 

monitoring and evaluation, and they reported that they spent more of their time on 

monitoring and evaluation than did FFP staff in Bangladesh. 

Page 32 GAO-09-980 International Food Assistance 
 

definition of monitoring is used, more staff members can be classified as 

performing this function, but then it is not possible to determine which of 

those staff are spending the majority of their time on monitoring program 

inputs and program implementation. 

FFP Lacks Staff in Headquarters Who Are Skilled in Monitoring 

and Evaluation

AEA has recommended that to support evaluations agencies either 

establish centers of evaluation or appoint evaluation coordinators for 

individual programs that conduct their own evaluation. According to FFP 

officials, FFP has been unable to hire monitoring and evaluation staff at 

headquarters to assist and support its officers in the field. FFP officials 

attributed this to restrictions in the Food for Peace Act, which precludes 

them from hiring any staff in Washington, D.C., to monitor and evaluate 

nonemergency food aid programs.39 Moreover, as USAID has only recently 

reestablished its central evaluation unit,40 FFP has not been able to seek 

advice and guidance from professional, experienced evaluators at 

headquarters, or to ask them to perform evaluations of FFP’s programs. 

The Food for Peace Act provides FFP with a stable source of new funding 

of up to $22 million annually for each of the fiscal years 2009 through 2012 

to improve, monitor, and evaluate the effectiveness and efficiency of 

nonemergency food aid programs. In addition, FFP has access to other 

funding streams, such as DA funds, which have recently increased. As a 

result, FFP officials told us that they currently have more resources to 

devote to monitoring and evaluation than in the past. 

Greater Resources Are Now 

Available for Monitoring and 

Evaluation, but Their 

Sufficiency Is Difficult to 

Determine Absent a Needs 

Assessment 

Resources

Principle:

Sufficient resources should be made 

available for evaluation, including stable 

annually recurring sources of funds and 

special one-time funds for evaluation projects

of interest to executive branch and 

congressional policymakers.

Source: AEA, An Evaluation Roadmap for a More Effective 

Government.

Although availability of the newly authorized funding for monitoring and 

evaluation as well as funding from other sources is generally consistent 

with the AEA principle on resources, it is not possible to determine if 

funding is sufficient because FFP has not systematically determined its 

research needs, prioritized those needs, or estimated the costs associated 

with them. In the course of our audit work, we identified several areas 

where the current resource levels might not be sufficient. For example, 

 

39The Food for Peace Act authorizes the hiring of personal services contractors only in 

recipient countries. 

40USAID’s central evaluation office was reestablished in 2008 but, as of August 2009, had 

only one employee, who is its chief. However, according to the chief, the office has begun 

the process of hiring about seven new staff. 

Page 33 GAO-09-980 International Food Assistance 
 

experts we interviewed provided examples of potential evaluations or 

studies that could help improve FFP’s programs. However, according to 

USAID officials, FFP has not undertaken the formal exercise of compiling 

a list of these studies, or prioritizing its needs for them. In addition, 

FANTA-2 staff who review many of the implementing partners’ multiyear 

plans for evaluation raised concerns that FFP does not sufficiently ensure 

that these evaluations are adequately funded. However, FFP has not 

reviewed or estimated the amounts its implementing partners are spending 

on monitoring and evaluating their multiyear projects because, according 

to FFP, that would be burdensome as it would require a review of each 

project’s contract.41 Without such an assessment, it is not possible to 

determine whether sufficient resources are being spent on the required 

final evaluations. 

USAID’s Actions Were Not 

Consistent with the AEA 

Principles for Monitoring 

and Evaluation Plans 

According to FFP officials, FFP plans some of its monitoring and 

evaluation activities,42 but lacks an overall plan that integrates its 

monitoring and evaluation with program management. FFP officials 

reported that they make decisions about monitoring and evaluation based 

on discussion and a thorough consideration of options but have not 

undertaken the rigorous planning process that is recommended by AEA. 

Therefore, FFP does not have an integrated plan for all of its oversight 

activities to facilitate strategic planning, budgeting, and program 

management, and to indicate how it will use monitoring and evaluation 

results to improve program management. Moreover, FFP does not have a 

mechanism to link resources to needs based on risk, according to USAID 

officials. As a result, when FFP allocates resources for monitoring and 

evaluation, it does not take into account factors such as the country 

context, vulnerability to fraud, waste, and abuse, program efficiency, and 

critical issues. As we noted earlier, we cannot determine whether FFP has 

sufficient resources because this type of planning has not been conducted, 

which means that FFP’s monitoring and evaluation needs have not been 

prioritized and compared against available resources. 

Evaluation Plans

Principles:

• Agency should require its major program 

components to prepare annual and 

multiyear evaluation plans of the studies

and other evaluation activities that it will 

undertake. The plans should be updated 

annually.

• The planning should take into account the 

needs of evaluation results for informing 

program budgeting, reauthorization, 

agency strategic plans, ongoing program 

development, and management and 

responses to critical issues.

Source: AEA, An Evaluation Roadmap for a More Effective 

Government.

 

41At our request, the two FFP implementing partners that operate in Bangladesh both 

estimated that about 3 percent of their total project budgets were spent on monitoring and 

evaluation. However, these estimates were for all their monitoring and evaluation, 

including staff salaries. We were not able to independently verify these estimates. 

42For example, FFP implementing partners are to plan final evaluations for multiyear 

assistance programs. 

Page 34 GAO-09-980 International Food Assistance 
 

A senior FFP official told us that he could see the potential value of such a 

plan but wondered whether FFP—which has a staff of about 60 people 

and which he characterized as being small in relation to other USAID 

units—could support such an effort. However, FFP appears to have the 

resources for such a planning effort, as the Food for Peace Act has 

provided it with up to $88 million to improve, monitor, and evaluate the 

effectiveness and efficiency of nonemergency food aid programs over a 4-

year period, and has access to other resources that can be used for 

monitoring and evaluation, such as DA funds.43

Nonemergency food aid programs are an essential component of the U.S. 

strategy to reduce global food insecurity, and Congress has authorized 

new funding for USAID to improve its oversight of these programs. In 

response, USAID’s FFP has initiated actions over the past year to 

strengthen its monitoring and evaluation of food assistance. However, 

weak planning could impede these efforts, including the upgrade of FFP’s 

information technology system. In addition, USAID has yet to determine 

how it intends to assure stable resources, within existing authorities, to 

fully implement all the actions planned by FFP to improve monitoring and 

evaluation of nonemergency food aid. As a result, planned actions that are 

essential to effective program management, such as the expansion of a 

computerized monitoring system for food aid programs and cross-cutting 

evaluations, could be jeopardized. Finally, FFP lacks an integrated and 

comprehensive monitoring and evaluation plan that links resources to 

needs based on risk. In the absence of such a plan, it is difficult to 

determine whether USAID is allocating resources for monitoring and 

evaluation to its priority needs, such as program efficiency, critical issues, 

and programs vulnerable to fraud, waste, and abuse. 

To facilitate the implementation of ongoing efforts to improve monitoring 

and evaluation and ensure effective program management of 

nonemergency food aid, we recommend that the Administrator of USAID 

take the following two actions: 

Conclusions 

Recommendations for 

Executive Action 

 

43USAID’s central evaluation unit is in the process of preparing an agencywide plan for 

evaluation, which might be useful to units like FFP as they develop plans for their own 

programs. The central evaluation unit had hoped to complete its agencywide plan by 

summer 2009 but recently reported that the plan was unlikely to be finalized until a new 

USAID Administrator was confirmed. 

Page 35 GAO-09-980 International Food Assistance 
 

• Develop a concept of operations document to help reduce the risks 

associated with upgrading FFP’s information technology system. Such a 

document should adhere to industry best practices and include key 

elements such as major system components, interfaces to external 

systems, and performance characteristics. It would also describe system 

characteristics for a proposed system from a user’s point of view and 

include high-level descriptions of information systems, their 

interrelationships, and information flows. 

• Develop an integrated monitoring and evaluation plan to ensure that the 

results of its oversight activities are used for effective management of 

nonemergency food aid programs. Such a plan should, among other things, 

(1) link monitoring and evaluation to key USAID and FFP goals; 

(2) establish a systematic process for determining appropriate budget 

levels and staff resources for monitoring and evaluation based on an 

analysis of the nature, scope, and size of the programs, and the unique 

conditions presented, in the recipient countries; (3) examine all available 

options for funding monitoring and evaluation at headquarters and in 

recipient countries; and (4) establish time frames for implementing and 

evaluating the plan. 

USAID provided written comments on a draft of this report. We have 

reprinted these comments in appendix IV, along with our responses. 

Additionally, USAID provided technical comments on a draft of this 

report, which we have addressed as appropriate. 

Agency Comments 

and Our Evaluation 

USAID concurred with our first recommendation to develop a concept of 

operations document to help reduce the risks associated with upgrading 

FFP’s information technology system. USAID disagreed with the second 

recommendation, asserting that we did not adequately take into account 

documents that detail its planning processes. We considered all the 

documents that USAID cited and found that they did not constitute plans, 

but only provided guidance for planning. Furthermore, the weaknesses we 

identified in FFP’s monitoring and evaluation efforts, including in the 

areas of resources and professional competence, demonstrate the need for 

a comprehensive monitoring and evaluation plan. 

USAID acknowledged that it does not have an integrated monitoring and 

evaluation plan, but said that it does not see the benefits of developing it 

since the elements of such a plan exist in some form already. USAID noted 

that we did not mention FFP’s Strategic Plan for 2006-2010 and a related 

document, which link monitoring and evaluation to agency goals and lay 

Page 36 GAO-09-980 International Food Assistance 
 

out performance indicators. We considered the strategic plan irrelevant to 

our analysis because it was prepared in 2005, prior to the passage of the 

2008 Food for Peace Act, and covers only some aspects of monitoring. 

USAID also stated that its planned studies form part of an agency agenda 

to inform program management. We reported on FFP’s planned studies 

but noted that, because funding for these studies is not assured due to 

legal restrictions, USAID may need to find alternative funding sources. 

Moreover, USAID officials reported that they did not use almost $9 million 

of last year’s available funds authorized by the 2008 Food for Peace Act for 

oversight of nonemergency food aid. We consider these to be compelling 

reasons for USAID to develop an integrated monitoring and evaluation 

plan. 

In terms of staffing, FFP officials said that their first priority is to place 

staff in all the countries where they have nonemergency food aid 

programs. FFP acknowledged that it does not have data on field staff that 

perform monitoring and evaluation functions, but said that such data 

would be costly to collect, and that we had not made the case for 

collecting them. However, we found that FFP currently does not know 

what percentage of time its staff spend on monitoring and evaluation and 

what specific monitoring and evaluation functions they perform. We 

believe that because FFP had a substantial new funding authority for 

oversight activities, it should invest in a survey of staff skills and an 

assessment of monitoring and evaluation needs, which would provide FFP 

with essential data for future staffing decisions. We believe that this basis 

for our recommendation for an integrated monitoring and evaluation plan 

remains valid. 

Page 37 GAO-09-980 International Food Assistance 
 

We are sending copies of this report to interested Members of Congress 

and the Administrator of USAID. The report is also available at no charge 

on the GAO Web site at http://www.gao.gov. 

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

me at (202) 512-9601 or melitot@gao.gov. Contact points for our Office of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

Thomas Melito 

listed in appendix V. 

Director, International Affairs and Trade 

Page 38 GAO-09-980 International Food Assistance 
Appendix I: Objectives, Scope, and 

Methodology 

Page 39 GAO-09-980 International Food Assistance 

Appendix I: Objectives, Scope, and 

Methodology 

In passing the Food for Peace Act in 2008, Congress required the 

Comptroller General of the United States to review the U.S. Agency for 

International Development’s (USAID) Report to Congress on the agency’s 

efforts to strengthen the monitoring and evaluation of its nonemergency 

food aid programs and provide recommendations for improvement. To 

address this congressional mandate, we reviewed (1) USAID’s plans and 

actions to improve its monitoring and evaluation of nonemergency food aid 

programs provided under the Food for Peace Act and (2) the extent to 

which USAID has integrated its monitoring and evaluation of nonemergency 

food aid with program management, particularly with regard to established 

principles. In this review, we focused on oversight practices of USAID’s 

Office of Food for Peace (FFP), not of the agency as a whole. 

To address USAID’s plans to improve the monitoring and evaluation of 

nonemergency food aid programs using the funds provided under the 

Food for Peace Act, we reviewed the list of activities that the agency 

reported to Congress in December 2008. This included plans to make 

improvements in 

• the number of field staff monitoring food aid programs, 

• computerized systems for monitoring food aid programs, 

• the market analysis required before food aid programs are approved in 

recipient countries, 

• cross-cutting evaluations of nonemergency food aid projects, 

• FFP’s information technology system, and 

• the Famine Early Warning Systems Network (or FEWS NET). 

We interviewed knowledgeable USAID officials and partners responsible for 

implementing these plans and reviewed relevant documents, including 

contracts and plans. We also examined FFP data on the allocations of the 

Food for Peace Act funding for oversight of nonemergency food aid in fiscal 

year 2009. Based on interviews, and our analysis of the available documents, 

we determined that the data were sufficiently reliable to indicate the relative 

amounts allocated to each of the oversight activities, and to demonstrate 

that almost $9 million were not used in fiscal year 2009. 

In addition, we conducted fieldwork in Bangladesh and Haiti. We selected 

these two countries because they have the largest Food for Peace 
Appendix I: Objectives, Scope, and 

Methodology 

nonemergency food aid programs, but they differ in their approaches to 

monitoring and evaluation. Haiti has more staff working on these 

programs than does Bangladesh and uses the Layers computerized 

monitoring system, which Bangladesh does not. Haiti’s staff spend 

relatively more time monitoring programs directly, while FFP in 

Bangladesh relies more on contract officers and implementing partners to 

perform its monitoring and evaluation. In addition, Haiti is in the 

Caribbean while Bangladesh is in South Asia, which provided a regional 

contrast. While we could not generalize from these two countries to all the 

countries that have Food for Peace programs, we gained useful insights 

into monitoring and evaluation from our fieldwork. 

To consider the extent to which USAID’s monitoring and evaluation of 

nonemergency food aid are aligned with program management, we 

selected the American Evaluation Association’s (AEA) principles for 

integrating evaluation into program management. We selected these 

principles as criteria because they are consistent with the goal set by the 

Secretary of State, who has ultimate responsibility for USAID, to ensure 

evidence-based decisions in development programs. 

In this review, we combined the AEA standards for scope and for coverage 

because we found overlap between them. In addition, we did not assess 

one of the AEA standards on methods because that would have involved a 

review of studies that was beyond the scope of this report, and because 

that principle was less specific than those for the other elements, 

essentially noting that a mix of methods should be used, but that the actual 

methods used should depend upon the topic to be evaluated. 

The AEA principles differ in length and detail, with some including several 

parts and clauses, while others are more succinct. For the more detailed 

principles, we identified the sentences that summarized them at the 

highest level and used those as our operating criteria. For the sake of 

transparency, we published the exact principles we used in our report 

next to our discussion of them. 

To gather evidence to apply against the principles, we interviewed 

cognizant FFP officials in Washington, D.C., and in Bangladesh and Haiti. 

We also interviewed the Chief of USAID’s Evaluation Office, senior staff at 

the Food and Nutrition Technical Assistance (FANTA-2) project of the 

Academy for Educational Development (AED), with which USAID has 

ongoing cooperative agreement, as well as experts knowledgeable about 

USAID’s evaluation and monitoring. We reviewed USAID and FFP policy 

guidance and bulletins that discuss and describe evaluation. We reviewed 

Page 40 GAO-09-980 International Food Assistance 
Appendix I: Objectives, Scope, and 

Methodology 

the evaluations that we found on USAID’s Development Experience 

Clearinghouse (DEC) Web site and that were given to us by USAID and its 

implementing partners. We also examined related monitoring and 

evaluation documents, such as performance plans and annual project 

reports, and documentation of the training USAID provides on monitoring 

and evaluation. 

We reviewed this evidence and compared it against each of the AEA 

principles to make a general, high-level determination on the broad degree 

to which FFP was consistent or inconsistent with them. In the course of this 

review, we recognized that FFP has its own guidance and practices, but that 

it follows the overall guidance and practices set by USAID for the agency as 

a while, and considered each source as appropriate. 

In addition to the AEA principles, we also considered GAO standards and 

prior GAO work, particularly on workforce planning; USAID guidance; and 

guidelines that the Institute of Electrical and Electronics Engineers (IEEE) 

has established for information technology. 

As USAID performs a wide range of activities to monitor and evaluate its 

Food for Peace program, we defined evaluation broadly for the purposes 

of this report. This definition includes evaluating inputs and 

implementation,1

 outcomes, and impacts. We also considered other 

research studies that FFP had conducted to help manage its programs, 

such as prospective studies on the impacts of providing particular food 

commodities to particular markets, and analyses of individual countries’ 

food strategies. In addition, we included the selection and tracking of 

performance indicators in our review because FFP and USAID define 

monitoring to include the tracking of these indicators during the life cycle 

of their programs, and use them in the final evaluations. 

We conducted this performance audit from March 2009 to September 2009, 

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. 

 

1

We considered the field monitoring of USAID programs a form of input and 

implementation evaluation. 

Page 41 GAO-09-980 International Food Assistance 
Appendix II: USAID Report to Congress Appendix II: USAID Report to Congress 

Note: This is USAID’s 

Report to Congress dated 

December 31, 2008, as 

required by the Food for 

Peace Act. 

Page 42 GAO-09-980 International Food Assistance 
Appendix II: USAID Report to Congress 

Page 43 GAO-09-980 International Food Assistance 
Appendix II: USAID Report to Congress 

Page 44 GAO-09-980 International Food Assistance 
Appendix II: USAID Report to Congress 

Page 45 GAO-09-980 International Food Assistance 
Appendix II: USAID Report to Congress 

Page 46 GAO-09-980 International Food Assistance 
Appendix II: USAID Report to Congress 

Page 47 GAO-09-980 International Food Assistance 
Appendix III: Examp

Supported with

les of Activities

 Nonemergency Food Aid 

Page 48 GAO-09-980 International Food Assistance 

Figure 5 provides examples of activities we observed in Bangladesh and 

Haiti that are illustrative of the various activities supported with 

nonemergency food aid. 

Appendix III: Examples of Activities 

Supported with Nonemergency Food Aid 

Figure 5: Examples of Activities Supported with Nonemergency Food Aid 

Sources: GAO analysis; GAO and USAID (photos).

Food provided in exchange for work; generally targeted 

seasonally and geographically to food insecure population 

groups.

Food-for-work: CRS Haiti provided temporary employment 

to 234 laborers for 6 months for soil conservation and 

reforestation activities.

Food-for-work: For several years, CARE Bangladesh has

been helping the Tangail district prepare for natural disasters

through infrastructure activities, including raising homesteads

to mitigate the effects of severe flooding on households.

Safe water and sanitation: Save the Children Bangladesh has

installed a water point in the Barisal district to ensure household 

access to safe water.

Proceeds from U.S. food aid sold locally support development 

projects, such as the rehabilitation and construction of new 

water points and mother and child health and nutrition programs.

Direct distribution Monetized food aid

Mother and child health and nutrition: World Vision Haiti 

provides pregnant and lactating women and children under the age of 

2 with monthly health checkups, immunizations, and counseling, at 

the Terre Casse clinic in Haiti’s Central Plateau region.
Appendix IV: Comments from USAID Appendix IV: Comments from USAID 

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of this appendix. 

Page 49 GAO-09-980 International Food Assistance 
Appendix IV: Comments from USAID 

See comment 1. 

Page 50 GAO-09-980 International Food Assistance 
Appendix IV: Comments from USAID 

Page 51 GAO-09-980 International Food Assistance 
Appendix IV: Comments from USAID 

See comment 2. 

See comment 3. 

Page 52 GAO-09-980 International Food Assistance 
Appendix IV: Comments from USAID 

See comment 4. 

See comment 5. 

Page 53 GAO-09-980 International Food Assistance 
Appendix IV: Comments from USAID 

Page 54 GAO-09-980 International Food Assistance 

The following are GAO’s comments on the U.S. Agency for International 

Development letter dated September 17, 2009. 

1. We reviewed the eight documents listed and acknowledged several of 

them in our report’s section on policies and procedures. However, 

none of these documents constitutes a plan. Instead, they are policy or 

technical documents that describe how USAID and its awardees 

should plan for aspects of monitoring and evaluation. 

GAO Comments 

2. We considered FFP’s Strategic Plan for 2006-2010 but determined it 

to be irrelevant to our analysis because it was prepared in 2005, prior 

to the passage of the 2008 Food for Peace Act, and covers only some 

aspects of monitoring. The Performance Management Plan is related 

to the strategic plan and provides a set of indicators to measure 

progress. Neither of these documents discusses funding, resources, 

staffing needs, or how results would be used to improve program 

management. 

3. We reported on the planned studies earlier in this report. However, 

USAID provided us not with a plan, but rather with a list of selected 

studies, their implementers, costs, and a high-level description. In the 

list, USAID did not discuss alternatives, outline priorities, or explain 

how the selected studies would address FFP’s most pressing needs or 

be used for program management. As we noted, several studies do not 

have assured funding due to the legal restrictions on FFP’s funding, 

which makes the need for integrated planning even more critical. 

4. We noted that FFP allocated the new staff positions in order to ensure 

coverage in all countries where it has programs. While this is one 

factor to consider in workforce planning, FFP did not consider other 

important factors, such as existing staff skills or country-specific 

needs for monitoring and evaluation because it did not collect data on 

them. Lacking a systematic process to collect such data, FFP is unable 

to determine if it has adequate staff with sufficient training and skills 

in monitoring and evaluation. 

5. FFP officials reported that they had not used almost $9 million of the 

$22 million available in fiscal year 2009. Better planning could ensure 

that the available funds are more fully used in future years for 

activities such as surveying FFP staff on their monitoring and 

evaluation skills and conducting an assessment of FFP monitoring and 

evaluation needs. 
Appendix V: GAO Contact and Staff Appendix V: GAO Contact and Staff Acknowledgments 

Acknowledgments 

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

In addition to the individual named above, Phillip Thomas, Martin De 

Alteriis, and Michael LaForge, Assistant Directors; and Sada Aksartova; 

Carol Bray; Ming Chen; Debbie Chung; Lynn Cothern; Mark Dowling; Brian 

Egger; Ian Ferguson; Etana Finkler; Kendall Helm; Joy Labez; Jeff Miller; 

Yvonne Moss; Ulyana Panchishin; Lisa Reijula; Julia Ann Roberts; Barbara 

Shields; Stephanie Shipman; and George Taylor made key contributions to 

this report. 

GAO Contact 

Staff 

Acknowledgments 

Page 55 GAO-09-980 International Food Assistance 
Related GAO Products Related GAO Products 

International Food Assistance: Key Issues for Congressional Oversight. 

GAO-09-977SP. Washington, D.C.: September 30, 2009. 

International Food Assistance: Local and Regional Procurement 

Provides Opportunities to Enhance U.S. Food Aid, but Challenges May 

Constrain Its Implementation. GAO-09-757T. Washington, D.C.: June 4, 

2009. 

International Food Assistance: Local and Regional Procurement Can 

Enhance the Efficiency of U.S. Food Aid, but Challenges May Constrain 

Its Implementation. GAO-09-570. Washington, D.C.: May 29, 2009. 

International Food Security: Insufficient Efforts by Host Governments 

and Donors Threaten Progress to Halve Hunger in Sub-Saharan Africa 

by 2015. GAO-08-680. Washington, D.C.: May 29, 2008. 

Foreign Assistance: Various Challenges Limit the Efficiency and 

Effectiveness of U.S. Food Aid. GAO-07-905T. Washington, D.C.: May 24, 

2007. 

Foreign Assistance: Various Challenges Impede the Efficiency and 

Effectiveness of U.S. Food Aid. GAO-07-560. Washington, D.C.: April 13, 

2007. 

Foreign Assistance: U.S. Agencies Face Challenges to Improving the 

Efficiency and Effectiveness of Food Aid. GAO-07-616T. Washington, 

D.C.: March 21, 2007. 

Darfur Crisis: Progress in Aid and Peace Monitoring Threatened by 

Ongoing Violence and Operational Challenges. GAO-07-9. Washington, 

D.C.: November 9, 2006. 

Maritime Security Fleet: Many Factors Determine Impact of Potential 

Limits of Food Aid Shipments. GAO-04-1065. Washington, D.C.: 

September 13, 2004. 

United Nations: Observations on the Oil for Food Program and Iraq’s 

Food Security. GAO-04-880T. Washington, D.C.: June 16, 2004. 

Foreign Assistance: Lack of Strategic Focus and Obstacles to 

Agricultural Recovery Threaten Afghanistan’s Stability. GAO-03-607. 

Washington, D.C.: June 30, 2003. 

Page 56 GAO-09-980 International Food Assistance 
Related GAO Products 

Foreign Assistance: Sustained Efforts Needed to Help Southern Africa 

Recover from Food Crisis. GAO-03-644. Washington, D.C.: June 25, 2003. 

Food Aid: Experience of U.S. Programs Suggest Opportunities for 

Improvement. GAO-02-801T. Washington, D.C.: June 4, 2002. 

Foreign Assistance: Global Food for Education Initiative Faces 

Challenges for Successful Implementation. GAO-02-328. Washington, D.C.: 

Feb. 28, 2002. 

Foreign Assistance: U.S. Food Aid Program to Russia Had Weak Internal 

Controls. GAO/NSIAD/AIMD-00-329. Washington, D.C.: September 29, 

2000. 

Foreign Assistance: U.S. Bilateral Food Assistance to North Korea Had 

Mixed Results. GAO/NSIAD-00-175. Washington, D.C.: June 15, 2000. 

Foreign Assistance: Donation of U.S. Planting Seed to Russia in 1999 

Had Weaknesses. GAO/NSIAD-00-91. Washington, D.C.: March 9, 2000. 

Foreign Assistance: North Korea Restricts Food Aid Monitoring. 

GAO/NSIAD-00-35. Washington, D.C.: October 8, 1999. 

Food Security: Factors That Could Affect Progress toward Meeting World 

Food Summit Goals. GAO/NSIAD-99-15. Washington, D.C.: March 22, 1999. 

Food Security: Preparations for the 1996 World Food Summit. 

GAO/NSIAD-97-44. Washington, D.C.: November 7, 1996. 

(320690) Page 57 GAO-09-980 International Food Assistance 
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