Domestic Origin Verification 

Audit Program (DOV) 
Background

The AMS Commodity Procurement Program (CP) under its commodity 

purchase program (USDA Foods) procures a wide variety of agricultural food 

products.

These purchases are wholesome, high-quality products that go to:

 Schools (National School Lunch Program)

 Food Banks and households country wide (Emergency Food Assistance 

Program)

 To help stabilize prices in U.S. agricultural commodity markets by balancing 

supply and demand
Requirement

 Products must be 100 percent U.S. Origin

 To qualify all products and product components shall have originated entirely 

from crops grown, processed, and packed in the United States, its territories or 

possessions, the Commonwealth of Puerto Rico, or the Trust Territories of the 

Pacific Islands

 Domestic origin compliance is required by each vendor that supplies a 

commodity to USDA by either:

performing a trace-back of, at a minimum, one code per facility, per purchase order, for 

each commodity provided on the USDA purchase order

OR

participating in the DOV Audit Program
Purpose of the DOV Program

 DOV is an audit based program developed to replace the requirement to 

trace for every contract.

 Applicants should already have a system or procedures in place to meet the 

current domestic origin contract requirements. 

 The DOV program provides a means for the applicant to use these 

procedures to develop an auditable process to verify the domestic origin of 

the product sold to the USDA.
Advantages of Program Participation

 Decreases the number of traces required to be submitted to the USDA 

and any redundancies.

 DOV certification is valid for one year

 Assists applicants in demonstrating continual improvement of their 

verification procedures. 

 Compliance with the domestic origin requirement can be assured prior

to receipt of components or products from suppliers.
Who is eligible to participate?

 Any financially interested applicant (contractor, subcontractor, supplier, or 

processor) providing components or products to the USDA may request the 

DOV Audit Program service.

 The DOV Audit Program may be used whether or not the applicant:

 handles imports

 requests lot inspection

 receives in-plant inspection
How to apply to the program?

 Applicants submit a DOV program manual that details the verifiable written 

procedures used to ensure compliance with the domestic origin contract 

requirement along with specific DOV Program requirements.

 Three main segments

 Pre-validation Assessment

 Validation Audit

 Verification Audit

(The DOV Quick Guide summarizes the specific DOV Program requirements and 

can be viewed at https://www.ams.usda.gov/services/auditing/dov )
Pre-Validation Assessment

 Applicant’s DOV program assessed on procedures and processes 

submitted for review

 Auditor provides feedback on any elements within the applicant’s submitted 

DOV program

 Ensures program fully addresses DOV Specific Requirements 

 Issues that may require additional clarification or information prior to the On-site 

Validation Audit

 Three results: Adequate, Requires Clarification, Does Not Meet
Validation Audit

Applicant’s Responsibilities:

 Pertinent DOV information and program made available

 Interviews with key personnel

 Updated information as necessary

Audit Coordinator:

 Completes Pre-validation Assessment process

 Deems the applicant ready for the on-site validation audit

 Assigns competent auditor(s) to conduct the validation audit

 Discusses any nonconformance with the applicant
Validation Audit

If any non-conformances are identified:

 Corrective Action Requests (CAR) are provided to applicant

 Applicants provide required written responses to the CAR requests

 Once all the corrective actions are determined adequate, the applicant is 

an:

Approved DOV Program Participant
Validation Audit

 If not approved as for DOV Audit Program

 Notification will be provided by DOV Program Manager

 Applicant will be required to continue to submit trace-backs for every 

contract and commodity for the facility audited
Validation Audit

In order to maintain status as an Approved Program:

 At minimum one on-site audit per year is required 

 Ensures continued compliance with program requirements and approval in the 

DOV Program. 

 Keep DOV procedures updated

 Notify DOV Program Manager of any changes to Applicant’s DOV Program

 Upon assessment of risk of non-compliance combined with verification audit 

findings, Verification Audits frequency may increase

 Handling non-domestic components or products

 Changes in applicant’s management or key personnel

 History of non-conformance with domestic origin requirements
Validation Audit

Verification audits are considered compliant when:

 DOV program approval is maintained 

 No audit deficiencies are found or adequate corrective action is taken in 

response to audit deficiencies

Upon approval an annual certificate is provided that is valid for 12 months from 

approval date.
Benefits of Participation

 Trace-back for every contract/commodity no longer 

needed

 Greatly reduces the paperwork of numerous traces

 Alleviates the redundancy of trace-backs on the same product used for 

multiple contracts

 Streamlines trace-back requests for No Checkloading Pilot

 Compliance with the origin requirement is established prior to production 

rather than traced-back after production
Benefits of Participation

Approved DOV Program Participants are listed on the 

USDA website

 Contractors can select suppliers from the approved list and be assured that 

the supplier is able to meet the domestic origin requirement prior to 

contracting with them.

 Eliminates any contractor concern regarding the ability of the supplier to 

provide trace documentation after delivery to the contractor. 
Summary

 DOV is an audit based program and an 

option to the current trace-back requirement.

 DOV improves domestic origin verification.

 Approved DOV Program Participants can be listed on the Specialty Crop 

Inspection Division websites.
Summary

 DOV Audit Program participation decreases 

paperwork, trace-backs, and redundancy.

 Any applicant can participate – contractor, 

subcontractor, supplier, or processor.

 Program participation enhances the management of domestic origin 

verification.

 Streamlines domestic origin requests for No Checkloading Pilot.
Resources

Complete DOV Audit Program information is available at: 

https://www.ams.usda.gov/services/auditing/dov

 Application for Service form

 DOV Audit Program General Policies and Procedures

 DOV Quick Guide

 Audit Report form

 List of Approved DOV Program Participants

 Audit rate information
Resources

Contact the DOV Program Coordinator to discuss the DOV specific 

requirements and application process. Contact information can be found at:

https://www.ams.usda.gov/services/auditing/dov

DOV Program Manager Sean Martin:

DOVS.FV@ams.usda.gov

503 586 6473

Complete the required Application for Service form and submit to the DOV 

Program inbox for review.