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Letter to the Secretary

February 27, 2023

Thomas J. Vilsack

Secretary, U.S. Department of Agriculture 

1400 Independence Ave., SW

Washington, D.C. 20250

Dear Secretary Vilsack:

The USDA Equity Commission is grateful for the opportunity to put forth a set of interim 

recommendations to advance equity at USDA. We commend USDA for its commitment to 

equity and recognize the progress made since January 2021, when President Biden signed 

Executive Order 13985 On Advancing Racial Equity and Support for Underserved Communities 

Through the Federal Government. 

In preparation for this interim report, the Equity Commission held four public meetings:

• February 28, 2022 

• May 10-11, 2022 

• September 21-22, 2022 

• January 31 – February 2, 2023 

Public input was gathered through written and oral comments provided at each of the public 

meetings. These comments were shared with members of the Equity Commission for their 

consideration and are posted on the public Equity Commission website. 

The Equity Commission members received briefings from the following USDA staff:

• Under Secretary Robert Bonnie, Farm Production and Conservation

• Deputy Assistant Secretary Dr. Penny Brown Reynolds, Civil Rights, Management and 

Operations

• Administrator, Zach Ducheneaux, Farm Service Agency

• Chief of Staff Katharine Ferguson, Office of the Secretary

• Former Director Claudette Fernandez, Program Equity and Opportunity Strategy

• Senior Counsel Rick Gibson, Office of the General Counsel

• Senior Advisor Dr. Dewayne Goldmon, Racial Equity

• Deputy Under Secretary Gloria Montaño Greene, Farm Production and Conservation

• Deputy Administrator Scott Marlow, Farm Programs

• Associate Director Chris Nelson, Office of Budget and Program Analysis

• Deputy Director Jennifer Nicholson, National Appeals Division

• Deputy Assistant Secretary Monica Rainge, Civil Rights 

• Director Heather Dawn Thompson, Office of Tribal Relations

• Director Frank M. Wood, National Appeals Division
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Additionally, USDA provided a library of resources to the Equity Commission including 

relevant Executive Orders, American Rescue Plan documents, Government Accountability 

Office (GAO) Reports and Findings, USDA internal reports and findings, USDA advisory 

committee reports and findings, and USDA strategic plans and equity action plans. 

The attached interim report includes our set of 32 initial recommendations, all of which were 

approved unanimously. 

Our goal was not to duplicate the efforts already underway at USDA, but to identify additional 

steps for embedding equity into USDA’s policies, practices, and processes. However, many of 

the issues we identified are not new issues or concerns. They require renewed commitment from 

USDA to improve its customer-facing business processes and address historical inequities. 

The Equity Commission and our two subcommittees will continue to research and develop 

recommendations to include in our final report, which we will submit by the end of 2023. We 

also look forward to continuing our work with the Rural Community Economic Development 

Subcommittee to develop an additional set of recommendations. It is an honor to be a part of this 

important work. On behalf of our fellow Commission members, we want to thank you again for 

the opportunity to help advance equity at USDA.

Sincerely,

Dr. Jewel Bronaugh Arturo S. Rodríguez

Co-Chair, Co-Chair, 

USDA Equity Commission USDA Equity Commission 
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Equity Commission Members

• Dr. Jewel Bronaugh, Co-Chair, Deputy Secretary, USDA

• Arturo S. Rodríguez, Co-Chair, Special Government Employee

• Shorlette Ammons, Special Government Employee

• Todd Corley, Special Government Employee

• Ertharin Cousin, Chair & Chief Executive Officer, Food Systems for the Future

• Derrick Johnson, Special Government Employee

• Yvonne Lee, Special Government Employee

• Elizabeth Lower-Basch, Special Government Employee

• Dr. Mireya Loza, Special Government Employee

• Dr. Ronald Rainey, Special Government Employee

• Charles Rawls, Special Government Employee

• Dr. Hazell Reed, Executive Director, National Black Growers Council

• Shirley Sherrod, Executive Director, Southwest Georgia Project for Community 

Education

• Poppy Sias Hernandez, Special Government Employee

• Rick Smith, Former President and Chief Executive Officer, Dairy Farmers of America

• Toni Stanger-McLaughlin, Chief Executive Officer, Native American Agriculture Fund

Subcommittee on Agriculture Members

• Erica Lomeli Corcoran, Systemic Change Director, United Farm Workers Foundation

• Dr. Gina Eubanks, Special Government Employee

• Janssen Hang, Co-Founder and Executive Director, Hmong America Farmers 

Association

• Phillip Johnson (P.J.) Haynie, III, Farmer/Owner, Haynie Farms LLC

• Savonala “Savi” Horne, Special Government Employee

• Michelle A.T. Hughes, Operations and Impact Director, National Young Farmers 

Coalition

• Kari Jo Lawrence, Executive Director, Intertribal Agriculture Council

• Gary Matteson, Executive Vice President of Young, Beginning, Small Farmer programs 

and Outreach, Farm Credit Council

• Dr. Alexis Racelis, Special Government Employee

• Russell Redding, Secretary of Agriculture, State of Pennsylvania

• Shari Rogge-Fidler, Chief Executive Officer, Farm Foundation

• Dr. Jennie Stephens, Chief Executive Officer, Center for Heirs' Property Preservation

• Sarah Vogel, Lawyer, Sarah Vogel Law Office
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Table of Contents

I. Executive Summary..............................................................................................................................7

II. Support of the Federal Government’s Focus on Equity........................................................................8

III. Historical Context .................................................................................................................................9

IV. About the Commission and its Subcommittees ..................................................................................11

V. Goals of the Commission and its Subcommittees...............................................................................12

VI. Commission Workplan .......................................................................................................................14

VII. Promoting Accountability and Transparency: Compilation of Historical Recommendations............15

VIII.Interim Report Recommendations......................................................................................................16

 How USDA Works with Farmers, Ranchers, and Producers Day-to-Day...............................................17

Recommendation 1: Heirs’ Property and Fractionated Land..............................................................17

Recommendation 2: Land Access.......................................................................................................18

Recommendation 3: Conservation......................................................................................................19

Recommendation 4: Technical Assistance and Outreach ...................................................................20

Recommendation 5: Subsistence Farmers ..........................................................................................22

Recommendation 6: Farm Service Agency Loan Programs...............................................................22

Recommendation 7: Base Acres Modernization.................................................................................23

Recommendation 8: County Committees...........................................................................................24

 USDA’s Need for Department-wide Change...........................................................................................27

Recommendation 9: Institutionalize Equity........................................................................................27

Recommendation 10: Legislation to Ensure Accountability for Equity .............................................27

Recommendation 11: Elevate the Office of Tribal Relations.............................................................29

Recommendation 12: Language Access.............................................................................................29

Recommendation 13: Customer Experience.......................................................................................30

Recommendation 14: Annual Compliance Reviews...........................................................................30

Recommendation 15: Equity Audits...................................................................................................31

Recommendation 16: Office of the Assistant Secretary for Civil Rights...........................................31

Recommendation 17: Private-Public Partnerships..............................................................................32

Recommendation 18: Procurement.....................................................................................................33

 USDA’s Commitment to Farmworkers and Their Families....................................................................35

Recommendation 19: Staffing Farmworkers’ Work...........................................................................35

Recommendation 20: Interagency Farmworker Service Council .......................................................35

Recommendation 21: Farmworker Nutrition......................................................................................35

Recommendation 22: Farmworkers’ Access to USDA Programs......................................................36

Recommendation 23: Funding for Farmworkers................................................................................36

 Re-evaluating Other USDA Programs.....................................................................................................38
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Recommendation 24: The Federally Recognized Tribal Extension Program.....................................38

Recommendation 25: 1890s Institutions Matching Requirements .....................................................39

Recommendation 26: Cooperative Extension Service Programming.................................................39

Recommendation 27: Cooperative Agreements and Competitive Grants..........................................39

Recommendation 28: Distinctions that Allow Access to Endowments and Appropriations..............40

Recommendation 29: Supplemental Nutrition Assistance Program (SNAP).....................................41

Recommendation 30: Thrifty Food Plan (TFP) ..................................................................................41

Recommendation 31: Customer-Centered Service of the Supplemental Nutrition Assistance Program 

(SNAP)................................................................................................................................................42

Recommendation 32: Review of Nutrition Programs.........................................................................42
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I. Executive Summary

The purpose of the USDA Equity Commission (“the Commission”) is to make recommendations 

for enduring changes to USDA programs and policies that eliminate or mitigate barriers to 

inclusion or access, eliminate systemic discrimination, advance equity and justice, and provide 

meaningful processes for continuing oversight of civil rights issues. Congressional reports, 

internal USDA studies, and court actions going back to the 1960s have well documented racial 

and other forms of discrimination at USDA in program access and delivery. Farmers who are 

Black, Hispanic, Native American and Alaska Native, Asian and Pacific Islander, women, and 

young, new, or beginning, have disproportionately encountered barriers to accessing critical 

USDA funding and resources needed to adequately support their agriculture operations, specialty 

crops/alternative enterprises, and local communities. Section 1006 of the American Rescue Plan

Act (ARP) and the Inflation Reduction Act (IRA) provide a critical opportunity for USDA to 

take concrete steps toward addressing longstanding barriers and inequities, including 

authorization of the Equity Commission to examine equity issues at USDA. 

The Equity Commission plays a vital role in identifying the root causes of existing inequities and

assisting USDA to center equity and justice within the Department’s efforts to develop and 

strengthen policies and approaches to truly serve all people regardless of their background or 

experience.

Ultimately, the Equity Commission is helping guide USDA’s efforts to deliver on the 

Department’s broad justice and equity goals addressing discrimination/disparity relating to race, 

gender, sexual preference, disability status, religion, rural versus urban, and persistent poverty 

communities. We are informed in that endeavor in part by the Executive Order on Advancing 

Racial Equity and Support for Underserved Communities through the Federal Government (EO 

13985) and the Executive Order on Diversity, Equity, Inclusion and Accessibility in the Federal 

Workforce (EO 14035). 

This Interim Recommendations report is the first report of the Commission. 

The Commission is submitting 32 recommendations for USDA’s consideration that focus on the 

following areas for near and long-term action:

• How USDA Works with Farmers, Ranchers, and Producers Day-to-Day

• USDA’s Need for Department-Wide Change

• USDA’s Commitment to Farmworkers and Their Families

• Re-evaluating Other USDA Programs
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II. Support of the Federal Government’s Focus on Equity

In January 2021, President Biden signed Executive Order 13985 On Advancing Racial Equity 

and Support for Underserved Communities Through the Federal Government and committed to 

creating an Equity Commission as part of his rural agenda and commitment to closing the racial 

wealth gap by addressing longstanding inequities in agriculture.

In March 2021, Section 1006 of the American Rescue Plan (ARP) (as amended by Section 22007 

of the Inflation Reduction Act of 2022) directed USDA to establish the Equity Commission and 

provided funds sufficient to ensure the Commission is well staffed and positioned to deliver on 

its charge. A report on the implementation of the ARP provides details on how each Federal 

Agency, including USDA, has taken steps to ensure that equity was part of the fabric of the 

program. Additionally, each Federal Agency was required to submit an Equity Action Plan to the 

White House.

To inform USDA’s Equity Action Plan, the Department issued a request for information (RFI) 

on June 16, 2021, which sought information from the public to help identify opportunities in 

current USDA policies, regulations, and guidance that would be useful in addressing systemic 

inequities. USDA received more than 400 public comments from individuals, advocacy 

organizations, Tribal entities, state, and local governments, and more. These submissions

informed USDA’s Equity Action Plan, published February 10, 2022, which states a clear and 

strong commitment to equity in the programs and operations of the Department, and provides a 

roadmap, in broad terms, for the equity work of the Department and each of its Agencies for the 

future.

The Commission supports and applauds ongoing USDA Equity initiatives including, but not 

limited to:

• USDA Equity Action Plans

• Mission Area and Program Initiatives

• Diversity, Equity, Inclusion, and Accessibility (DEIA) Strategic Plans

• Creation of a USDA DEIA Office and hiring of a Chief Diversity and Inclusion Officer

• ARP and IRA Funding and Implementation
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III. Historical Context

The Commission considers its primary equity charge to be forward looking: What data is useful 

to detect and document disparities in USDA programs and personnel? What barriers can we 

identify and eliminate to improve access and availability of USDA programs and services for all 

eligible Americans? Across America and many parts of the world, dedicated individual 

employees of USDA do important work to accomplish the Department’s many missions. A 

report on these various programs and activities and their successes would fill many volumes. 

USDA feeds millions of food insecure Americans every day, ensures a safe and wholesome food 

supply, provides clean water to thousands of rural communities, conducts vital research, provides 

critical solutions for plant and animal diseases, provides quantifiable soil and water conservation 

and forest management for a better environment, promotes markets for U.S. agricultural 

products, and provides stability and an economic safety net for America’s farmers and ranchers.

USDA serves the American public every day, in hundreds of ways. Therefore, it is vital that its 

programs are delivered equitably, efficiently, and fairly. Studies, listening sessions, and personal 

testimony informed the Commission that discrimination and unfair treatment has existed in 

numerous USDA programs—loans, grants, and services—as well as internally within hiring and 

promotion practices. Many individuals who have interacted with USDA have come away with 

the belief that discrimination, bias, or unfairness has played a significant role in limiting their 

access to services and benefits. We know that Black farmers lost nearly 90 percent of their 

valuable farmland between 1910 and 1997 and are still suffering from the effects of those losses 

today. We know the long-lasting impact of internment of Japanese Americans during World War 

II resulted in a loss of Asian agriculture ownership from early to mid-20th century. While hard to 

quantify, we also know that inequitable practices have harmed the success and contributed to the 

loss of farms for Hispanic and Indigenous farmers. We know that limited access to credit and 

unreasonable bureaucratic requirements are persistent barriers to economic development and 

success for Native American and Native Hawaiian producers. We know that the lack of access to 

language services, outreach, and nutrition programs negatively impact Asian American and 

Hispanic farmers and other immigrant farmworkers and their families. We know some members 

of several other communities, such as young, new, beginning farmers, and specialty crop 

producers continue to feel that they have not and cannot equally participate in USDA programs. 

Farming is challenging under any circumstance. Many factors play into the ability of farmers to 

grow and thrive in such a competitive and difficult environment. The unequal distribution of 

programs and benefits and disparities in risk management and conservation benefits reflect the 

cumulative impact of inequitable practices, creating an added and unnecessary burden. Systemic 

concerns about program design and implementation go beyond farm lending activities. The 

disparate access results in cumulative impacts that limit farm size, wealth accumulation, and 

quality of life issues for many communities.

The Commission recognizes the collective impact and compounding harm that inequitable 

practices of the past have perpetuated over time. These past actions inform the Commission’s 

critical view of existing USDA structures, programs, and service to Americans today. To be 

successful in its endeavors, the Commission is committed to recommending sweeping and 

generational change that must not only interrupt the perpetuation of discriminatory systems but 
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reconstruct the way USDA operates at all levels moving forward, to create an equitable and 

inclusive future.

The vision is that USDA cannot fulfill its mission without delivering equitable service. Equity is 

not about one USDA customer versus another; it is about ensuring ALL USDA customers 

receive equitable treatment and support needed to operate sustainable, efficient, and productive 

operations.
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IV. About the Commission and its Subcommittees

The purpose of the Equity Commission is to advise the Secretary of Agriculture by (1) providing

USDA with an analysis of how its programs, policies, systems, structures, and practices 

contribute to systemic discrimination, construct barriers to inclusion or access, and exacerbate or 

perpetuate racial, economic, health and social disparities, and (2) recommending corrective

action. The Equity Commission is subject to the requirements of the Federal Advisory 

Committee Act (FACA) and its membership and charge are established under a charter, as 

required by FACA.

The Equity Commission currently includes a Subcommittee on Agriculture, and a Rural 

Community Economic Development (RCED) Subcommittee. The recommendations of the 

Agriculture Subcommittee in this Interim Report address issues and concerns specifically related 

to agriculture and conservation. The RCED Subcommittee will provide recommendations on 

issues and concerns related to rural housing, rural utilities, and rural business and community 

development, persistent poverty, and underserved communities.

In September 2021, the Federal Register Notice called for nominations for the Equity 

Commission and its Subcommittee on Agriculture. Members were appointed by the Secretary in 

accordance with the membership balance plan in February 2022. Nominations for the RCED 

Subcommittee were solicited in the Federal Register in April 2022, with members named in 

August 2022.

Under its charter, the duties of the Commission are solely advisory. Commission 

recommendations will aid USDA in achieving its goals by helping the Department improve 

access to programs and services for all Americans and serve all its diverse stakeholders with 

greater fairness and equity. 
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V. Goals of the Commission and its Subcommittees

Based on stakeholder engagement and former recommendations, the following goals for the 

Equity Commission and its Subcommittees were established by USDA.

Equity Commission Goals:

• Identify and recommend actions to remove barriers to equitable access and use of 

USDA programs, policies, systems, structures, and practices, including impediments that 

are internal, external, discretionary, or statutory.

• Recommend actions and solutions that address racial equity issues, expand assistance, 

and provide support for historically underserved customers and communities needed for 

equitable access to USDA programs and services.

• Recommend actions and solutions that address broader and more systemic equity issues 

at USDA.

• Recommend actions that will ensure USDA is a modern, competitive workplace with 

an organizational culture that prioritizes diversity, equity, inclusion, and access for its 

staff and customers alike.

Subcommittee on Agriculture Goals:

• Improve technical assistance necessary for navigating USDA programs and

services.

• Improve access to capital.

• Improve access to programs and services related to agriculture and land use.

• Implement programs and services to mitigate effects of climate change, including 

improvements in risk management, conservation, and forestry programs.

• Address access to land, including financing programs and addressing unique issues 

related to heirs’ property, fractionated land, and other land access/retention issues.

• Increase market access to facilitate expanded access for value added opportunities 

(e.g., processing, trade, and marketing).

• Enhance customer service via improved USDA staffing, training, and transformation of 

the organizational culture within USDA.

• Review supporting functions such as county committees, conservation districts, and 

advisory boards.

• Improve use of data and technology both to ensure access and to increase accountability. 

• Improve USDA performance measurement and program evaluation so that implemented 

recommendations can be monitored, tracked, and reported with real outcomes.

• Make recommendations for ways to hold USDA accountable by requesting an 

implementation strategy and an action plan on recommendations.

Rural Community Economic Development Subcommittee Goals:

• Improve technical assistance, capacity building, and place-based economic development 

strategies necessary for navigating and accessing USDA programs and services. 
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• Improve access to capital for business growth and development in rural and Tribal 

communities.

• Improve USDA’s program delivery strategy to ensure investments are equitable now and 

into the future, including data-driven outreach and program design.

• Reduce climate pollution, implement environmental justice standards, and ensure better 

management of natural resources.

• Minimize disproportionate effects of climate change by increasing infrastructure 

resilience and economic support to rural and Tribal communities.

• Improve access to high-speed internet for all rural and Tribal residents.

• Ensure equitable access to safe, affordable housing.

• Ensure equitable access to safe, affordable, and resilient water and wastewater 

infrastructure.

• Improve equitable and sustainable access to natural resources, including recreational 

facilities.

• Enhance customer service via improved USDA staffing, training, IT modernization, and 

transformation of the organizational culture within USDA.

• Improve use of data and technology both to ensure access to programs and services and 

to increase accountability.

• Improve USDA performance measures and program evaluation so that the 

implementation of recommendations can be monitored, tracked, and reported with real 

outcomes.

• Make USDA accountable by requesting an implementation strategy and an action plan on 

recommendations.
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VI. Commission Workplan

The Equity Commission and Agriculture Subcommittee members were appointed and the first 

public meeting was held in February 2022. In accordance with FACA guidelines, the public was 

given the opportunity to provide comments for consideration to committee members in written 

and oral form. All public meetings are streamed virtually to allow maximum participation.

During the first public meeting the members were given their goals as stated above and 

subsequently grouped into three focus areas: Access, Service, and Performance. Following that 

meeting, members expressed the need to know where USDA implementation or consideration 

stood on the many equity-related recommendations that other committees and reports made over 

the years. In response, the Department started a Compilation of Historical Recommendations 

initiative based on relevant reports identified by the Commission. Further discussion of the 

initiative is included in Part VII of this report.

During the second public meeting held in May 2022, members received historical perspectives 

from USDA leadership and updates about current equity work being done at the Department. 

Members brainstormed a list of potential recommendations to explore further and collaborated 

on next steps for developing the Interim Report. Following the meeting, Farmworker, Nutrition, 

and Department-wide focus areas were added and subsequent workgroups were formed to align 

to the themes. Additionally, an Interim Report writing team was formed leveraging the varied 

expertise and stakeholder representation from the members.

During the third public meeting held in September 2022, members presented draft 

recommendations from the workgroups to ensure collective clarity and understanding of each 

recommendation. The Equity Commission members deliberated and voted on each 

recommendation to be included in the Interim Report. Other recommendations were deferred for 

further review and possible action during future meetings.

During the fourth public meeting held in February 2023, members revisited the interim 

recommendations as some changes were made since the previous public meeting vote. Members 

presented, deliberated, and voted to include the 32 recommendations within this Interim Report. 

One recommendation was tabled for further research and deliberation. 

As previously noted, the RCED Subcommittee was formed in September 2022 and is charged 

with providing recommendations on issues and concerns related to rural development, persistent 

poverty, and underserved communities. As of the publication of the Interim Report, the RCED 

Subcommittee is currently researching and developing recommendations for consideration by the 

Equity Commission during future public meetings.
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VII. Promoting Accountability and Transparency: Compilation of 

Historical Recommendations

The recommendations of the Commission are forward looking. However, at the beginning of the 

Commission’s formation, members recognized the benefits of knowing the status of the various 

recommendations that have been made in the past on—or closely related to—equity issues at 

USDA. Reports dating back to 1965, beginning with the Equal Opportunity in Farm Programs

Report, demonstrate concerns with inequality at USDA. In response, USDA staff supporting the 

Commission conducted a department-wide review process documented as a “compilation of 

historical recommendations” (CHR). Staff continue to refine the project in an effort to gather 

more information and to determine the most accurate and appropriate ways to categorize and 

display the data.

The Commission received a preliminary briefing on the summary of findings of the CHR at its 

third public meeting in September 2022. Once the analysis is finalized, the results will be 

provided to the Secretary and made available to the Commission. In summary, as part of this 

effort, 748 historical recommendations from 11 reports were compiled by the staff into a single 

inventory and assigned to the relevant mission areas and agencies for review and comments 

related to implementation status. 

Recurring issues identified for the Commission included lack of workforce diversity, 

cumbersome program processes, lack of technical assistance, county committee adverse impacts, 

and civil rights accountability and program complaints. Common challenges or obstacles to 

implementing past recommendations included lack of clear USDA ownership and authority to 

act, budgetary resources needed for implementation, and the need for metrics to measure and 

track progress. The briefing also noted the lack of standardized practices that would enable 

USDA to systematically incorporate stakeholder input, historical reports, and the outcomes of 

program evaluations into strategic planning, policy design, and regulatory development in a 

cohesive way.

While not final, the Commission is grateful for the significant work produced by USDA, and for 

the cooperation demonstrated by the various offices and agencies that participated in the review. 

This foundational work will be very helpful in prioritizing the Commission’s efforts going 

forward, and in establishing a system to track the implementation of future recommendations. 

This effort will be an important legacy of the Commission.
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VIII. Interim Report Recommendations

The challenge for this Commission is to recommend actions that will drive impactful and 

resilient change and restore public trust in USDA. The Commission is keenly aware of the 

difficulty of the challenge. To have maximum and lasting impact, the recommendations must 

support, enhance, and amplify the existing equity work at USDA. The recommendations are 

intended to drive systems-level change. 

The Commission makes the following recommendations to advance equity at USDA. The goal is 

to identify additional steps that can build a lasting infrastructure for embedding equity into its 

policies, practices, and processes. The guiding principles are accountability, transparency, and 

equity.

At the outset the Commission calls attention to the common issues identified in the responses to 

the USDA request for information. These are not new issues or concerns, but they do require a 

renewed commitment at USDA to improve its customer-facing business processes. Specifically, 

the Department should undertake a best practices business process review to improve outreach 

and information, review its various grant, loan, and other applications to reduce complexity, 

clarify program requirements, assure that applications are written in simple terms using plain 

English, and that language barriers are addressed for non-English speaking communities. 

Agencies need to consistently work to ensure that decisions are fully explained and documented. 

Many individuals do not understand the basis of the denial of service or benefits and are left to 

assume that race or other discrimination determined the outcome of their application. Customer 

service surveys, receipts for service, and training in customer satisfaction skills for employees 

should also be utilized.
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How USDA Works with Farmers, Ranchers, and Producers Day-to-Day

The work of the Equity Commission is to address broad-reaching and systemic issues that 

prevent equitable access and use of USDA programs and services. The Equity Commission and 

Subcommittees focused several recommendations on supporting the farmers, ranchers, and 

producers that make up today’s agricultural industry. The Commission and Subcommittee on 

Agriculture were informed by the current USDA structures, policies, laws, lived experiences, and 

public comments submitted to the Commission or shared during public meetings to form the 

body of recommendations. Furthermore, the Commission was given preparatory briefings on the 

current ongoing USDA activities that promote equity in agriculture which include relending 

programs and other support for underserved farmers. The Commission applauds these efforts and 

offers the following recommendations to further advance equity for farmers, ranchers, and 

producers.

Recommendation 1: Heirs’ Property and Fractionated Land

The Equity Commission recognizes that heirs’ property, as defined in the Uniform 

Partition Heirs Property Act, and fractionated land are barriers that prevent historically 

underserved1 producers, farmers, ranchers, and other landowners from accessing USDA 

programs, such as loans offered by Farm Service Agency (FSA) and Rural Development 

(RD), and cost-share programs offered by Natural Resources Conservation Service 

(NRCS) and the Forest Service (FS). Currently, the only USDA option for heirs’ property 

owners/producers to resolve their title issues to access USDA programs is the use of the 

loans through the FSA Heirs’ Property Relending Program (HPRP). The HPRP provides 

loans through third-party intermediaries such as community development financial 

institutions (CDFIs) that in turn makes loans to individuals to cover estate and/or 

succession plans and the cost to acquire legal counsel to resolve their title issues. 

Historically underserved/limited resource heirs’ property producers have difficulty 

receiving cost-share program funds from programs such as Environmental Quality 

Incentive Program (EQIP) and Conservation Stewardship Program (CSP), because they 

must compete with more experienced producers who have higher rankings.

1. Provide non-loan options for producers to prevent the creation of heirs’ 

property and fractionated land that would reduce the barriers this type of land 

ownership encounters when accessing USDA programs.

a. Appropriate funds for grants and cooperative agreements for communitybased nonprofit organizations to address and resolve heirs’ property and 

fractionated land issues for underserved producers through the delivery of 

legal technical assistance, education, and drafting of estate plans. 

b. Provide multi-year grants and/or cooperative agreements to 501c3 

organizations to deliver legal technical assistance and education that will 

prevent the creation of heirs’ property and remedy title issues which 

caused heirs’ property and fractionated land. These 501c3 organizations 

1 The Agriculture Improvement Act of 2018 (2018 Farm Bill) outlines four groups defined by USDA as “Historically 

Underserved,” including farmers or ranchers who are: Beginning; Socially Disadvantaged; Veterans; and Limited Resource, 

socially disadvantaged, beginning, limited resource, and veteran farmers and ranchers. The Equity Commission acknowledges 

that the definitions as currently written in the Farm Bill and other USDA policy may add to existing barriers to access programs 

and funding and continues to assess this and other definitions related to requirements to access funds, programs, or services.
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must have at least five years of experience delivering legal services to 

indigent persons.

c. Require all state Natural Resources Conservationists establish separate 

allocated funding of 10-15% of Environmental Quality Incentives 

Program (EQIP) cost-share funds for heirs’ property owners and socially 

disadvantaged producers (i.e., historically underserved minority 

producers). Currently, the requirement is 5%, but these landowners must 

compete with the more experienced producers who will receive a higherranking score. Creating a designated funding pool allows for more 

equitable competition and increases chances that disadvantaged producers 

will receive funding. Currently, the state conservationists in Alabama and 

South Carolina have used their discretion to establish such a pool for these 

producers.

Recommendation 2: Land Access 

The Equity Commission recognizes that USDA land-related programs have not been 

accessible to all, including farmers who are young, new, and beginning; women; and

Black, Indigenous, and people of color (BIPOC), and farmworkers. By funding 

community-led land access and transition projects, USDA will increase access to all 

farmers and ranchers, and increase engagement in programs and initiatives that can 

improve their land security, which is their greatest need to ensure a viable future for the 

agriculture industry.

2. Ensure equitable funding to community-led land access and transition projects.

a. Continue to direct funding to community-led land access projects designed to 

create land security for farmers. This USDA funding should be available to a 

wide variety of entities, such as tribes, municipalities, nonprofits, and 

cooperatives, with priority for projects led by and benefitting underserved 

farmers and ranchers. This funding should be available as a line of credit or 

grant prior to purchase, enabling eligible entities to act quickly in the real 

estate market.

b. Authorize mandatory, recurring funding for land-access related data gathering, 

including the Tenure, Ownership, and Transition of Agricultural Land survey 

that includes data collection on farmer demographics and economic data by 

county. Report data by county publicly and include median and average rates 

of participation by race, gender, and ethnicity.

c. Amend and fund the Commission on Farm Transition established in the 2018 

Farm Bill to study land access and transition to inform policy setting that 

facilitates equitable access to land.

d. Provide the Office of Tribal Relations (OTR) with the authority to 

immediately appoint a Designated Federal Officer from OTR to help facilitate 

the nomination process for seating the Tribal Advisory Committee authorized 

in the 2018 Farm Bill. This committee will provide advice to USDA on 

Tribal-related issues and policies throughout the Department.
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e. Increase investments in the Heirs’ Property Relending Program as the 

program grows and expand funding eligibility to include administration of 

program funds by relending entities.

f. Provide direct family loans to close heirs’ property estates and be inclusive of 

legal costs.

g. Maintain and expand the level of funding and technical assistance related to 

the Highly Fractionated Indian Land Loan Program, created by the 2014 Farm 

Bill.

h. Engage with Indigenous and community-based organizations and other 

interested entities in ensuring that heirship issues also address 

“fractionization” issues that Tribal communities face.

i. Ensure USDA land-related programs are accessible to all young, new and 

beginning, women, and BIPOC farmers specifically, and next generation 

farmers as a whole, by accommodating eligibility for collective, cooperative, 

and communal non-family entities, and tracking and publicly reporting 

demographics data on program participants. 

j. Provide continued funding for cooperative agreements with community-based 

organizations, such as the Natural Resources Conservation Service 

Cooperative Agreements for Racial Justice and Equity.

k. Implement thorough racial equity informed evaluation and reporting 

requirements to not only measure who is benefitting, but also to measure 

program effectiveness in facilitating secure land tenure for young, new and 

beginning, women, and BIPOC farmers.

Recommendation 3: Conservation

The Equity Commission recognizes that USDA climate programs have historically 

targeted large-scale producers and have not supported traditional sustainable practices. 

By including equitable climate justice actions, USDA can ensure Indigenous practices 

are integrated into the Natural Resources Conservation Services’ (NRCS) sustainable 

agriculture programs and support smaller, non-traditional farmers in accessing 

Environmental Quality Incentives Program (EQIP) funding and other environmental 

programs.

3. Include equitable climate actions in USDA conservation programs to address 

environmental justice.

a. Increase incentive payments for implementation of climate-resilient practices 

to ensure limited-resource farmers can participate in cost-share programs. 

Automatically provide EQIP advance payments for historically underserved 

producers. The Commission recommends that NRCS reduce the required 

number of years a producer must be in production on a particular parcel of 

land to qualify for EQIP. 

b. Adjust EQIP and Conservation Reserve Program (CRP) practice standards to 

better integrate, and to equitably compensate for, the use of Indigenous 

knowledge and land management practices. Federal conservation programs 

should streamline support for producers embodying these practices, not create 

a barrier to accessing NRCS. The Commission recommends that USDA take 
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into consideration non-traditional methods of agriculture (i.e., subsistence 

farming, aquaculture/fishing) for disaster relief purposes and other assistance 

programs offered by the Agency.

c. Prioritize research that helps small-scale, diversified farmers implement 

climate-smart conservation practices and measure their climate mitigation 

impacts through methods with a proven track record of success, which should 

include traditional or historical agricultural practices.

d. Increase funding for technical assistance to be linguistically and culturally 

appropriate and invest in local experts and communities through cooperative 

agreements with tribes, acequias, and other experts.

e. Support climate justice solutions that target resources to women and BIPOC 

farmers and protect farmworkers from hazardous working conditions due to 

climate change.

f. Require the collection and public reporting of demographic data on all 

conservation programs to better understand how producers who are young, 

new and beginning, women, and BIPOC are utilizing the conservation 

programs. 

g. Develop science-based climate-smart agriculture definitions that include 

Tribal Ecological Knowledge and further prioritize practices that afford the 

greatest climate benefit, such as incorporating cover crops, perennial crops, 

managed grazing of perennial pasture, and other investments in soil health.

h. Codify the new Micro Farm program through the Risk Management Agency 

to improve access to crop insurance for operations that are diversified, 

organic, and/or selling in local, regional, and specialty markets.

i. Expand direct marketing prices within the Noninsured Crop Disaster 

Assistance Program (NAP) or allow all farmers to use their own yields and 

historic pricing data to more equitably serve farmers who sell direct-toconsumer or receive a premium on their crops. 

j. Administer NAP as an on-ramp to more holistic risk management programs 

such as the Whole Farm Revenue Protection program and the Micro Farm 

program. 

k. Increase the maximum allowable farm revenue for historically underserved 

applicants to the Micro Farm program.

l. Mandate NRCS provides the public with an impact report on how EQIP 

funding has been used, and the impact those dollars have had on the 

environment. 

Recommendation 4: Technical Assistance and Outreach

The Equity Commission has heard from multiple stakeholders that navigating USDA 

programs and services can be an impediment and, in some instances, impossible for 

certain stakeholders. By allocating funding for third-party organizations to provide 

technical assistance, mediation services, and/or legal services, USDA can ultimately help 

applicants get the tools and resources they need to submit competitive applications for 

programs. 
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Furthermore, the existing outreach and engagement structures in USDA across mission 

areas, offices, and programs need to have a centralized hub to better identify, reach, and 

align USDA programs and services with those stakeholders requiring technical 

assistance. In doing so, USDA will be better equipped to respond, cross-coordinate, and 

plan for ongoing stakeholder needs across mission areas, offices, and programs and 

provide stakeholders and customers a more seamless experience across USDA’s 

technical assistance portfolio of support.

4. Establish and/or ensure USDA’s external engagement office has the necessary 

capacity, resources, and skillsets to operate in a robust and centralized manner 

that will enhance the Department’s role and financial investment in 

organizations (nonprofit, non-governmental, community-based) to provide 

technical assistance. 

a. Increase the Department’s institutional bandwidth, both technically and 

financially, to increase support for young, new and beginning, small-scale, 

underserved, and specialty crop farmers. 

b. Invest in early mediation and technical services for farmers transitioning 

and accessing land, in particular Heirship and Trust or Restricted 

property.

c. Develop and implement innovative, culturally responsive communication 

platforms and outreach strategies, including mobile technologies to engage 

young, new and beginning, small-scale, underserved, and specialty crop 

farmers on starting and maintaining a successful agricultural enterprise 

while facilitating strong, consistent connections with USDA personnel.

d. Provide cooperative agreements to organizations offering effective 

agricultural business management tools, such as the Center for Farm 

Financial Management, to strategically engage in expanded, targeted 

outreach and offer technical assistance tools to young, new and beginning, 

small-scale, underserved, and specialty crop farmers.

e. Develop a dashboard of nonprofit organizations and institutions of higher 

education that provide technical assistance to young, new and beginning, 

small-scale, underserved, and specialty crop farmers so USDA can 

provide information and updates to these entities as well as request for 

feedback on programs and potential opportunities to partner with USDA.

f. Provide targeted technical assistance trainings and coaching to nonprofit 

organizations that serve underserved producer communities by focusing 

on understanding USDA grant programs, funding technical assistance 

efforts, and enhancing capacity to submit quality, competitive grant 

proposals.

g. Provide technical assistance to USDA-funded, nonprofit organizations 

serving young, new and beginning, small-scale, underserved, and specialty 

crop farmers to increase their internal capacity for effective nonprofit 

organizational management.
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Recommendation 5: Subsistence Farmers

The Equity Commission is concerned that the Census of Agriculture does not fully 

account for subsistence farmers who rely on trading and/or sharing resources. The 

current farmers/ranchers included in the census–whether rural or urban–count if $1,000 

or more of agricultural products were produced and sold, or normally would have been 

sold, during the census year. The Native farming community believes that the Census of 

Agriculture data on Native farmers is incomplete, making policymakers and USDA staff 

believe the community is smaller than it is and therefore ineligible to receive program

benefits.

5. Direct the National Agricultural Statistics Service (NASS) to include the varying 

types of farmers and ranchers in the next Census of Agriculture to account for 

the nature of many traditional forms of how agriculture products are produced, 

sold, or exchanged. In addition, NASS should evaluate the threshold used to 

quantify a qualifying farmer and provide education on alternative forms of 

documentation that can be used for eligibility. The Secretary should also direct 

NASS to research and consider changing the definition of a farm. 

Recommendation 6: Farm Service Agency Loan Programs

Existing Farm Service Agency (FSA) loan programs and processes challenge the ability 

of underserved individuals to access credit. Because FSA is seen as an entry point for 

those seeking assistance from USDA, transforming FSA’s culture to a customer service 

centered approach will lead to increased access to capital for programs and services in a 

more equitable way. Responding to the borrowing needs of underserved individuals with 

clarity of eligibility, simplicity of process, flexibility in administration—all delivered in a 

timely manner—will further equitable engagement more than any other effort.

6. Transform FSA into a customer service organization that provides equitable

treatment for all.

a. Examine FSA loan processes and use plain language and clearly describe 

eligibility criteria regarding loan programs and processes to improve equitable 

access to underserved populations of both new and experienced farmers and 

ranchers.

b. Provide additional flexibility regarding the timing and processing of loans, 

including the ability to offer an initial statement of eligibility or accept 

preliminary paperwork before an application is submitted. Additional 

flexibility regarding loan terms and conditions should be available when 

structuring financial packages for underserved farmers and ranchers.

c. Identify gaps between FSA loans and USDA grant programs intended for 

underserved populations to assure that Inflation Reduction Act (IRA) and 

USDA initiatives can be effectively combined to meet the needs of 

underserved individuals.

d. Define “distressed borrower” to include those that have not yet entered 

delinquency yet are under financial stress that may prevent them from 

continuing farm operations.
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e. Develop cooperative agreements with community-based organizations who 

work as agents of and advocates for individual borrowers with their 

permission to allow examination of individual borrower applications and loan 

decisions.

Recommendation 7: Base Acres Modernization

Starting with the Agricultural Adjustment Act of 1933 (New Deal), USDA has deployed 

various strategies to subsidize farmers producing covered commodities. From the 1930s 

to the early 1990s, these payments were closely tied to the farmer’s production, a process 

which was largely monitored and regulated by the Farm Service Agency through county 

committees. In the 1996 Farm Bill (the Food, Agriculture Improvement and Reform Act), 

farm program payments were decoupled from actual plantings, instead based on the 

historical production. This system of paying farmers via crop acreage bases (CABs), 

which is the established acreage and yields of eligible commodities, has become an 

important part of an operation’s cash flow, especially in times of low crop prices or 

challenging production environments. CABs are used to calculate annual subsidies paid 

to producers and landowners (with crop share leases).

The critical years for establishing these CAB components were 1981-1985, when farmers 

were allowed to report annual planted acreage and average yields, excluding the years 

with the highest and lowest yield. During this period, covered crops included wheat,

corn, sorghum, barley, oats, upland cotton, and rice and subsequent farm bills utilized 

these CABs as the foundation for making future payment modifications. The 2002 Farm 

Bill (Farm Security and Rural Investment Act) continued decoupled payments, but 

allowed soybeans, peanuts, and other oilseeds (sunflower, canola, rapeseed, mustard, 

flaxseed, Crambe, and sesame) to be added to uncommitted acreage. In nearly all cases, 

growers elected to add these oilseeds to eligible uncommitted acreage, a process which 

strengthened the safety net but did little to address disparities among producers.

Subsequent opportunities to modify CABs provided some assistance, but still did not 

properly address large discrepancies, according to recent data.

USDA reports and congressional testimony have provided evidence of huge 

discrepancies in subsidies paid to underserved producers in comparison to their 

neighbors, with some reports showing them receiving only 20-25% of the per acre 

subsidies received by their neighbors. Admitted discrimination during the critical period 

(1981-1985) for establishing CABs likely played a role in certain farmers only being able 

to secure funding to produce lower yields of lower value crops. Farmers who were privy 

to loans were able to install irrigation, improve drainage, adopt technology, and make 

other infrastructure improvements that allowed them to increase yields, diversify crops, 

and expand acreage. Contrarily, many underserved farmers still operate acres that need 

improvements as they can only produce lower yields of lower value crops (e.g. winter 

wheat or oats and non-irrigated summer crops). The disparate annual subsidies, 

currently Agriculture Risk Coverage and Price Loss Coverage (ARC/PLC) payments, 

distributed annually only exacerbate these longstanding problems.
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7. Modernize base acre policies to address the concern of producers’ inability to 

receive necessary program payments that help stabilize on-farm revenue during 

economic downturns with commodity markets.

The base acre modernization would support a combination of one or more of the 

following: 

a. Review base acre farm program payment calculations and consider 

redistribution of base acreage to address disparities among farmers. Determine 

commodity specific base acres on lands historically not included in the initial 

base acre establishment.

b. Allow cost-shared improvements to significantly inferior base acres in a 

prioritized format.

c. Allow re-establishment of crop acreage bases (CABs) after improvements are 

completed. As an alternative, allow significantly inferior base acres to qualify 

for an annual revenue adjustment based on county or regional discrepancies.

Recommendation 8: County Committees

The County Committee’s purpose, impact, and general efficacy has continued to be a 

point of research and reflection since its enactment via the Agricultural Adjustment Act 

of 1933 and throughout the series of congressional and legal adjustments made to their 

scope and operations via the Soil Conservation and Domestic Allotment Act of 1936 and 

subsequent Farm Bills (2002 and 2008). Continued study and recommendations for 

reform have been documented in reports such as the 1996 D.J. Miller Report, the 1997 

Civil Rights Action Team Report, and the 2011 Jackson Lewis Report. 

Despite the many past recommendations and attempts to alleviate the documented

inequities associated with the County Committee’s election process and power, 

addressing County Committees continues to be a critical step in advancing equity in 

USDA’s programs and services. County Committees in many states have not represented 

minority farmers and ranchers and the powers afforded to County Committees have 

continued to result in decisions that often cripple the economic livelihood of minority 

farmers and ranchers. As an extension of the FSA, County Committees presently have the 

authority to advise and make decisions on income safety-net loans and deficiency 

payments, conservation payments, emergency programs, and incentive, indemnity, and 

disaster payments for certain commodities. 

By elevating the voice of minority advisors, bolstering the training of new County 

Committee members, and improving the appeals process, the Commission aims to 

strengthen the accountability and transparency of County Committees. More broadly, the 

role of County Committees in today’s agricultural system should be reassessed and, if 

required, redesigned to ensure more equitable outcomes. 
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8. Address historical and present-day inequitable services by making County 

Committees more equitable. 

Training:

a. Require diversity training related to African American, Asian, Hispanic,

American Indian, Alaska Natives, Native Hawaiian, and Pacific Islander 

issues where a high number of diverse communities exist.

b. Include the appeals process and role of the minority advisor in training for 

new committee members.

c. Train County Committees to exercise their voting powers and use the tools at 

their disposal to ensure members can vote without retribution or sense of 

retribution for voting actions.

Representation:

a. Give current minority advisors the same voting rights and terms as elected 

members; where a minority advisor does not currently exist, the Secretary 

should appoint a minority VOTING member.

b. Consider a minimum percentage of representation required that is reflective of 

population for County Committee member vote. For example, if 10 percent of 

the county population consists of minority farmers and ranchers, 

approximately at a minimum, 10 percent of the County Committee 

representation should consist of voting minority farmers and ranchers 

reflective of that population.

c. Ensure equitable opportunities for individuals interested in serving on County 

Committees are available by reducing the complexities of the nomination and 

election process and increasing awareness about opportunities to serve on 

County Committees through multiple mechanisms, including but not limited 

to online outlets. Use the NASS Census outreach process as a way to notify all 

farmers of County Committee election and voting process and eligibility. 

d. Given the nature of Tribal Governments and their membership/citizenship, 

specific outreach should be created and implemented to provide awareness of 

the opportunity to serve through focused outreach.

e. The Secretary should explore the feasibility to change the eligibility of County 

Committee elections to expand efforts and allow nominations from the 

following categories: 

i. Community-Based Organizations with relevant expertise

ii. 1890 and 1994 Land Grant Institutions 

iii. Hispanic Serving Agricultural Colleges and Universities 

Accountability:

a. Establish a USDA County Committee Liaison responsible for identifying and 

instituting diverse representation on County Committees.

b. Increase transparency and accountability for County Committee staff by 

establishing performance metrics with controls and mechanisms to ensure 

they adhere to equitable standards and have access to USDA resources. The 

County Executive Director (CED) and County Committee staff should be 
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subject to oversight and evaluation by FSA with civil rights, equity, and 

demographic indicators included as metrics. 

c. Immediately implement a process to ensure that County Committee minority 

advisors have access to the FSA Administrator to bring in real time issues or 

concerns within the county and an annual report or accounting to the 

Administrator on how that committee is operating.

d. Provide more transparency on FSA elections by making reports and contact 

information available to the public in a timelier manner. Reports should 

include demographic information of the members. 

e. Conduct a biannual assessment on performance measures that indicate 

equitable outcomes for County Committees. Should the above 

recommendations not yield the desired equitable outcomes, conduct an 

external analysis and study on the equity disparities of the County Committees 

and a potential reform of the County Committee system to a more equitable 

alternative for ALL farmers. The analysis should include the current role of 

the County Committee creating disparities for women and BIPOC farmers, 

both the historical role of the County Committee system and the current 

displacement of women and BIPOC farmers. 
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USDA’s Need for Department-wide Change

The structure of the Department and how it serves the Nation has changed significantly over 

time; however, some structures, policies and cultural norms have persisted that no longer serve 

the American people and in fact have perpetuated inequity or widened the gaps that existed 

among Americans over time. USDA is currently made up of 29 agencies spread across the 

United States and overseas, serving more than 4,500 locations. The Commission recognizes and 

applauds USDA for restoring a standalone Office of Tribal Relations and appointing a Senior 

Advisor for Racial Equity in the Office of the Secretary. The following recommendations outline 

department-wide change that affects the Department’s structure, leadership responsibilities, and 

overarching accountability and data collection.

Recommendation 9: Institutionalize Equity

Lasting and long-term organizational change requires consistent leadership attention, 

adequate resources, and accountability. The Equity Commission understands that USDA 

has experienced uneven levels of commitment and success related to equity over the 

years, especially across changes in administration. We are making this recommendation 

to establish leadership responsibility and organizational accountability within the Office 

of the Deputy Secretary to ensure that equity efforts are institutionalized throughout the 

Department.

9. Institutionalize equity within the Department to drive compliance, 

accountability, and culture change across all of USDA.

a. Utilize existing leadership structures with line authority to provide consistent 

leadership attention for institutional change and organizational accountability.

b. Task the Deputy Secretary, through a Departmental regulation, to review Agency 

equity plans and ensure, through the annual budget process, that those plans are 

faithfully carried out and senior executives are accountable for making 

measurable improvements in equity in programs and services. 

c. The Deputy Secretary should use any staff and resources under its control beyond 

the Mission Areas, including operational, budgetary, administrative, financial, and 

economic analysis functions to carry out these responsibilities.

d. Support workforce diversity and cultural competency by enhancing and 

improving job descriptions and hiring requirements. This should include utilizing 

specialized experience and selective placement in recruitment actions to prioritize 

demonstrated experience with target populations, where applicable.

e. Conduct an Annual Convening on Equity to have data available to inform the 

ongoing work of the Equity Commission.

Recommendation 10: Legislation to Ensure Accountability for Equity

There have been many studies, reports, and recommendations over time across several 

groups outlining the need for change within USDA; however, the Commission recognizes 

the need for a sustainable and consistent framework within USDA that is transparent to 

the public, USDA staff, USDA customers, and partners.

For all equity efforts outlined in this report and those currently taking place across 

USDA to be successful, there is a need to enact legislation and policy to ensure that 
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continued work towards equity in programs and services is a priority of USDA 

leadership over time. More importantly, USDA should be measured and held accountable 

for their progress against impacting populations most affected by unfair or inequitable 

programs, services, or practices.

10. Support legislation to provide standing authority and accountability for the 

Secretary and senior leadership to carry out a continuous program to improve 

the equitable availability and distribution of services and program benefits to all 

eligible American residents. 

Key elements of the legislation would include the following:

a. The Secretary shall be responsible for directing and carrying out a continuous 

program to ensure all applicants and participants have equitable access to services 

and program benefits at USDA. 

b. The Secretary shall collect data, information, and conduct studies and analysis to 

understand and document the extent to which underserved communities are not 

participating equitably in the programs and benefits provided or administered by 

the Department, including those administered through state or local agencies, 

County Commissions, or nonprofit organizations. This shall include research and 

information sharing on the best ways to collect demographic information that do 

not rely on third-party visual observations, including both best practices for 

encouraging voluntary provision of demographic information and statistical 

methods to incorporate missing data.

c. Use data to evaluate programs and policies to identify and understand 

communities in need, where the funding is distributed, and who benefits. 

Participants benefitting from funding distributions should align with communities 

in need so that the investing efforts effectively reduce disparities.

d. The Secretary shall provide a publicly available annual report to Congress and the 

American public that provides details on the data collection and studies 

conducted, and the results thereof. The report shall also include discussion of 

efforts to implement necessary improvements to equity so identified, including 

metrics and timelines. 

e. Performance evaluations of Agency heads and senior executives shall reflect an 

individual’s appropriate and direct efforts to improve equity in the programs and 

services within their span of control or authority. 

f. If the Secretary identifies an opportunity to improve equity in a particular 

program or service but lacks authority to make the necessary changes, Congress 

shall be notified and provided a recommendation for a legislative change. If the 

Secretary identifies the need for additional resources to improve equity, Congress 

shall be notified and provided an explanation of the needed resources.

g. Revise definitions as needed: Such as “Equity,” “Equitable,” and “Underserved 

Communities” as defined from the Executive Order.

h. Funds and staff required to implement these provisions shall be from within 

existing budgets and appropriations.
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Recommendation 11: Elevate the Office of Tribal Relations

The Equity Commission agrees with a repeated recommendation from the 2021 RFI 

(Request for Information) Listening Sessions about the need for USDA to respect Tribal 

nations’ sovereignty. By elevating the Office of Tribal Relations to the Assistant 

Secretary level and providing dedicated resources, USDA can strengthen the Nation-toNation relationship with Indian Tribes and help improve support for Tribal ownership, 

protection, and conservation of land. The Tribal Liaison positions should have direct 

access to senior decision makers and be a combination of both career and appointed 

positions to ensure appropriate oversight and continuity over time.

11. Elevate the Office of Tribal Relations from its current office to become The 

Office of the Assistant Secretary of Tribal Affairs.

a. Establish the Assistant and Deputy Assistant Secretary of Tribal Affairs 

positions.

b. Align or create Tribal Liaison positions within each Agency, Mission Area, 

and Offices that have access to the highest ranking official within those areas; 

some of these positions already exist, some may need to be created, some 

should be elevated within their area to serve as the highest ranking official or 

career leader (example: Senior Executive Service [SES], Assistant Secretary, 

Administrator or Chief). These positions should also have the authority to 

coordinate and work with the Office of Tribal Relations or newly elevated 

Office of the Assistant Secretary of Tribal Affairs. 

c. Dedicate a Tribal Affairs attorney (GS-15 or SES) within the Office of 

General Counsel (OGC) to act as a support for the office and Agency-level 

Tribal Relations staff. 

Recommendation 12: Language Access

The Equity Commission recognizes language as a barrier for linguistically and culturally 

diverse communities trying to access USDA programs and services. It also recognizes 

language access as a key element of the U.S. Department of Justice Policy Guidance 

“Enforcement of Title VI of the Civil Rights Act of 1964 - National Origin Discrimination 

Against Persons with Limited English Proficiency” (LEP Guidance). Additionally, the 

Equity Commission notes that per Executive Order 13166 “Improving Access to Services 

for Persons with Limited Language Proficiency” (August 11, 2000), a memo issued by 

the Attorney General on November 21, 2022, asks USDA to submit an updated plan to 

improve language access within 180 days. By adhering to these policies and improving 

language accessibility, USDA can become a more equitable, inclusive, and culturally

competent Department.

12. Ensure equitable language and culturally competent access to USDA services.

a. Designate an executive level career staff member to be responsible for 

Language Access guidance, compliance, and oversight.

b. Cultivate a sustainable department-wide culture of equity and inclusion by 

investing in long term financial partnerships with women and BIPOC 

servicing educational institutions and Tribal, territorial, and community 
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service organizations to build Language Access capacity for current and next 

generations of agricultural partners, stakeholders, and department workforce. 

c. Increase funding for technical assistance to be linguistically and culturally 

appropriate and invest in local community serving organizations and 

communities through cooperative agreements with tribes, acequias, and 

organizations.

Recommendation 13: Customer Experience 

The Equity Commission has identified the need for USDA to improve its customers’ 

experience and establish consistent and high-quality service across all agencies. By 

institutionalizing a routine, robust, and coordinated customer feedback loop into USDA’s 

programs and services, USDA can improve its efforts to provide more equitable and 

consistent services to all individuals that seek service from and engage with USDA.

13. Improve Customer Experience through institutionalizing customer feedback, 

service delivery, and program design.

a. Establish an enterprise-wide feedback loop for all USDA agencies and offices 

to hear from stakeholders through multiple mechanisms such as evaluations, 

surveys, dial-in calls, QR Codes, newspaper advertising, radio, etc. 

b. Ensure feedback opportunities and responses are provided in multiple 

languages.

c. Provide specific feedback opportunities for individuals with lived experience 

and compensate them for their time and expertise.

d. Train USDA staff to be culturally sensitive, understand their constituents, and 

include community-based organizations in USDA language contracts to 

interpret and translate with more accuracy and cultural competence.

e. Increase staff knowledge of farmer and rancher customer profiles to 

adequately match relevant services and programs with USDA’s customers. 

Recommendation 14: Annual Compliance Reviews 

The Equity Commission supports the USDA’s adherence and execution of Section 14006

of the Food, Conservation, and Energy Act of 2008 (2008 Farm Bill), that mandates 

USDA prepare an annual report on each of its agency’s civil rights complaints, 

resolutions, and actions. By designating a responsible party for administering reports, 

providing the related data to inform compliance and customer service, and authorizing 

funding to conduct audits, USDA can increase trust, transparency, and accountability to 

its stakeholders.

14. Fund, establish, and maintain accountability for the execution or conduct of 

annual civil rights compliance reviews across all USDA agencies.

a. Complete and execute annual civil rights compliance reviews across all 

USDA agencies as mandated by the 2008 Farm Bill (section 14006), starting 

FY 2023.

b. Ensure reports and related data are accessible to the public and shared with 

Congress.
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c. Designate a responsible party for administering reports by the end of each 

fiscal year. 

Recommendation 15: Equity Audits

The Equity Commission reviewed reports and stakeholder input that detailed problems 

with the program complaint system such as the timeliness, complexity, and lack of 

transparency of the results of audits and reports. The Commission agrees with the 2021 

OIG determination that USDA needs to develop a stronger internal control environment 

over its civil rights program complaints processing to ensure that complaints and 

findings are timely, appropriately handled, and made publicly available. By complying 

with the existing Farm Bill audit requirements, USDA can leverage targeted research 

and analysis of existing publicly available data to identify and address patterns of 

complaints, discrimination, and systemic issues.

15. Under existing authorities, conduct periodic system-wide audits to look at equity 

across USDA’s services. Publish results on the USDA website and release 

underlying data to independent researchers. Analyze program complaints and 

make use of findings.

a. Hire a third party to conduct an analysis of all program complaints received 

over the past five years and identify patterns for complaints, looking for 

programs, specific offices, and types of discrimination that have been 

alleged. These patterns should be used as a basis for identifying immediate 

fixes that can be made (e.g., making buildings and websites accessible, 

translating materials into additional required languages), prioritizing audits 

and statistical analysis of disparities in services received.

b. Conduct periodic audits across USDA system-wide to look at service of 

underserved customers. Publish results on USDA website. Release underlying 

data (with personally identifiable information removed) for independent 

researchers to replicate and build on official audits.

Recommendation 16: Office of the Assistant Secretary for Civil Rights

The Office of the Assistance Secretary for Civil Rights (OASCR) has received much 

attention through testimony and reports from organizations such as the U.S. Commission 

on Civil Rights, U.S. Equal Employment Opportunity Commission, USDA’s Office of 

Inspector General, and the Government Accountability Office. It has been noted by the 

Commission that oftentimes relief is found through class-action lawsuits versus working 

through the OASCR process due to backlog, capacity issues, and lack of expediency. 

Concerns persist around addressing backlogged complaints, processing times of 

incoming complaints, and capacity and staffing within OASCR. Ensuring program 

participants can effectively navigate the complaint process and receive timely resolutions 

will be instrumental in USDA’s ability to achieve its equity goals.
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16. Transform and adequately fund the Office of the Assistant Secretary for Civil 

Rights (OASCR).

a. Allocate necessary funding to ensure OASCR capacity to deal with ALL civil 

rights violations in a timely manner.

b. Provide adequate funding and resources to OASCR so they can process 

customer cases within 180 days.

c. Explore alternative program complaints models, including changing rules and 

regulations (consider using parts of NAD as a model).

Recommendation 17: Private-Public Partnerships

The Equity Commission supports increasing the role of the private sector in advancing 

farming and agriculture programs. By piloting “private-public partnerships,” with 

organizations that have strong DEIA plans on file, both USDA and the partners can 

benefit from mutual learning and expanded access to capital with the intention of 

building out programs that garner longevity and sustainability for communities served.

17. Enhance private-public partnership authorities that empower program leaders 

across thousands of offices and in headquarters to pursue innovation 

independently and rapidly, but with a central mechanism to manage funding, 

monitor results, and disseminate/scale best practices to create a shared 

responsibility. Such an authority can be established as a new program through 

Congress and Secretarial authority, and/or by leveraging existing authorities. 

The Secretary shall explore opportunities to:

a. Pilot a “private-public” partnership whereby the private sector partner (with 

more than 1,000 full-time employees) matches at a minimum of $20,000 per 

award from USDA to a nonprofit or community-based organization that is 

serving members of a distressed community and has a diversity, equity, and 

inclusion plan on file with USDA’s office of equity. Prior to the partnership, 

private sector partners will be evaluated for credibility by way of interviews 

and any other necessary avenues. Nonprofit or community-based 

organizations may also be evaluated on credibility and commitment to serving 

distressed communities.

b. Pilot a “private-public” partnership whereby the private sector partner (with 

more than 1,000 full-time employees) matches each $20,000 award from 

USDA to a nonprofit, community-based organization or college/university 

that is helping farmers and ranchers create farm management plans that 

generate more output while conserving water resources and rebuilding soil 

health. 

c. Pilot a “private-public” partnership whereby the private sector partner 

provides financial assistance (e.g., renewable tuition-scholarship) to a 

scholarship fund to assist an admitted student attending a land grant 

university; federally designated Minority Serving Institution (MSI); or a 

Hispanic Serving Agriculture College and University (HSACU) (USDA and 

said private sector partner will select the student recipients).

d. Pilot a “private-public” partnership whereby the private sector partner is 

strongly encouraged to leverage its social media platforms to highlight their 
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support of USDA programs and opportunities that advance equity; create 

brand activations/cause-related campaigns (e.g., “Giving Tuesday”) that 

increase public support/engagement for USDA programs and opportunities 

that advance equity; and promote existing and recognized efforts in the public 

sector, like Challenge.gov in order to stimulate innovative ideas and solutions.

Additional opportunities USDA should consider:

a. Small Business Innovation Research (SBIR) – USDA, as a large Research & 

Development sponsor, posts hundreds of opportunities annually for small 

business participation. Thousands of companies across the U.S. have been 

created through SBIR, often in partnership with higher education. The 

Commission suggests a portion of SBIR funding be directed towards projects 

that impact the equity recommendations.

Recommendation 18: Procurement

The Equity Commission recognizes USDA’s supplier and procurement contracting 

programs are vital for small agriculture businesses to build on generational wealth and 

experience that could sustain and expand their businesses. Systemic racism and historical 

discrimination have excluded Native, BIPOC, and women owned agricultural businesses 

from accessing and qualifying for USDA programs. By focusing on procurement and 

supplier diversity, USDA can rectify the generational exclusionary practices that have 

effectively precluded disadvantaged businesses. Procurement systems and culture need to 

change simultaneously to ensure there is greater opportunity for funding organizations 

who are not historically funded each year. 

18. Establish a team focused on procurement and supplier diversity specifically to 

work with the underserved and underrepresented agriculture communities to 

build the capacity and experience necessary to gain equitable access to USDA’s 

supplier, contracting, and procurement programs.

a. Create set aside programs for minority, tribal, and women owned small 

businesses.

b. Create a special 8(a) category for minority, tribal and women farm/

agricultural businesses by lowering the threshold for entry into the program.

c. Establish limited competition programs within each of these categories.

d. Include incentives for major contractors to form partnerships with 

underserved and disadvantaged small agriculture businesses as 

subcontractors.

e. Create a pilot project within the Food and Nutrition Service under which at 

least 50% of purchases by school meal and pantry programs would be 

supplied by local small agriculture businesses from the underserved 

communities. 

i. FNS to provide technical assistance, reimbursement flexibilities and 

enhanced funding to cover additional costs. 

f. Distribute an annual report or host a live database that is available to the 

public that shows which organizations or farms receive USDA dollars. This 

information should be accessible, easy to navigate, and should include data on
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not just contract awards but various financial types (subsidies, grants, etc.). 

Furthermore, the data should contain information on the subcontractors in 

addition to the prime contractors. 
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USDA’s Commitment to Farmworkers and Their Families

The Commission and Subcommittees recognize that among the most vulnerable populations 

within the agricultural sector are farmworkers and their families. Farmworkers are often not 

directly served, protected, nor eligible for programs, services or benefits provided to the larger 

agricultural community due to immigration and labor laws, inequitable structural incentives and 

barriers, and lack of inclusion. New vulnerabilities of agricultural jobs due to the increasing 

impacts of climate change are also remain a significant challenge for farmworkers and their 

families. The Commission commends USDA for their recent initiatives that provide support and 

financial relief to farmworkers such the Farm and Food Workers Relief Grant Program. The 

Commission and Subcommittees propose the following recommendations to enhance support to

farmworkers and their families. 

Recommendation 19: Staffing Farmworkers’ Work

The Equity Commission recognizes that USDA has not treated farmworkers consistently 

as a specific constituency over time. By funding and elevating roles for professional staff 

dedicated to farmworkers, USDA can drive coordination, compliance, and culture 

change at a systems level to protect farmworkers from inequities. Although there is 

currently a billet for Farmworker Coordinators, it has not been adequately funded and 

sustained. 

19. Institutionalize equity compliance and culture change across all of USDA by 

appointing a senior official with dedicated staff (career or political) with 

decision-making authority and access to senior level officials and the resources 

needed to serve farmworkers, their families, and the organizations that serve 

them. The senior official would serve as the USDA representative to interagency 

workgroups regarding farmworkers and associated issues.

Recommendation 20: Interagency Farmworker Service Council 

The Equity Commission recognizes the value and need for farmworkers to be consistently 

recognized as a specific constituency within intergovernmental processes, programs, 

services, and policies. Establishing an Interagency Farmworker Service Council will help 

USDA drive accountability, coordination, compliance, and culture change at a systems 

level to protect farmworkers from continued inequities.

20. Issue a recommendation from the Secretary that the White House pursue the 

establishment of an Interagency Farmworker Service Council for infrastructure 

coordination on intergovernmental work processes. The Council should be 

convened by USDA and include the Department of Health and Human Services, 

the Department of Labor, the Department of Education, the Environmental 

Protection Agency, the Department of Homeland Security, the Department of 

Justice, the Department of Treasury, and private sector partners.

Recommendation 21: Farmworker Nutrition

The Equity Commission recognizes that many farmworkers and their families live near or 

on the federal poverty line and experience food insecurity. By improving language 

access, developing targeted outreach, and making distribution programs and application 
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sites more accessible, USDA can ensure farmworkers and their families are able to 

access nutrition programs available to them.

21. Ensure farmworkers and their families have access to all USDA food and 

nutrition programs.

a. Improve language access. 

b. Mandate creation and distribution of targeted outreach materials with a 

required annual cadence for updating and distributing. 

c. Develop inclusive and accessible distribution programs and application sites.

d. Ensure farmworkers and their families are encouraged to apply for and receive 

nutritional supports by not requiring a social security number. 

Recommendation 22: Farmworkers’ Access to USDA Programs

The Equity Commission recognizes that minority farmers and farmworkers have been 

underrepresented and underserved by USDA. By requesting, supporting, and analyzing 

data and reports, USDA can better understand the needs of farmworkers to improve 

working conditions and create potential pathways for them to transition from 

farmworkers to farmers.

22. Direct the USDA Office of the Inspector General (OIG) to conduct a report or a 

joint report from USDA and Department of Labor (DOL) on farmworker living 

and working conditions that are essential to understanding the needs of 

farmworker populations. The report shall also look at farmworker access to 

USDA programs. OIG and DOL should consult with farmworker organizations 

and farmworkers themselves and they must use innovative research methods to 

ensure anonymity, accurate data, and protection against retaliation.

a. The report should be funded, conducted, and published bi-annually to ensure 

compliance and systems level changes for farmworkers, their families, and 

organizations.

Recommendation 23: Funding for Farmworkers

The Equity Commission recognizes farmworkers face widespread violations of the few 

rights they possess, high injury and fatality rates, and poverty, including food insecurity. 

By prioritizing farmworkers in USDA’s programs, policies, and resources, USDA would 

help not only farmworkers but also provide broader societal benefits, including improved 

food safety, healthier and stronger rural communities, and a level playing field for lawabiding employers.

23. Pursue legislation and utilize existing authority to ensure funding that benefits 

farmworkers and their families. 

a. Support an initial minimum funding of $5 billion for farmworker 

organizations to improve farm labor working conditions, labor protections, 

healthcare, wages, access to justice, supply and stability, services, and safety 

and training.   
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b. Leverage existing and ongoing funding and resources to promote improved 

farmworker living and working conditions, workplace safety compliance and 

farmworker economic opportunities through funding opportunities, funding 

requirements, penalties, and incentives. 

c. Ensure that spending for employer grants and procurement promotes 

improved farmworker living and working conditions by requiring that 

employers throughout the supply chain demonstrate labor law compliance and 

meet “high road” workplace standards, such as collective bargaining and other 

metrics for improved workplace protections, to qualify for such funding or 

procurement. 

d. Take action to ensure that additional funding opportunities such as existing 

and ongoing grants or other programs include requirements and incentives 

regarding farmworker living and working conditions.

e. Take executive action to ensure funding for farmworker organizations to help 

ensure improved farmworker working and living conditions and to ensure 

farmworker access to economic opportunities. 

f. Ensure that farmworkers, their families, and their organizations are equally 

included in any funding intended to address the impact of pandemics, natural 

disasters and climate change, including extreme weather, wildfires, droughts, 

etc.

g. This recommendation is intended to support farmworkers and their 

organizations and not farm labor contractors.
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Re-evaluating Other USDA Programs

The Equity Commission and Subcommittees have the monumental task of identifying persistent

and pervasive inequities across USDA, many of which are made operational through the policies 

that inform USDA on how programs were designed, operated, and continue to be managed 

today. The Commission and Subcommittees have identified several programs, structures, or tools 

that require evaluation, revision, restructuring, or a new system. The following recommendations 

address interrupting patterns of systemic inequities across other USDA programs not already 

discussed.

Research and Extension

USDA coordinates and conducts research, education, and extension with scientists and 

researchers across sectors including the Federal Government, universities, and private partners. 

Historically, 1890 and 1994 minority-serving land-grant institutions have not received USDA 

funding comparable to 1862 land-grant colleges and universities. The Commission applauds the 

recent investment of over $21.8 million to build the capacity of 1890 Historically Black Colleges 

and Universities (HBCUs) in the land-grant network to deliver innovative solutions that address 

emerging agricultural challenges impacting diverse communities. The following

recommendations aim to strengthen research, extension, and teaching in the food and agricultural 

sciences at all minority-serving institutions across the country.

Recommendation 24: The Federally Recognized Tribal Extension Program

The Equity Commission understands that one of the most significant inequities faced by 

Tribal producers is a lack of access to technical assistance when compared to other 

producers. The land grant extension system, meant to serve all producers, has 

historically left Tribal producers behind. The Federally Recognized Tribal Extension 

Program (FRTEP) was created to solve that issue; however, the program has not had an 

influx of funding since 1990, and although the 2018 Farm Bill did add 1994 Tribal 

Colleges and Universities as eligible sites for FRTEP, no new funding came with this.

Currently, 38 FRTEP agents across the country are intended to serve as many as 2,000 

producers per person, while their counterparts in the land grant extension system each 

serve approximately 200. This results in inequitable service to Tribal producers. The 

Commission recommends USDA allocate a set aside, using a similar formula method 

used in County Extension, for the FRTEP to bring equity between the extension 

programs. 

24. Seek increased funding for the Federally Recognized Tribal Extension Program 

(FRTEP) and remove the competitive nature of the current application process 

to allow for more collaboration across Tribal extensions.

a. Increase funding for the FRTEP program to $50 million. The current funding 

requires FRTEP agents to serve as many as 2,000 producers per person, while 

their counterparts in the land extension program only need to serve 200. The 

competitive funding is static for FRTEP and the 1994s. As new programs 

compete and are added, all existing programs in Tribal Nations suffer from 

further reduced funding. This type of competitive funding is not found in 

County Extension programs. County Extension is based on a formula, and we 

recommend Tribal extension be based on this formula.
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Recommendation 25: 1890s Institutions Matching Requirements 

The Equity Commission recommends USDA address the historical inequities in funding 

provided by the 1862 and 1890 Morrill Acts to make agricultural research, outreach, and 

technical assistance more equitable. The Commission recognizes the need to make the 

matching requirements consistent across institutions and address the fact the 1890 

institutions never received their equitable allocation of land, the primary funding 

mechanism for the institutions.

25. Address disparities and difficulties with 1:1 matching requirement for 1890s 

land grant universities.

a. The Governor of the State for the eligible institution must submit any request 

for a waiver for matching requirements. 

b. Allow for a variety of non-federal funding matches (i.e., private donations, 

endowments, etc.).

Recommendation 26: Cooperative Extension Service Programming

Given their experience serving small and specialty crop producers and non-traditional 

farmers, the Commission recognizes that 1890 Land Grant colleges, 2008 Hispanic 

Serving Agricultural Colleges and Universities (HSACUs), and 1994 Tribal Land Grant 

College and Universities (TCUs) are the best equipped to conduct agricultural research, 

outreach, and provide technical assistance to the diversity of constituencies.

26. Increase funding and support to expand Cooperative Extension Service 

programming to marginalized communities through cooperative agreements and 

more descriptive language within Requests for Applications (RFAs) for 

competitive funding to facilitate collaboration with minority serving agricultural 

colleges and universities. 

Recommendation 27: Cooperative Agreements and Competitive Grants

Given their experience and relationships with their constituencies, the Equity 

Commission recognizes that 1890 Land Grant colleges, 2008 Hispanic Serving 

Agricultural Colleges and Universities (HSACUs), and 1994 Tribal Land Grant College 

and Universities (TCUs) are best positioned to reach marginalized communities. 

27. Increase financial support (in the form of cooperative agreements and 

competitive grants) and allocate equitable funding to federally designated 

minority serving institutions (including 1890 Land Grant colleges, 1994 TCUs, 

HSACUs, and community-based organizations).

a. Mandate program managers to be specific, intentional, and equitable in how 

funding is dispersed to research and extension by adding detailed language 

that targets diverse clientele and encourages collaborations across types of 

institutions and community-based organizations. 

b. Encourage collaboration and cooperation with minority serving 

institutions/organizations through evaluation criteria. The Request for 

Application (RFA) language should be transparently linked to proposal 
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evaluation rubrics to promote service to marginalized communities.

c. Appropriate funding that equals an increase of at least 20% over the next five 

years.

Recommendation 28: Distinctions that Allow Access to Endowments and 

Appropriations

The Equity Commission recognizes there is a growing gap among different constituencies 

across the U.S. in degree attainment and access to research, education, and outreach 

related to food, agriculture, and natural resources. In an effort to reach a broader 

constituency of underserved publics and to build a workforce required to enhance and 

strengthen American agriculture, investments must be made in institutions recognized for 

this work.

28. Recognize minority serving agricultural institutions who are making important 

contributions towards equitable access to information, education, and capacity 

to underserved (minority) students, farmers, ranchers, etc. The distinction 

should allow access to endowments and annual appropriations available to other 

land grant universities—resources intended to support and enhance regionally 

relevant research, access to education and other capacity building, and 

community engagement (extension). 

a. Enhance the legislative authority given in The Food, Conservation, and 

Energy Act of 2008 (PL 110-246) that included a federal designation for 

Hispanic Serving Institutions (HSIs) offering associate, bachelors, or other 

accredited degree programs in agriculture and related fields that became the 

Hispanic Serving Agricultural Colleges and Universities (HSACUs). An 

enhanced distinction should name a select few HSACUs that are strategically 

and most effectively meeting the mission of USDA and that have a 

demonstrated record of contributing to research, education, and 

extension/community engagement related to food, agriculture, and natural 

resources related sciences. This distinction should allow for appropriated 

funding that allows investment in these institutions through access to 

appropriated funding or through collaborations with USDA Agencies (NRCS, 

ARS, APHIS, etc.) that allows for cooperative agreements or partnerships 

akin to those at land grant colleges.

b. Create a new distinction for Minority-serving Agricultural College or 

Universities that meet specific, clear benchmarks for (a) access to education: 

offering underserved (minority) students associate, bachelors, or other 

accredited degree programs in agriculture and related fields (higher than 

existing 25 percent benchmark), (b) access to research: are conducting 

regionally relevant research supported by the USDA or other competitive 

funding mechanisms; (c) capacity building: have a clear and demonstrated 

track record of outreach, extension, or community engagement. These 

Minority Serving Agricultural Colleges and Universities (MSACUs) will 

benefit investments in research, education, extensions through USDA 

competitive grants eligibilities, a MSACU Fund in U.S. Treasury with 

appropriated funding.
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Ensuring Equitable Nutrition Assistance for Those in Need 

The Equity Commission recognizes the opportunity to not only address inequitable access to 

farm programs among underserved communities, but also access to nutrition programs and 

services that have historically left some in America unable to receive assistance. Addressing 

these barriers to access and inclusion directly impacts families by fostering healthier 

communities. Increasing participation in nutrition assistance programs also benefits producers 

through increased demand for their products. Producers in turn can better serve consumers and 

positively impact the food system by participating in nutrition assistance programs with greater 

reach and impact. 

Although there are many initiatives the Commission is aware of and applauds that are already 

addressing the systemic disparities related to food security and nutrition assistance, the 

Commission recommends updates to several programs that would allow for greater access for 

underserved individuals and families.

Recommendation 29: Supplemental Nutrition Assistance Program (SNAP)

The Equity Commission has identified several policies that explicitly limit nutrition 

program access based on residency and immigration status as well as other policies that 

have a disparate impact on BIPOC access to nutrition programs because of the ways that 

BIPOC people have been marginalized through the labor market and carceral systems. 

Many of the restrictions have been in place since 1996. By supporting legislative actions 

to remove select eligibility restrictions on Supplemental Nutrition Assistance Program 

(SNAP), USDA can ensure all communities have access to healthy and nutritious foods. 

29. Support legislative action to remove eligibility restrictions on the Supplemental 

Nutrition Assistance Program (SNAP) that disproportionately limit access to 

nutrition supports by BIPOC, including:

a. The restrictions on receipt based on immigration status.

b. The denial of standard SNAP benefits to residents of Puerto Rico and other 

insular territories (they receive limited nutritional support from the Nutrition 

Assistance Program). 

c. The prohibition on receiving SNAP benefits and food from the Food 

Distribution Program on Indian Reservations (FDPIR) in the same month.

d. The time limit on benefit receipt for unemployed people who are not living 

with dependent children. 

e. The ban on SNAP assistance for people with previous drug felony 

convictions.

Recommendation 30: Thrifty Food Plan (TFP)

The Equity Commission notes that there have long been concerns that the Thrifty Food 

Plan (TFP) is unrealistic in its expectations and does not provide recipients with enough 

benefits to purchase an adequate and healthy food supply. The Commission 

acknowledges that the re-evaluated benefits that went into effect in 2021, as a result of 

the 2018 Farm Bill direction for USDA to reevaluate the TFP by 2022 and every five 

years thereafter, made significant improvements. The Commission supports the 

continuing reevaluation of the TFP and urges that additional adjustments be made to the 
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SNAP benefit levels and calculations to assist recipients in better meeting their 

nutritional needs.

30. Continue to revise the Thrifty Food Plan (TFP) to reflect the needs of today’s 

consumers, explore options for boosting the minimum benefit and increasing

benefits more than annually during periods of high inflation, and consider 

basing SNAP benefit levels on the Low-Cost Food Plan.

Recommendation 31: Customer-Centered Service of the Supplemental Nutrition 

Assistance Program (SNAP)

The Equity Commission recognizes there is too often a lack of customer-centered service 

which fails to treat people seeking nutrition assistance with respect and results in 

reduced receipt of benefits. Barriers to access frequently have disproportionate impact 

on BIPOC and other socially marginalized populations. By removing barriers to access 

for applicants and participants, USDA can ensure eligible people have access to 

available nutrition programs. 

31. Monitor state SNAP agencies to ensure that SNAP is administered in a way that 

treats applicants and participants with dignity and respect. USDA should seek 

legislative authority to hold states accountable for barriers to access and require 

states to develop processes for beneficiaries to be involved in program and 

systems design and evaluation. USDA should report SNAP participation data 

among eligible individuals disaggregated by race and ethnicity.

Recommendation 32: Review of Nutrition Programs

The Equity Commission recognizes that vendor access to USDA nutrition programs has 

been restrictive and inequitable. By reviewing program access and procurement 

requirements, USDA can address policies that may create barriers to entry for small 

vendors and local farmers. Removing barriers would also make it easier for childcare 

providers to access and procure culturally specific and nutritious foods. The Commission 

recognizes that there may be additional opportunities throughout USDA programs to use 

procurement to promote equity.

32. Review the nutrition programs at the federal, state, and local levels to identify 

barriers to vendor and procurement opportunities for disadvantaged and 

underrepresented communities; remove barriers within federal control and 

provide technical assistance to states and localities on best practices.

a. Conduct outreach and support small businesses, especially those owned by 

underrepresented communities in becoming approved SNAP vendors and 

maintaining eligibility. Support innovative approaches to improving access in 

food/SNAP access deserts and promoting local food systems.

b. Review data-mining algorithms used to identify SNAP retailers as possible 

sites for fraud for bias and disproportionate impact. Provide remediation 

options to avoid creating SNAP access deserts.

c. Assess meal pattern requirements under Child Care and Adult Feeding 

Program (CACFP) and school meals for inclusion of culturally appropriate 
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foods, ability of underrepresented community providers to participate as 

vendors, and access by small home childcare providers (many of whom come 

from disadvantaged communities).

d. Assess Special Supplemental Nutrition Program for Women, Infants and 

Children (WIC) food packages for inclusion of culturally appropriate foods, 

ability of underrepresented community providers to participate as vendors. 
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Press Inquiries: press@usda.gov | Public Inquiries: EquityCommission@usda.gov

Equity Commission Website: https://www.usda.gov/equity-commission
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