Foreign Assistance: Global Food for Education Initiative Faces Challenges for Successful Implementation
Published: 2002-02-28T00:00:00

Fast Facts:

Highlights:
section_title: What GAO Found
paragraphs: At the Group of Eight industrialized countries' summit in July 2000, President Clinton proposed a Global Food for Education Initiative (GFEI) whereby developed countries would provide school breakfasts or lunches to needy children in poor countries. The aim of the initiative is to use school meals to attract children to school, keep them attending once they enroll, and improve learning. The president also announced a one-year, $300 million pilot program to be run by the U.S. Department of Agriculture (USDA) to jump-start the proposed global effort. Research and expert views on the effectiveness of school feeding programs indicate that the programs are more likely to be successful when they are carefully targeted and integrated with other educational, health, and nutritional interventions. In establishing the pilot program, USDA did not build on some important lessons from previous school feeding programs. Although USDA expects more than eight million children to benefit from the pilot program, the structure, planning, and management fall short in ensuing that the program's objectives will be attained. Representatives of most other donor countries GAO interviewed said their governments were either noncommittal about, or unwilling to provide, substantial support for a comprehensive, long-term food for education program. This lack of support is a problem because the United States envisioned a multilateral program with other donors funding about three-quarters of the program's total cost. GFEI seems unlikely to attract much support from other donors unless the United States adopts a permanent program that does not depend on surplus agricultural commodities or the pilot program produces strong, positive results.

section_title: Letter
paragraphs: At the July 2000 Group of Eight industrialized countries’ summit in Okinawa, Japan, President Clinton proposed a Global Food for Education  Initiative (GFEI) whereby developed countries would provide school  breakfasts or lunches to needy children in poor countries. The overall goal of the initiative is to contribute to universal education for all by using school meals to attract children to school, keep them attending once they enroll, and improve learning. An estimated 300 million children in  developing countries are chronically undernourished, and many of them  are among an estimated 120 million who do not now attend school. At the same time, the president announced a 1-year, $300-million pilot food for education program to be administered by the U.S. Department of  Agriculture (USDA) to jump-start the proposed global effort. The pilot’s objectives are to use school meals to improve student enrollment,  attendance, and performance. Under the program, the United States is using the authority of section 416(b) of the Agricultural Act of 1949 to  donate surplus agricultural commodities from the Commodity Credit Corporation’s (CCC) inventory for use in existing as well as new and  expanded school feeding and preschool nutrition projects in developing  countries. Congress is currently considering whether to provide additional  funding for the pilot program and/or establish a permanent program.
As you requested, we examined (1) lessons that can be drawn from existing  research and expert views on the effectiveness and cost of school feeding  programs in promoting increased school enrollment, attendance, and  performance; (2) the extent to which the U.S. pilot program has built upon  these lessons to date; (3) whether the U.S. pilot program is being operated  and managed so as to reasonably ensure that the food aid and monetized  proceeds are effectively and efficiently used; and (4) the views of other  major donors regarding support for a comprehensive, long-term global  food for education initiative.
As you also requested, we are providing our analysis in advance of the pilot  program’s completion.  The first meals of the pilot were not delivered until  fall 2001, and USDA expects the program to carry over into 2003.  As a  result, our observations on the pilot program concern its design and  implementation through December 2001 and do not assess the in-country  phase of the program. To address the issues outlined above we met with  and reviewed information from U.S. government officials at the  Departments of Agriculture and State, as well as the U.S. Agency for  International Development (USAID), the Office of Management and  Budget, and the White House. We also gathered information from and met  with officials of the U.N. World Food Program (WFP), some private  voluntary organizations, foreign donor governments, the European  Commission, the World Bank, and private research institutions. Appendix I  provides detailed information on our scope and methodology.
subsections: section_title: Background
paragraphs: At Jomtien, Thailand, in March 1990, representatives of the global  education community held the “World Conference on Education for All”  and adopted a declaration on universal access to education as a  fundamental right of all people.  In April 2000, the “World Education  Forum”met in Dakar, Senegal.  Delegates from 181 nations adopted a  framework for action committing their governments to achieve quality  basic education for all—including ensuring that by 2015, all children—  especially girls, children in difficult circumstances, and those from ethnic  minorities—have access to completely free primary education of good  quality.
Also in early 2000, the U.S. ambassador to the U.N. Food Agencies in Rome  proposed that the United States, within the U.N. framework, take the lead  in organizing a worldwide  school lunch program. The purpose would be  to provide a meal every day for every needy child in the world.  Doing so,  the ambassador said, would attract children to school and keep them there  under conditions in which they are able to learn and grow. The United  States would pay 25 percent of the cost, and other donor nations would pay  the rest.  The United States would benefit, since Americans produce more  food than they can eat or profitably sell and since most of the U.S.  contribution would be in the form of agricultural commodities and thus  would strengthen the market for cereal grain, dairy products, and livestock.  According to the ambassador, other farm surplus countries such as France,  Canada, and Australia would benefit as well.
In late May 2000, President Clinton met with the ambassador to discuss the  idea and asked senior advisers to prepare an analysis of how the United  States might participate. In early July 2000, the advisers reported that all  relevant agencies recommended that the president announce a U.S. pilot  program to support the international community’s goal of achieving  universal access to basic education by 2015 and the U.N.’s 10-year “Girls’  Education Initiative” to help poor countries eliminate gender disparities in  educational access. The advisers recommended spending approximately  $300 million in the first year on the pilot program, with levels in subsequent  years dependent upon factors such as the extent of international  participation and the continued availability of CCC funding.  At the  Okinawa Summit on July 23, 2000, the president announced the Global  Food for Education Initiative and the pilot program.
According to the White House press release, which was issued the day the  program was announced, the purpose of the pilot program is to improve  student enrollment, attendance, and performance in poor countries.  These  objectives were reaffirmed in USDA’s September 2000 request for proposals  from cooperating sponsors and, more recently, in a December 2001 paper  describing the goals, scope, and framework for action for monitoring and  evaluating the pilot program.
For the pilot, USDA sought proposals from various potential implementing  partners, and approved 53 projects in 38 countries covering an estimated  8.3 million children.  Partners include WFP and various cooperating  sponsors. Among the latter are 13 PVOs and 1 foreign government  (Dominican Republic).  As of mid-December 2001, USDA had finalized  agreements for 21 of 25 PVO projects, 26 of 27 WFP projects, and 1 project  with the Dominican Republic. The recent total estimated cost for all of the  pilot projects was $227.7 million, allocated as follows: WFP projects, $92.5  million; PVO projects, $121.1 million; and the government of the Dominican  Republic, $14.1 million. The total cost is $72.3 million less than the  originally planned $300 million initiative. According to USDA officials, the  balance will be used in fiscal year 2002 to expand existing projects that  show the most potential, based on performance. Appendix II provides more  detailed program and cost information.
section_title: Lessons Learned from School Feeding Programs Define Conditions for Likely Success
paragraphs: Research and expert views on school feeding programs indicate that these  programs are more likely to have positive results when they are carefully  targeted and integrated with other educational, health, and nutritional  interventions.  There is considerable evidence that school feeding  programs can increase enrollment and attendance if the programs are  targeted at the right communities or populations.  Evidence of the  effectiveness of school feeding programs in improving learning is  somewhat more mixed, possibly because of difficulties isolating factors  associated with increased learning, the quality of studies assessing such  relationships, or the quality and settings of such programs. Programs are  more likely to have a positive result on enrollment, attendance, and  learning when they are integrated with a facilitative learning environment  and appropriate health and nutritional interventions. Community  participation and parental involvement also promote these objectives.  Taking steps to ensure that programs will be sustainable when donor  assistance is no longer available is important for ensuring long-term  effectiveness. At the same time, school feeding programs are costly and  may not be cost effective, relative to other possible interventions. (Apps. IV  and V provide results from selected studies on these issues.)
subsections: section_title: Targeting the Right Population Can Improve Enrollment and Attendance
paragraphs: Evidence indicates that school feeding programs can improve school  enrollment and attendance if they target the right population. In general,  studies and experts point to the importance of targeting programs on low- income communities that lack a secure supply of food and have relatively  low rates of school enrollment and attendance. When school feeding  programs do improve enrollment and attendance, their contribution is  primarily through a transfer of income (the food) to families. School  feeding programs may not have much of an impact if children are staying  away because the distance to school is too far to walk, parents perceive the  quality of the education to be low, or children are disabled. Providing  national coverage to all children is usually not cost effective. Targeting  high-risk communities is preferable to targeting individual children within  schools, which could lead to competition among students and parents,  dilution of nutritional impact through food sharing, and insufficient  community support. (See app. IV for results from selected studies on the  use of targeting to improve the effectiveness of school feeding programs.)
According to several experts and practitioners, school feeding programs  can also help reduce the educational gender gap—where the proportion of  school-age boys attending school significantly exceeds that for school-age  girls. Many studies have shown that the inability of households to cover  direct and indirect costs of education results in fewer girls attending  school. This inequity exists partly because parents perceive less value in  educating girls, there is greater demand for girls’ labor at home, and girls  are more affected by issues of school location and security. Yet some of the  highest returns to education and other development investments derive  from girls’ education. For example, according to studies cited by WFP:
Illiterate girls have an average of six children each while girls who go to  school average 2.9 children;
Infants born to mothers with no formal education are twice as likely to  die before their first birthday than are babies born to mothers with a  post-primary school education;
Between 1970 and 1995, 44 percent of the decrease in child malnutrition  was attributable to improvements in female education; and
Educated mothers are more likely to send their own daughters to  school.
To increase educational opportunities for girls, a “package” of strategies is  often tailored to meet a country's special needs. These packages typically  contain some combination of interventions to (1) reduce the opportunity  costs of sending girls to school; (2) improve the quality and relevance of  education; (3) increase access to close, safe schools equipped with basic  infrastructure; (4) educate parents and communities about the benefits of  girls' education; and (5) establish supportive national policies.
section_title: Facilitative Environment Needed for Effective Learning
paragraphs: A group of experts and practitioners who convened at USAID headquarters  in October 2000concluded that little learning is likely to occur without a  facilitative learning environment, where teachers engage children in  stimulating learning tasks, provide frequent feedback and encouragement,  and are equipped with motivational textbooks and other learning  materials. A facilitative learning environment also requires a suitable  physical environment and minimal school supplies. Unfortunately, most  schooling in the developing world is far from this kind of environment.Teaching is frequently of poor quality and is poorly supported; and the  curriculum often has little relevance to rural life, making formal schooling  unconnected with the needs of rural communities. Thus, most developing  countries require investments in teacher training; basic supplies (books,  blackboards, desks, and chairs); a suitable physical environment; and other  learning materials. Furthermore, many school systems in developing  countries are dysfunctional, characterized by dispersed or displaced  populations (as a result of conflict or natural calamities), limited basic  infrastructure, and endemic child malnutrition. Many experts and  practitioners also conclude that food for education programs must take  place within the context of broad, national education reform programs that  focus on essential inputs to education and learning, such as teacher  development, curriculum reform, and student assessment. (See app. IV  for results from selected studies on the impacts that school feeding  programs have on learning.)
section_title: Nutritional and Health Measures Are Needed for Effective Programs
paragraphs: According to various studies, poor nutrition and health among  schoolchildren contribute to diminished cognitive abilities that lead to  reduced school performance. According to experts, school feeding  programs can be effective in reducing short-term hunger—which in turn  can improve learning capacity—by providing an inexpensive breakfast or  small snack, shortly after students arrive at school. Meanwhile, using  enriched foods or complementing commodities in school feeding programs  with locally available vitamin and mineral-rich foods is an effective route to  alleviating the complex micronutrient deficiencies that schoolchildren in  developing countries often suffer. At the same time, school feeding  programs designed to capture both nutritional and educational gains need  to invest in adequate water and sanitation at schools, since poor water and  sanitation give rise to infectious diseases, including parasites, which  adversely affect schoolchildren’s enrollment, attendance, and learning.  These programs also benefit from inclusion of deworming treatments and  health and nutrition education. (See app. IV for results from selected  studies on nutrition and health measures that can be used in combination  with school feeding programs to improve school performance.)
section_title: Community and Parental Involvement Also Can Contribute to Enrollment, Attendance, and Learning
paragraphs: Community and parental involvement are also important to successful  school feeding programs. Community involvement in implementing school  feeding programs can increase contact, and hence communication,  between parents and teachers, officials, and others; provide parents an  opportunity to become more aware of what goes on at schools; help raise  the value of education and the school for parents and the whole  community; and motivate parents to enroll their children in school and  ensure regular attendance.  Parent-teacher associations (PTA) or other  outreach efforts can be used to educate parents and other community  groups on issues such as the negative effects of temporary hunger on  learning or the social and health benefits of educating girls.
section_title: Strong Government Commitment Boosts Effectiveness of School Feeding
paragraphs: According to WFP, another important ingredient in successful school  feeding programs is national government commitment to the goal of  “education for all.” This commitment should be put into practice through  policies, programs, and financial commitments within a country’s means  that support basic education.
Governments also need to commit to school feeding programs within the  context of broad, national school reform programs, according to  practitioners and experts who met at USAID in October 2000. These  reforms should target essential inputs to education and learning, including  teacher development, curriculum reform, and student assessment.
section_title: Cost of School Feeding Programs Affects Sustainability
paragraphs: While the benefits of school feeding programs are recognized, the  programs are expensive both financially and in terms of the human  resources required to operate them. In addition to the price of the food,  costs associated with food logistics, management, and control can  represent a significant financial burden for recipient country  governments. These costs may be difficult for national governments to  absorb and thus adversely affect long-term program sustainability.
Estimates of the average cost of school feeding programs vary considerably  (see app. V). According to WFP, the average cost per student of its  development school feeding projects in 2000 was 19 cents per day, or $34  for a 180-day school year (see app. V). Programs costing $34 per pupil per  school year are substantial when compared with what many developing  countries spend on education.  For example, in 1997 public expenditures of  19 least-developed countries for both pre-primary and primary education  averaged only $20 per pupil, according to UNESCO.  Average public  expenditures of five southern Asian countries were reported at $40 per  pupil.
According to many experts, national ministries of education in developing  countries should not be encouraged to take on school feeding at the  expense of other educational inputs. Few national governments are  committed to school feeding programs over the long term, they said. In  addition, many governments and education ministries already are  struggling to maintain barely functioning education systems; may not be  equipped, financially or technically, to assume the additional burden of  food distribution; and do not have the financial resources to sustain feeding  programs after donor support is withdrawn. These experts say that  getting local communities involved from the beginning and giving them  ownership of school feeding programs greatly increase the chances for  long-term program sustainability.  According to WFP, its guidelines for  school feeding programs require both national governments and local  communities to provide a significant amount of resources and  infrastructure.
There are potential detrimental impacts if school feeding programs are not  effectively implemented. For example, where adequate infrastructure is not  available, increased attendance may lead to overcrowding and actually  reduce educational achievement for existing students, while providing  minimal benefit to new students.  In some developing country  circumstances, the school day is only a few hours. In such cases, time  taken to prepare a meal may further limit an already inadequate period of  instruction. In addition, if volunteers are not available to provide labor,  teachers may be required to undertake this task at the expense of  instructional time. Since school feeding is a highly visible income transfer,  it may also be used for political purposes by actors in the recipient country.  If school feeding programs are relatively ineffective, they may result in  resources being taken away from better performing programs.
According to several experts, in particular situations, school feeding  programs may not be as cost effective in promoting learning as other  possible approaches, such as establishing maternal child health and early  childhood development programs or providing alternative nutritional and  educational interventions (see app. V).
section_title: Pilot Program Did Not Adequately Incorporate Lessons Learned
paragraphs: The pilot program has not provided reasonable assurance that lessons from  previous school feeding and food for education programs have been  integrated into approved pilot projects. Under pressure to get the pilot up  and running quickly, USDA gave interested applicants little time to prepare  proposals, and it did not require them to provide basic information on and  analysis of various factors important to successful food for education  programs. Written criteria for evaluating proposals similarly did not focus  on many of these factors. Many of the proposals approved did not address  key elements of successful school feeding programs. Moreover, USDA  provided little funding for important nonmeal components of the food for  education projects, and only a few of the approved PVO proposals  indicated they had obtained other donors’ support for nonmeal  components.
subsections: section_title: USDA Did Not Have Sufficient Information for Its Evaluation
paragraphs: According to USDA officials with whom we spoke, the agency was under  pressure to start a new and complex food for education program quickly  and with far less funds—$300 million—than what is needed to fully address  the educational components of school feeding. As a result, USDA did not  solicit basic information on various factors linked to effective school  feeding and food for education programs. Table 1 lists a set of questions,  based on lessons learned, that USDA could have used to guide the type of  information and analysis requested from implementing partners (i.e.,  cooperating sponsors and WFP) and, subsequently, for evaluating proposal  quality.  As shown in table 1, many important factors that experts cited  were not addressed specifically by USDA in its formal request for  proposals, and other items were only partly addressed in its request. The  request was made to cooperating sponsors but not to WFP. (Less  information was sought from WFP because, as a USDA official told us,  many projects in the WFP proposals had previously been reviewed and  approved by the U.S. government as part of the process by which the WFP  Executive Board approves its projects.) We derived the questions from  our review of lessons described in various studies and other documents on  school feeding and food for education programs (see app. IV, especially  tables 4 to 10. Also see app. VI for a more complete discussion of the  interagency process used to evaluate, and approve proposals.)
As table 1 indicates, USDA sought some information on how the projects  would be targeted.  For example, USDA indicated that it wanted to target  poor countries and that it favored programs that would significantly  improve enrollment and attendance.  However, USDA did not require that  proposals address how programs would be designed to improve  educational performance, nor did it seek any information on factors that  are key to whether learning could occur, such as adequate numbers of well- trained teachers and reasonable supplies of good learning materials.  Similarly, USDA asked requesters how their programs would affect health  and nutrition but did not specifically ask whether the schools had safe  water and adequate sanitation facilities and whether intestinal parasitic  infections in the student population were likely to be a problem. A USDA  official told us there were limits on how much information the agency  could require, given the short amount of time sponsors had to prepare  proposals and the 1-year duration of the pilot. Further, the agency did not  want to make the information requirements so costly for sponsors that it  would get few or no proposals, the official said.
Regarding the criteria used to evaluate the programs, table 1 also shows  that U.S. agencies’ written criteria did not specifically address most of the  key factors we derived, based on our review of lessons from previous  school feeding and food for education programs.  Of the 20 questions in  table 1 on key factors in effective school feeding and food for education  programs, 1 question was addressed specifically in the agencies’ written  criteria and 8 were partly addressed.  None of the agencies’ criteria  specifically addressed the four learning environment questions shown in  table 1. See appendix VI for a discussion of the written criteria used by  agencies in evaluating the proposals.
section_title: Some PVO and WFP Proposals Included Additional Information on Key Factors
paragraphs: We also reviewed the approved PVO and WFP proposals and found that  many included information related to the key factors we identified as  important to successful food for education programs, although fewer than  a third of the approved PVO and WFP proposals discussed most of the  items. In general, the response rate was highest for those factors where  USDA had solicited information.
Table 2 shows the number of approved PVO and WFP proposals that  provided information related to the key factors irrespective of whether  USDA requested this information. For example, a considerable number of  the PVO and WFP proposals included information on certain health and  nutrition issues that were not specifically requested by USDA. To a lesser  extent, proposals also included information on factors associated with the  learning environment. Overall, the highest response rates were mostly for  factors for which USDA had sought information (i.e., school enrollment  and attendance levels, literacy rates, target area based on low economic  status, and programs that involve the community and parents.) (See app. VI  for additional discussion about the information that was included in WFP  proposals.)
section_title: USDA Provided Little Funding for Components Identified as Important to Successful Programs
paragraphs: USDA provided little funding for nonmeal components—such as basic  classroom materials, nutritional education, and treatment of parasitic  infections—that are essential elements of an integrated approach to food  for education programs. Altogether, USDA approved 60 proposals,  including 34 for WFP, 25 for PVOs, and 1 for the government of the  Dominican Republic. For WFP projects, USDA largely funded only school  meals and related costs, including storage, transportation, and handling of  the food. For the PVO projects, USDA was willing to consider proposals  that included nonfood components to be funded by monetizing some of the  surplus commodities or by the PVOs themselves. We found that 17 of the  25 approved PVO proposals included nonmeal components; but of the 17  proposals, only 10 included in their proposed budget a dollar value for  resources that would be allocated to some or all of these activities. (See  app. VII, table 14, for additional information on the extent to which PVO  proposals included nonmeal components and budgeting for these  activities.)
section_title: Weaknesses in Structure, Planning, and Management Reduce Chances for Pilot Program Success
paragraphs: While the U.S. pilot program expects to provide food to more than 8 million  schoolchildren in developing countries, its structure, planning, and  management to date do not reasonably ensure a program that will produce  substantial gains in enrollment, attendance, and especially learning. The  administration’s decision to fund the program through surplus  commodities may be appropriate for a 1-year pilot but is not sustainable for  a longer-term program. USDA, which was selected to manage the pilot,  lacked the expertise and resources of USAID--the agency traditionally  responsible for foreign development aid such as food for education  programs. The pressure on USDA to get the pilot program up and running  quickly did not allow time to adequately plan the program and hire  additional staff to manage it. USDA launched the pilot before fully  developing a strategy for monitoring and evaluating performance; and,  because of the pilot’s short time frame, USDA officials told us they would  not be able to evaluate improvements in learning—one of the program’s  three objectives. This weakness, as well as others related to ensuring  financial accountability for some parts of the projects, could make  determining the pilot’s effectiveness difficult.
subsections: section_title: Surplus Commodities Not Reliable Funding Mechanism
paragraphs: The administration’s decision to use surplus agricultural commodities to  fund the pilot was an expedient way to get the program quickly under way.  However, surplus commodities are not a good vehicle for funding a  medium- or long-term development program, since surpluses cannot be  ensured on a regular basis. (For example, between fiscal years 1996 and  1998, there was no section 416(b) program.) Although the pilot was  expected to run for just over 1 year, the administration contemplated a  multiyear food for education program, possibly lasting as long as a decade.  Under this scenario, when surpluses were not available, the administration  would have to end the program or sustain it through the foreign aid budget,  which is expected to have many competing priorities in the foreseeable  future.
section_title: USDA Lacked Expertise on School Feeding Programs
paragraphs: USAID—traditionally the U.S. agency for providing foreign development  assistance, including school feeding and food for education programs—  would normally have been the logical choice to establish and run the pilot.  However, in light of constraints on foreign aid funding generally and other  high priority development needs, the administration wanted CCC to  manage the pilot, and to do so using available surplus agricultural  commodity funding authority (i.e., section 416(b) of the Agricultural Act of  1949).
The administration’s decision to assign management responsibility for the  pilot to USDA rather than USAID follows a recent trend of giving USDA a  larger role in U.S. food aid programs, primarily because of increased  section 416(b) program activity.  However, USDA lacked USAID’s resources  (such as USAID’s overseas development missions) and USAID’s school  feeding/food for education development expertise. The principal mission  of USDA’s Foreign Agricultural Service (FAS) is to help ensure open  markets for U.S. agricultural exports; it generally has had little experience  in managing school feeding development assistance programs. USDA has  previously used section 416(b) authority to provide some commodities for  international school feeding programs, but we were told the amounts were  relatively smalland not for integrated food for education programs. In  contrast, USAID has been engaged in school feeding programs since the  1950s and administers economic and humanitarian assistance programs in  more than 80 countries. Beginning in the mid-1990s, USAID began  reducing its support for traditional school feeding programs that provided  only meals, citing mounting evidence that school feeding, in and of itself,  contributed little to improving child learning ability or child nutrition on a  sustainable basis. According to USAID officials, its school feeding  assistance has evolved into programs designed to improve education (i.e.,  enrollment, attendance, and graduation rates, especially for girls) by  focusing on national education policy reform, curriculum development,  and teacher training programs. In 2000, USAID spent $33 million on PVO- operated food for education programs in eight countries that benefited 1.3  million children.
section_title: Pilot Program Was Launched Quickly and Has Been Understaffed
paragraphs: President Clinton announced GFEI on July 23, 2000.  USDA began to  implement the pilot program almost immediately, leaving little time for  planning and relying on existing staff from within the Foreign Agricultural  Service to work on the assignment. USDA issued its request for proposals  on September 6, 2000, with a closing date for all submissions at the end of  September. (See app. IX for key events from the time the concept of an  international school lunch program was suggested until approval of the  GFEI pilot program proposals.)
According to USDA officials, USDA was understaffed when the GFEI pilot  was launched and a year later still lacked sufficient staff for handling food  aid matters. For example, in a July 2000 meeting with PVOs to discuss the  pilot program, the Secretary of Agriculture said the lack of staffing in U.S.  agencies for running food aid programs was acute.  At the same time, he  said the president wanted to see some benefits from the pilot program  before leaving office.  In November 2000, a USDA official told us that USDA  was generally understaffed for monitoring food aid programs.  At a July  2001 meeting with PVOs, other USDA officials apologized to PVO  representatives for having too few staff available to negotiate agreements  and address other food aid program issues in a timely manner.44, 45  According to OMB, in March 2001, the administration authorized USDA to  use $2.5 million of the $300 million in CCC funds for administrative salaries  and expenses. According to a USDA official, the funds are being used to  facilitate monitoring and evaluation of the pilot program’s impact. As of  September 2001, a year after the pilot was launched, USDA was still in the  planning stage regarding hiring regional coordinators and local national  staff in PVO recipient countries to help monitor pilot program projects.
USDA’s Foreign Agricultural Service has managed the pilot with existing Program  Development Division staff resources, which were already stretched thin because of a  recent section 416(b) program expansion, personnel turnover, and slow hiring of  replacements.  During our review, a significant portion (ranging from between 25 percent to  33 percent) of the division’s permanent staff positions were vacant.
WFP and IPHD noted that many of the recipient countries were well into their academic  year before USDA commodities were procured, shipped, and available for distribution.
section_title: USDA Policy Change on Funding PVO Projects Delayed Implementation
paragraphs: USDA’s September 2000 Federal Register notice indicated that CCC funds  might be available to cover some of the cooperating sponsors’ expenses  related to implementing the school feeding projects.  As a result, many  PVOs submitted proposals based on the assumption that they would  receive CCC funds to cover part of their expenses. However, in January  2001 USDA reversed its position, announcing that funding would not be  available. This meant that PVOs’ expenses in recipient countries would  have to be covered by selling (monetizing) commodities in the recipient  countries and using the resulting local currency proceeds to cover in- country costs.  The policy change further meant that PVO direct  administrative headquarters’ costs could not be covered, since the section  416(b) program does not allow monetization of commodities for that  purpose.
USDA’s policy shift resulted in several of the proposals having to be  restructured, causing discontent within the PVO community and leading to  delays in concluding a number of agreements. In fact, about one-third of  the approved PVO agreements were not signed by the end of September  2001. In addition, the change presented problems for some PVOs because it  required them to monetize increased quantities of commodities within  recipient countries to recover some of their costs, and there were limits on  the commodity tonnage that could be monetized effectively.  Some PVOs  were also upset because all of WFP’s operating expenses, including  headquarters’ costs, were funded by CCC cash payments.  Legislative relief  in the form of limited CCC funding was provided to PVOs in late July 2001;  at that time, only 4 PVO agreements had been signed. (App. IX discusses  the funding sources used for pilot program sponsors in more detail.)
section_title: Weaknesses in Program Management and Short Duration of Pilot Will Affect Monitoring and Evaluation
paragraphs: To know whether programs are effective, program objectives should  clearly describe the intended end results and accompanying indicators so  that changes and progress toward achieving the objectives can be tracked  over time. However, USDA initiated its requests for proposals in September  2000 without having a comprehensive plan for how it would monitor and  evaluate project performance and has spent much of the time since then  establishing such a plan. USDA and WFP will collect baseline data on  school enrollment and attendance for the time before the projects began  and monitor and assess change in these variables over the course of the  projects. However, USDA has not set specific targets or desired  performance levels for enrollment and attendance in its agreements with  most of its implementing partners. In addition, although improved learning  is one of the three principal objectives of the pilot program, USDA said it  will not monitor and evaluate performance on this variable, unless  improved learning is an element within an agreement, because of the  program’s short duration.
Officials from USDA’s Foreign Agricultural Service told us USDA is  responsible for evaluating the performance of WFP, PVOs, and the  Government of the Dominican Republic in implementing GFEI projects.  According to these officials, FAS’ mandate is to monitor and review the 25  PVO and 1 country government projects in 20 countries from October 2001  through March 2003, and at appropriate intervals report to the Congress on  the projects’ status. They added that FAS headquarters staff is also  responsible for evaluating WFP’s GFEI project implementation. They  stated that the agency intends to complete an interim status report on the  pilot for the Congress by July 2002 that will address several performance- related issues.
In its September 6, 2000, Federal Register notice, USDA said that  cooperating sponsors would be required to report periodically the number  of meals served, enrollment levels, and attendance levels, including female  attendance levels. In addition, USDA said that reports should include  information on infrastructure relevant to sustaining the feeding program,  such as establishment of PTAs and community groups. However, the notice  did not indicate whether sponsors would be required to collect baseline  data on these variables, which would permit comparisons of conditions  before a project got under way and when it was completed.  It did not  indicate whether or how success would be measured—for example, what  percent improvement in attendance would represent achievement of the  program’s objectives. In addition, the notice did not discuss whether  sponsors would be required to report on educational performance, one of  the program’s three principal objectives.
In February 2001, USDA began negotiating final agreements with  cooperating sponsors and WFP for approved proposals. As of December  2001, USDA had completed agreements for 21 of 26 approved cooperating  sponsor project proposals. All 21 proposals contained provisions that  required reporting on the number of meals served, enrollment and  attendance levels (including female attendance), and establishment of  infrastructure relevant to sustaining the feeding program, such as PTAs and  community groups.  However, less than half of these agreements indicated  a requirement for baseline data; and a majority of the agreements did not  specify performance targets for enrollment, attendance, and female  attendance. None of the agreements included reporting requirements for  educational performance. (According to USDA officials, PVOs opposed  such reporting, arguing that the pilot was too short in duration to permit a  meaningful analysis of impacts on learning.) By September 2001, 33 of 34  agreements for WFP projects were concluded, with 1 deferred until fiscal  year 2002.  None of these agreements specified requirements for measuring  project performance; in fact, they did not even say that WFP would report  the types of data USDA had required from cooperating sponsors, such as  enrollment and attendance data.
Nonetheless, WFP developed a detailed survey instrument for collecting  baseline information on its GFEI-funded projects. The survey was pilot- tested in August 2001, approximately 1 year after USDA received proposals  from WFP and cooperating sponsors. According to USDA and WFP  officials, WFP conducted the surveys in a sample of schools for all of its  projects before the end of 2001 and before the food aid was distributed. In  addition to collecting basic information on the feeding program, the  survey sought detailed baseline and subsequent performance data on school  enrollment and attendance (broken down by boys and girls and grade  level); the number of certified and uncertified teachers in the school; the number of classrooms; certain baseline information on community and parental involvementand health and nutrition issues;  and whether the school had other ongoing programs related to effective  school feeding programs and if so, the name of the donor providing the  program.
The survey also called for the use of focus groups to collect views on the  likely reasons why eligible children did not enroll and enrolled boys and  girls did not attend school during a year.
The survey instrument indicates WFP’s interest in upgrading monitoring  and evaluation of its feeding programs, since previous efforts revealed  some weaknesses. However, the survey included only two questions  focused on the possible impact of the programs on improved learning.WFP is sharing its survey results with USDA.  (See app. III for additional  information on WFP activities to improve monitoring and evaluation of  school feeding programs.)
During the summer of 2001, USDA was still debating how to monitor and  evaluate performance for the cooperating sponsors’ projects.  In August  2001, it convened a working group of USDA officials and USAID  consultants with expertise in monitoring and evaluation methodologies to  discuss the issue. The group recommended use of local school or  government records for collecting data on enrollment and attendance, but  it was against collecting quantitative data on indicators for measuring  educational progress (such as reduced dropout rates, retention and/or  completion, and promotion to the next grade) and level of community  participation and infrastructure development.  For the latter variables, it  recommended information be collected through a combination of focus  groups and structured interviews with school staff and parent and  community groups.
In fall 2001, USDA decided to use the WFP survey instrument for the  cooperating sponsors’ projects and, like WFP, apply the survey in a sample  of the schools in each project. According to USDA officials, doing so would  allow collection of comparable data, provided USDA’s sampling strategy  was properly designed. USDA also decided to contract with about 20 local  national monitors (approximately 1 per country) to collect the data and 5  regional coordinators to manage the monitors. In late December 2001,  USDA officials told us they planned to add a few more questions to the  survey to address concerns about whether some of the projects were well  targeted. They also said the surveys would be conducted in early 2002.
USDA officials told us that they ultimately decided not to measure change  in school learning. They said that from the beginning of the pilot, USDA,  WFP, and PVOs were concerned about the ability to effectively evaluate  and judge an increase in student performance under a 1-year pilot program.  Research that tries to demonstrate improvements in academic achievement  is lengthy and requires a long-term approach, they said. USAID officials  with whom we spoke were also critical of the short time allowed for  running the pilot program. They said USAID pilot programs usually take 4  to 5 years, with an evaluation done in the third year to see if the program is  on track, and an assessment of the impact conducted in the fourth year.
section_title: Processes to Prevent Disincentive Effects of Food Aid Raise Some Concerns
paragraphs: An effective global food for education program needs to ensure that food  aid does not interfere with commercial markets and inhibit food  production in developing countries. USDA uses an international  consultative process—the Consultative Sub-Committee on Surplus  Disposal (CSSD)—to keep the pilot program’s food aid from interfering  with commercial exports.  The process involves notification of various  categories of food aid donations, prior consultation with other exporters,  and establishment of Usual Marketing Requirements (UMR) to ensure that  food aid recipients maintain a normal intake of commercial imports in  addition to the food aid they receive. According to the CSSD, in recent  years several factors reduced the effectiveness of the UMR approach,  including (1) lack of uniformity in the compliance period (fiscal year, crop  year, and calendar year); (2) fewer food aid operations covered by the UMR  because many transactions are exempt; (3) a rise in UMR waivers for  countries facing difficult economic situations; and (4) delays in collecting  trade data, which make establishment of 5-year average commercial  imports as a benchmark for current import levels unrealistic.  USDA  officials acknowledged that some countries have expressed concerns that  GFEI might adversely affect commercial exports but said they have not  received any specific complaints about the U.S. pilot’s food exports.
To address disincentive effects of food aid on local production, the United  States requires all proposed food aid projects to submit an analysis  showing the recipient has adequate storage facilities and that food aid will  not disrupt domestic production and marketing. (Technically the analysis is  known as a Bellmon determination.)
We reviewed the analyses by cooperating sponsors whose projects were  approved for the pilot and found the analyses were not adequate for  determining disincentives to production of local commodities. All  cooperating sponsors concluded that the amount of food for their projects  was so small it was unlikely to significantly affect local production. But  their analysis of data on local market conditions was generally based on  production of identical commodities. For example, if wheat was not grown  in the recipient country, sponsors concluded there was no disincentive to  importing and monetizing wheat—without considering whether the  amount of imported wheat would affect price or demand for locally  produced substitute commodities.  Cooperating sponsors did not  adequately verify that the commodities were in demand and would not  compete with local markets, other commercial export programs, and other  donor imports.
USDA officials told us that cooperating sponsors are responsible for  analyzing the potential disincentive effects of their projects. They said  USAID no longer has agricultural officers stationed overseas and now  USDA has to rely on PVOs—which have on-the-ground, in-country staff—to  determine whether the food aid will adversely affect recipient country  markets. (USAID advised us that while the number of agricultural officers  overseas has been reduced in recent years, it still has such officers in a  number of posts.) Although USDA and/or USAID attaches may review  such analyses, USDA does not independently verify the results. USDA  officials also noted that the lack of good data could affect sponsors’ ability  to prepare more robust analyses. USDA does not require WFP to conduct  or submit similar analyses of WFP projects that are partly funded by the  U.S. pilot program. However, WFP told us a review is required of all WFP  proposed projects for their potential impact on production and markets,  and food aid donors (including the United States) participate.
section_title: Key Weaknesses in Financial Accounting Could Have Negative Impact on Pilot Program
paragraphs: We identified several weaknesses in how USDA has maintained financial  accountability over WFP and PVO projects that could adversely affect the  pilot program.  Although USDA advances funds (in the case of WFP) or  food (in the case of cooperating sponsors) on the basis of their estimated  needs and requires them to provide regular though different forms of  financial and project status reporting, WFP in particular has not adequately  accounted for past Section 416(b) program donations.  The PVOs provide  more detailed financial reporting, in part, because a large portion of the  commodities they receive are to be monetized in country to cover foodand other expenses.  USDA requires that PVOs monetize commodities at  market prices, but it has not systematically tracked whether the PVOs  received prices for the monetized commodities that were commensurate  with their cost or whether the funds were spent in accordance with  approved program plans.
subsections: section_title: WFP Reporting Has Been Inadequate
paragraphs: Under a section 416(b) umbrella agreement, WFP is required to account for  the costs it incurs and charges USDA on food aid donations.  WFP is  supposed to submit annual standardized project reports that provide  implementation and actual expenditure data for ongoing activities similar  to what is required of PVOs. We found that WFP had not met its obligation  to provide USDA with an accounting for past Section 416(b) program  donations by providing detailed actual cost data.  As a result, USDA is not  in position to know whether its advances to WFP, on the basis of initial cost  estimates, are consistent with actual project costs and to what extent the  project objectives are being achieved within the approved budget  estimates. A similar situation exists with USAID-funded donations to WFP.  According to a USAID official, WFP has not provided actual cost data for  direct and indirect project costs at the level of project activities and by  donors. Such data is needed, the official said, to know whether the United  States is meeting and not exceeding its fair share of a project’s total cost, as  well as the costs of specific project activities.
In April 2001, U.S. officials reiterated to WFP officials the need for  disaggregated actual cost data. During the meeting, WFP officials noted  that WFP was in transition, using a new financial information system for  new business while still using the earlier system for old business.  According to a USAID review conducted in June 2001, WFP’s new system  appeared to have the capacity to accurately monitor and report on full cost  recovery in the aggregate. However, the system was not yet fully  operational and thus the adequacy of the complete system could not yet be  determined. In September 2001, WFP told USDA it would not be able to  provide finalized reports for fiscal year 1999 obligations that were due by  the end of that month. According to USAID, pursuant to bilateral  consultations between an interagency U.S. government delegation and  WFP management, the United States agreed to a 6-month extension for  WFP to report actual cost data for all U.S. government contributions to  WFP.
section_title: Oversight of PVO Monetized Commodities Is Limited
paragraphs: As previously indicated, a substantial portion of the commodities provided  to PVOs are to be monetized, with the proceeds used to pay for other foods  and/or other expenses, such as administrative expenses and inland  transportation, storage, and handling costs.  For the first 17 completed PVO  agreements, more than 80 percent of the commodities are to be monetized.  At issue is whether USDA is sufficiently tracking the proceeds that PVOs  receive from the commodities they monetize. Also, if a PVO sells a  commodity for less than the market value, the commodity could undercut  other commercial sales, including imports or domestically produced  commodities, and fewer proceeds would be available for financing the  school meals or related activities.
USDA regulations require that PVO commodity sales meet local market  conditions and that PVO and government sponsors provide a report  showing deposits into and disbursements out of special accounts  established for commodity sales proceeds.  In past Section 416(b)  programs, USDA did not determine to what extent proceeds compared  with what sponsors expected to receive as stipulated in the project  agreements, nor whether the commodities were sold at real market prices.  However, in September 2001, USDA officials told us they plan to conduct  such an analysis for the pilot program projects.
section_title: Most Other Donors Currently Uncommitted or Opposed to Major Support of GFEI
paragraphs: The success of a comprehensive, long-term GFEI strongly depends on  other donor support, but most other donors are either opposed or not  committed to supporting GFEI at this time.  A few donors have indicated  support for the food for education initiative but have offered little in terms  of specific additional contributions.  While WFP officials are confident of  eventual support, most donor countries seem unlikely to provide  substantial support unless the United States adopts a permanent program  that is not dependent on surplus commodities and/or unless the pilot  program demonstrates strong, positive results.  Some donors are opposed  to GFEI on the grounds that developmental food aid assistance is  ineffective in promoting sustainable development.  Others are  noncommittal for a variety of reasons, including possible adverse impacts  on commercial agricultural exports to and domestic agricultural  production in recipient countries.
subsections: section_title: Long-Term Program Will Need Substantial Support from Other Donors
paragraphs: The U.S.-proposed GFEI challenged other donor countries and  organizations to join the United States in helping achieve the goal of  education for all children in developing countries by 2015.  Indeed, the  United States said that its willingness to extend the pilot program beyond  its first year would depend in part on other donors’ response. Since the  initiative was first proposed, U.S. officials have indicated they would like to  see other donors contribute, in aggregate, anywhere from two-thirds to  three-quarters of the total cost of a global food for education program.
The Clinton administration estimated that at least 300 million children in  developing countries need school meals. Assuming an annual average cost  of $34 per student for a 180-day school year, the annual meal cost alone for  300 million children would be approximately $10.2 billion.To put this  estimate in perspective, in 1999, $10.2 billion represented about 96 percent  of the Organization for Economic Cooperation/Development Assistance  Committee countries’ official development assistanceto least developed  countries, or about 18 percent of development assistance directed to all  developing countries. In addition, net official development assistance has  declined during the past decade, from $56.7 billion in 1991 to $53.7 billion  in 2000.
We estimate the food tonnage required to provide a school meal for 300  million children (for a 180-day school year) to be in excess of 16 million  metric tons, which would exceed average annual global food aid deliveries  between 1990 and 2000 by about 40 percent. (Global food aid deliveries  averaged approximately 12 million metric tons per year from 1990 through  2000.) Moreover, food aid for development programs, only a part of which  is for school feeding, averaged about 3 million metric tons per year.  Thus  GFEI would represent more than a fivefold increase for these types of  programs.
section_title: Donors Have Been Generally Noncommittal to GFEI
paragraphs: According to a State Department cable, when the United States proposed  GFEI at the July 2000 G-8 Summit, the proposal received a cool reception.  Subsequently, in November 2000, the State Department headquarters asked  U.S. diplomats in 23 countries to explain the U.S. pilot program to foreign  governments and encourage their support.  In addition, the previous U.S.  Ambassador to the U.N. Food Agencies in Rome sought other countries’  support for GFEI through his participation in the WFP Executive Board  and in official visits to food aid donor countries, such as Denmark and  Finland.  These efforts notwithstanding, most donor countries have yet to  respond in a strongly positive or substantial way.
Of the top 13 food aid donating countries for the period 1995 through 1999,  the United States supplied more than half of all deliveries, with the other  donors providing slightly more than 41 percent (see app. X).  Table 3  summarizes general views of all but one of these other donor countries as  well as Finland and their plans or actions to contribute to GFEI or the  WFP’s school feeding initiative. As table 3 shows, representatives of 4 of  the 12 donors (Japan, France, Italy, and Finland) indicated general  support  for the food for education initiative.  The European Commission, the  second largest provider of food aid in the world, has said it is against a  “one-program-fits-all” approach, citing a preference for strategic planning  that identifies all of a country’s development needs and then analyzes  alternative ways to achieve them. According to the Commission,  education forms an integral part of the European Union’s development  policy, and it is crucial that all shortcomings in providing education are  tackled at the same time. If analysis indicated that a food for education  program would have a positive impact, the Commission would still want to  assess the relative cost effectiveness and efficiency of the alternatives.  Representatives of Germany, the United Kingdom, the Netherlands, and  Sweden also expressed reservations about GFEI not being an integrated  approach to development assistance and/or about the ability of recipient  countries to sustain the programs over the long run.  Representatives of  Australia, Canada, Sweden, and the United Kingdom indicated they would  like to see whether the U.S. pilot program or WFP program demonstrates  successful results.  Representatives of the European Commission, Canada,  Germany, the Netherlands, and Sweden expressed concerns about or said  they thought the U.S. program was being used to dispose of surplus  commodities.
In addition, some donors indicated they favor using food aid for emergency  (rather than development) purposes, expressed reservations about  providing assistance for school feeding programs in the form of food or  surplus commodities, or indicated they lack convincing information on the  effectiveness of WFP school feeding activities. (See app. VIII for additional  information on donor views on food aid.)
Regarding actual support for GFEI, Italy has contributed nearly $1 million  to the WFP initiative in three African countries. A French representative  said France might provide some support, either on its own or through WFP,  but added that France wanted to maintain its current level of WFP  development activities, which would limit France’s ability to greatly  increase funding for WFP’s school feeding initiative.  Representatives of  Japan and Finland, the two other supporters, indicated their countries  would not increase their current level of donations to support the  initiatives. Meanwhile, representatives of Canada, Australia, the United  Kingdom, and Sweden all indicated that they would track the progress of  the food for education initiatives for the results.  The German  representatives said their country’s budget situation does not permit  providing additional support.
In mid-April 2001, the U.S. Ambassador to the U.N. Food Agencies in Rome  acknowledged that there had been very little movement by other donor  countries toward supporting GFEI but said that they were coming around  to the idea.  They want to see an American commitment, which will begin  with the pilot program’s implementation, he said. The Ambassador said he  thought Denmark, Finland, Norway, and Sweden would be on board within  the next few months and that France and Germany would soon join in.  At  the same time, WFP officials told us that most or all governments, donors  and recipients alike, support a global school feeding effort and that they  were optimistic that additional contributions would be forthcoming by the  end of 2001.
At the beginning of August 2001, WFP officials told us the Swiss  government was contributing 194 metric tons of food, and France intended  to contribute a total of 5,280 metric tons of rice, beans, oil, and corn/soy  blend to a Honduran program.  In addition, they said, Cargill, Inc., had  provided a $50,000 donation to assist WFP’s school feeding operation in  Honduras (to be matched by the local Cargill affiliate in Honduras). Apart  from food donations, the Canadian government approved the use of a  $250,000 grant facility for WFP for a deworming effort in conjunction with  WFP school feeding efforts in Africa, WFP officials said. In addition, an  international fund offered to consider providing upwards of $300,000 to  fund nonmeal items (such as construction of schools, teacher training,  training materials, school books, and cooking utensils) in least-developed  countries.  And, the officials said, WFP was negotiating new partnerships  for school feeding, including the health, sanitation, and educational aspects  of primary schools, with a variety of U.S. government and international  agencies.
At the end of December, 2001, the U.S. Mission to the U.N. Food Agencies  in Rome told us that Italy, France, and Switzerland were still the only  countries that had agreed to supplement the U.S. government contribution  to the WFP school feeding program.
section_title: Conclusions
paragraphs: In our review of the current GFEI pilot, we found a number of weaknesses  that make it difficult to evaluate the program’s effectiveness. For example,  our research of past school feeding programs indicated that the programs  are more likely to improve enrollment, attendance, and learning if they are  carefully integrated with other educational, health, and nutritional  interventions—such as ensuring adequate numbers of well-trained teachers  and providing treatments for parasitic infections and micronutrient  deficiencies. However, USDA began the GFEI pilot quickly and did not  require potential implementing partners to provide important information  on the linkages to these other interventions. Since most of the pilot’s  funding is targeted for the school meals, it is unclear whether these other  important factors that contribute to effective programs are adequately  addressed. In addition, USDA has not effectively managed the pilot in part  because of its lack of expertise and resources for food for education  development programs. It has not set specific targets or desired  performance levels for enrollment and attendance in its agreements with  most of its implementing partners. WFP has recently collected baseline  data on enrollment and attendance, and USDA is in the process of doing so.  USDA will not try to measure the projects’ impacts on learning, as it  believes the 1-year time frame is too short for such an assessment.Because of these weaknesses, we do not believe the pilot program will  yield adequate information on whether its projects have succeeded or  failed in improving enrollment, attendance, and learning—and why.  Furthermore, a number of other donor countries will not contribute to  GFEI until they see if the pilot is successful. These are important concerns  as the Congress considers what actions to take regarding legislation on  GFEI.
section_title: Matters for Congressional Consideration
paragraphs: As the Congress decides whether to further fund GFEI, it may wish to  consider: extending the pilot program to permit an assessment of its effects on  learning, as well as a more meaningful review of its impact’s on  enrollment and attendance; deciding whether additional funding for pilot project related activities,  such as teacher training and textbooks, may be needed for effective  projects; assuring that the administering agency has sufficient expertise and staff  resources to effectively manage the program; and requiring the administering agency to establish measurable performance  indicators to monitor progress and evaluate project results.
section_title: Agency Comments and Our Evaluation
paragraphs: We received written comments on a draft of this report from USDA, USAID,  and the Office of Management and Budget (OMB) that are reprinted in  appendixes XII, XIII, and XIV. These agencies also provided technical  comments, which we incorporated in this report as appropriate. The  Department of State’s liaison for GAO told us that State believes the report  findings are essentially factual and correct and opted not to comment  further. We also obtained technical comments on parts of the report from  the World Bank, WFP, and six PVOs and have incorporated them as  appropriate.
In its comments, USDA reiterated a number of key points and findings that  were in the draft report and provided some additional information about  certain aspects of the pilot program. Beyond that, USDA said it believes we  have taken an overly critical view of how it has administered the pilot  program, given time and resource constraints. Our draft report cited time  and resource limitations as key factors affecting the management and  possible effectiveness of the program. USDA also said it believes the report  fails to recognize that the president directed a school feeding program, not  an entire educational program. We disagree with this statement.  We clearly  said— as the White House did on the day the program was announced and  as USDA itself did in its comments—that the pilot is a school feeding  program with the three purposes of improving student enrollment,  attendance, and learning.
USAID said our draft report accurately and fairly depicted the complex and  formidable challenges confronting the GFEI, fully endorsed our matters for  congressional consideration, and said the findings and matters should be of  great use to the Congress as it debates the structure of U.S. food assistance.  USAID observed that the pilot placed priority on getting the program up  and running, with program designers believing that improvements could  then be made that would address issues of cost, sustainability, and the need  for complementary programs.
OMB commented that the draft report was balanced and generally accurate  and would serve the Congress and the public in future deliberations about  school feeding programs.  OMB also said that the principal criticisms of the  pilot program problems may be attributable to the urgency with which the  program was generated. In addition, OMB said, greater emphasis was  placed on the nutritional goals of the pilot rather than education objectives.  One could expect that some of these problems could be addressed by a  more deliberate approach to performance and evaluation, it said.
We are sending copies of this report to interested congressional  committees and the secretary of state; secretary of agriculture; and the  administrator, USAID. Copies will also be made available to others upon  request.
If you or your staff have any questions about this report, please contact me  on (202) 512-4347. Other GAO contacts and staff acknowledgments are  listed in appendix XII.
section_title: Scope and Methodology
paragraphs: We obtained information on the Global Food for Education Initiative  (GFEI) and pilot program from U.S. government officials at the  Departments of Agriculture (USDA) and State, as well as officials from the  Agency for International Development (USAID), the Office of Management  and Budget (OMB), and the White House. We also obtained information  from officials of the World Food Program (WFP), foreign donor  governments, and representatives of private voluntary organizations. In  addition, we met with representatives of the European Commission and the  World Bank, and experts from private research institutions. We conducted  our review in Washington, D.C.; Rome, Italy; and Brussels, Belgium.
Our review addressed lessons learned from past international school  feeding programs, the application of lessons learned to the pilot program,  an assessment of the design and implementation phase of the pilot project,  the impact of the GFEI on recipient country agricultural markets, and the  commitment of other donor countries to the initiative. Our review did not  address the in-country phase of the pilot program because projects were  not operational during most of the time of our review. Our contact with  PVOs was limited because most of their agreements were not finalized until  we had completed most of our field work.
To examine the lessons learned about the effectiveness and cost of school  feeding programs in promoting increased school enrollment, attendance,  and performance, we reviewed studies completed by the U.S. government,  international organizations, private voluntary organizations, and private  research institutions. We also met with selected experts in international  school feeding. We reviewed the studies in terms of past programs’ impact  on enrollment, attendance, and learning. In reviewing studies and meeting  with experts, we also identified key factors common to effective school  feeding programs. Through our analysis of information from World Bank  and WFP, we also compared estimated costs of various school feeding  programs.
To examine the extent to which the U.S. pilot program has been built upon  the lessons learned from previous school feeding programs, we met with  senior officials of the USDA and State, USAID, the White House, and OMB,  as well as representatives of private voluntary organizations, research  institutions, and international organizations. We also reviewed program  decisionmaking documents. We compared information obtained from these  sources to key conclusions of past international school feeding studies and  the views of various experts.
To determine whether the U.S. pilot program was designed and  implemented to reasonably ensure that the food aid and monetized  proceeds were used effectively and efficiently, we gathered information  and met with officials from the USDA, USAID, the White House, and OMB.  We also obtained information from private voluntary organizations and  WFP. We reviewed pilot program guidance, proposals, and relevant laws  and regulations governing the development and administration of the pilot  project. We also gathered and analyzed a variety of key pilot project  information to provide estimates of tonnage, project costs, and number of  beneficiaries by cooperating sponsor. We assessed selected information in  proposals for approved pilot projects and nonmeal program components of  these projects, including the amount budgeted and number of project  beneficiaries. We applied our governmentwide internal control standards in  evaluating the pilot project’s management and financial controls.
To determine the views of other major food aid donors regarding support  for a comprehensive, long-term global food for education initiative, we  gathered information and met with officials from donor countries including  Australia, Canada, Denmark, Finland, France, Germany, Italy, Japan, the  Netherlands, Sweden, and the European Commission. We developed an  analytical framework to summarize their individual and collective views on  how food aid should be provided in terms of emergencies, development,  cash, or food-in-kind.
We conducted our review from November 2000 through December 2001 in  accordance with generally accepted government auditing standards.
section_title: Pilot Program Projects’ Implementing Partners, Countries, Agreement Status, Tonnage, Cost, and Beneficiaries
subsections: section_title: International Orthodox Christian Georgia Charities (IOCC)
paragraphs: Does not include a late fiscal year 2002 shipment of 2,350 metric tons.
Some projects involve multiple commitments. The United States approved 34 WFP proposals  covering 27 WFP projects in 23 countries. Of the 34 proposals, 8 were for expansions of already  existing school feeding projects. The United States approved two different projects each for Guinea,  Kenya, Nicaragua, and Uganda. As of February 21, 2002, USDA and WFP were still negotiating the  terms of the second project for Guinea, and no figures for this project are shown in the table.
section_title: The World Food Program’s Role in School Feeding and Food for Education
paragraphs: The World Food Program (WFP), set up in 1963, is a major U.N. agency in  the fight against global hunger.  In 2000, WFP fed 83 million people in 83  countries, including most of the world’s refugees and internally displaced  people.  It shipped 3.5 million tons of food; received $1.75 billion in  donations; and had operational expenditures of $1.49 billion (provisional  figures).
WFP provides three basic kinds of food aid:  (1) emergency assistance to  cope with the adverse food effects of natural disasters, civil conflict, and  war; (2) protracted relief or rehabilitation aid to help people rebuild their  lives and communities once the causes of emergencies recede; and (3)  development assistance that aims to make communities food secure so  they can devote time, attention, and work to escaping the poverty trap.  When WFP was founded, its food assistance primarily focused on  development, and for years development projects accounted for more than  two-thirds of its expenditures. However, during the past 15 years, WFP has  become increasingly involved in responding to humanitarian emergencies.  According to WFP officials, WFP devoted 28 percent of its resources to  development in 1997, 18 percent in 1999, and only 13 percent in 2000.
WFP relies entirely on voluntary contributions to finance its projects.  Governments are the principal source of funding, but corporations,  foundations, and individuals also contribute. Donations are made either as  cash, food (such as grains, beans, oil, salt, and sugar), or the basic items  necessary to grow, cook, and store food—kitchen utensils, agricultural  tools, and warehouses.  Since it has no independent source of funds, WFP’s  Executive Board has mandated that all food donations, whether in cash or  in-kind, must be accompanied by the cash needed to move, manage, and  monitor the food aid.
WFP has been running school feeding programs for nearly 40 years.  In  1999, it operated 76 school feeding projects in 48 developing countries.  These included 33 emergency or protracted relief projects that had 5.28  million beneficiaries and 43 development projects that had 5.85 million  beneficiaries. Thus, total beneficiaries were 11.13 million.  In 2000, WFP  operated 68 projects in 54 countries, with a total of 12.27 million  beneficiaries.  According to WFP, the total expenditure for its school  feeding operations in 2000 was approximately $421 million. About $239  million was for development projects focused on school feeding, and the  remainder was for school feeding components of emergency or protracted  relief and recovery operations.
WFP welcomed President Clinton’s July 23, 2000, announcement of the  $300 million pilot program to launch a universal school feeding program,  noted that it had been working closely with the U.S. ambassador to the U.N.  Food Agencies in Rome to assist in the creation of such a program, and  expressed the hope that the initiative would become a permanent feature  of the global community of nations. A few days later, WFP’s executive  director, in testimony before a U.S. Senate committee, said a global  program needs to be managed by a global organization and WFP, as the  food aid arm of the U.N., was uniquely qualified to manage the initiative.
Regarding its role in implementing a global program, WFP has said that  much could be done to strengthen the education system in many  developing countries.According to WFP, this a highly complex task, one  for which food aid is not the most effective resource. WFP’s approach will  be to use food aid where the food is needed. WFP does not propose to  monetize food commodities to fund related educational support activities.  WFP will monetize only to effect an exchange between donated  commodities and locally grown foods when this is cost effective and does  not have an adverse effect on local markets. At the same time, WFP  recognizes that while school feeding can bring children to school and help  them learn while they are there, school feeding does not ensure qualified  teachers, books and supplies, or a suitable curriculum. According to WFP,  this is the role of national governments, often supported by international  organizations or Private Voluntary Organizations (PVO); and the  relationship between improvements in an education system and a national  system of school feeding is one that must be managed by governments.
However, within the broad framework of government cooperation, WFP  said, it is eager to work with other operational partners and experienced in  doing so.
subsections: section_title: Underfunding of Projects
paragraphs: WFP told us that many of its school feeding projects have shortfalls.Funding for all components of approved projects, including current school  feeding programs, depends on the level of contributions received. When  and where possible, WFP will allocate unearmarked donations to  underfunded projects, taking into consideration the urgency of the need  and a need to comply with the executive board’s approved allocation  formula.
According to WFP, it usually is not technically feasible to identify how  many children were not fed due to under-resourcing. An unstable  resourcing situation often compels project managers to temporarily adjust  the on-site ration size or the number of food distribution days, rather than  reducing the number of beneficiaries, it said. When under-resourcing is of a  more permanent nature, the project plan is revised and a formal change in  the beneficiaries occurs.
section_title: WFP’S Approach to Certain Key Factors Associated with Effective School Feeding Programs
paragraphs: WFP has developed several documents that describe its policies for  establishing school feeding programs and which guide the project  development and approval process for all WFP school feeding activities.The following is a brief summary of some of the points presented in these  documents, or provided directly to us by WFP in response to questions that  we provided to the agency, regarding certain key factors associated with  their school feeding programs.
Targeting—The focus of WFP’s world school feeding initiative is on  feeding preschool and primary school age children. On an exceptional  basis, food aid activities designed to encourage girls to continue their  education beyond primary school will be considered. Some fundamental  issues to be examined in determining the problems to be addressed are  (1) enrollment and dropout rates in primary education broken down by  gender, region and sociocultural groups, to the extent possible, and  factors explaining these rates; (2) extent of, and factors contributing to,  short-term hunger; (3) average distances walked by the students, who  will be covered in the school feeding activity, between their homes and  their school; and (4) cultural practices affecting enrollment/attendance,  especially of girls.
As a general rule, targeting within school feeding projects will be  conducted at the level of geographic areas, with no selection of  individual pupils within schools. The only exception for this may be  when the effectiveness of an incentive for a particular category (e.g.,  girls) can be demonstrated. According to WFP, it requires at least 50  percent of its resources in education to be targeted for girls, and WFP  has been very successful in achieving this requirement.
WFP has a vulnerability analysis and mapping unit (VAM) to identify  people most vulnerable to hunger and to target their needs. According to  WFP, VAM uses state of the art satellite imagery of rainfall and crop  conditions, as well as monitoring of food prices in local markets. WFP  has VAM sub-units in more than 50 developing countries. According to  WFP, this system is also used in targeting its school feeding programs.
Facilitative learning environment—WFP told us that it does not require  a facilitative learning environment to be in place  or provided as part of  its programs, but such an environment is highly desired and encouraged.  According to WFP, the presence of school feeding in schools helps bring  attention to other school conditions (e.g., classrooms, materials,  sanitary facilities, teachers, curricula, and health conditions) and, in  turn,  helps WFP and its partners to bring attention to problems and  attract other needed resources.
Safe water and sanitation—WFP guidelines say basic water supply and  sanitation standards must be met if food is to be safely stored and  prepared for school feeding, and safe water supply should be available  on the school premises at all times. WFP provides detailed information  on optimal and minimal standards for a safe water supply and sanitation  at schools. However, WFP told us it does not require safe water and  sanitation facilities to be in place in order to implement school feeding  in a given school and, as a rule, does not provide water and sanitation  facilities. However, WFP said, it  does work with the national and local  governments and with other U.N. agencies, donors, and  nongovernmental organizations who have the appropriate skills and  resources to “trigger” action where the lack of such facilities is a  problem.
Deworming treatments—According to WFP guidelines, WFP will  generally support deworming in a school feeding program when more  than 50 percent of the children have intestinal parasites. Treatment is  with a single dose of the proper medicine, up to three times a year, and  should be combined with improved sanitation and safe water supply, as  well as health education on prevention. In April 2001, WFP told us that it  did not yet have complete information regarding which of its school  feeding programs had already initiated deworming activities (due to  decentralized decision-making and no prior requirements for reporting  such information). However, WFP said it did know that most or all of its  school feeding operations in Latin America and the Caribbean and two  or more in Asia had at least implemented limited deworming activities.  WFP estimated that by the end of 2001, it would have initiated  deworming in its school feeding programs in 15 or more countries, in  partnership with WHO and the World Bank, and assisted, in part, by a  Canadian grant. WFP said that it hopes to achieve deworming activities  in most or all GFEI, as well other WFP school feeding operations. WFP  also noted that national, regional, or local governments may require  deworming to be in place.
Micronutrient supplementation—WFP guidelines note that school  feeding can be a vehicle for micronutrients in countries where school  children are affected by and/or at high risk of developing micronutrient  deficiencies. WFP provides information on micronutrient deficiencies  that have been shown to affect school attendance and performance,  recommended levels of intake of these micronutrients for 3- to 12-year  old children, and guidance on how to use them in school meals. WFP  told us that micronutrient supplementation is most often handled as an  additive to the commodities that are distributed. In cases where the  commodities that arrive are not fortified, WFP most often works locally  to fortify the food or seeks other remedies. WFP collaborates with  groups that have expertise and resources to bring to bear, especially  UNICEF, WHO, a Canadian micronutrient initiative, and certain NGOs.  WFP noted that national, regional, or local governments may require  micronutrient supplementation to be in place.
Health and nutrition education—WFP told us that this is not strictly  required in all WFP school feeding operations. However, such activities  are highly encouraged, are frequently planned and implemented, and  will be further strengthened through collaboration with appropriate  partners and coworkers on the ground. WFP noted that national,  regional, or local governments may require health and nutrition  education to be in place.
Community and parental participation—WFP told us that community  and parental participation are not strictly required in all WFP school  feeding operations. However, WFP said, such activities are highly  encouraged,are frequently planned and implemented, and are and will  be further strengthened through collaboration with appropriate partners  and coworkers on the ground. WFP noted that its data indicates that as  girls’ enrollment and attendance increases, so does parental  participation. WFP also noted that national, regional, or local  governments may require parental involvement to be in place.
Education for All—WFP expects recipient governments to have  demonstrated a commitment to Education for All.
Sustainability—WFP requires that plans be in place for eventual take- over of a feeding program by recipient countries. WFP generally insists  that programs be supported by national governments and local  communities and that resources and infrastructure be provided as  counterpart contributions. However, WFP will consider providing  school feeding activities in some emergency and protracted relief  situations where full government support is not possible. In addition, for  low income countries, it is probably necessary to provide most or all of  the food commodities, technical assistance, and equipment.
According to a WFP official, sustainability depends on the economic  status of the recipient country. There are countries where the national  government has been able to take over a program. However, in the  poorest, least developed countries, he said, sustainability is only  possible where there is substantial community involvement. In many  least developed countries, government expenditure on the education  sector often represents up to 30 percent of the national budget; it is  difficult enough for such countries to maintain the physical  infrastructure and teachers. For least developed countries,  sustainability is a long-term process. A realistic estimate is 10 to 15  years, he said.
Monitoring and Evaluation	 WFP officials told us that there had been some problems in the past, but  WFP is working hard to overcome them for both the U.S. pilot program and  its other school feeding activities. As an example of problems, collection of  baseline date had varied, depending on the country, the specific goals of the  school feeding activity, and the resources available. Principal performance  indicators that WFP tended to use were increased enrollment and  attendance, reduced dropout rates, and improved performance (such as  number of students who had completed primary school the previous year  and gone on to higher education). WFP had looked at these indicators,  especially as they relate to girls’ education, and had been able to report  some notable successes. However, WFP had only done that in isolated  cases/countries. Therefore, WFP intends under GFEI to standardize the  indicators and upgrade its monitoring and evaluation systems so as to be  able to regularly collect and report comparable and up-to-date data for its  school feeding operations. WFP also said that data collection and analysis  in developing countries is challenging and requires additional resources  and capacity building of national counterpart staff.
WFP’s guidelines for its new World School Feeding Initiative require a  baseline monitoring study to establish the situation prior to the onset of the  initiative, followed by periodic updates as a program is implemented. To  this end, WFP developed a detailed survey instrument for collecting  baseline information on its GFEI-funded projects. The survey was pilot- tested in August 2001, and WFP conducted the surveys in a sample of  schools for all of the U.S. pilot program projects before the end of 2001  (details of the survey instrument are discussed in the letter).
In addition, according to WFP, during 2001, it  developed and successfully  pilot-tested a new system of collecting key monitoring data on a timely  basis directly from the schools involved in its feeding programs. The  system involves school staff entering key data directly into devices,  installed at the schools, that transmit the data via satellite to a data  collection center in France, using the ARGOS satellite system (that is  jointly managed by the governments of France and the United States).  Country data is then reported from the data collection center to the  country’s relevant ministry of education and to WFP. WFP is seeking  donors to fund implementation of the system.
WFP also conducted a major, global survey of national school feeding  programs (not specific projects) between May and December 2001. The  survey collected information on countries’ school feeding programs and  related information on their demography; education system;  nongovernmental program assistance; health-related education services at  school; and evaluations, studies, and surveys about school feeding and  related topics. According to WFP, the survey provides a focal point for  school feeding information, which WFP will use to promote dialogue with  governments and nongovernmental organizations concerning the use of  food aid for education and related issues. WFP will also use the data to  produce special reports and identify country specific needs and coordinate  partnerships between countries with experience in school feeding and  those in need. WFP is posting country-specific results on its Web site. WFP  is seeking donors to fund installation of the system in its schools.
Regarding evaluations, WFP’s central evaluation office generally does not  conduct separate evaluations of the school feeding projects that WFP  assists. (Occasionally separate evaluations of school feeding projects are  undertaken if specifically requested by the executive board.) WFP  mandates that evaluations of its country programs be conducted about  every 4 years, on average. The evaluations are submitted to WFP’s  Executive Board for review. If a country has a school feeding project, the  project’s role, relevance, and performance as an activity is to be included in  the review.
section_title: Results from Review of Experts’ Findings and Views on School Feeding Programs
paragraphs: This appendix provides additional information on our review of experts’  findings and views concerning (1) the effect of school feeding programs on  enrollment and attendance, (2)  the effect of school feeding programs on  educational performance or learning, and (3) key factors contributing to  effective school feeding programs (see tables 4 and 5).  It also provides  further information on key factors associated with effective school feeding  programs (see tables 6 through 10). (See also app. V, which discusses the  costs and cost effectiveness of school feeding programs.)
Our review relied considerably on the views of two experts who have  reviewed the results of many school feeding program studies; WFP, which  has conducted school feeding programs for 4 decades and also reviewed  the results of other studies; and the summary views of a meeting of  experts and practitioners held at USAID in October 2000. We also  conducted literature searches, reviewed the results of individual studies on  school feeding programs, and spoke with experts and practitioners.
Table 4 summarizes the results of studies and expert views on the  relationship between school feeding and school enrollment and  attendance.
Table 5 summarizes the results of several studies and expert views on the  relationship between school feeding and school performance.
Table 6 provides results and views on how targeting factors can affect  school feeding program effectiveness.  Ways to target programs include  focusing on areas/communities that are (1) low-income and food insecure,  (2) have relatively low levels of school enrollment and attendance, and (3)  where girls’ enrollment and attendance are considerably lower than boys’.
Table 7 provides results and views on how learning environment factors  can affect school feeding program effectiveness, including ensuring  adequate numbers of teachers, teacher training, supplies of textbooks and  other learning materials, and school infrastructure.
Table 8 provides results and views on how health and nutrition factors can  affect school feeding program effectiveness, including through treating  intestinal parasitic infections, ensuring clean water and adequate sanitation  facilities, addressing micronutrient deficiencies, and ensuring health and  nutrition education.
Table 9 provides results and views on how community and parental  involvement can impact the effectiveness of school feeding programs.
Table 10 provides results and views on the effect of government  commitment and sustainability on the effectiveness of school feeding  programs.  Among the factors addressed are national government  commitment to broad, national school reform programs, resource  commitments by national governments and local communities, and plans  for program sustainability.
subsections: section_title: References
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section_title: Costs of School Feeding Programs
paragraphs: This appendix discusses actual costs of school feeding programs as  determined by two World Bank studies, as well as World Food Program  (WFP) cost estimates of its programs and our own estimates of school  feeding programs based on WFP guidelines and cost factors and other data.  It also provides information on situations where school feeding programs  may not be as cost-effective in promoting learning as certain other  approaches.
Table 11 provides figures on the actual costs of more than 30 school feeding  programs in 21 countries that were reported in two World Bank studies.  Table 11 shows the annual cost of providing 1,000 calories per student on a  daily basis for a 180-day school year; dollar values have been expressed in  2000 dollars.  As the table shows, costs vary significantly, ranging from a  low of $4.29 for one program to a high of $180.31 for another. All but four of  the programs cost more than $23 per pupil, and the average cost for all  programs was $58.66 per student.  Cost differences can be due to a variety  of factors, such as differing program objectives, type of food served, and  costs in transporting the food to the country and, once there, to its final  destination.
In April 2001, WFP officials told us they estimated the current average cost  of WFP school feeding programs ranged between about $22 to $27 per  student, for a 180-day school year.  They said WFP did not have precise  figures available on the average costs of its school feeding programs  because it has not required data to be reported in the specific category of  school feeding. Many large projects have a school feeding component, they  noted, but are not entirely devoted to school feeding. Subsequently, in July  2001, WFP issued a paper that reported the average cost of its school  feeding development projects in 2000 at 19 cents a day (or $34.20 for a 180  day program).
We prepared a separate estimate of the cost of school feeding programs  using some WFP guidelines and cost factors and other data. According to  WFP, the recommended daily school feeding ration for full-time primary  school students can range between 600 to 2,000 calories, depending on  whether schools are half day, full day, or boarding. For day school, the  recommended acceptable range is between 1,200 to 1,500 calories (i.e., 60  to 75 percent of the daily energy requirements of school-age children). The  guidelines also indicate that a minimum of 10 percent of calories should be  obtained from consumption of edible fats. In addition, the guidelines for  day schools recommend that school feeding programs provide 28 to 36  grams of protein; 13 to 17 grams of fat; and no more than 300 grams of  cereals, 30 grams of pulses, and 15 grams of vegetable oil.
We analyzed the nutritional value of typical food aid commodities and  determined that the least costly mix of commodities—consisting of corn  and vegetable oil--that met the above requirements for primary day schools  would cost 3.72 cents per child per day (based on USDA valuations of the  commodities for 2001). If this diet were supplied for 180 days, the food  alone would cost approximately $6.69 per child. On the basis of overall  WFP costs for its various food aid programs in 1998 to 1999, we estimated  that administrative, storage, and transportation costs would result in an  additional cost per child (for a 180-day school meal program) of $7.70.  The  total average cost of this diet would be $14.39 per student. When factoring  in the nutritional requirements of school-age children to include other  essential elements, such as vitamins, micronutrients, and minerals, we  found the lowest-cost, most nutritionally-complete recipe would cost  $29.67 per child ($13.80 for the food and $15.87 for administrative and  transportation costs.)
subsections: section_title: Situations Where Other Approaches May Be More Cost Effective
paragraphs: According to a number of experts, school feeding programs may be less  cost effective than other possible approaches, such as establishing  maternal child health and early childhood development programs and  providing alternative nutritional or educational interventions.
According to a USAID official, if nutrition is the problem, maternal child health and  preschool feeding programs are more cost effective than school feeding programs. If  education is a major weakness, investments in educational reform, teacher training, and  learning facilities are more cost effective.
In 2001, a USAID contracted evaluation of its school feeding program in Haiti, covering  the period 1996 to 2000, was completed. (The program was primarily a school feeding only  operation; however, some resources were devoted to food for education activities.) The  report concluded there is no causal connection between school feeding and improved  educational performance. Other factors such as school quality and parental variables, have a  more direct influence on educational outcomes, it said. The report found the food for  education approach to be very promising, provided that food is used as leverage to improve  school quality. The report recommended USAID consider devoting all of the school feeding  resources to food for education activities. However, USAID decided to phase out school  feeding activities over a 3-year period. According to a USAID official, Haiti was loosing too  many kids before they ever got to school. As a result, USAID concluded it would be more  cost effective to employ the resources in a maternal and child health program. increase the likelihood that children will be healthy when they reach school  age.
Table 12 provides an estimate of the cost effectiveness of nutrition-related  interventions for a typical developing country, in terms of the return on  each program dollar spent, as reported by the World Bank.  (Impact is  estimated in terms of wages rather than learning per se.) As shown in table  12, school feeding has one of the lowest return ($2.80) of the 11  interventions.  Interventions with the highest returns on each program  dollar spent are iron fortification of flour ($84.10), vitamin A  supplementation for all children under age 5 ($50), nutrition education  ($32.30), and iodized salt ($28).
In a study of the cost effectiveness of 40 educational interventions in Latin  America, the authors surveyed a panel of 10 world experts on educational  research and practical attempts at educational reform in the region, as well  as 30 Latin American planner/practitioners working primarily in education  ministries. Of the 40 interventions, 4 were variations on school feeding  programs. None of the school feeding options were identified as being  among the top 10 interventions for increasing learning, taking account of  the estimated likelihood of adequate implementation (see table 13). The  school feeding options were ranked between 23 and 34 in terms of  increasing learning and between 34 and 40 when cost effectiveness was  also considered.
According to Beryl Levinger, an expert on school feeding and food for  education programs, there are children in developing countries that can  effectively and efficiently benefit from school feeding programs. Short- term hunger is a genuine problem, and school feeding is one way to get and  keep children enrolled in school, she said. At the same time, success in  improving school enrollment, attendance, and learning is context driven,  and many external factors can affect and interfere with these outcomes,  she said.  Therefore, according to Levinger, one needs to assess the total  picture and identify the most important needs and best solutions for  addressing them. For example, if the quality of education in a particular  community is low and resources are limited, it is possible that resources  could be better spent on improving education than addressing short-term  hunger. As learning tasks become more interesting, she noted, learning  goes up. Levinger estimated that providing motivational textbooks and  other learning materials and training teachers in active learning methods  would cost roughly about $5 per pupil per year. For an additional $2, she  said, one could also provide some micronutrient supplementation and  deworming treatments.
Multiple studies of treatments for intestinal parasite infections, through  iron supplementation and regular deworming, have shown benefits of  lower absenteeism and higher scores on tests of cognition or school  achievement at a cost of about $1 per child per year. This is considerably  less costly than school feeding programs that average $34 per child per  year. However, we are not aware of any studies that assess and compare  the relative impacts of programs that only treat for parasite infections to  programs that provide a school meal.
In April 2000, the World Health Organization, the U.N. Educational,  Scientific, and Cultural Organization, the U.N. Children’s Fund, and the  World Bank proposed a strategy for Focusing Resources on Effective  School Health (FRESH) to give a fresh start to improving the quality and  equity of education and promoting the Education for All goal. They noted  that poor health and malnutrition are important underlying factors for low  school enrollment, absenteeism, poor classroom performance, and early  school dropout. The agencies identified a core group of activities that they  said captured the best practices from their programming experiences, were  highly cost-effective, and a starting point to which other interventions  might be added as appropriate. The agencies recommended that the  following basic components of a school health program be made available  together, in all schools: (1) health related school policies; provision of  safe water and sanitation; (3) skills based health, hygiene, and nutrition  education; and (4) school based health and nutrition services.
Regarding the latter component, the agencies said schools can effectively  deliver some health and nutritional services provided that the services are  simple, safe, and familiar and address problems that are prevalent and  recognized as important within the community. For example, they said,  micronutrient deficiencies and worm infections may be effectively dealt  with by infrequent (6-monthly or annual) oral treatment. As another  example, they said changing the timing of meals, or providing a snack to  address short-term hunger during school—an important constraint on  learning—can contribute to school performance.
In commenting on a draft of portions of this report, WFP officials said there  has been no more cost-effective approach identified than school feeding for  the combined objectives of increasing enrollment, attendance, and  performance in developing countries--especially in areas of food insecurity.  Further, when the key resource available is food, the case for school  feeding to accomplish these objectives is indisputable, they said.
section_title: Process to Solicit, Evaluate, and Approve Proposals for the Pilot Program
paragraphs: USDA used a considerably different process to solicit, evaluate, and  approve program proposals from interested cooperating sponsors and  WFP. Cooperating sponsors, including Private Voluntary Organizations  (PVO) and the government of the Dominican Republic, underwent an  expedited two-stage qualification and proposal review process that either  did not apply to or generally was different from that applied to WFP.  Proposal formats and criteria applied to them by reviewers varied  considerably.  An interagency Food Assistance Policy Council (FAPC)  made the final selection of project awards.
subsections: section_title: Proposal Process and Information Required
paragraphs: On September 6, 2000, USDA published a notice in the Federal Register  requesting proposals from interested cooperating sponsors to carry out  activities under GFEI. (See app. XI for key events under GFEI.)  USDA said  it would use section 416(b) of the Agricultural Act of 1949 to provide  surplus agricultural commodities in support of an international school  feeding program to improve student enrollment, attendance, and  performance in poor countries.  Proposals would be reviewed on an  expedited basis.  Given time constraints and the considerable effort and  time involved in preparing and evaluating proposals, USDA invited  interested sponsors to present an initial submission that contained only  information intended to demonstrate, based on experience, the  organizations’ administrative capabilities for implementing and managing  school feeding or monetization of commodities for school feeding.  USDA  identified nine types of information that should or could be provided.  The  deadline for initial submissions was September 15, 2000.
USDA said that sponsors found to be most capable of successfully  implementing school feeding activities under step one would then be  invited to provide a supplemental submission addressing their specific  proposed activities. The deadline for the step-two submission was  September 29, 2000.  USDA said the submissions should provide  information that supported the goal of establishing a preschool or school  feeding program to draw children into the school environment and improve  access to basic education, especially for females.  Priority consideration  would be given to countries that had a commitment to universal free education but needed  assistance in the short run; places where preschool or school feeding programs would promote  significant improvements in nutrition, school enrollment, and  attendance levels; projects involving existing food for education programs; and projects where the likelihood of support from other donors was high.
USDA requested that sponsors provide, to the extent possible, information  on (1) literacy rates for the target population; (2) percentage of children  attending schools, with special emphasis on school-age girls; (3) public  expenditure on primary education; (4) whether the country currently  operated a school feeding initiative (either through USAID, with assistance  from the World Bank, or through internal resources); (5) program impact  on areas such as teacher training, community infrastructure (e.g., PTAs and  community groups), health, and nutrition; and (6) other potential donors.  USDA also referred interested parties to the Code of Federal Regulations,  which describes the requirements for the standard 416(b) program. These  regulations provide additional guidance on factors to address in preparing  a proposal.
Twenty-nine PVOs submitted part one of the proposal application within  the required time frame.  On September 22, 2000, USDA announced that 20  PVOs had qualified for further consideration and invited them to submit the  second part of the application on the specific projects they were proposing.  In addition, USDA announced that the government of the Dominican  Republic had submitted an application, which had been approved for  further consideration, and that WFP was eligible to participate in the pilot  program.
The September 6, 2000 Federal Register notice stated that the pilot  program was also open to WFP. USDA did not require WFP to provide  either the initial or supplemental submission.  WFP had already submitted  a set of proposals to USDA in August 2000, following consultations with  USDA officials. These proposals (1) were abbreviated; (2) concerned  already existing or approved WFP school feeding projects that had not  been fully funded, as well as planned expansions of these or other  projects; (3) and, in general, did not address many points that USDA had  asked cooperating sponsors to address in the second-stage submission.  The proposals typically contained a brief half-page description of the  project, accompanied by a summary budget for the commodities requested.  Some, but not all, U.S. agency officials charged with reviewing the  proposals were told they could obtain additional information describing  the projects on WFP’s Web site. However, some projects had been  approved by WFP’s Executive Board in prior years.  Information posted on  the Web site was sometimes incomplete and/or out of date.
USDA officials noted that the United States is a member of the WFP  Executive Board and as such has a vote on which WFP proposed projects  should be approved. They also noted that a vote by a donor country to  approve a project does not mean that the country intends to donate to that  project. In addition, they noted that approved WFP projects submitted to  the pilot program in August 2000 would have been approved by the  executive board prior to the U.S. announcement of the pilot program and  GFEI.
According to WFP officials, WFP is strongly committed to addressing the  key factors associated with effective food for education programs  discussed in this report. The U.S. government is well aware of this  commitment, and as a result WFP did not deem it necessary to make  repeated reference to this commitment in the country-specific information  included in its proposals. WFP officials noted that proposals submitted to  USDA for projects that had already been approved by WFP’s Executive  Board had gone through a long vetting process, adding that approval of a  WFP project requires unanimous consensus from all executive board  members, including the United States. The officials also noted that written  documentation on its projects had been provided to U.S. government  representatives during previous WFP Executive Board sessions when the  projects had been reviewed and approved, as well as in sessions to review  projects that had been operational. As a result, WFP officials said, the U.S.  government had plenty of documentation for evaluating WFP proposed  projects apart from documentation available at WFP’s Web site.
However, USAID told us that when the United States concurs in an  executive board decision to approve a project, the United States frequently  states its concerns or reservations about the feasibility or sustainability of  program activities and has done so in the case of school feeding programs.  Therefore, the fact that a particular project had been approved by WFP’s  Executive Board did not necessarily mean the project was a good  candidate for the U.S. food for education pilot program. In addition,  according to a USAID official, though in principle U.S. government  personnel responsible for evaluating WFP proposals could have gone to  WFP’s Web site to look up additional documentation, there was little time  to do this because of the push to get the pilot program up and running so  quickly. He added that he knew of no one who used the Web for this  purpose. He also said the evaluation task force members did not receive  hard copies of documentation beyond the abbreviated set of proposals  provided by WFP to USDA.
section_title: Proposal Evaluation Process And Agencies’ Criteria
paragraphs: USDA/Foreign Agricultural Service (FAS) staff evaluated the initial PVO  submissions on the basis of criteria in USDA’s September 6, 2000, Federal  Register notice.  USDA/FAS assigned different weights to the criteria.  PVOs that scored above a certain level were invited to submit the second  part of the requested proposals.  Of 20 PVOs invited to make a second  submission, 19 responded and 1 declined, citing a lack of adequate time to  prepare the type of careful proposal the organization wanted to submit.
The 19 PVOs submitted a total of 62 project proposals.  The government of  the Dominican Republic also responded with a proposal.
For the second part of the proposal process, which covered the actual  programs sponsors proposed to implement in various developing  countries, USDA/FAS employed a more elaborate review procedure.  The  Food Assistance Policy Council (FAPC)was designated to make the final  project selections.  An FAPC working group was established to evaluate the  PVO, government of the Dominican Republic, and WFP proposals and  make recommendations on which ones to approve.  The working group  consisted of staff from FAS and its Food and Nutrition Service (FNS), the  Department of State, USAID, OMB, and the White House.
USDA/FAS provided the other members of the working group with copies  of all of the second-stage as well as WFP set of proposals.  USDA/FNS  assigned a nutritionist to review all of the proposals from a nutrition  perspective.  The Department of State assigned two staff to review the  proposals. Four offices within USAID were involved in evaluating the  proposals: a country backstop officer, the appropriate regional bureau, a  nutritionist analyst from the Bureau of Humanitarian Response, and an  education specialist from USAID’s Global Bureau, Field Support and  Research.  USAID’s Food for Peace Office within the Bureau of  Humanitarian Response coordinated the process within USAID.  The Food  for Peace Office is responsible for USAID’s food aid programs, including  any programs that have funded school feeding or food for education  programs.  Each member of the working group conducted an evaluation of  the proposals separately during October 2000 and met in early November to  discuss their results and reach consensus on which proposals to submit to  the FAPC for final approval.
USDA/FAS did not score but recommended approval of WFP proposals for  all 27 countries in which WFP had established, but unmet, food aid  requirements. However, USDA scored and divided the non-WFP proposals  into three distinct categories (i.e., strongly recommended, recommend  approval, or not recommended).  In conducting its second-stage evaluation  of the non-WFP proposals, USDA/FAS employed a considerable number of  written criteria, nearly all of which were taken from its standard approach  to evaluating 416(b) programs.  The standard criteria do not focus on  school feeding or food for education programs.  Apart from the standard  criteria, USDA’s evaluation included some criteria that related to school  feeding/food for education.  (All of USDA’s second-stage criteria were  weighted.) USDA considered whether:
Objectives supporting the goal of establishing preschool or school  feeding programs to draw children into the school environment and  improve basic education for females were clearly stated.
The proposal targeted a country with existing food for education  programs in the host country’s development plan.
The method for choosing beneficiaries (whether for preschool or school  feeding) activities was clear and justifiable; emphasis on females.
The cooperating sponsor provided indicators to measure program  impact, including baselines and expected outcomes.  Potential  indicators might include literacy rates for target populations, percentage  of school-age children attending school (emphasis on females), and  public expenditure on primary education.
The cooperating sponsor included specific performance targets as part  of its proposal, such as magnitude of change in number of meals served;  enrollment levels, specifically female enrollment; attendance levels;  capacity building in areas necessary to sustain the feeding program,  such as development of PTAs and other community groups; or  infrastructure development for delivery of service.
Agriculture officials told us they did not have time and adequate staff to  study lessons learned from past school feeding/food for education  programs given the short lead time they had to get the program up and  running.  Instead, they said, USDA relied considerably upon USAID for this  aspect of the evaluation, since USAID had extensive experience with  school feeding programs.
Most of USAID’s written criteria did not focus specifically on food for  education.  Evaluators in the Regional Bureaus were asked to review how  the proposals fit with the bureau priorities for the country and how a  proposed project might affect (positively and/or negatively) USAID  programs in the country.  The bureaus were also responsible for providing  each country proposal to the respective cognizant field mission and for  incorporating mission responses and concerns into their review.  Field  missions were also responsible for providing input regarding the Bellmon  analysis. Country backstop officers were asked to review each country  proposal regarding commodities, monetization, and logistics and how these  issues might affect (positively and/or negatively) USAID’s Title II food aid  programs in country.  The USAID nutritionist was asked to review the  nutritional components of the proposal and their adequacy.  USAID’s  Global Bureau was asked to review the educational components of the  proposals and their adequacy, as well as host country policies and  commitment to basic education. All of the USAID evaluators were  instructed to indicate briefly whether they approved or disapproved of a  proposal and, if they approved, to indicate the priority they thought the  proposed program should have (low, medium, high, very high).
In USAID’s weighting scheme, the Global Bureau’s assessment of the  educational component could have accounted for about 25 percent of a  proposal’s total score. However, for several reasons, its analysis did not  contribute to USAID’s evaluation of which proposals were the best. The  USAID staff person assigned to rate this dimension of the proposals told us  that although he had expertise in the education area, he was not an expert  on school feeding programs. In addition, he said that nearly all of the  proposals did not provide adequate information to judge the quality of the  educational component. He told us it might have been possible to obtain  this information if discussions could have been held with the sponsors.  However, the evaluation process did not provide for such interaction. As a  result, he assigned the same score to all but one of the proposals.  Since  virtually all proposals were scored exactly the same, education was not a  discriminating factor in the Global Bureau’s overall ranking of the  proposals.
No formal record was kept of the interagency working group’s  deliberations, but a summary of its consensus recommendations was  forwarded to the FAPC for action.  This summary contained a brief  description of the proposed food aid to be delivered to each country, its  cost and rationale, economic assessments, and prior aid. In the end, the  FAPC approved 34 WFP proposals covering 23 countries.  Of the 34, 26  were for approved WFP projects with unmet food aid needs and 8 were for  expansion projects.  FAPC approved 25 PVO projects and the only proposal  submitted by a government entity (the Dominican Republic). FAPC  allocated almost equal program value to WFP (about $138 million) and the  other sponsors (about $150 million), with instructions that the remainder  be first offered in support of additional WFP proposals.  However, cost  estimates that FAPC used in its award determinations were too high and  have since been reduced by USDA in implementing agreements. The total  cost of WFP agreements was recently estimated by USDA at about $92.5  million; cooperating sponsors’ agreements were estimated at about $135  million.
section_title: Selected Information Contained in Proposals for Approved School Feeding Programs
paragraphs: This appendix discusses selected information in school feeding program  proposals approved by USDA, including proposed nonmeal components of  the program, proposed funding of nonmeal components, and comments on  other donor assistance.
In its request for proposals, USDA indicated that PVOs could monetize  some of the food to cover certain other elements important to food for  education programs. Table 14 provides information on the PVOs that  proposed funding for nonmeal components, including the specific  components and the overall proposed funding amount for these  components. As the table shows, for 17 of the 25 approved proposals, PVOs  proposed to include a variety of nonmeal components. Examples include  repairs to school buildings, investments in teacher training and school  supplies, treatments for parasite infections, and health and nutrition  education. Ten of the 17 proposals included a budget amount for some or  all of these components.
According to information from USDA, it provided little funding for nonmeal  components of WFP projects.  WFP requested funding for the underfunded  school meals of already existing projects or for meals for expansion of  existing projects or start-up of new projects. These requests included  funding for the commodities and related costs, including ocean freight and  overland transportation costs to the recipient countries; internal  transportation, storage and handling costs for the commodities within the  recipient countries; direct support costs; and administrative costs.
According to WFP, its projects often include funding for nonmeal  components, which can be obtained through donor countries, partnership  arrangements with other international donors, or by recipient country  governments. WFP officials told us they are working to develop more  partnerships with other donor agencies to address nonmeal aspects of their  food for education projects.  Table 15 provides information on planned  funding of nonmeal components for the pilot program approved WFP  projects, based on WFP documentation that was available at WFP’s Web  site. Nonfood components typically involve training, construction or  rehabilitation of school facilities, or health related activities (such as  deworming).
Although USDA said that priority would be given to proposals where the  likelihood of other donor support was high, neither USDA nor USAID  included this factor in written criteria for evaluating the proposals.  We  reviewed the PVO proposals to assess whether sponsors in fact provided  such information in their proposals.  As table 16 shows, only five of the  approved proposals indicated that other donors might support the project.  Of the five, two proposals said other donors would  support the project and  identified the expected amount of support.
section_title: Donor Views on Uses of Food Aid And How It Is Provided
paragraphs: This appendix discusses the views of food aid donating countries other  than the United States regarding the use of food aid and how it is provided.
Table 17 lists donor countries’ views on whether food aid should be used  for emergencies, development, or both and whether food aid should be  provided as cash or food-in-kind.
section_title: Sources USDA Uses to Finance Its Implementing Partners’ GFEI Project Costs
paragraphs: USDA uses three funding sources to pay for implementing partners’  (PVO/government cooperating sponsors and WFP) operating costs under  the GFEI pilot program.  These costs cover the distribution of surplus  commodities acquired under Commodity Credit Corporation Charter Act  (CCC) authority and donated under Section 416(b) authority to friendly and  developing countries.  The funding sources are (1) local currency proceeds  derived from monetization (sale) of the commodities, (2) direct cash  payments made by CCC under commodity surplus removal (CCC Charter  Act 5(d)) authority, and (3) direct cash payments made by CCC pursuant to  specific limited appropriations authority granted to sponsors in July 2001.
Section 416(b) of the Agricultural Act of 1949, as amended, is the authority  that CCC uses to pay for most of the cost of removing and disposing of  donated surplus commodities in connection with the GFEI pilot program.  This authority allows CCC to directly pay freight forwarders selected by  implementing partners for the cost of ocean transportation and reasonably  related expenses of moving the commodities to a designated discharge port  or point within the country’s border where the food aid is to be distributed.  This cost is the largest except for the commodities themselves and is  estimated to be roughly one-third of the overall pilot program.  In the case  of urgent and extraordinary relief requirements, CCC may also pay the  partners for internal transportation, storage, and handling (ITSH) expenses  but not for nonemergency development assistance, which is the principal  type of aid provided by the pilot.  In addition, under section 416(b)  authority, CCC funds cannot be used to pay partners’ direct administrative  headquarters costs of running the program.
In lieu of getting CCC funding to recover their ITSH expenses for  nonemergency programs and administrative costs, partners are permitted  to monetize (i.e., sell) all or a portion of the commodities in the country or  region.  Local currency proceeds generated from the sale of section 416(b)  commodities can be used to finance most of the sponsors’ operating  costs—as long as they are specifically approved by USDA in program  agreements.  Monetization is generally how the PVOs and government  sponsors recover their operating costs.  Furthermore, these sponsors’  budgets and provisions for financial statement and monetization reporting  as well as limitations on budget adjustments without prior USDA approval  are incorporated into the program agreements.
USDA’s treatment of WFP on these matters differs from that of PVOs and a  government sponsor. USDA pays cash to WFP for all of these costs,  including headquarters’ administrative expenses.  In doing so, it relies on  section 5(d) of the CCC Act.  This section provides authority for CCC to  expend funds in connection with disposal of surplus commodities if such  expenditure is required to aid in removing the surplus. WFP’s general  policy, as approved by its executive board, is not to monetize commodities.  Thus WFP requires cash to cover its expenses.  In addition, WFP operates  under a “full cost recovery” policy, which requires that the country making  a donation cover its full cost.  According to USDA’s Office of General  Counsel, if USDA wants to dispose of surplus commodities through WFP, it  may pay associated costs using section 5(d) authority.
Specifically, USDA costs incurred in connection with providing  commodities to WFP under the GFEI program are governed by an  agreement between CCC and WFP that covers matters related to donation  of commodities furnished under section 416(b) during calendar years 2001  and 2002.  Under this agreement, CCC agreed to pay WFP not only ocean  transportation but other authorized expenses incurred by WFP in  connection with distribution of commodities donated to it.  Collectively,  these other authorized expenses include internal transportation, storage  and handling, direct support costs, other direct operational costs, and  indirect support costs, up to the maximum amount approved by CCC.For the GFEI program, these costs amounted to about $35 million.
When USDA requested sponsor proposals for the GFEI pilot program in  September 2000, it said CCC cash funds might also be available to cover  expenses related to implementing activities supported with commodities  acquired under section 5(d) of the CCC Charter Act.  USDA delivered the  same message in a meeting with PVOs to discuss the planned pilot  program.  As a result, most PVOs submitted proposals that were based on  receiving cash to cover some of their expenses. However, in January 2001,  USDA informed PVOs with approved proposals that cash would not be  available to them. Although USDA said it was prepared to adjust  approved sponsors’ proposals to permit greater monetization of  commodities to cover costs, the USDA reversal posed a few problems.  First, monetized commodities cannot be used to cover the sponsors’ direct  U.S. headquarters’ administrative expenses. Second, depending on the  situation in a recipient country, additional monetization of commodities  might risk disrupting commercial sales.  Representatives of one PVO told  us the organization had submitted proposals for two countries where it was  not possible to monetize commodities; therefore, without cash to cover its  expenses, the PVO could not go forward. Several PVOs were also upset  because they felt that USDA was providing preferential treatment to WFP.
USDA noted that its long-standing policy for section 416(b) projects was  not to provide cash to PVOs unless the country is deemed urgent and  extraordinary. It further said that PVOs and WFP were treated differently  because they were fundamentally different in nature and in how they  acquired their funding.  USDA said that whereas PVOs are operated  privately and have access to other funding sources, WFP is governed and  funded only by its donor nations and thus not subject to or constrained by  the limitations of the section 416(b) regulations.  These reasons  notwithstanding, USDA did not explain why it had earlier indicated an  intention to provide cash to the sponsors.
USDA’s policy reversal led to delays in USDA’s negotiating agreements for  implementing approved proposals for a number of PVO projects.  Some  PVOs were not satisfied with the policy change and made their views  known to members of Congress.  Subsequently, in July 2001, the Congress  approved legislation (P. L. 107-20) that included a provision authorizing  USDA to approve use of CCC funds up to about $22.9 million for financial  assistance to sponsors participating in the pilot program.  Funds could be  used for internal transportation, storage, and handling of commodities, as  well administrative expenses deemed appropriate by the secretary of  agriculture.  As a result of the congressional action, USDA agreed to  consider renegotiating agreements that it had already concluded with some  of the PVOs if they so desired.
section_title: Top Food Aid Donating Countries
paragraphs: This appendix provides details on the top food aid donating countries in  recent years. Table 18 lists the top 20 food aid donors based on shipments  for the period 1995 through 1999. Apart from the United States, which  supplied more than half of all deliveries, the other 19 donors provided  about 43 percent of the food assistance during this period.
section_title: Key GFEI Events from Announcement of Concept to Notification of Project Approvals
paragraphs: This appendix outlines key events related to the GFEI pilot from the time  the program was announced until early January 2001, when USDA notified  proposal winners.
As table 19 shows, USDA’s expedited schedule allowed interested  cooperating sponsors at most 8 business days to prepare and submit the  first part of the proposal.  Sponsors who began preparing for the second  part of the proposal at the earliest possible time (i.e., without waiting to  learn whether they qualified to do so), had a maximum of 18 business days  to complete and submit it to USDA.
section_title: Comments from the U.S. Department of Agriculture
subsections: section_title: GAO Comments
paragraphs: 1.
USDA noted that GFEI has three purposes – to improve student  enrollment, attendance, and performance, but indicated it is not  possible to improve learning in a 1-year pilot program.  According to  USDA, GAO evaluated USDA against an unrealistic standard—  performance—rather than the objectives of enrollment and attendance.  In addition, USDA said, a much longer time frame would be required to  address all of the factors mentioned in the report (examples cited  include teacher training, infrastructure, learning materials, health and  nutrition programs, and community involvement). We disagree with  USDA’s statements for two reasons. First, our conclusion is that school  feeding programs are more likely to improve enrollment and  attendance, as well as learning, if they are carefully integrated with  other key factors and interventions. Second, we conclude that the pilot  program could have been improved by determining in advance which  proposals were for communities where key factors were already in  place or would be addressed during the projects themselves.
2.
USDA disagreed with our statement that USDA lacked expertise in  managing development and humanitarian assistance such as food aid.  We have revised  that statement to specify expertise in food for  education development programs. At the same time we note that a  recent USDA study of its food aid monetization programs cited  difficulty evaluating the programs’ impacts because of limited  personnel resources, high staff turnover, and increasing demands to  implement large food aid programs. In addition, the limited presence of  overseas agricultural attaches has adversely affected USDA’s ability to  oversee some of its sponsors’ monetization projects, the study said.  USDA’s Inspector General has also expressed concern about this  matter.
3.
USDA said it believes that GAO’s comparisons between the proposals  and the recommended program elements understate the quality of the  GFEI programs, since the proposal is only the beginning text of a  negotiated contractual process. We focused on the proposal process to  determine to what extent USDA secured information for judging and  selecting proposals that offered greater promise of improving school  enrollment, attendance, and learning.
4.	 Regarding differences in the treatment of PVOs and WFP, USDA  reiterated (as discussed in our draft report) that the United States sits  on the WFP Executive Board, which approves all projects.  However,  executive board approval does not mean that the United States may not  have concerns about a particular project. As USAID advised, even when  the United States concurs with an executive board decision to approve  a project, the United States frequently states its concerns or  reservations about the feasibility or sustainability of program activities  and, according to USAID, has done so in the case of school feeding  projects. USDA also said it is confident that the information submitted  by WFP contains the required information listed in the Federal Register  notice or the regulations governing USDA food assistance programs.  However, WFP did not have to address requirements of the Federal  Register notice; the notice did not require as much information as we  believe would have been useful for evaluating proposals; and USDA’s  416(b) regulations did not include specific information requirements  for assessing food for education programs.  5.	 USDA indicated agreement with our finding that analysis of the  disincentive effects of food aid projects should include the impact of  commodity donations on alternative food commodities. USDA said  doing so could improve analyses and be a goal for future projects. At  the same time, USDA said it stands by the pilot project assessments  that significant market disruptions will not occur—even though such  analysis was not conducted.
Our report notes that cooperating sponsors are responsible for analyzing  the potential disincentive effects of their projects and that USDA does not  independently verify the results of such analyses.  In addition, we noted  that USDA officials acknowledged that because PVOs want to provide the  food aid, these organizations may not be completely unbiased in preparing  analyses of disincentive effects. In its letter, USDA said the latter statement  is correct but in the opposite direction suggested by GAO. According to  USDA, PVOs are going to more rigorously analyze the food needs of an  area, because program success depends upon community support, which is  not going to occur if markets are disrupted. We agree that the latter is one  possible interpretation of the statement and therefore removed the  statement from the letter.
section_title: Comments from the U.S. Agency for International Development
section_title: Comments from the Office of Management and Budget
section_title: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Acknowledgments
paragraphs: In addition to those named above, Gezahegne Bekele, Janey Cohen, Stacy  Edwards, Mary Moutsos, and Rolf Nilsson made key contributions to this  report.
section_title: GAO’s Mission
paragraphs: The General Accounting Office, the investigative arm of Congress, exists to  support Congress in meeting its constitutional responsibilities and to help improve  the performance and accountability of the federal government for the American  people. GAO examines the use of public funds; evaluates federal programs and  policies; and provides analyses, recommendations, and other assistance to help  Congress make informed oversight, policy, and funding decisions. GAO’s  commitment to good government is reflected in its core values of accountability,  integrity, and reliability.
section_title: Obtaining Copies of GAO Reports and Testimony
paragraphs: The fastest and easiest way to obtain copies of GAO documents is through the  Internet. GAO’s Web site (www.gao.gov) contains abstracts and full-text files of  current reports and testimony and an expanding archive of older products. The  Web site features a search engine to help you locate documents using key words  and phrases. You can print these documents in their entirety, including charts and  other graphics.
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subsections: section_title: Order by Mail or Phone
section_title: Visit GAO’s Document Distribution Center
section_title: To Report Fraud, Waste, and Abuse in Federal Programs
paragraphs: Web site: www.gao.gov/fraudnet/fraudnet.htm, E-mail: fraudnet@gao.gov, or 1-800-424-5454 or (202) 512-7470 (automated answering system).
section_title: Public Affairs