Veterinarian Workforce: Actions Are Needed to Ensure Sufficient Capacity for Protecting Public and Animal Health
Released: 2009-02-18T00:00:00

Letter

Background

High-performing public organizations have found that maintaining a quality workforce requires them to systematically assess current and future workforce needs and formulate a long-term strategy to attract, retain, develop, and motivate employees. While simple in theory, strategic planning can be difficult to carry out. Managers must, for example, acquire accurate information on the workforce, set goals for employee performance, and develop ways to measure that performance. According to our previous work, strategic workforce planning should involve certain key principles. Among these principles is the need to involve top management, employees, and other stakeholders in developing, communicating, and implementing a strategic workforce plan. Other principles include determining the critical skills that will be needed, developing strategies to address any gaps in these skills, building the capability needed to address educational and other requirements important to support workforce planning strategies, and monitoring and evaluating progress toward workforce goals. However, federal agencies have for years lacked a strategic approach to workforce management. Consequently, since 2001, we have identified human capital management as a high-risk area needing urgent attention and transformation.

OPM provides information and guidance on a wide range of strategies that departments and agencies can use to help strategically plan for and maintain a workforce sufficient to accomplish their missions. This includes standard retention and recruitment payments, such as recruitment incentives and student loan repayments. OPM can also authorize departments to use additional strategies to address workforce shortage situations should standard strategies prove insufficient. For example, OPM can approve higher salaries for individual positions in an occupation if the agency has difficulty staffing a position requiring an extremely high level of expertise that is critical to the agency’s successful accomplishment of an important mission.

In addition to maintaining a workforce sufficient for routine functions, departments and agencies are directed by the President to ensure they can carry out essential functions during a “catastrophic event.” Such a catastrophic event is any natural or man-made incident, including terrorism, that results in extraordinary levels of mass casualties, damage, or disruption severely affecting the population, infrastructure, environment, economy, national morale, and/or government functions. To do so, agencies must develop continuity of operation plans for emergencies that disrupt normal operations. Continuity planning includes identifying and establishing procedures to ensure vital resources are safeguarded, available, and accessible to support continuity operations. Vital resources are personnel, equipment, systems, infrastructures, supplies, and other assets required to perform an agency’s essential functions. DHS’s Federal Emergency Management Agency (FEMA) provides direction to the federal executive branch for developing continuity plans and programs, including pandemic plans.

For one type of catastrophic event, a pandemic that severely reduces the workforce, DHS has developed guidance that identifies specific elements agencies should consider as they plan to maintain essential services and functions. FEMA concluded that planning for a pandemic requires a state of preparedness that goes beyond normal continuity of operations planning. On March 1, 2006, FEMA first issued guidance to assist departments and agencies in identifying special considerations for protecting the health and safety of employees and maintaining essential functions and services during a pandemic. The Implementation Plan for the National Strategy for Pandemic Influenza recommends that organizations plan for a 40 percent absenteeism rate at the height of a pandemic. In addition, it called for department and agency pandemic plans to be completed by March 31, 2006.

Departments and agencies must also plan for other events that could place extraordinary demands on their workforce, such as a catastrophic outbreak of a foreign animal disease. In December 2003, the President issued a Homeland Security Presidential Directive (HSPD-8) to establish national policy to strengthen the preparedness of the United States to prevent and respond to terrorist attacks, major disasters, and other emergencies. As part of its efforts to meet HSPD-8, a White House Homeland Security Council working group developed National Planning Scenarios for 15 major events, including a biological attack with a foreign animal disease, foot-and-mouth disease. According to the scenario, terrorists introduce the disease in several locations and states simultaneously. The transportation of livestock spreads the contagious virus to surrounding states and, within 10 days of the attack, more than half of the states may be affected. Ultimately, almost half the nation’s beef, dairy, and swine would be affected. These scenarios serve as the basis for assessing the nation’s preparedness for such an event by defining tasks that may be required and the capabilities needed governmentwide to perform these tasks. Although not a prescription for the resources needed to achieve these capabilities, they are intended to help identify such resource needs and guide planning efforts. No single jurisdiction or agency will be expected to perform every task, so the response to a catastrophic event will require coordination among all levels of government. State and local agencies are typically the first to respond, but federal agencies become involved if state resources are overwhelmed. In certain catastrophic events, it becomes the responsibility of DHS to coordinate the federal response.

The Federal Government Lacks a Comprehensive Understanding of the Sufficiency of Its Veterinarian Workforce

Four of the five key agencies that employ veterinarians—APHIS, FSIS, ARS, and Army—regularly assess the sufficiency of their veterinarian workforces for routine program activities, and all four identified existing or potential shortages. FDA does not perform such assessments. At the department level, USDA and HHS have not assessed their veterinarian workforces across their component agencies, whereas DOD has delegated this task to the Army. Finally, there is no governmentwide assessment of the veterinarian workforce. Specifically, OPM has not conducted a governmentwide effort to address current and future veterinarian shortages identified by component agencies, and efforts by the Congress to address the national shortage have thus far had minimal impact.

Four of Five Agencies Have Identified Existing and Potential Veterinarian Shortages

APHIS, FSIS, ARS, and Army conduct regular workforce assessments. While APHIS reported it does not currently have a shortage, it identified a potential future shortage. FSIS, ARS, and Army have identified both existing and potential future shortages. FDA does not conduct such assessments, but officials there told us the veterinarian workforce is adequate to meet its responsibilities. Our work has shown that agencies should be held accountable for the ongoing monitoring and refinement of human capital approaches to recruit and hire a capable and committed federal workforce.

APHIS reported that none of its six units that employ veterinarians has identified a current shortage, but officials told us they are concerned about the future size and skills of the veterinarian workforce. First, the agency reported that 30 percent of its veterinarians will be eligible to retire by the end of fiscal year 2011, potentially creating a serious shortage. This is consistent with our previous work where we reported that one-third of federal career employees on board at the end of fiscal year 2007 are eligible to retire between spring 2008 and 2012. In addition, APHIS is concerned that it will be unable to maintain an adequate workforce of veterinary pathologists. This is consistent with a report by the United States Animal Health Association, which found a shortage of over 40 percent nationwide. An APHIS laboratory director told us that veterinary pathologists are integral to work conducted in APHIS diagnostic laboratories, including work on diseases that threaten animal and human health. For example, APHIS veterinary pathologists work on bovine spongiform encephalopathy, a fatal degenerative disease—commonly known as mad cow disease—that has been linked to at least 165 human deaths worldwide. APHIS also identified a need to maintain a veterinarian workforce with sufficient expertise to help protect livestock and the nation’s food supply from foreign animal diseases. We reported in 2005 that many U.S. veterinarians lack the training needed to identify such diseases, whether naturally or intentionally introduced. Finally, after the terrorist attacks of 2001, USDA’s responsibilities were broadened to enhance the ability of the United States to manage domestic incidents. As such, in addition to being the lead for coordinating any response efforts to incidents involving an animal disease, APHIS will now also play a supporting role in incidents not directly related to animal diseases. For example, APHIS veterinarians may be called upon to assist in ensuring the safety and security of the commercial food supply or for caring for livestock stranded in hurricanes and floods. These increased responsibilities raise concerns about the ability of veterinarians to respond to multiple, simultaneous events, according to agency officials.

APHIS has supported training opportunities to help overcome some of these projected skill gaps. The agency has also set a goal of recruiting at all veterinary colleges and working with universities to help them include relevant training in their course offerings. In addition, APHIS uses bonuses to attract and maintain its veterinarian workforce. During the first 9 months of fiscal year 2008, it provided one retention and one relocation bonus to veterinarians, totaling $41,654.

Over the past decade, FSIS has not had a sufficient number of veterinarians and remains unable to overcome this shortage, according to FSIS officials. The agency’s goal was to have 1,134 veterinarians on staff in fiscal year 2008, but it fell short of that by 166 veterinarians, or 15 percent. Moreover, since fiscal year 2003, the FSIS veterinarian workforce has decreased by nearly 10 percent—from 1,073 to 968. The majority of these veterinarians work in slaughter plants. Federal law prohibits slaughtering livestock or poultry at a plant that prepares the livestock or poultry for human consumption for use in interstate commerce unless the animals have been examined by USDA inspectors and requires the humane slaughtering and handling of livestock at such plants. In implementing federal law, each slaughter plant is covered by one or more FSIS veterinarians to, among other things, ensure the safety and quality of meat and poultry products and the humane treatment of livestock during slaughter. Agency data from the past 5 years reveal that vacancy rates for veterinarian positions in slaughter plants vary by location and year, from no vacancy to as many as 35 percent of the positions vacant.

FSIS headquarters officials and veterinarians working in slaughter plants differed on the impact of this shortage. Headquarters officials told us that, despite the shortage, the agency has been able to meet its food safety and other responsibilities by redistributing the workforce. For example, in some cases, FSIS has assigned one veterinarian to several slaughter plants or assigned only one to plants that previously had two. In contrast, several veterinarians working in slaughter plants told us that, because of inadequate staffing, they are not always able to meet their responsibilities and perform high-quality work. For example, veterinarians told us they cannot always verify crucial sanitation and security checks of the plant or promptly log data on animal diseases and welfare.

In early 2008, veterinarians also told us they did not always have time to ensure the humane treatment of livestock. Inhumane treatment triggered an investigation that led to the largest beef recall in U.S. history. More specifically, in February 2008, the Humane Society of the United States released videos to the public that documented abuse of cattle awaiting slaughter at a plant in Chino, California. These alleged abuses, which took place in the fall of 2007, included electrically shocking nonambulatory “downer” cattle, spraying them with high-pressure water hoses, and ramming them with a forklift in an apparent attempt to force them to rise for slaughter. These acts are not only cruel, they pose a risk to the safety of the food supply, because downer animals are known to be at greater risk for bovine spongiform encephalopathy. FSIS regulations require that downer cattle be separated to await disposition by an inspector, even if they become nonambulatory after an inspector has approved the animal for slaughter during the preslaughter inspection. On February 1, 2008, the plant voluntarily ceased operations pending investigation by FSIS into the alleged abuses. On February 17, 2008, the plant announced that it was voluntarily recalling approximately 143 million pounds of raw and frozen beef products because of its failure to notify FSIS of the downer cows and the remote possibility that the beef being recalled could cause adverse health effects if consumed. The release of the videos by the Humane Society led congressional committees and USDA to question how such events could have occurred at a plant in which FSIS inspectors were assigned. At the request of the Secretary of Agriculture, USDA’s Office of Inspector General (OIG) is leading a criminal investigation that is ongoing at the time of this report. In addition, OIG conducted an audit of FSIS’s controls over preslaughter activities and reported in November 2008 that controls to demonstrate the sufficiency and competency of FSIS’ personnel resources could be strengthened to minimize the chance that such events could recur, among other things.

Veterinarians and other FSIS officials we interviewed told us that, at the time of the incident, only one veterinarian was assigned to the plant that was the source of the recall, whereas two had been assigned in past years. Two veterinarians were needed, according to these officials, because the plant processed “cull” dairy cows, which are no longer used for milk production. These cows are generally older and in poorer condition than other livestock and thus require more frequent veterinary inspection. In the wake of this incident, FSIS required veterinarians to spend more time verifying the humane treatment of animals. However, veterinarians told us that this exacerbated the difficulty of completing their other work. In 2004, we made recommendations aimed at ensuring that FSIS can make well- informed estimates about the inspection resources—including veterinarians—needed to enforce the Humane Methods of Slaughter Act of 1978. Specifically, we recommended that FSIS periodically assess whether the level of resources dedicated to humane handling and slaughter activities is sufficient, but the agency has yet to demonstrate that they have done so.

FSIS officials told us that there are several reasons for the agency’s ongoing shortage of veterinarians. For example, most veterinarians do not want to work in the unpleasant environment of a slaughterhouse. Furthermore, veterinarians are trained to heal animals, but FSIS veterinarians are hired to oversee the slaughter of animals. The job can also be physically and emotionally grueling, and many of the plants are in remote and sometimes undesirable locations. In addition, as a result of staff shortages, there is little opportunity to take time off for training that could lead to promotion. Finally, FSIS veterinarians told us that their salaries do not sufficiently compensate for the working conditions and are low relative to those of other veterinarians. According to OPM’s Central Personnel Data File, the mean annual salary for FSIS veterinarians in 2007 was $77,678; in contrast, the mean salary for private-practice veterinarians was $115,447 in 2007, according to the most recent data from the American Veterinary Medical Association. In commenting on a draft of this report, FSIS officials added that there is a lack of public health and food-safety emphasis in veterinary schools.

FSIS has taken several steps to address the shortage. For example, it awarded 35 recruitment bonuses totaling more than $583,000 in the first 9 months of fiscal year 2008. FSIS also has internship programs that have, according to agency officials, increased awareness and generated interest in veterinarian work at the agency. For example, over the past 5 years, FSIS has established agreements with 16 veterinary schools to provide volunteer training opportunities to veterinary students with an interest in food safety and public health. In fiscal year 2008, there were 26 participants in the program, compared with only 1 when the program began in 2003. Two participants have thus far returned to FSIS for full-time employment after graduation. FSIS also has a paid veterinary student program that is designed to provide experience directly related to the student’s educational program and career goals. Since 2002, when FSIS began tracking this program, 77 students have participated, and 6 have become full-time employees. In addition, FSIS has sought special hiring authorities from OPM. For example, in July 2008, the agency was delegated authority to hire a limited number of retirees at full salary instead of at the reduced salary required for those with annuity income. Officials told us they hope this will encourage retired veterinarians to join FSIS, but, as of the date of this report, no retirees have been hired through this program. FSIS intends to track the effectiveness of this special hiring authority. Moreover, FSIS has proposed implementing a demonstration project that would allow the agency to test a pay system that offers more competitive salaries to veterinarians, among others. OPM requires that agencies undertaking such a project provide OPM with an analysis of the impact of the project results in relation to its objectives. OPM officials told us the project may be implemented in July 2009. Finally, OPM has in the past granted FSIS the ability to make immediate job offers to veterinarians without following prescribed competitive procedures, which can slow the hiring process. This “direct-hire authority” expired in 2007 and was not renewed at that time because, according to FSIS officials, USDA did not provide the expiration notification to FSIS. We were recently informed that USDA received approval from OPM on November 25, 2008, for direct hire for FSIS veterinarians lasting through December 31, 2009. However, FSIS officials raised concerns about the length of time of the authority, among other things, stating that it takes 5 to 6 months to renew this authority.

ARS employed 57 veterinarians in fiscal year 2008, 12 percent short of its goal of 65. It has reported similar shortages throughout the last 5 years. Although veterinarians represent a small share of the ARS workforce (about 1 percent of more than 4,300 scientists and research technicians), the agency considers them critical to its mission. According to ARS officials, a sufficient veterinarian workforce is important to the quality and breadth of research ARS is able to conduct. For example, ARS would not have been able to conduct its research on the detection of avian influenza and development of vaccines against it, or on the transmission of bovine tuberculosis, without its veterinarians’ skills and experience.

ARS officials told us it is difficult to attract and retain veterinarians because the agency requires its research veterinarians and senior program leaders who are veterinarians to have a Ph.D. in animal sciences or a related field, as well as a veterinary degree, and there is a limited pool of candidates for these positions. A recent report by the National Academy of Sciences identified a declining interest in veterinary research among veterinary students as a cause of a shortage of Ph.D. veterinarians. In addition, ARS officials told us the agency cannot compete with many of the salaries offered in the private sector. In 2007, the mean salary for ARS veterinarians was $102,081, according to OPM’s Central Personnel Data File. This is about $28,000 less than the mean salary reported by the American Veterinary Medical Association for veterinarians with a Ph.D. working at universities and colleges and about $96,000 less than those working in industry with similar qualifications, such as at pharmaceutical companies.

To address its shortage of Ph.D. veterinarians, ARS provided six recruitment or retention bonuses to its veterinarians totaling $48,313 in the first 9 months of fiscal year 2008. The agency also created a tuition program in 2003, but participation has been limited. Only four individuals have been hired through the tuition program, and only two remained with the agency, according to officials. Under this program, ARS hires veterinarians without a Ph.D. and pays tuition and other educational costs while they earn this degree. Officials told us that the lack of success is most likely due to low salaries at ARS. In addition, the agency is reluctant to use this program because it diverts funding from the hiring of employees already qualified and ready to work.

Army

The Army reported that it filled its 446 authorized active-duty veterinarian positions, but that its veterinary reserve corps is not at full strength. Specifically, the Army only filled 173 of its 197 reserve positions in fiscal year 2008, a 12 percent shortage. According to the Army’s analysis, the reserve corps has been at less than full strength since fiscal year 2005. These veterinarians commit to part-time training and to being deployed to full-time active duty when needed. The shortage means there is not a sufficient pool of veterinarians that can be called into active duty as the need arises. This is a concern, according to the official responsible for assessing Army veterinarian workforce needs, because the Army’s need for veterinarian services is increasing due to growing concerns over bioterrorism, intentional contamination of the food supply, emerging zoonotic diseases, and due to operational requirements, such as agricultural reconstruction in Afghanistan and Iraq, among other things. This official told us that recruitment into the reserves has been a problem because of the length, frequency, and uncertainty of deployments, which, in some cases has also resulted in veterinarians losing their jobs or suffering financial hardships. However, he told us that recent changes to the reserve corps program—such as decreasing the length of deployment from 1 year to 180 days, and making additional incentives available to veterinarians in the reserves—have helped strengthen the capacity of the veterinary reserve corps.

Officials also told us they are concerned about a growing need for certain special veterinary skills. For example, there is an increasing demand for Army veterinary pathologists, who are essential for interpreting test results from animals used in drug and vaccine research. The official responsible for assessing Army veterinarian workforce needs told us the Army has yet to formally assess this need. Other Army veterinarians conduct medical intelligence work for DOD’s Defense Intelligence Agency, where officials told us they are concerned about the difficulty of recruiting veterinarians with appropriate skills to meet a growing need to, among other things, collect and analyze data on animal diseases that could be used in a terrorist attack. Veterinarians are important to such work because, according to these officials, the majority of diseases considered to be potential bioterrorism agents are animal diseases that could also affect humans. They told us that while the agency is working to expand its workforce capabilities to address bioterrorism, there is a concern that the growing demand for veterinarian capabilities may outpace the growth of the Army’s workforce.

The primary reason for the Army’s success in maintaining its active-duty veterinarian workforce is a scholarship program, according to the official responsible for assessing Army veterinarian workforce needs. This program targets veterinary students and pays their tuition and fees to veterinary school in exchange for a commitment to (1) serve as a veterinarian in the Army for 3 years and (2) serve an additional 5 years either in active duty or in the Army reserve program. In fiscal year 2008, the Army reported it had 106 qualified applicants for 47 scholarships. According to the official, the program is successful because it targets students before they accumulate school-related debt. Veterinary students graduate with more than $106,000 in debt, on average, according to the American Veterinary Medical Association. In addition, the funding for this program is directed specifically by congressional committees, separate from funds the Army uses to hire veterinarians.

FDA officials reported that the agency has not assessed the sufficiency of its veterinarian workforce, but they told us that the workforce is sufficient to meet its responsibilities. However, a 2007 report by an FDA Advisory Committee found that FDA cannot fulfill its mission because of an insufficient scientific workforce. More specifically, the report states that FDA’s scientific workforce has remained static while its workload has increased, and that FDA’s Center for Veterinary Medicine (CVM) is in a state of crisis. This center employs nearly two-thirds of FDA’s 152 veterinarians and is responsible for ensuring the safety of veterinary drugs and regulating animal feed, among other things. An author of the report told us that veterinarians enter FDA employment lacking necessary skills and experience to examine the wide variety of veterinary products that require FDA approval and that FDA needs to better train its veterinarians to review the many diverse products under its jurisdiction. FDA officials told us the agency is currently undertaking significant reforms to address fundamental concerns in the report. For example, FDA reported it hired more than 1,000 scientists in order to build a more robust workforce, and it created the position of Chief Scientist to improve coordination of science planning and execution across the agency. However, FDA did not tell us how these reforms address the identified veterinarian skill gaps.

Although FDA officials said the veterinarian workforce is sufficient, CVM officials recently told us that as a result of new obligations, the center hired 26 veterinarians in 2008 to fill vacancies. This represents a 17 percent increase in FDA’s overall veterinarian workforce in 2008, and it plans to hire more. The additional staff will enhance FDA’s ability to review generic animal drug submissions, among other things, according to these officials. In addition, in commenting on a draft of this report, OPM informed us that it is currently reviewing a request for direct-hire authority from FDA to fill veterinary positions. According to OPM, this request is based on a severe shortage of candidates and it is projected that this authority may be granted through December 31, 2010. CVM also plans to develop an internship program for entry-level veterinarians and other scientists in order to develop a qualified talent pool from which to draw permanent employees. Further, these officials said that, as a result of recent participation in interagency efforts to protect the nation’s food supply, CVM has begun to analyze the gap between its current resources and its needs.

Departments Have Done Little to Assess the Sufficiency of Their Veterinarian Workforces across Their Component Agencies

Even though their component agencies identified concerns about their veterinarian workforces, officials from both USDA and HHS told us that they have not undertaken a departmentwide assessment of these workforces to gain a broader perspective on trends and shared issues. In contrast, DOD has a process for such an assessment. Our prior work has found that top-level management needs to be involved in order for strategic workforce planning to be effective.

Although USDA regularly collects veterinarian workforce data from its component agencies that employ veterinarians, it does not use this information to assess the sufficiency of the veterinarian workforce departmentwide. Department officials told us that workforce assessment is the responsibility of the agencies. Because USDA delegates this responsibility, it appears to be unaware of the scope of the workforce problems facing its agencies. For example, in its fiscal year 2007 human capital management report, USDA reported that its agencies had met or surpassed certain veterinarian workforce goals but made no mention of the shortages that FSIS and ARS identified in their workforce reports. USDA officials agreed that the report did not capture this critical information and that future reports should address the shortages.

One result of this lack of department-level involvement is that USDA agencies compete against one another for veterinarians instead of following a departmentwide strategy to balance the needs of the agencies. According to FSIS officials, APHIS is attracting veterinarians away from FSIS because the work at APHIS is more appealing, there are more opportunities for advancement, and the salaries are higher. Indeed, our analysis shows that veterinarians are more concentrated in lower grade levels at FSIS than at APHIS (see fig. 1). Moreover, according to OPM’s Central Personnel Data File, the mean annual salary for veterinarians at FSIS in 2007 was about $78,000, the lowest among the three key USDA agencies (see fig. 2). According to an APHIS human resources official, the agency hired 75 veterinarians from FSIS between fiscal years 2003 and 2007, 17 percent of total new APHIS veterinarians hired.

HHS neither assesses veterinarian workforce needs departmentwide nor has it instructed any of its component agencies that employ veterinarians—FDA, CDC, and the National Institutes of Health (NIH)—to assess their own workforces. HHS is thus not fully aware of the status of the veterinarian workforce at these component agencies and cannot strategically plan for future veterinarian needs. If it were able to provide such planning, it might be able to help FDA address workforce concerns raised in the 2007 FDA Science and Mission at Risk report. However, senior HHS strategic workforce planning officials we spoke with were unaware of the report.

HHS officials told us that departmental leadership in workforce planning is important. In fact, they said the department is in the preliminary stages of developing a strategic departmentwide approach to workforce planning for certain professions. This effort will initially focus on workforce assessments for specific occupations, such as nurses and medical doctors.

HHS officials told us they will not initially include veterinarians in this effort, because veterinarians are not deemed mission critical for the department, even though they are critical to the missions of FDA, CDC, and NIH. However, HHS officials said that this effort does not preclude agencies from assessing their own veterinarian workforce needs and sharing that information with the department. HHS officials also told us that because the department is expected to provide veterinary medical care and support during public health and medical disasters that warrant a coordinated federal response, it is critical that appropriate veterinary resources are identified and maintained. Furthermore, these officials told us that efforts are under way at the component agency level to address the national veterinary shortage. Specifically, CDC, in collaboration with Emory University, has developed a residency program designed to provide comprehensive training in laboratory animal medicine to better prepare veterinarians for working in laboratory research facilities at CDC and across the nation. In addition, in 2006 and 2008 CDC sponsored a “Veterinary Student Day” to promote public health careers for veterinarians.

Unlike USDA and HHS, DOD has a process for assessing veterinarian workforce needs departmentwide. It has given this responsibility to the Army, which employs 89 percent of DOD veterinarians, with the remaining veterinarians working as public health officials for the Air Force. The Army assesses not only the number and type of veterinarians it will need but also what will be needed for the other services. For example, Army veterinarians are routinely assigned to care for working dogs and other animals at Army, Navy, Air Force, and Marine bases. Army veterinarians also conduct medical intelligence activities at the Defense Intelligence Agency. As the executive agency charged with assessing veterinarian workforce requirements for DOD, the Army takes all of these needs into consideration, then forwards the assessment results to DOD, which integrates them with overall workforce planning.

There Is No Governmentwide Assessment of the Veterinarian Workforce

No effort is being made to assess the sufficiency of the veterinarian workforce governmentwide. This is problematic because the majority (67 percent) of the 24 component agencies and other federal entities that employ veterinarians told us they have concerns about their veterinarian capabilities. OPM has not conducted a governmentwide effort to address current and future veterinarian shortages identified by component agencies, as it has done for other professions, and efforts by the Congress to address the national shortage have thus far had minimal impact.

Sixteen of the 24 component agencies and other entities employing veterinarians reported concerns about their veterinarian workforce (see table 1). For example, several agencies reported that they lack veterinarian expertise required to fully meet agency responsibilities, such as addressing wildlife disease outbreaks.

These current challenges are likely to worsen because a large number of federal veterinarians are eligible to retire in the near future. These retirements would exacerbate the veterinarian shortage and possibly increase interagency competition. Our analysis found that 697 veterinarians at FSIS, APHIS, ARS, Army, and FDA—27 percent of the combined veterinarian workforce of these agencies—are eligible to retire over the next 3 years. As the shortage grows, agencies across the federal government may experience a situation similar to the competition between FSIS and APHIS, and agencies with higher salaries for veterinarians are likely to gain an advantage. As figure 3 illustrates, mean veterinarian base salaries vary widely across agencies, from just under $70,000 at Interior’s National Park Service to just about $122,000 at DHS’s Office of Health Affairs. Salaries for individual veterinarians range from $35,000 for those in the residency program at the National Zoo to $205,000 for the highest paid veterinarian at NIH.

Some agencies, such as those within HHS and the Department of Veterans Affairs, can augment base salaries for veterinarians using special statutory authorities. Agencies can use these authorities to hire veterinarians when standard hiring practices, including the use of recruitment incentives, are impracticable, less effective, or have been exhausted. In addition, DOD can provide all of its veterinarians with a $100 per month stipend, as well as up to an additional $5,000 per year of special pay if they have met the education and training standards of an American Veterinary Medical Association-recognized specialty college. There is no similar authority for USDA veterinarians.

OPM’s mission is to ensure the federal government has an effective civilian workforce, but it has not conducted a governmentwide effort to address current and potential veterinarian shortages, as it has done for other professions. For certain professions, OPM has initiated governmentwide direct-hire authority, which allows expediting hiring during a time of critical need or a severe shortage of candidates. For example, in 2003, OPM authorized departments to immediately hire doctors, nurses, and other types of medical professionals without following prescribed competitive procedures. OPM officials told us their agency issued this authority based in part on department and agency concerns. OPM can also hold interagency forums to discuss workforce concerns but has not done so for veterinarians. According to OPM officials, interagency forums are open to all senior human capital representatives from all departments, including USDA and HHS. The forums provide an opportunity to discuss concerns, exchange ideas, and explore solutions to governmentwide staffing issues. OPM officials told us that no department has requested a discussion about veterinarian workforce concerns. Further, officials told us that the agency will facilitate a governmentwide solution, such as an interagency forum, if the departments demonstrate that a shortage exists. Our prior work has identified the need for OPM to use its leadership position to provide assistance to departments and agencies efforts to recruit and retain a capable and committed workforce.

OPM officials told us the agency has taken some steps that could improve veterinarian recruitment and retention. During the course of our review, OPM created a Personnel Action Team to determine whether a governmentwide direct-hire authority should be granted for all veterinarians. OPM did not provide further details other than to state that a decision is expected in early 2009. In addition, OPM recently changed the federal classification of veterinarians. OPM raised the entry grade level for newly hired veterinarians from GS-9 to GS-11 and expanded the description of the federal veterinarian occupation to include areas of specialization, such as toxicology and pathology. OPM officials believe this will help attract more veterinarians into federal service. Agency officials also told us that they meet periodically with departments to ensure occupation classifications meet department needs. This was the first change of the veterinarian classification in over 20 years and was initiated at USDA’s request.

The Congress has taken steps that address the broader, national veterinarian shortage, but its efforts thus far have had minimal impact. The National Veterinary Medical Services Act enacted in 2003, directs the Secretary of Agriculture to carry out a program to help veterinarians repay their school loans when they agree to work in areas of need. Although USDA is responsible for implementing the act, it has been delayed in doing so. USDA’s Undersecretary for Research, Education, and Economics testified before the Congress that this was because the Cooperative State Research, Education, and Extension Service (CSREES)—the USDA agency in charge of implementation—does not have experience with complex loan repayment programs. The Congress provided initial funding for the act in fiscal year 2006. In August 2008, CSREES began holding public hearings to solicit stakeholder input. Officials from USDA and veterinary associations told us that the $1.8 million allocated thus far for the program is insufficient and would have minimal impact on the shortage. With veterinary student debt averaging $106,000 upon graduation, $1.8 million would cover about 17 students with loans. Moreover, the program targets veterinarians who already have their degree and may not have the skill set the federal government is seeking. To be effective, officials from professional veterinary associations told us, the program would have to provide guarantees and target students early in veterinary school. The Congress also enacted the Higher Education Opportunity Act in August 2008, which has provisions intended to increase the number of veterinarians in the workforce through a competitive grant program that can increase capacity at veterinary colleges. According to the American Veterinary Medical Association, however, these grants will be capped at $500,000 per school, which will not be enough to increase capacity to meet veterinarian demands.

Efforts to Identify the Veterinarian Workforce Needed during a Pandemic and Large-Scale Animal Disease Outbreak Are Insufficient

Four of the five key agencies we reviewed—APHIS, FSIS, ARS, and FDA— have plans intended to detail how essential functions and services, including those that veterinarians perform, would continue during a pandemic that has the potential to severely reduce the workforce. However, each lacks elements that FEMA considers important for effective planning. The Army is still in the process of getting its plan approved and, therefore, we have not evaluated it. In addition, DHS’s efforts to identify the veterinarian workforce needed to address a catastrophic nationwide outbreak of foot-and-mouth disease are based on an unrealistic assumption and limited information.

Agency Planning to Ensure Continuity of Essential Veterinary Functions during a Pandemic Is Incomplete

FEMA’s pandemic guidance assists agencies in identifying special considerations for maintaining essential functions and services during a pandemic outbreak that may cause absenteeism to reach 40 percent. For example, the guidance directs agencies to identify in their pandemic plans how operations will be sustained until normal business activity can be reconstituted, which may be longer than the 30 days usually planned for other types of emergencies. Agency plans are also to identify the essential functions that must be continued on-site and those that can be conducted from a remote location. They also should take into consideration the need for logistical support, services, and infrastructure that help an agency achieve and maintain essential functions and services. To account for the expected high rate of absenteeism at the peak of a pandemic, FEMA guidance also directs agencies to identify at least three people who can carry out each responsibility and identify how the agency will continue to operate if leadership and essential staff are unavailable. Finally, agencies are directed to test their pandemic plans, including the impacts of reduced staffing on facilities and essential functions and services.

APHIS has developed pandemic plans for its headquarters, regional offices, and three laboratories that employ veterinarians, but these plans are missing elements in FEMA’s guidance and are not well-organized. For example, they do not explain how animal care, disease investigation, and other essential functions and services would continue if leadership and essential staff are unavailable. Moreover, pieces of these pandemic plans are spread throughout a large number of documents and are not well linked. For example, APHIS officials provided us with an undated pandemic plan that they told us was an appendix to the headquarters continuity of operations plan. But this continuity of operations plan made no reference to such an appendix, and officials were never able to provide us with a document that made reference to such an appendix. USDA recently hired a new emergency preparedness director to revise APHIS’s pandemic plans, among other things. The director told us that APHIS recognizes the importance of easily locating the plans and quickly implementing them in the event of a pandemic, and he acknowledged that the current documents are not an effective plan. APHIS is now combining its plans into one comprehensive document that will cover APHIS headquarters, regional offices, and laboratories. In addition, the director told us the new plan, to be completed by early 2009, will better adhere to FEMA guidance.

FSIS has developed a pandemic plan that addresses many of the elements in FEMA’s guidance, but it lacks some crucial details. Importantly, the plan takes into account the work that veterinarians do at private slaughter plants. However, it does not address the logistics of how FSIS will work with industry to ensure veterinarians and other employees are available in the event of a pandemic so that food production can continue. FSIS officials told us that they have discussed this logistic with industry and expect, based on these discussions, that some plants would not be able to operate during a pandemic, as a result of FSIS or plant personnel absenteeism. The agency would maintain close communication with industry during a pandemic in order to determine how best to allocate available veterinarians and other FSIS inspection personnel so that slaughter plants could continue to operate. Veterinarians would be allocated to plants based on considerations such as the location of the outbreak and the type of slaughter plant affected. For instance, poultry plants may receive priority consideration because birds can only be slaughtered at a very specific weight. That is, the equipment for processing birds is designed for birds of a very specific size, and industry would not be able to process them if they were permitted to grow too large. However, such logisitcs are absent from FSIS’s plan, effectively postponing any decisions until the middle of a crisis. Similarly, the plan does not mention how FSIS would work with APHIS, even though the agencies have formally agreed to jointly plan for critical activities related to surveillance of animal diseases. In addition, the plan does not consider the impact of local quarantines on access to plants.

ARS has developed pandemic plans for all of its 12 laboratories where veterinarians work. We reviewed plans for the two laboratories that employ the most veterinarians: the Southeast Poultry Research Laboratory and the National Animal Disease Center (NADC). These plans are important because they spell out the site-specific details needed to ensure that essential functions at each laboratory can continue. However, the plans lack crucial details, such as how the laboratories will continue operations if absenteeism reaches 40 percent. Specifically, neither of the plans take into account how the laboratories would continue to conduct essential functions and services if leadership and essential staff are unavailable. Agency officials told us they would temporarily suspend projects to account for increased absenteeism, but there is no mention of this in the plans; nor is there mention of how the agency will select projects for suspension or what would trigger suspension. Ensuring a sufficient veterinarian workforce at these laboratories during a pandemic is important because veterinarians carry out critical research and must be available to ensure the proper care of research animals. In addition, NADC is part of a USDA research complex that is transitioning to joint ARS and APHIS support services, including veterinary care for research animals. However, ARS and APHIS have yet to jointly plan for continuity of operations for any type of emergency.

FDA has also developed a pandemic plan, but it is high-level plan that does not address several of FEMA’s elements, leaving it unclear if consideration has been given to how veterinarians would carry out any essential functions and services during a pandemic. For example, it does not identify which essential functions—whether they be the responsibility of the veterinarian or others—must be performed on-site and which can be performed remotely. Nor does it explain how veterinarians, or others, will continue operations if absenteeism reaches 40 percent by, for example, delegating authority to three individuals capable of carrying out each of the agency’s essential functions. The plan omits other important details, such as contact information for individuals who could assume authority should essential staff and leadership become unavailable. FDA officials told us they will take these gaps into consideration when they update their plan in 2009.

The Army is still in the process of getting its pandemic plan approved and, therefore, we have not evaluated it. According to Army officials, the agency has developed a pandemic plan that has been validated by the U.S. Army Northern Command, but it has not yet been formally referred for approval to the Army’s senior leadership, and it does not contain details of how essential functions would continue. According to DOD officials, subordinate divisions within the Army intend to develop detailed plans, but the division responsible for veterinary services (Veterinary Command) has yet to do so. However, DOD officials told us that the Army has been instrumental in helping the United States plan for an outbreak of highly pathogenic avian influenza in birds. Controlling the outbreak in birds reduces the opportunity for the virus to mutate into a strain that could cause a pandemic in humans.

FEMA guidance also directs agencies to test how well their pandemic plans might maintain essential functions and services given reduced staffing levels. FSIS and FDA are the only agencies we reviewed that have done so. In March 2007, FSIS conducted a “tabletop” pandemic exercise where key personnel discuss simulated scenarios in an informal setting in order to test their plans, policies, and procedures. In a summary report, FSIS officials noted that, among other things, additional exercises were needed to improve coordination with industry. FSIS subsequently conducted a similar tabletop exercise with industry in November 2008, but the summary report on lessons learned has yet to be published. FDA conducted an operational exercise in October 2008—a drill to test how well it could continue operations under a staffing shortage. As part of this exercise, FDA tested its ability to reassign tasks, but it is not clear if tasks performed by veterinarians were among those reassigned. FDA officials told us that they plan to issue a report with lessons learned from the exercise in early 2009 and will incorporate that information into FDA’s pandemic plan. ARS and APHIS have not tested their plans to see how well their agencies might maintain essential functions and services in the event of reduced staffing levels, but officials told us they intend to do so.

An Infeasible Assumption and Limited Information Hinder Veterinarian Workforce Planning Efforts for a Catastrophic Outbreak of Foot-and- Mouth Disease

DHS has two efforts under way that involve identifying the veterinarian workforce needed to quickly perform rapid diagnoses and other essential activities during a large-scale outbreak of foot-and-mouth disease, but both efforts have shortcomings. The first is a long-term national effort that DHS is coordinating to assess the nation’s preparedness for multiple, intentional introductions of foot-and-mouth disease. This effort includes identifying the veterinarian workforce and other capabilities that would be needed to best respond to such an outbreak. For example, it has identified the need for 750 veterinarians nationwide to conduct animal health epidemiological investigations and surveillance. It has also identified the need for teams of six livestock and six companion animal veterinarians in each affected state and local jurisdiction to implement disease containment measures, provide animal welfare, and euthanize and dispose of animals.

However, this effort is based on a national planning scenario that USDA and DHS officials’ say includes an infeasible assumption. The scenario, developed by a White House Homeland Security Council working group in 2006, involves the mass slaughter of all potentially exposed animals. This “stamping out” method is the same one the United States has used in the past for eradicating smaller outbreaks of foreign animal diseases, but under this scenario, it would result in the slaughter of almost half the nation’s beef, dairy, and swine. DHS and USDA officials, as well as state officials who have conducted large-scale foot-and-mouth disease exercises, consider this stamping out method infeasible because, among other things, it would lead to serious logistical and environmental concerns, would not be tolerated by the public, and could wipe out a viable livestock industry. As a result, DHS and USDA officials told us, any workforce estimates produced from this effort are not relevant. However, these officials told us it has helped them better understand the enormity of the workforce response and the coordination that would be required for such a catastrophic event.

DHS and USDA officials told us that to arrive at more relevant workforce estimates, the United States would have to consider alternatives to stamping out for outbreaks as large as the one depicted in the national planning scenario. For example, some countries protect against and control foot-and-mouth disease using vaccines. There are numerous reasons the United States has not used this approach, including limitations to vaccine technology. However USDA, DHS, and state officials recognize that newer, more promising vaccines may play an important role in controlling a catastrophic outbreak. DHS officials also told us that they are looking into revising the Homeland Security Council’s planning scenario to make it a more useful planning tool.

For its second effort to identify the veterinarian workforce needed during a foot-and-mouth disease outbreak, DHS has contracted with the Department of Energy’s Lawrence Livermore National Laboratory to create a decision support system that models various foot-and-mouth disease outbreak scenarios. This effort includes estimating the number and type of workforce needed for responding to outbreaks, both with and without vaccination. However, according to the project leader, modeling efforts could be improved if certain information were available. For example, in order to model workforce needs for a response that includes the use of vaccines without subsequent stamping out, known as “vaccinate to live,” it is important to know what segments of the livestock industry might use such a strategy, and under what circumstances, and how animals and animal products would be identified and their movement tracked. Because the concept of vaccinate to live is new in the United States, USDA has yet to detail in contingency response plans how it would employ this concept, according to agency officials. In the absence of such plans, the project leader, a veterinarian who took part in the response to the 2001 United Kingdom foot-and-mouth disease outbreak, told us that she is left to base her modeling assumptions on personal knowledge and experience, as well as conversations with agency subject matter experts.

Moreover, data limitations make it difficult for any computer modeling effort to accurately predict the spread of the disease. Specifically, modelers must estimate the number and location of animals, as well as their interaction with other segments of industry, because the United States does not have a mandatory, national system that identifies the location and tracks the movement of livestock. Instead, modelers currently use outdated county-level data from USDA’s National Agricultural Statistical Survey census, reducing the accuracy of predictions about the spread of foot-and-mouth disease. Also, without knowing the exact location of livestock, it is difficult to understand the interaction between livestock and wildlife. Limited data and information on the number and movement of wildlife and the susceptibility of wildlife populations to the virus further complicates matters, according to agency officials. This is an important gap, since foot-and-mouth disease has been known to spread from livestock to wildlife in past outbreaks. In fact, the last time the United States had an outbreak was in California in the 1920s, when the virus spread from pigs to cattle and black-tailed deer. It took 2 years and the slaughter of 22,000 deer to eradicate the disease from a local deer population in one national park. In areas where livestock graze extensively, there is potential for interaction with susceptible species, such as deer and feral pigs. According to the project leader, as well as USDA and DHS officials, control and eradication strategies would be greatly complicated if wildlife became infected and could require more veterinarians and different expertise. Given the important role wildlife can play in disease outbreak, officials agree it is important to better understand the interaction between livestock and wildlife. In fact, new technologies, such as global positioning systems, have been developed that can, for example, help determine the number and movement of animals, making it possible to gather this type of data, according to a USDA Wildlife Services official. A DHS official told us that, as a first step, it would be important for those agencies with responsibility for overseeing the health of humans, wildlife, and livestock to discuss how wildlife data can be gathered to most accurately model the spread of disease in wildlife.

Federal and State Agencies Are Missing Important Opportunities to Ensure Efficient Use of Veterinarians During Disease Outbreaks

During four recent zoonotic disease outbreaks, the veterinarian workforce challenge cited most often by federal and state officials was having too few veterinarians to control the outbreak while also adequately carrying out other routine activities. Specifically, officials from 3 of 4 federal agencies—APHIS, CDC, and Interior’s U.S. Geological Survey (USGS)— and 9 of 13 state agencies cited this challenge. See table 2 for the 17 agencies that were identified as playing an important role, those that cited insufficient veterinarian capacity as a challenge, and other details about these outbreaks.

Two primary reasons emerged for this insufficient capacity. First, according to federal and state officials, veterinarian capacity was insufficient because most of the agencies involved in the four outbreaks had difficulty recruiting and retaining veterinarians in general. For example, officials at many of the public health agencies and diagnostic laboratories we spoke with said that it has been challenging to hire or retain veterinarians with the specialized qualifications they need—public health and pathology skills, respectively. According to 2008 survey results from the American Association of Veterinary Laboratory Diagnosticians, it takes most diagnostic laboratories more than 6 months to fill vacancies for veterinary pathologists. In addition, numerous state agency officials told us that the salaries they offer are not competitive with those of the federal or private sectors. Moreover, officials told us that it has been particularly challenging recruiting veterinarians to work in remote areas or in areas with a high cost of living.

Second, in 2002 and 2003 many veterinarians went to California to address a particularly demanding outbreak of exotic Newcastle disease, limiting the number of veterinarians available to respond to other outbreaks. The exotic Newcastle disease outbreak quickly exhausted California’s supply of veterinarians, both at state agencies and APHIS, because so many backyard birds—which are kept as a hobby or for personal consumption— were affected. Responders had to spend valuable time going door-to-door trying to locate potentially infected birds in densely populated urban areas. APHIS called in over 1,000 federal, state, and private-sector veterinarians from outside California to help with the response. But, even with a task force of over 6,000, it took almost a year to control the outbreak. Moreover, because so many veterinarians converged on California, the number available to work on the other three outbreaks— located in Michigan, Wisconsin, and Colorado—was insufficient, according to federal and state agency officials. In part because of the strain on veterinarian resources during the four outbreaks, officials from 16 federal and state agencies expressed concern that they will not have sufficient veterinarian capacity for multiple outbreaks in the future. FDA assisted in one of the four outbreaks and was the only agency not to express concerns about veterinarian capacity. Some federal officials said that the United States has never been tested with two major outbreaks occurring at once, such as simultaneous outbreaks of foot-and-mouth disease and highly pathogenic avian influenza—two highly infectious foreign animal diseases. They said that should this happen, the effects on animal and public health could be devastating.

Federal and state agency officials reported several consequences of this insufficient veterinarian capacity. Examples are as follows: Michigan state agency officials told us they had trouble testing enough cattle during the bovine tuberculosis outbreak. Over a 6-1/2 year period, veterinarians struggled to test more than a million cows—an average of more than 3,500 a week—but the state has yet to eradicate the disease.

Some Michigan officials told us that APHIS and the Michigan Department of Agriculture did not have enough veterinarians to both respond to bovine tuberculosis and address other animal diseases, such as E. coli. In fact, during all four outbreaks, veterinarians at some point had to delay important work on other diseases, in part because there were not enough veterinarians.

During the 2003 West Nile virus outbreak in Colorado, a lack of sufficient veterinarians to track and control the disease, among other things, may have allowed the virus to infect more people and animals than it otherwise would have.

The volume of work required to control and eventually eradicate exotic Newcastle disease in California physically and emotionally exhausted veterinarians to the extent that, once the outbreak was over, they needed significant time off to recover, further delaying work on routine activities.

The demanding nature of the exotic Newcastle disease and bovine tuberculosis outbreaks may have caused some veterinarians to seek employment elsewhere.

Despite reports of insufficient veterinarian capacity during these four outbreaks, the agencies have not taken full advantage of two important opportunities to learn from past experience. First, 10 of the 17 agencies have not assessed how well their own veterinarian workforces responded to individual outbreaks. Our prior work has shown that agencies can improve response by conducting postoutbreak assessments. One outcome of such an assessment might be a better understanding of how to most efficiently use veterinarians. For example, APHIS—one of the agencies that has performed postoutbreak assessments—found that it had difficulty locating veterinarians with the specialized expertise needed for addressing the exotic Newcastle disease outbreak. As a result, APHIS is developing a national list identifying veterinarians and their credentials to call upon in the future. In addition, federal and state agencies working on bovine tuberculosis in Michigan meet periodically to assess what strategies are working and what they need to change in order to better control the disease. APHIS also conducts periodic reviews of its efforts and the state’s efforts to address bovine tuberculosis.

Moreover, none of the 17 agencies have come together to share their experiences across the outbreaks in order to identify workforce challenges that they may have had in common, including veterinarian workforce challenges. Consequently, the agencies are missing the opportunity to identify and address challenges they are likely to face in the future. The majority of the federal and state agency officials we spoke with agreed that it would be useful for agencies not only to conduct assessments of their own workforce response but also to periodically meet to identify common workforce challenges across multiple outbreaks and discuss strategies for overcoming these challenges. However, some agencies told us that their veterinarian workforce is already facing heavy workload demands that make it difficult for them to meet their existing responsibilities, and thus they have not had time to conduct postoutbreak assessments.

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Veterinarians are a small but vital part of the federal workforce, playing important roles in protecting people from zoonotic and foodborne diseases, ensuring the health and humane treatment of food animals, and helping to keep America’s food system safe. The nation is facing a growing shortage of veterinarians, and component agencies and other federal entities have already identified insufficiencies in their veterinarian workforces. At FSIS, for example, the veterinarian workforce is finding it difficult to adequately carry out its responsibilities for ensuring food safety and the humane treatment of animals. In 2004, we recommended that FSIS periodically assess whether it has enough inspection resources, including veterinarians, dedicated to humane handling and slaughter activities, but the agency has yet to demonstrate that they have done so. Nor has the federal government conducted the broader assessments and planning activities necessary to address veterinarian workforce problems at FSIS and beyond. Unless USDA and HHS conduct departmentwide assessments of their veterinarian workforces, they will not fully understand the size and nature of the challenges they face in recruiting and retaining veterinarians with the appropriate skills. This will leave their component agencies without a high-level solution to problems they have so far been unable to solve on their own. Moreover, without a governmentwide effort to identify shortcomings in veterinarian capabilities, the federal government may be missing opportunities to find common solutions for attracting veterinarians into federal service.

In addition, unless component agencies complete and test their pandemic plans in keeping with FEMA guidance, they will not be fully prepared to carry out essential veterinarian functions in the face of high rates of absenteeism. Until USDA details how responders would control a foot- and-mouth disease outbreak using vaccines, the nation will not have a complete understanding of the veterinarian workforce needed to control such an outbreak. Similarly, until more information is gathered on the spread of foot-and-mouth disease in wildlife, agencies will not be able to more accurately model the number and type of veterinarians that would be needed if the disease were to spread beyond livestock. Failure to understand the workforce needed during a catastrophic event—whether a pandemic or an attack on the food supply—could unnecessarily increase the scope and severity of the crisis. Finally, unless component agencies involved in responding to outbreaks of zoonotic disease regularly review their own performance and collectively assess opportunities for improvement, they cannot be assured they are using veterinarians as efficiently as possible. They are, therefore, more likely to face an insufficient veterinarian workforce capacity during future outbreaks, which may cause an unnecessary increase in the severity of the outbreaks and worsen the threat to public health.

Recommendations for Executive Action

We are making nine recommendations to improve the ability of the federal veterinarian workforce to carry out routine activities, prepare for a catastrophic event, and respond to zoonotic disease outbreaks.

To help ensure the federal veterinarian workforce is sufficient to meet the critical responsibilities it carries out on a routine basis, we recommend that 1. the Secretary of Agriculture direct FSIS to periodically assess whether its level of inspection resources dedicated to food safety and humane slaughter activities is sufficient, and 2. the Secretary of Agriculture conduct a departmentwide assessment of USDA’s veterinarian workforce—based, for example, on workforce assessments by its component agencies—to identify current and future workforce needs (including training and employee development) and departmentwide solutions to problems shared by its agencies. When the Secretary completes the assessment, the results should be forwarded to the Director of the Office of Personnel Management. 3. We also recommend that the Secretary of Health and Human Services direct the department’s component agencies that employ veterinarians to conduct regular workforce assessments and that the Secretary then conduct a departmentwide assessment of HHS’s veterinarian workforce to identify current and future workforce needs (including training and employee development) and solutions to problems shared by its agencies. When the Secretary completes the assessment, the results should be forwarded to the Director of the Office of Personnel Management. 4. Finally, we recommend that the Director of the Office of Personnel Management determine, based on USDA’s and HHS’s departmentwide veterinarian workforce evaluations, whether a governmentwide effort is needed to address shortcomings in the sufficiency of the current and future veterinarian workforce.

To help the veterinarian workforce continue essential functions during a pandemic, we recommend that 5. the Secretaries of Agriculture, Defense, and Health and Human Services ensure that their component agencies that employ veterinarians complete pandemic plans that contain the necessary elements put forth in DHS’s continuity of operations pandemic guidance, including periodically testing, training, and exercising plans.

To improve estimates of the veterinarian workforce needed to respond to a large-scale foot-and-mouth disease outbreak, we recommend that 6. the Secretary of Agriculture detail in a contingency response plan how a response using vaccines would be implemented, and 7. the Secretary of Homeland Security coordinate an interagency effort to identify the data necessary to model the spread of disease in wildlife and how best to gather these data.

To improve the ability of the federal veterinarian workforce to respond to zoonotic outbreaks in the future while also effectively carrying out routine activities, we recommend that the Secretaries of those departments most likely to be involved in response efforts—such as USDA, HHS, and Interior—ensure that their agencies: 8. conduct postoutbreak assessments of workforce management; and 9. in coordination with relevant federal, state, and local agencies, periodically review the postoutbreak assessments to identify common workforce challenges and strategies for addressing them.

Agency Comments and Our Evaluation

We provided a draft of this report to USDA, DOD, HHS, OPM, DHS, and Interior for their review and comment. USDA, DOD, OPM, DHS, and Interior generally agreed with the recommendations. HHS generally concurred with the report but not with one finding we reported regarding FDA’s veterinarian workforce. Also, all departments provided technical comments, which we incorporated as appropriate.

USDA agreed that it should periodically assess whether its level of inspection resources dedicated to food safety and humane slaughter activities is sufficient and believes that FSIS is already doing this assessment as a part of its budget formulation process. However, we made this recommendation in 2004, and are repeating it now, because FSIS has yet to demonstrate that they have done this assessment. USDA also reported that because APHIS and FSIS employ the majority of veterinarians within the department, these component agencies will work together, with departmental consultation, as needed, to develop solutions to shared problems. We continue to believe that a departmentwide assessment is necessary. In addition, the department commented that it will track veterinarian workforce trends and devise strategies to train, recruit, and retain veterinarians in order to mitigate attrition and maintain progress toward the department’s mission to protect the public health. Furthermore, USDA reported that APHIS and FSIS are already taking steps to revise their pandemic plans to overcome many of the gaps we identified to help ensure the USDA veterinarian workforce can carry out essential functions during a pandemic. USDA’s written comments and our evaluation appear in appendix III.

DOD stated that efforts are under way to finalize the Army’s pandemic influenza plan and that the implementation date will be determined based on current mission priorities. DOD’s written comments and our evaluation appear in appendix IV.

HHS reported that veterinarians are essential to protecting the health of the American people. In addition, the department commented that veterinarians are a valuable resource at CDC and conducting workforce assessments, as recommended in our report, will ensure that HHS maintains a sufficient capacity for outbreak response. HHS further reported that all operating staff division heads are required to have workforce plans in place for their organizations by September 2009. Once the plans are completed, the HHS Office of Human Resources will look across the plans to identify opportunities for collaboration with regard to strategic recruitment, development, and retention. The department also plans to strengthen its oversight of the operating divisions to ensure that they are implementing their workforce plans, focusing on those occupations critical to the success of their missions. While veterinarians are not currently identified as a department-level Mission Critical Occupation, largely because they represent less than 1 percent of the HHS workforce, the department plans to review its Mission Critical Occupations in the coming year using criteria that are more risk-based. However, HHS did not agree with a statement in our report that references a 2007 FDA Advisory Committee report claiming that CVM is in a state of crisis. The department stated that, given the broad nature of the 2007 Advisory Committee report, it is not applicable to veterinarians. However, we reported information pertaining directly to veterinarians—information we obtained from an interview with an author of the Advisory Committee report. Furthermore, HHS stated that CVM has made great strides in the past few years assessing its workforce needs and that the 2007 report is outdated. Our report identifies many of the efforts CVM has recently undertaken, such as hiring additional veterinarians and beginning an effort to analyze the gap between current resources and needs. It also notes that, according to FDA officials, the agency is undertaking significant reforms to address fundamental concerns in the 2007 report. However, as our report also states, FDA did not tell us how these efforts address the identified veterinarian skill gap specifically. HHS’s written comments and our evaluation appear in appendix V.

OPM informed us that it has established a team to research and analyze data to determine the feasibility of issuing a governmentwide direct-hire authority for veterinarians under its statutory and regulatory authority. OPM did not provide further details except to say that a decision is expected early in 2009. Until this study is completed, OPM relies on individual agencies to make such requests when they have encountered a severe shortage of candidates or a critical hiring need for veterinarians. In addition, OPM informed us that on November 25, 2008, it approved USDA’s request for direct-hire authority. OPM also commented that, in 2003, the agency approved direct-hire authority for temporary and term positions, including veterinarians, to help protect the health or safety of the U.S. food supply during a pandemic or other declared emergency situation. OPM’s written comments and our evaluation appear in appendix VI.

DHS recommended that the federal government enhance efforts to identify the veterinarian workforce needed during catastrophic events. They stated that this could be achieved through an OPM pursuit of a multidepartment assessment of veterinary manpower requirements. They further recommended that agencies develop plans that identify how veterinarians will continue essential functions during additional catastrophic events, taking into consideration the potential for absenteeism that exceeds the level of 40 percent estimated for a pandemic. In addition, DHS stated that, once a governmentwide veterinarian workforce need is determined, effective recruitment and retention programs should be developed that are consistent across all agencies. However, DHS disagreed with our finding that the estimate produced from one of its efforts to identify the workforce needed during a catastrophic outbreak of foot-and-mouth disease is not relevant. We continue to believe, as does DHS, that this effort is based on an infeasible assumption. Therefore, we do not agree that this estimate is relevant to any response that could reasonably be implemented during such an outbreak. DHS’s written comments and our evaluation appear in appendix VII.

Interior commended GAO for conducting a well-researched examination of the federal veterinarian workforce. The department emphasized the importance of including wildlife disease expertise in a strategy for protecting human and animal health. The department also identified the importance of detecting and preventing non-native invasive infectious diseases from entering U.S. borders via imported wildlife as important to protecting human and animal health. Interior’s written comments and our evaluation appear in appendix VIII.

As agreed with your offices, unless you publicly announce the contents of this report earlier, we plan no further distribution until 22 days from the report date. At that time, we will send copies to the Secretaries of Agriculture, Commerce, Defense, Energy, Health and Human Services, Homeland Security, Interior, Justice, Smithsonian Institution, and Veterans Affairs; the Director of the Office of Personnel Management; the Administrators of the Environmental Protection Agency, National Aeronautics and Space Administration, and U.S. Agency for International Development; appropriate congressional committees; and other interested parties. The report also will be available at no charge on the GAO Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at (202) 512-3841 or shamesl@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made contributions to this report are listed in appendix IX.

Appendix I: Location and Responsibilities of Veterinarians in the Federal Government

Number of veterinarians by component agency or other entity

1,771 Animal and Plant Health Inspection Service 667 Protect American livestock and poultry health through diagnosis, control and eradication of animal diseases, and partnering with state officials to manage and eradicate disease outbreaks. Some are employed overseas.

Secretary for Preparedness and Response personnel for events requiring emergency and disaster-related veterinary medical care services to impacted animal populations (including household pets and service animals) in or outside of shelter locations until local infrastructures are reestablished.

Number of veterinarians by component agency or other entity37 Conduct research to improve the health of veterans and oversee the health and welfare of animals used in research. 16 Investigate, diagnose, develop control methods, and develop databases for wildlife diseases; provide training to wildlife biologists and resource managers in wildlife disease identification and control; conduct clinical veterinary research on wildlife diseases; and oversee the health and welfare of experimental and wild animals used in research, including research on wildlife diseases.

Growth, Agriculture and Trade; for Global Health; and for Africa pathogenic avian influenza outbreaks and recovery; identify opportunities to share and leverage resources for avian influenza response efforts with international and domestic health agencies and universities.

Number of veterinarians by component agency or other entity9 Conduct audits of seafood plants and products as part of the Seafood Inspection Program; provide guidelines and oversight of the Marine Mammal Health and Stranding Response Program, Aquatic Animal Health Program, disease surveillance, health monitoring, outbreak investigations, and contaminants/pathogen/toxin/health research.

5 Office of the Chief 5 Provide and coordinate animal care at agency research facilities; one veterinarian is an astronaut. 1 Oversees the laboratories’ Food and Agricultural Security program, which includes the work on modeling animal disease to determine workforce resources that will be needed for response to outbreaks. 1 Provide veterinary expertise in the investigation of an intentional disease outbreak.

The Army veterinarian workforce consists of 446 active duty; 173 reserve corps; and 134 other.

The number of veterinarians listed for the Department of Health and Human Services does not include those United States Public Health Service Commissioned Corps veterinarians working at the FSIS and the Environmental Protection Agency because they are counted as employees of those agencies.

Appendix II: Scope and Methodology

To determine the extent to which the federal government has assessed the sufficiency of its veterinarian workforce for routine activities, we interviewed officials and collected documents from the American Veterinary Medical Association, the National Association of Federal Veterinarians (NAFV), and the Association of American Veterinary Medical Colleges to identify general concerns about the federal veterinarian workforce. NAFV also provided a review it had conducted in 1996 that identified federal departments and agencies that employ veterinarians. We expanded this list of departments and component agencies based on referrals and experience from our past reports, resulting in a list of 24 component agencies and other federal entities. We then surveyed these 24 entities to obtain information on the federal veterinarian workforce— including the number of veterinarians employed, their grade level, salaries, roles and responsibilities, number of vacancies, and sufficiency of the workforce. We conducted this self-administered electronic survey in October 2007 and then requested an update of this survey information in July 2008. We achieved a 100 percent response rate both times. However, one entity was unable to provide some of the specific salary information we requested, and we noted this in our report.

Because this was not a sample survey, but rather a survey of the universe of respondents, it has no sampling errors. However, the practical difficulties of conducting any survey may introduce errors, commonly referred to as nonsampling errors. For example, respondents may have difficulty interpreting a particular question, the sources of information available to respondents may introduce errors or variability, and analysts may introduce errors when entering data into a database or analyzing these data. We took steps in developing the questionnaire, collecting the data, and analyzing them to minimize such nonsampling error. For example, we pretested the survey to ensure that the questions were relevant, clearly stated, and easy to understand.

To obtain salary information for Department of Agriculture (USDA) agencies over the past 5 years, we used data from the Office of Personnel Management’s (OPM) Central Personnel Data File. We did not independently verify these data for the years we reviewed; however, in a 1998 report, we found that governmentwide data from this file for the key variables in this study (agency, birth date, service computation date, occupation, and retirement plan) were 99 percent accurate or better.

Therefore, we feel these data were sufficiently reliable for the purposes of this review.

On the basis of information we received in our survey of these component agencies and other entities, we then analyzed the workforce assessment efforts of USDA, the Department of Defense (DOD), and the Department of Health and Human Services (HHS). We selected these departments because they employ the majority of federal veterinarians (96 percent) identified in our survey. Within these three departments, we further focused our review on five component agencies—the Animal and Plant Health Inspection Service (APHIS), FSIS, Army, and the Food and Drug Administration (FDA)—to determine the extent to which they assessed the sufficiency of their veterinarian workforce. We also selected the Agricultural Research Service (ARS) for further review because it is USDA’s chief scientific research agency and conducts research to solve agricultural problems of high national priority. We conducted our assessment by reviewing department and agency documents, such as workforce plans, human capital management reports, workforce models, and gap assessments. We then compared workforce assessment efforts of the three departments and five component agencies with GAO workforce planning guidance. We also conducted semistructured interviews with workforce planning and veterinarian program officials. In addition, we interviewed an author of the report FDA Science and Mission at Risk regarding the report’s findings and their relation to FDA veterinarian skill gaps. Further, we visited one poultry and two beef slaughter plants of varying sizes to observe conditions and interview veterinarians and other FSIS officials. We also interviewed FSIS officials working at the slaughter plant that was the subject of the nation’s largest beef recall. We selected these plants on the basis of proximity to the sites of the four recent zoonotic disease outbreaks we reviewed, and recommendations from FSIS officials. Moreover, other veterinarians contacted us to relay concerns about the sufficiency of the FSIS veterinarian workforce. We interviewed officials from the OPM to determine the agency’s role in workforce planning for federal veterinarians and to identify recruitment and retention authorities available to agencies and departments. Finally, we interviewed experts from the Council of State and Territorial Epidemiologists, the National Association of State Public Health Veterinarians, the American College of Veterinary Pathologists, the American Association of Wildlife Veterinarians, the American Association of Veterinary Laboratory Diagnosticians, and the National Academy of Sciences to identify workforce needs for veterinary specialties including public health, wildlife veterinarians, veterinary laboratory diagnostics, and veterinary pathology.

To determine the extent to which the federal government has identified the veterinarian workforce needed during a catastrophic event, we analyzed workforce planning efforts for two potential large-scale national incidents that the White House Homeland Security Council deemed critical for planning purposes: a pandemic and a foot-and-mouth disease outbreak. For the first, we compared pandemic plans from APHIS, FSIS, ARS, Army, and FDA to guidance the Department of Homeland Security’s (DHS) Federal Emergency Management Agency provided to departments and agencies for identifying special considerations for maintaining essential functions and services under such conditions. These agencies were selected for the reasons described above. We interviewed agency officials to discuss identified gaps and determine the extent to which the plans were being updated and tested. Furthermore, we interviewed HHS officials to understand their review of state pandemic plans, which are under development to ensure continuity of the food supply system and the ability to respond to agriculture emergencies. For the second, we reviewed veterinarian workforce outcomes from DHS’s nationwide effort to assess the nation’s preparedness for multiple, intentional introductions of foot- and-mouth disease. In addition to interviewing the DHS official responsible for coordinating the animal health emergency capability, we also interviewed state officials who have conducted large-scale exercises simulating a response to foot-and-mouth disease, as well as USDA officials with responsibility for such an event, to determine the feasibility of the response depicted in the scenario. Because vaccine use was suggested as an alternative strategy to the slaughter of animals infected with foot-and- mouth disease, we also interviewed USDA’s Chief Veterinary Officer, and DHS and USDA officials at Plum Island Animal Disease Center to determine the status of foot-and-mouth disease vaccine development and the feasibility, as well as practicality, of their use. Finally, at the recommendation of DHS, we interviewed the Department of Energy official responsible for overseeing the development of a decision support system that models various foot-and-mouth disease outbreak scenarios in order to estimate the number and type of workforce needed for responding to outbreaks. The Department of Energy is performing this work under contract for DHS. We also interviewed USDA, DHS, and Department of the Interior (Interior) officials to determine the extent to which agencies are including the possible spread of foot-and-mouth disease in wildlife in their planning efforts.

To determine the extent to which federal and state agencies encountered veterinarian workforce challenges during four recent zoonotic outbreaks, we conducted semistructured interviews with 17 federal and state agencies involved in these outbreaks. We relied on federal and state officials to identify those agencies that played an important role in outbreak response. Based on this information, we then interviewed officials from USDA, HHS, Interior, state public health departments, state agriculture and wildlife agencies, state diagnostic laboratories, and one county public health agency. We also interviewed other individuals involved in the outbreaks, including researchers from Northwestern University, the University of California at Davis, and Western University of Health Sciences. We selected the four outbreaks in our review—bovine tuberculosis in Michigan, exotic Newcastle disease in California, monkeypox in Wisconsin, and West Nile virus in Colorado—because these outbreaks were most frequently recommended by federal officials as examples of recent zoonotic diseases; are ongoing or have occurred since 2001; and have affected various types of animals, including livestock, wildlife, pets, and exotic animals. In addition, we chose these four outbreaks for review because of the unique nature of the outbreaks in these states. Specifically, we selected Michigan as the state for the bovine tuberculosis review because the ongoing outbreak is the longest outbreak of this disease in the United States in recent history. We chose California because it experienced the greatest number of animal infections for the exotic Newcastle disease outbreak. We selected Wisconsin because it experienced the most human monkeypox infections. We selected Colorado for West Nile virus because the number of human infections in Colorado in 2003 was the highest for a single state. In addition to the interviews, we also analyzed federal, state, and county documents, such as after action reports, in order to (1) understand the extent to which agencies formally assessed the management of their veterinarian workforces during these outbreaks and (2) identify any workforce-related challenges and steps agencies took to address these challenges.

Appendix III: Comments from the Department of Agriculture

The following are GAO’s comments on the Department of Agriculture’s letter dated January 16, 2009.

GAO Comments

1. USDA commented that FSIS already regularly assesses the level of inspection resources it needs, as we recommended in 2004. However, as our report states, FSIS has yet to demonstrate that they have done so. We regularly follow up to request evidence that agencies have implemented our recommendations, and FSIS has not provided such evidence. 2. USDA reported the majority of its veterinarian workforce is located within two agencies, APHIS and FSIS, and each has the staff and expertise to conduct veterinarian workforce analyses for their respective agencies. Therefore, these two agencies will work together, with departmental consultation, as needed, to develop solutions to problems shared by both agencies. We continue to believe that a departmental assessment, not a consultation, is necessary, particularly in light of the competition between the two agencies. As we reported, APHIS is attracting veterinarians away from FSIS because the work at APHIS is more appealing, there are more opportunities for advancement, and the salaries are higher. Furthermore, ARS continues to experience difficulties recruiting and retaining highly qualified veterinarians to carry out critical research of national importance, yet there is no mention of ARS in USDA’s comments. 3. USDA commented that it has contingency plans and a decision tree for use of foot-and-mouth disease vaccine from the North American Foot- and-Mouth Disease Vaccine Bank. We acknowledge that USDA has these plans. In fact, we reviewed a draft plan titled, Response to the Detection of Foot-and-Mouth Disease in the United States, dated October 2007, that USDA officials told us was their new response plan that considered alternative response strategies, including “vaccinate to live.” However, this plan does not detail how a policy of this nature would be implemented. USDA further commented that policy decisions as to who may administer the vaccine will be made based on the circumstances of the outbreak. While we recognize that each outbreak is unique, this should not preclude USDA from identifying a plausible scenario or scenarios and detailing how a vaccinate to live strategy would be carried out in order to enhance preparation, response, and recovery in a time of crises. 4. We modified our report to reflect that USDA would like to change their statement from FSIS has “never” had a sufficient number of veterinarians to “over the past decade.” USDA also asserts that our report says that FSIS has been able to reallocate veterinary resources sufficient to meet its statutory mandates for food safety and humane handling of livestock. However, our report only presents this as the view of FSIS headquarters officials. We raise this point to illustrate that FSIS headquarters officials and veterinarians working in slaughter plants differ on the impact of this shortage. 5. We modified our report to reflect more clearly the relationship between the events at a Chino, California, plant and the February 2008 beef recall. 6. USDA commented that that our report emphasizes the incident at a plant in Chino, California. We raise the point because some veterinarians told us they did not have time to ensure the humane treatment of livestock, and this example illustrates inhumane treatment occurred despite the presence of FSIS inspectors. USDA further commented that we attribute this incident to having only one veterinarian. We do not state this in our report. We use this and other statements about resources to illustrate the need for FSIS to periodically assess whether the level of resources dedicated to humane handling and slaughter activities is sufficient. They have yet to do so. In addition, USDA commented that the USDA Inspector General did not find systematic problems associated with oversight of humane handling at slaughter facilities that process cull cows. However, the Inspector General did conclude that there is inherent vulnerability at the other plants in the scope of its audit, and that inhumane handling could occur and not be detected by FSIS inspectors due to lack of continuous surveillance. 7. USDA commented that GAO has closed the 2004 recommendation that FSIS periodically assess whether the level of resources dedicated to humane handling and slaughter activities is sufficient. We recognize that FSIS has taken actions in response to a number of recommendations made in the 2004 report and have documented implementation of these recommendations. However, with regard to periodic assessment, we closed this recommendation because enough time had passed that we considered it unlikely to be implemented. As our report states, FSIS has yet to demonstrate that it has been implemented. Based on our current work, we continue to believe that periodic assessment is needed, and we make a recommendation to that effect. 8. We modified our report to include the recent approval of USDA’s direct-hire authority and noted that USDA has raised some concerns. 9. We modified our report to include the concern about veterinary schools and enhanced the chart to include the concern for salary.

Appendix IV: Comments from the Department of Defense

Appendix V: Comments from the Department of Health and Human Services

The following are GAO’s comments on the Department of Health and Human Services’ letter dated January 14, 2009.

GAO Comments

1. HHS commented that a premise of our report is that the control of zoonotic diseases is solely dependent on the capacity of the veterinarian workforce. Our report does not state this. The scope of this report, as described in the introduction, was to review the sufficiency of the federal veterinarian workforce. 2. Our report does not identify the Centers for Disease Control and Prevention (CDC) as having too few veterinarians to control the 2003 West Nile virus outbreak while also adequately carrying out other routine activities. However, CDC officials we interviewed who were involved with the 2003 monkeypox outbreak in Wisconsin told us there were too few veterinarians during this outbreak. 3. We modified our report to reflect the new information about the difficulty the National Institutes of Health has recruiting veterinarians. 4. Our report states conclusions from the FDA Advisory Committee report: that FDA “cannot fulfill its mission” because its scientific workforce has remained static while its workload has increased, and that FDA’s Center for Veterinary Medicine (CVM) is “in a state of crisis.” We discussed with an author of the Advisory Committee report how that report’s findings specifically related to veterinarians. Consequently, our report also states that an author of the FDA Advisory Committee report told us that veterinarians enter FDA employment lacking necessary skills and experience to examine the wide variety of veterinary products that require FDA approval and that FDA needs to better train its veterinarians to review the many diverse products under its jurisdiction. HHS further stated that CVM has made great strides in the past few years in assessing its workforce needs and that the conclusions of the Advisory Committee report are out of date. Our report identifies several of the efforts CVM has recently undertaken, such as hiring additional veterinarians and beginning efforts to analyze the gap between current resources and needs. It also notes that, according to FDA officials, the agency is undertaking significant reforms to address fundamental concerns in the 2007 report. However, as our report states, FDA did not tell us how these efforts address the identified veterinarian skill gap specifically. 5. We modified our report to add a statement that the increase observed in CVM’s veterinarian workforce was primarily in response to new obligations.

Appendix VI: Comments from the Office of Personnel Management

The following are GAO’s comments on the Office of Personnel Management’s letter dated January 15, 2009.

GAO Comments

1. We modified our report to reflect OPM’s establishment of a team to determine the feasibility of issuing a governmentwide direct-hire authority for veterinarians. 2. We modified our report to include OPM’s recent approval of USDA’s direct-hire authority request.

Appendix VII: Comments from the Department of Homeland Security

The following are GAO’s comments on the Department of Homeland Security’s letter dated January 14, 2009.

GAO Comments

1. DHS stated that current policy requires slaughter of all potentially exposed animals and, therefore, the projected manpower requirement is relevant. We agree that this estimate is relevant to this method. As our report notes, the United States has used this “stamping out” method in the past for eradicating smaller outbreaks of foreign animal diseases. However, DHS and USDA officials told us, and DHS reiterates in its comments, that stamping out is infeasible for a large- scale outbreak of foot-and-mouth disease. Therefore, we do not agree that this estimate is relevant to a catastrophic outbreak, which was the scope of this section of our report. Indeed, as we note, DHS and USDA officials we interviewed during the course of our review told us that the estimate was not relevant. 2. We modified our report to clarify the Office of Health Affairs’ concerns about the sufficiency of its veterinarian workforce.

Appendix VIII: Comments from the Department of the Interior

Appendix IX: GAO Contact and Staff Acknowledgments

Staff Acknowledgments

In addition to the individual named above, Charles Adams, Assistant Director; Mary Denigan-Macauley; Jennifer Gregory; Terry Richardson; Benjamin Shouse; and Michelle K. Treistman made key contributions to this report.

Other important contributors included Kevin Bray; Candace Carpenter; Nancy Crothers; William Doherty; Joyce Evans; Brian Friedman; Katheryn Hubbell; Judith Kordahl; Jena Sinkfield; and Gloria Sutton.