Getting on the same page

by Jay Sjerven
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The Government Accountability Office in a December 2014 report urged Congress and the Obama administration to take steps to improve planning and cooperation between federal agencies with responsibilities for food safety, principally the Food Safety and Inspection Service of the U.S. Department of Agriculture and the Food and Drug Administration of the Department of Health and Human Services.

The G.A.O. in its report titled “Federal food safety oversight: Additional actions needed to improve planning and collaboration” decried the lack of a government-wide strategy and performance plan for food safety and the suspension of activity of the Food Safety Working Group, which, for a time, provided oversight and guidance in federal efforts to modernize the food safety system.

“Because challenges associated with the fragmented federal food safety system are long-standing, decision makers do not have an integrated perspective on federal food safety performance, and centralized mechanisms have not been sustained, Congress should consider directing the Office of Management and Budget to develop a government-wide performance plan for food safety that includes results-oriented goals and performance measures and a discussion of strategy and resources,” the G.A.O. asserted.

The G.A.O. acknowledged that both the U.S.D.A. and the H.H.S. have taken steps to implement the Government Performance and Results Act Modernization Act of 2010 (G.P.R.A.M.A.) but added the agencies “could more fully address crosscutting food safety efforts.”

The G.P.R.A.M.A. requires each federal agency, such as the U.S.D.A. or the H.H.S., to describe in its strategic and performance planning how it is working to achieve its goals and objectives, including by working with other agencies. Agency strategic plans must be issued by each head of a federal agency in “any year in which the term of the president commences,” i.e., once every four years, and the plans should cover a period of not less than four years forward.

The G.A.O. said, “H.H.S. and U.S.D.A. vary in the amount of detail they provide on their crosscutting food safety efforts” (Under the G.P.R.A.M.A., “crosscutting” means across organization or agency boundaries.)”

The G.A.O. pointed out in 2011 it recommended the O.M.B. develop a government-wide performance plan for food safety.

“O.M.B. has not acted on that recommendation,” the G.A.O. said.

The G.A.O. also recommended Congress “consider formalizing the Food Safety Working Group through statute to help ensure sustained leadership across food safety agencies over time.”

The F.S.W.G. was established in March 2009 by President Obama and served as a centralized mechanism for broad-based collaboration on food safety. It played a critical role in paving the way for the F.D.A. Food Safety Modernization Act as well as several initiatives to improve interagency collaboration. But the F.S.W.G. has not met since 2011, the G.A.O. said.

With regard to executive action, the G.A.O. recommended the Secretaries of Agriculture and Health and Human Services “should continue to build upon their efforts.”

David Acheson of The Acheson Group said the G.A.O. may have the right idea that “broad-based, centralized collaboration between F.D.A. and F.S.I.S. would provide for a more unified food safety system.” But Mr. Acheson was critical of the report’s focus on the agencies’ parent departments and its perhaps excessive reliance on assessing the quality of department-level strategic reports.

“Since there are a number of areas in which the agencies have collaborated such as the National Antimicrobial Resistance Monitoring System, PulseNet, Whole Genome Sequencing, etc., what is the point of writing a 46-page report on what is or isn’t detailed in a departmental strategic plan?” he asked.

Mr. Acheson also noted O.M.B. would be hard pressed to develop a government-wide food safety plan given its many responsibilities.

“Now, this is not to say that the agencies shouldn’t have a strategic plan, nor that the G.A.O. shouldn’t assess it,” Mr. Acheson continued. “We just don’t believe that developing a ‘Federal Food Safety Oversight’ report from these upper level (H.H.S./U.S.D.A.) strategic documents is really all that helpful.

“We also see it as no great revelation that, as G.A.O. asserts, ‘a government-wide performance plan for food safety is necessary.’ But, we would take that a step further to say that perhaps it is a single, united, government-wide agency that is needed, and G.A.O. has supported that assertion in the past,” Mr. Acheson said. “A single F.D.A./U.S.D.A. that is responsible for all food safety, reports up to the same department, and has the same congressional mandates. Then collaboration would be truly enabled. Then we could truly make system-wide improvements in food safety.”

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