Detailed Information on the
Food Distribution Program on Indian Reservations Assessment

Partner with Indian tribal organizations to develop a method of allocating administrative funds that is more equitable and better supports program operations.

Improve the nutrient content of the food package.

Develop nutrition education services for program participants.

Measure: Percentage of calories from fat and saturated fat in FDPIR food package.

Explanation:Because FDPIR food packages make a significant contribution to the diets of program participants, it is important that their nutrient content be made consistent with science-based dietary recommendations. The targeted reduction in saturated fat, while maintaining the percentage of calories from total fat in the FDPIR package at less than or equal to 30%, is intended to bring the package in line with the 2005 Dietary Guidelines for Americans, which are designed to offer nutrition guidance for all Americans over the age of two.

Measure: Regional difference in administrative funding per participant

Explanation:This measure is intended to assess progress in improving parity in administrative funding among FDPIR-participating Indian tribal organizations (ITOs). The measure represents the difference between highest and lowest regional average funding per participant as a proportion of the national average. In the past, administrative funding allocations were developed based on a historical formula that did not objectively or equitably distribute funds among grantees. USDA has partnered with ITOs to develop a method of allocating administrative funds that is more equitable and better supports program operations; this metric will track the success of the new method as it is used in 2008 and beyond.

Measure: Average monthly FDPIR participation

Explanation:Targets for the number of people to be served by FDPIR are based on projected needs estimated for the budget process. The program is designed to serve low-income Native Americans in areas where there is limited access to food stores meet their food needs; those in need of assistance with access to retail food outlets may choose to participate in the Food Stamp Program as an alternative. (Program rules prohibit dual participation.) Therefore, the actual target population for the program is smaller than the potentially eligible population, and changes based on trends in access to food retailers and the preferences of potential participants.

Measure: Average FDPIR inventory levels.

Explanation:Excessive inventory levels reduce program efficiency by increasing storage and food costs, and raising the potential for food to go out of condition for distribution due to excessive age. USDA has also committed to reduce average inventory levels by developing alternative methods for ordering and delivery of commodities to ITOs/State agencies, including methods for providing multi-food shipments of commodities. The Department pilot-tested more efficient methods that may offer shorter order time-frames (which could reduce inventory levels and storage costs), and better service. USDA recently approved the expansion of one such method nationwide. Out overall goal in this area is to reduce the average FDPIR inventory level to 60 days worth of inventory on-hand by 2012. This measure will help USDA track progress in meeting this goal.

Is the program purpose clear?

Explanation: The Food Distribution Program on Indian Reservations (FDPIR) is a commodity-package alternative to the Food Stamp Program (FSP) for low-income households residing on Indian reservations and low-income Native American households residing in designated service areas near reservations and in Oklahoma. Like Food Stamps, the purpose of the program is to reduce hunger and improve nutrition among low-income individuals. A Congressional concern when the program was established was that many reservations were in remote areas with limited or no access to the Food Stamp Program or food stores. In addition, the Food Stamp Act, which authorizes FDPIR, has the goal of strengthening the agricultural economy and achieving a fuller and more effective use of food abundances.

Evidence: Declaration of policy, Food Stamp Act of 1977 (as amended), Section 2. Establishment of the food stamp program, Food Stamp Act of 1977 (as amended), Section 4(b). Legislative history leading to the establishment of FDPIR: House Report 95-464, 95th Congress, 1st Session, June 24, 1977.

Does the program address a specific and existing problem, interest, or need?

Explanation: Poverty-related hunger is particularly acute among Native Americans. USDA estimates that 27 percent of Native Americans living in non-metropolitan areas of States in which FDPIR operates are food insecure and 10 percent have very low food security. Comparable U.S. rates are 11 and 4 percent. In addition, there is a higher prevalence of obesity, diabetes, and other diet-related health conditions among Native Americans than among other groups. USDA's Healthy Eating Index (HEI) indicates that only 7 percent of low-income people have a "good" diet, 20 percent have a "poor" diet, and the remainder "needs improvement." Although data are lacking for low-income Native Americans on reservations, research shows that overall scores of Native Americans on the HEI were not significantly different from the rest of the U.S. population. It is therefore probable that HEI findings for low-income Native Americans are similar to the findings for low-income people in general. It is unclear whether accessibility to the Food Stamp Program and grocery stores is currently a problem on reservations. Accessibility may be an issue for some FDPIR participants. A 1990 FDPIR study, although dated, found that in most regions, 20 to 30 percent of FDPIR households would have to travel more than 20 miles to the nearest grocery store that sold fresh meat and produce, and 30 to 40 percent of participants would have to travel more than 20 miles to a Food Stamp Program. At the same time, the same study found that a large segment of FDPIR participants cited the higher value of the FDPIR commodity package and more lenient eligibility rules as reasons for their participation in FDPIR.

Evidence: Special tabulation from the Food Security Supplement to the Current Population Survey for 2001-2004 prepared by the Economic Research Service; Basiotis et al (2002), The Healthy Eating Index: 1999-2000, U.S. Department of Agriculture, Center for Nutrition Policy and Promotion; Finegold et al (2005) Background Report on the Use and Impact of Food Assistance Programs on Indian Reservations, U.S. Department of Agriculture, Economic Research Service; Broussard et al (1991) reports that the prevalence of obesity among American Indians in 1987 was 13.7% for men and 16.5% for women, both of which are higher than US rates of 9.1% and 8.2%. Usher, C.L., D.S. Shanklin, and J.B.Wildfire. 1990. Evaluation of the Food Distribution Program on Indian Reservations (FDPIR). USDA, Food and Nutrition Service.

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: FDPIR was established in order to serve individuals with limited access to the Food Stamp Program (FSP) or grocery stores. While some individuals may be eligible for both programs, participants are not permitted to receive benefits from both FDPIR and FSP in the same month. Other Federal nutrition assistance programs target supplemental benefits to specific populations in specific settings to meet particular needs. Eligibility for FDPIR is based, in part, on income, which includes cash assistance received from other government programs, family earnings, and other income.

Evidence: USDA Strategic Plan for FY 2002-2007; Finegold et al (2005) Background Report on the Use and Impact of Food Assistance Programs on Indian Reservations, U.S. Department of Agriculture, Economic Research Service.

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: FDPIR is better designed to reduce hunger and malnutrition related to inadequate income, than to achieve further incremental improvements in the dietary status of low-income Native Americans. Although neither program is designed to address special dietary needs of recipients, the Food Stamp Program can better accommodate the diets of individuals with diet-related illnesses because it provides participants full flexibility to choose the food purchased with food stamp benefits. While the nutrient content of the food package offered to FDPIR participants has improved over time, further improvements can be made to bring the package in line with the 2005 Dietary Guidelines for Americans. In addition, the nutrient content of the package participants actually receive depends in part on participant choice. FDPIR nutrition education is limited and varies by location. In addition, FDPIR's effectiveness is reduced by its current formula for allocating administrative funds across regions. The current formula does not objectively or equitably distribute funds among grantees.

Evidence: Finegold et al (2005) Background Report on the Use and Impact of Food Assistance Programs on Indian Reservations, U.S. Department of Agriculture, Economic Research Service; U.S. General Accounting Office. (1990). Food Assistance Programs: Recipient and Expert View on Food Assistance at Four Indian Reservations FY 2005 Funding Methodology Work Group documents.

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: The majority of households participating in FDPIR have incomes below the poverty level (only 1 in 5 participating households report income in excess of the poverty level). Nearly 1 in 10 FDPIR households report no income at all, and more than 1 in 3 had gross incomes that were no more than 50% of the poverty level. FDPIR regulations require that all participants meet specified eligibility standards, including income, resources, and non-economic factors. Indian Tribal Organizations (ITOs) and State agencies are required to collect documentation from the applicants as evidence that applicants meet the eligibility criteria. FDPIR Management Evaluations specifically target certification procedures at the ITOs/State agencies, to ensure that the ITOs/State agencies are performing certification procedures properly.

Evidence: Effects of Food Assistance and Nutrition Programs on Nutrition and Health: Volume 3, Literature Review, U.S. Department of Agriculture, Economic Research Service; FNS Handbook 501; FDPIR regulations.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: FDPIR has two long-term performance measures that meet the PART guidance: (1) the percentage of calories from fat and saturated fat in the FDPIR food package received by participants and (2) the average FDPIR inventory levels. The program also contributes to two crosscutting measures: the prevalence of very low food security among low-income households and the Healthy Eating Index (a measure of dietary quality) for low-income individuals and children. FNS has not set outcome goals specific to FDPIR because of the complexity of measuring program impacts on participants. Since households at greater risk of hunger are more likely to seek assistance, assessment of program effectiveness requires more complex analytical methods to account for differences between participants and non-participants.

Evidence: USDA Strategic Plan for FY 2002-2007; Internal Planning Documents; Nord et al (2005) Household Food Security in the United States, 2004. U. S. Department of Agriculture, Economic Research Service.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: USDA seeks to maintain the percentage of calories from fat in the FDPIR package to less than or equal to 30%, while reducing the percentage of calories from saturated fat from 13.4% to 10%. The target is based on established dietary guidelines; there is minimal benefit, and potential harm, in going significantly below this level. USDA has also committed to improve program efficiency by reducing average inventory levels. The target is to reduce the average FDPIR inventory level from the 90 days in 2002 to 60 days by 2012.

Evidence:

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: The program's annual performance measures are the same as the long-term measures: the percentage of calories from fat and saturated fat in the FDPIR food package and the average FDPIR inventory levels.

Evidence: Internal Planning Documents

Does the program have baselines and ambitious targets for its annual measures?

Explanation: The program has baselines and ambitious targets for each annual measure. The percentage of calories from fat and saturated fat in the FDPIR food package was 30.1% and 13.4% in 2002; the target for 2005 and beyond is to reduce the percentage of calories from fat to no more than 30% and the percentage from saturated fat to no more than 10%, consistent with the standards contained in the 2005 Dietary Guidelines for Americans. The average FDPIR inventory level was 90 days in 2005; the target for inventory levels is 80 days in 2008.

Evidence: Internal Planning Documents

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: The FDPIR performance measures with annual and long-term targets are newly established. While the measures reflect management objectives that ITOs/State agencies are aware of, neither the measures nor the targets have been communicated to the grantees. ITO's/State agencies currently report on their performance as it relates to the new measures. However, they have not had an opportunity to express their support for the new measures and targets. ITOs participate in efforts to make improvements in the program to meet the long term goals. FNS, in cooperation with ITOs in the Midwest and Southwest Regions, piloted two alternative methods for ordering and delivering commodities to ITOs/State agencies in shorter timeframes (which could reduce inventory levels and storage costs). FNS, in cooperation with ITOs and nutrition experts, also is reviewing the FDPIR food package to ensure the food package meets the goals for fat and saturated fat as a percentage of calories.

Evidence: Form SF-269, Financial Status Report; Form FNS-152, Monthly Distribution of Donated Foods to Family Units; Kamara, Sheku (2004) An Evaluation of the Prime Vendor Pilot of the Food Distribution Program on Indian Reservations, Nutrition Assistance Program Report Series, No. FDD-04-PVP, U.S. Department of Agriculture, Food and Nutrition Service, Alexandria, VA.

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: Independent evaluations are not conducted on a regular enough basis nor are they of sufficient scope to improve program planning. A 1989 nationally representative study provided baseline information on FDPIR program operations and participant characteristics, including dietary needs. It found that FDPIR households sustain much higher poverty rates than the general population, include more households with elderly members, and are highly dependent on FDPIR as their primary source of food, a finding that was also replicated by GAO in their 1990 review of food assistance programs on four Indian reservations. More recent research explored the importance of traditional foods and food resources as a means of improving the diets, food security and self-sufficiency of Native Americans. A recent review of existing sources of data on Native Americans living on reservations provides a basis for assessing future evaluation designs.

Evidence: Usher, C.L., D.S. Shanklin, and J.B.Wildfire. (1990). Evaluation of the Food Distribution Program on Indian Reservations (FDPIR). USDA, Food and Nutrition Service; U.S. General Accounting Office. (1990). Food Assistance Programs: Recipient and Expert View on Food Assistance at Four Indian Reservations: Report to Congressional Requesters; Lopez, D., T. Treader, and P. Buseck. (2002). Community Attitudes Toward Traditional Tohono Oodham Foods. USDA, Economic Research Service; Grant et al (2000). Federal Food Programs, Traditional Foods, and the Gros Ventre and Assiniboine Nations of Fort Belknap Indian Reservation, FANRR-10. USDA, Economic Research Service; Finegold et al. (2005). Background Report on the Use and Impact of Food Assistance Programs on Indian Reservation. USDA, Economic Research Service; Kamara, Sheku (2004). An Evaluation of the Prime Vendor Pilot of the Food Distribution Program on Indian Reservations. Nutrition Assistance Program Report Series, No. FDD-04-PVP, U.S. Department of Agriculture, Food and Nutrition Service, Alexandria, Va.

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: FNS' budget request displays resources for FDPIR and other programs in alignment with the long-term performance goals in USDA's Strategic Plan. It also shows the unit cost per FDPIR participant and includes measures of estimated participation. However, the budget does not explicitly tie the FDPIR budget request to the accomplishment of or improvement in the program's annual or long-term performance goals, nor report all direct and indirect costs needed to attain performance results.

Evidence: FNS FY 2007 budget submission. USDA Strategic Goal 5: Improve the Nation's Nutrition and Health and its related objectives: 5.1-The Reduction and Prevention of Hunger by Improved Access to Federal Nutrition Assistance Programs and Strategic Goal and 5.2-Eating Habits More Consistent with the Dietary Guidelines for Americans.

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: Performance measures have been identified for improvements in the dietary content of food packages, and reductions in the amount of inventory maintained by the ITOs (which will reduce storage costs and improve food safety). USDA is obligated by Executive Order 13175 to consult and coordinate with ITOs on all program changes. Work groups composed of FNS, tribal representatives and various experts have been formed to provide input on dietary content of food packages and the administrative funding allocation method.

Evidence: USDA, Food and Nutrition Service, Program Management (internal document); Executive Order 13175, November 6, 2000; http://www.fns.usda.gov/fdd/programs/fdpir/FundingWkGrp/defautl.htm

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: ITOs/State agencies submit monthly reports on commodity inventories and distributions, including data on the number of households certified, the number of households and individuals participating, the amounts of each commodity delivered from the central distribution point to the reservations, distributed to households, and returned. On a quarterly basis, ITOs/State agencies submit a financial management report, including data on the use of administrative funds. FNS conducts a management review of every ITO/State agency every three years to evaluate the effectiveness of the ITO/State agency in meeting the plan of operation and applicable policies, instructions, and regulatory requirements, and in providing efficient service to participants. The areas of review may include outreach activities, staffing, training, financial accountability and controls, certification and issuance procedures, program monitoring activities, complaints and fair hearing procedures, commodity ordering procedures, warehousing facilities and practices, recordkeeping and reporting, and civil rights compliance. These data are used to assess program performance, and initiate corrective action when necessary.

Evidence: Form SF-269, Financial Status Report; Form FNS-101, Participation in Food Programs, By Race; Form FNS-152, Monthly Distribution of Donated Foods to Family Units; Form DA-663E, Food Distribution Commodity Acceptability Progress Report; FDPIR ME Module. Some issues identified in recent management reviews include ITOs failing to obtain complete documentation for household resources and income and errors in determining average monthly income. In each of these circumstances, the ITOs were instructed on proper program procedures to comply with program regulations.

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: All FNS managers, including those responsible for FDPIR, are required to have their performance plans aligned with USDA strategic goals and FNS priorities. Performance plans explicitly tie managers' responsibilities to accomplishment of this designed priority work, and related strategic and annual goals. Commodity vendors are held accountable for compliance with procurement contracts. Regulations and FNS Instructions make ITOs and State agencies responsible for the commodities they receive, in terms of proper storage, handling, and disposition. Regulatory requirements for State/local agreements, in turn, apply these responsibilities to the local level.

Evidence: Memorandum to Subcabinet and Agency Heads from USDA Deputy Secretary on President's Management Agenda and Performance Standards of GS-14s and 15s; Attestation of Under Secretary Bost to compliance with requirements; Sections 250.12, 250.13, 250.14, 250.16, 250.17, 250.20, and 250.24 of Food Distribution Program regulations, FNS Instruction 410-1 (Non-Audit Claims, Food Distribution Program), FNS Instruction 433-1 (Intra-Agency Commodity Reconciliation), FNS Instruction 709-5 (Shipment and Receipt of Foods), and FNS Instruction 710-1 (Commodities Found Out-of-Condition After Receipt by Distributing Agencies).

Are funds (Federal and partners') obligated in a timely manner, spent for the intended purpose and accurately reported?

Explanation: Funds are obligated in a timely manner. A limited amount of funds remain unobligated at the end of the year. States and ITOs report financial data quarterly and annually. USDA monitors these reports to ensure State agencies are meeting program requirements.

Evidence: SF-133, Report on Budget Execution and Budget Resources; and Financial Status Report (SF-269).

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: FDPIR commodity procurements are conducted competitively to control costs. In addition, FNS recently completed two pilot programs to evaluate alternative methods for ordering and delivery of commodities to ITOs/State agencies, including methods for providing multi-food shipments of commodities. These pilots were designed to test whether a more efficient method could be devised for providing commodities to ITOs/State agencies, including shorter order time-frames (which could reduce inventory levels and storage costs), and better service. FNS recently approved the expansion of the more cost effective design nationwide. ITOs/State agencies are encouraged to make use of volunteers to augment program services without increasing administrative costs. As an efficiency measure, FDPIR tracks food inventory levels and has a set a baseline and outyear targets for achieving reductions in inventory levels.

Evidence: Copies of procurement documents are available from FNS's commodity procurement agents, the Agricultural Marketing Service for fruits, vegetables, meats, poultry, and fish; and the Farm Service Agency for dairy, grains, and oils; FNS Handbook 501; Kamara, Sheku (2004). An Evaluation of the Prime Vendor Pilot of the Food Distribution Program on Indian Reservations, Nutrition Assistance Program Report Series, No. FDD-04-PVP, U.S. Department of Agriculture, Food and Nutrition Service, Alexandria, VA.

Does the program collaborate and coordinate effectively with related programs?

Explanation: Under program regulations, ITOs and State agencies are required to advise participants of other available assistance programs, and to have procedures to detect and prevent dual participation in FDPIR and the Food Stamp Program. In addition, USDA reports that the Cooperative Extension Service, the Indian Health Service, school and child care meal programs, and elder programs coordinate nutrition education in some areas, and that FNS is working with States to develop nutrition education plans that involve all providers of nutrition assistance programs. However, USDA reports that it can provide no evidence of collaborative actions.

Evidence:

Does the program use strong financial management practices?

Explanation: Financial management practices of the agency comply with Federal financial management system requirements, Federal accounting standards and the Standard General Ledger at the transaction level. Financial Management practices applicable to the program are established in program regulation and OMB Circulars. Program regulations stipulate that the agency perform state and local evaluations and review claims for participant eligibility. Federal financial management reviews assure that administrative costs are accounted for properly. However, State agencies and ITOs are not required to independently verify the information provided by applicants when determining eligibility. While FNS conducts State financial management reviews, such reviews are relatively infrequent in ITOs and seldom focus directly on FDPIR.

Evidence: Guidance requirements: Food Stamp Act and program regulations; OMB Circulars: A-87 (Cost Principles for State, Local, and Indian Tribal Governments), A-102 (Grants and Cooperative Agreements with State and Local Governments), A-123 (Management Accountability and Control), A-136 (Financial Reporting Requirements). Reports/procedures/activities: USDA Financial Statement audits; Program management evaluations; Federal Financial management reviews.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: Program management deficiencies are identified through the annual management evaluations of States and ITOs, the Agency's Management Control Steering Committee, review of audit work conducted by agencies external to FNS, and ongoing review of program operations by Federal program staff. Efforts to improve the FDPIR funding formula, pilot programs to improve food ordering and distribution, and guidance/technical assistance to improve certification practices are all examples of management deficiencies that were identified through these processes. Workgroups composed of FNS, tribal representatives and subject experts have been formed to provide input on the dietary content of food packages and the administrative funding allocation method.

Evidence: Closure (02/04) of report #27601-6-KC based upon demonstrable improvement; FNS management evaluations (MEs). OIG Audit Report #27601-6-KC, issued June 1997, found that income in some participating households exceeded program guidelines; some households were participating simultaneously in FSP and FDPIR; and commodity and storage issuance procedures needed improvement. Corrective action taken by the Department in response included providing additional guidance to ITOs and State agencies regarding proper certification procedures, including eligibility determinations and verification, and focusing the attention of management evaluations for a two-year period on the certification process.

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: USDA also conducts management evaluations of FDPIR every 3 years. As part of the management reviews, FNS reviews program operations at the ITO/State agency level to evaluate the effectiveness of the ITO/State agency in meeting the plan of operation and applicable policies, instructions, and regulatory requirements, and in providing efficient service to participants. The areas of review may include outreach activities, staffing, training, financial accountability and controls, certification and issuance procedures, program monitoring activities, complaints and fair hearing procedures, commodity ordering procedures, warehousing facilities and practices, recordkeeping and reporting, and civil rights compliance. Finally, program regulations require ITOs/State agencies to regularly monitor and review its operations, and local agency operations, as appropriate, at least annually to ensure compliance with all the requirements for administration of the program. Program deficiencies must be documented and corrective actions plans initiated. Program reviews and corrective action plans must be made available to FNS.

Evidence: Management Evaluation and Reviews; Food Distribution Program on Indian Reservations Regulations; FNS Handbook 501.

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: FNS collects and publishes on the FNS website annual data on FDPIR participants by State. No other grantee performance data is currently made widely available to the public.

Evidence: FDPIR State-level participation data may be found at the following FNS website link: www.fns.usda.gov/pd/fdpmain.htm.

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: FDPIR has made progress in reducing the percentage of fat in the FDPIR food package with the introduction of new low-fat foods in the food package since 1998 and expansion of the Fresh Produce Program. The percentage of fat in the FDPIR food package declined from 31.9% in 1996 to 30.1% in 2005. However, the percentage of saturated fat has remained relatively steady at around 13.4%. The ongoing food package review is anticipated to further reduce the percentage of calories obtained from fat and saturated fat in keeping with the dietary guidelines. FNS has set a new goal to reduce average FDPIR inventory levels. Data has not been provided to assess progress over prior years.

Evidence: Food and Nutrition Service, 2005-2007 Explanatory Notes; Internal Planning Documents.

Does the program (including program partners) achieve its annual performance goals?

Explanation: The current food package has not changed since 2002. Implementation of recommended changes that emerge from the ongoing food package review will enable the program to meet this goal. Measures of improvement in the average FDPIR inventory have only been recently developed with 2005 as the baseline. FNS recently approved expansion of a piloted approach for ordering and delivery of commodities which should improve inventory levels and storage costs.

Evidence: Food and Nutrition Service, 2005-2007 Explanatory Notes; Internal Planning Documents; Kamara, Sheku (2004). An Evaluation of the Prime Vendor Pilot of the Food Distribution Program on Indian Reservations. Nutrition Assistance Program Report Series, No. FDD-04-PVP, U.S. Department of Agriculture, Food and Nutrition Service, Alexandria, VA.

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: FNS has committed to tracking and working to achieve annual reductions in average FDPIR inventory levels. This is a new measure with a baseline set in 2005. USDA has not provided data comparing 2005 inventory levels to 2004 levels.

Evidence: FNS has committed to reducing average FDPIR inventory levels from 90 days in 2005 to 60 days in 2012.

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: FDPIR likely continues to be more accessible than the Food Stamp Program for many FDPIR participants. A 1990 FDPIR study, though dated, found that in most regions, 20 to 30 percent of FDPIR households would have to travel more than 20 miles to the nearest grocery store that sold fresh meat and produce and 30 to 40 percent of participants would have to travel more than 20 miles to a FSP office. However, FDPIR is less able to accommodate special dietary needs than the Food Stamp Program. In FY 2005, average per person administrative costs in FDPIR were $20.17, which was significantly higher than the Food Stamp Program ($7.75) and CSFP ($4.71). Compared to CSFP, FDPIR generally uses more paid staff and fewer volunteers, and operates more in rural areas where it is more costly, per participant, to distribute commodities.

Evidence: Usher, C.L., D.S. Shanklin, and J.B.Wildfire. 1990. Evaluation of the Food Distribution Program on Indian Reservations (FDPIR). USDA, Food and Nutrition Service. HHS, ACF, OFA, Division of Tribal TANF Management. 2006. Characteristics of Tribal TANF Programs as of October 1, 2002. ww.acf.hhs.gov/programs/dts/ttanchar_1002.htm

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: There have been no impact evaluations of FDPIR. A 1990 national evaluation of FDPIR provided information on program operations, and participant characteristics, including dietary needs. Other available research provides information on the role of the FDPIR in the food supply in Indian reservations, characteristics of the diets of various subgroups of Native Americans, and information on specific health issues facing Native Americans (though not specific to those on reservations). The general finding is that concerns about nutrient intakes of Native Americans largely reflect those of the overall population. Native American's overall scores on the HEI ere not significantly different than the rest of the U.S. population Since FDPIR is the primary source of food for many Native Americans on reservations, these findings suggest that the diet provided by FDPIR is reasonably effective, though in need of improvement.

Evidence: Fox, M. et. al. 2005. Evaluation the Impact of Food Assistance and Nutrition Programs: Summary of the Literature Review. USDA, Economic Research Service. Basiotis, P. et. al. 1999. The Diet Quality of American Indians: Evidence from the Continuing Survey of Food Intake by Individuals. Nutrition Insights 12 (March 1999). Finegold, K. et al. 2005, Background Report on the Use and Impact of Food Assistance Programs on Indian Reservation. USDA, Economic Research Service.