September 6, 2018
The Honorable Sonny Perdue
Secretary of Agriculture
U.S. Department of Agriculture
1400 Pennsylvania Ave SW
Washington, DC 20250
The Honorable Stephen Censky
Deputy Secretary of Agriculture
U.S. Department of Agriculture
1400 Pennsylvania Ave SW
Washington, DC 20250
Dear Secretary Perdue and Deputy Secretary Censky:
The Academy of Nutrition and Dietetics, the world's largest organization of food and nutrition professionals, is committed to improving the health of Americans by ensuring access to a nourishing, safe and affordable food supply. Representing more than 100,000 credentialed practitioners, the Academy is committed to offering preventive and medical nutrition therapy services in a variety of settings, leading cutting-edge nutrition research, in addition to ensuring that quality nutrition services and education are integral components of food and nutrition assistance programs.
The Academy respectfully opposes USDA's recent proposal to relocate both the Economic Research Service and the National Institute of Food and Agriculture outside of the National Capital Region.i Specifically, we oppose 1) the USDA’s proposed geographic move of ERS and NIFA without further release of the rationale and cost-benefit analysis and a cross-sector stakeholder dialogue and 2) the extraction of both agencies from USDA’s Research, Education and Economics mission area.
The Academy is grounded in an evidence-based scientific portfolio that informs development and enhancement of food and nutrition services and programs, ensures high-quality, systematic monitoring and evaluation of food and nutrition services and programs and provides guidance for structuring and strengthening patient and consumer education delivery systems. To support this portfolio, the Academy and our members heavily rely on the food and nutrition research programs, resources, data and statistical resources provided by ERS and NIFA. For example:
- Food insecurity affects millions of Americans every year – from children to seniors, veterans and active duty military, families and people with disabilities. Academy members extensively use food security, food access and diet quality and nutrition statistical resources from ERS to ensure food and nutrition services are meeting the needs of economically disadvantaged populations.
- Behavioral economics and social determinants of health have become essential tools in the nutrition practitioner’s toolbox and data sets such as consumer nutrition information and labeling and food consumption trends produced by ERS are invaluable when designing, delivering and evaluating evidence-based food and nutrition programs and services. Data provided by ERS are instrumental in evaluating programs and services against benchmarks and desired outcomes to demonstrate cost-effectiveness.
- Thousands of Academy members execute NIFA's research, education and extension initiatives which touch the lives of millions of individuals. This is specifically accomplished through grant programs that increase access to and consumption of fruits and vegetables; research on effective nutrition education and obesity prevention strategies, interventions and translational activities; 4-H programming that promotes positive health and well-being; cooperative extension programs focused on individual and community-based nutrition education services; as well as domestic and global food security initiatives.
- A significant number of land grant institutions provide accredited undergraduate programs in dietetics, dietetic internships or graduate programs in dietetics, food science and human nutrition. Current and future dietetic graduates and interns benefit from NIFA's commitment to building research and extension capacity via scholarships, research funding and outreach.
To maintain the integrity and quality of these agencies avoid increasing the regulatory burden associated with the proposed relocation, the Academy requests:
- Retain both ERS and NIFA in the National Capital Region until a thorough cost benefit analysis is conducted and made public by the Congressional Budget Office, General Services Administration and the USDA Office of Budget and Program Analysis.
- ERS and NIFA employ highly skilled technical, scientific and management staff and relocating outside of the National Capital Region would undoubtedly result in significant loss of intellectual and technical capital and undermine staff recruitment, retention and diversity inclusivity for both agencies.
- Maintaining ERS and NIFA in the National Capital Region will retain a high degree of flexibility, coordination and efficiencies among scientific societies (National Academies of Sciences Engineering and Medicine; National Science Foundation); internal stakeholders (National Agricultural Statistics Service, Food and Nutrition Services, Center for Nutrition Policy, Centers for Disease Control and Prevention, Office of Disease Prevention and Health Promotion); external partners such as professional nutrition and health organizations; as well as with policymakers.
- As experienced by other USDA agencies who are not located in the immediate National Capital Region, it is more difficult to maintain visibility, communication, interaction and decision-making opportunities across USDA mission areas and agencies. Likewise, locating agencies outside of the National Capital Region may make the agency, staff and resources less accessible to stakeholders and policymakers. It is important that the agency and staff are able to participate in both inter- and intra-agency dialogues regarding research priorities and funding.
- Issue a Federal Register Notice of a 75-day public comment period on the cost benefit analysis conducted by the aforementioned agencies in #1.
- A public comment period would best reflect the needs of stakeholders within the agriculture, food and nutrition communities.
- Offering a public comment period on a significant reorganization within USDA supports transparency of the decision-making process similar to what has been included in the review process previously.
- Maintain the integrity and independence of ERS and NIFA as research and statistical agencies within the USDA's Research, Education and Economics mission area.
- Ensuring that USDA's initiatives meet the highest levels of integrity and quality requires separation from undue political influence. This requires that ERS and NIFA leadership publish data and report outcomes independent of the political environment.
- It is imperative that research and statistical agencies within Federal government be led by professionals with outstanding scientific credentials.
- Sustain current level funding for ERS in FY2019 appropriations beyond and in the future.
- Proposed budget cuts to ERS would significantly reduce personnel, further impacting the agencies' ability to maintain a robust statistical portfolio. This would have a profound ripple effect across Federal agencies and stakeholders, increasing regulatory burden and hindering policymakers' and stakeholders' abilities to make informed decisions about agriculture, food and nutrition.
We ask USDA to delay this decision to move ERS and NIFA from outside of the National Capital Region until full, transparent deliberation with stakeholders' input can be achieved. Thank you in advance for your consideration of this request.
Mary Russell, MS, RDN, LDN, FAND
Academy of Nutrition and Dietetics