Based on USDA Data, CBO Estimates that Authorizing Tribal Governments to Enter into 638 Contracts for FDPIR will Increase Spending by $380 Million Over Five Years
On August 9, 2024, the Native Farm Bill Coalition's (NFBC) co-chairs sent a letter to the U.S. Department of Agriculture (USDA) requesting information on the data it provided to the Congressional Budget Office (CBO) informing its score associated with making the 638 Food Distribution on Indian Reservations (FDPIR) pilot program permanent.
CBO released its score of the House Agriculture Committee’s 2024 Farm Bill Proposal – H.R. 8467, the Farm, Food, and National Security Act of 2024 – on August 2, 2024. The score came as a shock to the NFBC and Indian Country when CBO reported that USDA-provided data estimated making the pilot program permanent has an estimated cost of $380 million over the 2025-2033 period. CBO’s report reads (emphasis added):
“Section 4102 would permanently allow Indian tribes to administer FDPIR through self-determination contracts between tribes and the federal government. FDPIR provides food procured by USDA to Native American families residing in Oklahoma and to low-income households on Indian reservations. Using information from USDA, CBO anticipates that the cost of food procured by tribes would be 70 percent higher than that procured by USDA. Additionally, CBO expects that by 2033, FDPIR would serve about half of all program participants, or 40,000 people, through self-determination contracts. CBO estimates that enacting the provision would increase direct spending by $380 million over the 2025-2033 period.”
As part of the 2018 Farm Bill, which included the 638 FDPIR pilot program, CBO reported a mere cost of $34 million for FDPIR to accommodate for inflation. It is clear that costs presented to CBO are not premised on inflation, since inflation would equally burden both Tribal and federal procurement.
“It is unclear to us how USDA and CBO came to a cost of $380 million over an eight year period when we are witnessing firsthand the progress being made with the 638 FDPIR pilot sites, which are procuring food locally and building sustainable regional food economies,” said NFBC Co-Chairs Cole Miller, Chairman of the Shakopee Mdewakanton Sioux Community and Kari Jo Lawrence, Executive Director of the Intertribal Agriculture Council. “This analysis clearly ignores the fact that Tribal governments and producers alike have been building local agricultural capacity to best maximize the use of federal dollars supporting FDPIR through 638 agreements. Additional benefits that come from this work are a reduction in transportation costs, impact on the environment, and healthcare costs because Tribal members have access to high quality, nutritious, traditional foods that only Tribal governments can provide.”
638 contacting has long been used as a tool to maximize the use of federal appropriations and authority serving Indians. Because of its success, 638 has bipartisan support throughout Congress.
“Nearly 50 years of experience show that Tribal governments using self-determination and self-governance authorities to administer federal programs do so more effectively and cost-efficiently than the federal government. The Self-Governance Communication and Education Tribal Consortium (SGCETC) is deeply concerned about USDA's reporting to CBO that it will cost 70 percent more for a Tribe that enters into a FDPIR Self-Determination contract to procure food than for the USDA,” said W. Ron Allen, Tribal Chairman/CEO of the Jamestown S’Klallam Tribe and President of the SGCETC Board of Directors. “For years, Tribes have worked to reestablish complex food systems and economies. Tribal Nations are top producers of crops, cattle, and buffalo in some regions, construct and operate meat processing facilities, run successful fish and shellfish hatcheries, and build regional food economies. The belief that USDA is better positioned or more efficient in procuring food for our communities contradicts decades of experience with Tribal self-determination and self-governance.”
After outreach to several 638 FDPIR pilot sites, the NFBC has been unable to determine USDA and CBO’s reason for such a large increase in cost. Until the USDA’s formulas and data are made public, the NFBC and many of the pilot projects remain skeptical of the score’s accuracy.
“Spirit Lake has been participating in the 638 self-determination demonstration project since October 1, 2023, and we have had tremendous success in providing a healthier option of Tribal-grown bison as well as an enhanced variety of products to select from,” said Mary Green Trottier, Spirit Lake’s Director of FDPIR and CSFP and NAFDPIR’s President, “And we have done this all without spending more than the federal government would have spent on serving our Tribal members. USDA’s data and CBO’s analysis is misguided.”
As part of the NFBC’s letter, the NFBC co-chairs requested that USDA share the data they provided to CBO and requested a 30-day response to seven questions which provide additional context into USDA and CBO’s analysis.
“Accurate information is critically important to Indian Country's policy priorities in the Farm Bill,” said Carly Griffith Hotvedt, Interim Executive Director of the Indigenous Food and Agriculture Initiative, the NFBC’s policy and research partner. “CBO's methodology resulting in a surprising 70 percent cost increase estimate for FDPIR 638 Sourcing is unclear and requires additional investigation to determine what criteria, data, and analysis were performed to reach such a large number. IFAI is dedicated to transparency and will be inquiring further to ensure that this successful and popular program is not undercut by misinterpreted data.”
The NFBC looks forward to receiving a prompt response from USDA and are hopeful that the harm done can be rectified. In the meantime, the NFBC is urging its members to weigh in with USDA, the White House, and Congress to address this inaccuracy.
Additional resources:
View the NFBC letter sent to USDA and CBO.
View CBO’s score of the H.R. 8467, Farm, Food, and National Security Act of 2024.
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The Native Farm Bill Coalition (NFBC) brings together Tribes, intertribal organizations, other Native organizations and non-Native allies around the country to advocate with a strong, unified voice to advance investments in Native agricultural production, ranching, nutrition programs, rural infrastructure, economic development, conservation, and forestry. The NFBC is the largest-ever coordinated effort in Indian County around federal food, agriculture and nutrition policy.
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