Proprietary HSG Frameworks
Five named methodologies HSG brings to the FFP transition.
Each framework operationalizes a PWS scope area through (a) an analytical innovation specific to HSG's approach, (b) a bench credibility anchor on the senior team, and (c) a federal-defensibility anchor on externally-documented Government classifications and non-discretionary statutory / regulatory provisions. The frameworks are named deliberately — they are auditable methodological objects USDA can adopt, train against, and survive Congressional / OIG scrutiny with.
Enhanced Bellmon Framework
Three-tier extension of the statutory Bellmon Amendment that operationalizes the America First doctrine at the commodity-decision level.
PWS Anchor: Prepositioned Commodities (PWS 3.2) and Geography & Commodity Prioritization (PWS 3.4). Applied to every monetization-funded commodity decision.
Bench Credibility Anchor
Maurice W. House (Bilateral-trade career, 38 yrs FAS) + Kevin Latner (Food for Progress monetization) + Audrey McGuire (capital-markets composite scoring)
Three-anchor methodology with distinct contributing disciplines.
Maurice's bilateral-trade-policy career across six FS postings anchors the Tier 2 commercial-displacement analysis; Kevin's Food for Progress monetization market-assessment work parallels the Tier 1 statutory screen; Audrey's capital-markets portfolio-allocation discipline structures the Tier 3 composite scoring.
Federal-Defensibility Anchors
- ›P.L. 480 § 403 (Bellmon Amendment, 1977) — Tier 1 statutory authority preserved
- ›FFPIB 13-03 (Bellmon Estimation Guidance, 2013) — methodology baseline
- ›FFPIB 23-01 (Bellmon Estimation Update for Inflation) — inflation-adjusted disincentive thresholds
- ›Treasury OFAC sanctions program list — Tier 3 strategic-classification anchor (non-discretionary)
- ›USTR Free Trade Agreement registry — Tier 3 ally-classification anchor (non-discretionary)
- ›DoD National Defense Strategy (current cycle) — Tier 3 strategic-competitor designations
- ›State Department MNNA + treaty-ally registry — Tier 3 treaty-ally designations
Operational Problem the Framework Solves
FFP's statutory Bellmon screen — required before any monetization-funded commodity decision — is methodologically rigorous on the recipient-country side but silent on third-country commercial-displacement effects (a Tier 2 question) and U.S. strategic-relationship implications (a Tier 3 question). The administration's America First doctrine, operationalized through the State Department's 31-MOU Global Health Strategy template ($20.6B, 38% recipient co-investment), explicitly requires bilateral-relationship-aware foreign-aid programming. The Enhanced Bellmon Framework supplies the missing analytical layers without modifying the statutory screen.
Analytical Innovation
The statutory Bellmon Amendment screens for recipient-country market disruption. The Enhanced Bellmon Framework extends the screen along two additional axes: (Tier 2) third-country commercial-displacement effects on U.S. ally exporters, modeled against USDA FAS GATS bilateral export flows and UN Comtrade cross-validation; and (Tier 3) U.S. strategic-alignment overlay, anchored on externally-documented Government designations (OFAC, FTA, NDS, MNNA) so the framework requires zero discretionary judgment to apply. Composite output is a single tri-color signal (proceed / coordinate / hold) per commodity-country combination.
Framework Pillars
PILLAR 01
Tier 1 — Statutory Recipient Screen
Preserves the Bellmon Amendment unchanged: the donation's market-disruption effect on the recipient country's domestic agricultural producers. Methodology baseline is FFPIB 13-03 with FFPIB 23-01 inflation adjustments. Output: PASS / FAIL against statutory disincentive thresholds.
PILLAR 02
Tier 2 — Third-Country Commercial Displacement
Extends the screen to commercial-trade displacement on U.S. ally exporters. Models bilateral export flows from USDA FAS GATS at HS-10 granularity, cross-validated against UN Comtrade. Flags donations that would compete with allied exporters (Argentina soy, Brazil wheat, Australian beef) for the recipient market. Output: GREEN (no ally displacement) / AMBER (consultation required) / RED (consultation required + bilateral coordination).
PILLAR 03
Tier 3 — U.S. Strategic-Alignment Overlay
Overlays U.S. strategic-relationship classification, anchored on externally-documented Government designations (Treasury OFAC sanctions list, USTR FTA partner list, DoD NDS competitor designations, State MNNA + treaty-ally registry). Each recipient-country donation is classified by what it would mean strategically: humanitarian (Bellmon-positive); ally-supportive (FTA / MNNA / NATO recipient); competitor-pressuring (a donation that displaces strategic-competitor commercial exports into the recipient market). Output: composite alignment score, ANCHORED on documented Government designations so the framework requires zero discretionary judgment to apply.
PILLAR 04
Composite — Tri-Color Signal
PROCEED (all three tiers green) / COORDINATE (any Tier 2 amber or Tier 3 amber → bilateral or interagency coordination required) / HOLD (any Tier 1 fail, Tier 2 red, or Tier 3 sanctioned-counterparty flag). The single signal preserves the statutory rigor of Tier 1 while making the bilateral-relationship implications surfaceable to USDA decision-makers before the commodity decision is made.
Sample Matrix
Sample Composite Output (4 illustrative recipient-commodity combinations)
| Recipient · Commodity | Tier 1 Bellmon | Tier 2 Displacement | Tier 3 Alignment | Composite |
|---|---|---|---|---|
| Bangladesh · HRW Wheat | PASS (well below disincentive) | GREEN (no major ally exporter) | AMBER (MNNA Bangladesh — coordinate) | COORDINATE |
| Yemen · HRW Wheat | PASS | AMBER (Argentina-FTA partner displaced) | AMBER (Houthi FTO — review) | COORDINATE + REVIEW |
| Pakistan · Yellow Peas | PASS (no domestic pulse competition) | GREEN | GREEN (MNNA) | PROCEED |
| Syria · any commodity | n/a | n/a | RED (OFAC sanctioned) | HOLD |
Illustrative. Production methodology runs the full three-tier screen against every candidate recipient-commodity combination on every monetization-funded decision. Tier 2 and Tier 3 inputs use ONLY externally-documented Government classifications — no discretionary judgment.
House Country-Tier Risk Framework
Four-tier operating-environment classification keyed to triangulated State Travel Advisory + DoD threat + OFAC + FFP-specific operational thresholds — defensible, reproducible, anchored on the canonical Tier 4 execution case.
PWS Anchor: Non-Traditional Operating Environments (Risk Management Guide, Deliverable 5, due Month 7). Tiering decision flows downstream to every operational element: required diligence, field-office posture, TPM decision, evaluation methodology.
Bench Credibility Anchor
Maurice W. House
Senior FAS Advisor · Title II SME
Maurice executed the canonical Tier 4 case from his USDA FAS Islamabad post: the first U.S. wheat export to Taliban-led Afghanistan (1996–1998). Six Foreign Service postings across Algiers, Lagos, Islamabad, Bangkok, Beijing, and Brussels supply the operating-environment-tier intuition no other senior bench in the small-business contractor market carries.
Federal-Defensibility Anchors
- ›State Department Bureau of Consular Affairs Travel Advisories (Levels 1–4) — public, continuously refreshed
- ›Treasury OFAC sanctions programs list (38 active programs covering 30+ jurisdictions) — public, official
- ›DoD National Defense Strategy + posture statements — public, official
- ›GAO-17-224 audit-readiness baseline (carry-forward findings)
- ›OMB Circular A-123 / M-16-17 (Enterprise Risk Management) — federal internal-controls baseline
- ›USAID FFP M&E V2.0 Pillars 4, 5, 9 — evaluation methodology inheritance
Operational Problem the Framework Solves
USDA inherits FFP's operating footprint across 30+ countries spanning the full risk spectrum — Bangladesh and Madagascar (Tier 1 stable) through Afghanistan and Yemen-Houthi areas (Tier 4 hostile). Risk-tier decisions drive every downstream operational choice: which diligence level applies, whether direct field presence or third-country embassy lead, whether TPM is required, and what evaluation methodology survives OIG scrutiny. Without a transparent, reproducible tiering methodology, USDA faces ad hoc country-by-country risk language — invitation to political capture, audit findings, and program disruption when a senior official's discretionary read of a country shifts.
Analytical Innovation
FFP-country risk tiering has historically been ad hoc — each country assessed against generic emergency-programming risk language. The House Country-Tier Risk Framework structures the assessment as a 4-tier classification keyed to TRIPLE-ANCHORED non-discretionary Government designations (State Travel Advisory level + DoD threat classification + Treasury OFAC sanctions status) combined with two FFP-specific operational thresholds (host-government engagement viability + implementing-partner personnel safety). Each tier carries documented Required Diligence, Field-Office Posture, and TPM Decision criteria. Re-classification is rule-bound — when any anchor input changes (e.g., Travel Advisory escalation), the tier classification updates mechanically without discretionary review.
Framework Pillars
PILLAR 01
Tier 1 — Stable
Functioning government, full diplomatic access, standard pre-engagement diligence available. State Travel Advisory Level 1–2. Required Diligence: Standard A-123 controls. Field-Office Posture: Direct USDA field presence. TPM Decision: Default to direct monitoring. Example FFP-eligible countries (CY 2026): Bangladesh, Madagascar, Honduras (selected regions).
PILLAR 02
Tier 2 — Constrained
Government partially functional, access restricted by region. State Travel Advisory Level 3. Required Diligence: A-123 controls + supplemental scoping by region. Field-Office Posture: Embassy-based. TPM Decision: Available, case-by-case based on access. Example FFP-eligible countries: Ethiopia, Pakistan, Mali, DRC.
PILLAR 03
Tier 3 — Insecure
Non-state actors active, field access limited. State Travel Advisory Level 4. Required Diligence: Limited-information diligence + senior-advisory sign-off. Field-Office Posture: Third-country embassy lead. TPM Decision: REQUIRED. Example FFP-eligible countries: Sudan (RSF/SAF areas), South Sudan, Yemen (excluding Houthi-FTO areas), Somalia, Burkina Faso.
PILLAR 04
Tier 4 — Hostile
Active conflict, sanctioned regime, or non-recognized counterparty. State Travel Advisory Level 4 + Treasury OFAC active sanctions or DoD threat classification. Required Diligence: Senior leadership + interagency clearance + OFAC review. Field-Office Posture: Region-managed; no in-country presence. TPM Decision: REQUIRED + remote monitoring + senior review per shipment. Example FFP-eligible countries: Afghanistan (Taliban), Yemen (Houthi-FTO areas per EO 14175 Jan 2025), Syria (OFAC), Iran (OFAC), North Korea (OFAC). The canonical Tier 4 case — Maurice House's first U.S. wheat export to Taliban-led Afghanistan from Islamabad — is the precedent USDA inherits as proof-of-execution-possibility.
Sample Matrix
Tier × Country Application (current FFP operating footprint, CY 2026)
| Country | State Adv. | OFAC Status | Tier | Field-Office Posture |
|---|---|---|---|---|
| Bangladesh | Level 2 | No sanctions | Tier 1 — Stable | Direct USDA presence |
| Madagascar | Level 2 | No sanctions | Tier 1 — Stable | Direct USDA presence |
| Honduras | Level 3 (parts) | No sanctions | Tier 1–2 — Mixed | Direct + regional |
| Pakistan | Level 3 | Targeted (Haqqani Network) | Tier 2 — Constrained | Embassy-based |
| Ethiopia | Level 3 | Targeted (Tigray-era sanctions) | Tier 2 — Constrained | Embassy-based |
| DRC | Level 3 (E) | Targeted (M23, FDLR designees) | Tier 2–3 — Regional | Embassy + third-country lead |
| Mali | Level 4 | Active (Wagner-related) | Tier 3 — Insecure | Third-country embassy lead |
| Burkina Faso | Level 4 | Targeted (JNIM-related) | Tier 3 — Insecure | Third-country embassy lead |
| Sudan | Level 4 | Active (RSF/SAF designees) | Tier 3 — Insecure | Third-country embassy lead |
| South Sudan | Level 4 | Active (multiple designees) | Tier 3 — Insecure | Third-country embassy lead |
| Somalia | Level 4 | Active (al-Shabaab FTO) | Tier 3 — Insecure | Third-country embassy lead |
| Yemen (excl. Houthi areas) | Level 4 | Active (multiple designees) | Tier 3 — Insecure | Third-country embassy lead |
| Yemen (Houthi areas) | Level 4 | FTO + EO 14175 (Jan 2025) | Tier 4 — Hostile | Region-managed; no in-country |
| Afghanistan | Level 4 | Taliban (non-recognized) | Tier 4 — Hostile | Region-managed; no in-country |
| Syria | Level 4 | Comprehensive sanctions | Tier 4 — Hostile | Region-managed; no in-country |
Sources: State Department Travel Advisory levels (travel.state.gov, current); Treasury OFAC sanctions program list (treasury.gov/ofac); Executive Order 14175 (Jan 2025) reinstating Houthi FTO designation. Tiering re-evaluates mechanically when any anchor input changes — no discretionary judgment required for re-classification.
House R&I Adaptation Framework
Adapts USAID's Refine-and-Implement two-phase DFSA design pattern for USDA FAR Part 16 IDIQ task-order architecture and Food for Progress sister-program execution discipline — preserves R&I's analytical rigor while migrating it into USDA's contracting model.
PWS Anchor: Non-Emergency Programming Planning Guide (Deliverable 9, due Month 9). Applied across all Title II Development Food Security Activities (DFSAs) plus Title V Farmer-to-Farmer integration.
Bench Credibility Anchor
Kevin Latner
Senior FAS Advisor · Food for Progress Monetization SME · Cross-Cutting Programs Lead
Kevin led the commodity-monetization piece of USDA Food for Progress — the sister USDA program to Food for Peace and the closest operational analog to non-emergency Title II programming. Three consecutive USDA FAS MAP/FMD Unified Export Strategy submissions ($25M global program) anchor the cooperator-program template HSG recommends as the structural inheritance vehicle. M.S. Ag Econ + J.D. International Trade Law, UC Davis.
Federal-Defensibility Anchors
- ›USAID FFP Refine & Implement methodology documents (historical) — substrate USDA inherits
- ›FFPIB 14-01 (Refine and Implement Guidance) — operational baseline
- ›P.L. 99-198 § 1505 + 7 USC § 1726 — Title V (Farmer-to-Farmer Program) statutory authority
- ›FAR Part 16.504 — IDIQ task-order architecture under which USDA-side R&I phases map
- ›AGAR 416 (USDA acquisition supplement) — Department-specific task-order administration
- ›OMB Circular A-11 § 200 — program design and integrated budget submission
- ›USDA Food for Progress program documentation — sister-program execution template
Operational Problem the Framework Solves
USAID-era R&I was administered through USAID Acquisition & Assistance instruments — cooperative agreements with PVOs structured around USAID's ADS 303 / ADS 308 frameworks. USDA inherits the methodology but not the contracting substrate. Mechanical inheritance (porting the R&I design pattern as-is) creates partner confusion at the contract-modification touchpoints; abandonment loses the formative-research discipline that R&I's structure was built around. The House R&I Adaptation Framework supplies the bridge: same analytical rigor, USDA-native contracting mechanics, Food for Progress-grade execution discipline.
Analytical Innovation
USAID's Refine and Implement (R&I) two-phase design pattern is operationally elegant — the formative-research phase (Phase 1, typically 12 months) reduces the risk of mid-implementation course corrections that would otherwise consume 25–40% of activity-cycle cost. USDA inherits R&I but does not inherit USAID's contracting model. The House R&I Adaptation Framework preserves Phase 1 / Phase 2 / Evaluate analytical rigor while migrating the decision-gate architecture from USAID Acquisition & Assistance instruments into USDA's FAR Part 16 IDIQ task-order model — formal stop/go decision gates between phases become contract modification authorities, baseline studies become Government-furnished data, and the Phase 1 → Phase 2 review becomes a structured option-exercise decision the Contracting Officer makes against documented criteria.
Framework Pillars
PILLAR 01
Phase 1 — Refine (12 months typical)
Formative research, technical refinement, Phase-2 implementation plan, baseline study design. Outputs: refined activity design + baseline study + Phase 2 implementation plan. USDA contracting layer: ordered as a Phase-1 task order against the FAR Part 16 IDIQ master, with formal stop/go decision-gate criteria embedded in the task-order quality assurance surveillance plan.
PILLAR 02
Phase 1 → Phase 2 Decision Gate
Contractor-prepared Phase-1 deliverable package (refined activity design + baseline + plan) reviewed against documented decision criteria. Contracting Officer exercises the Phase-2 option, modifies the Phase-2 scope based on Phase-1 findings, or terminates if findings indicate the activity design will not achieve the desired outcome. This is the operational core — preserves R&I's stop/go discipline while migrating it into a USDA-native contract action.
PILLAR 03
Phase 2 — Implement (48 months typical)
Refined-approach implementation, routine M&E per USAID FFP M&E V2.0 pillars 3–5, mid-term evaluation. USDA contracting layer: separately scoped task order(s) issued after Phase-2 option exercise, with mid-term evaluation gates structured as contract modifications informed by Recurrent Monitoring Studies (Pillar 5).
PILLAR 04
End of Activity — Evaluate (6–12 months)
Final evaluation against baseline; lessons-learned report; portfolio-learning rollup. Outputs feed forward into next-cycle Phase-1 design decisions. Sister-program template: Kevin Latner's Food for Progress monetization-portfolio rollups supply the USDA-side template (vs USAID-side FANTA / Tufts academic-partner cycle).
Sample Matrix
Refine-and-Implement Decision-Gate Architecture under USDA FAR Part 16 IDIQ
| Phase | Duration | Activities | Outputs | USDA Contracting Action |
|---|---|---|---|---|
| Phase 1 — Refine | 12 months (typical) | Formative research; technical refinement; Phase-2 plan; baseline study | Refined activity design + baseline + Phase-2 plan | Phase-1 task order under FAR 16.504 IDIQ |
| Phase 1 → Phase 2 Gate | Decision point (~30d) | CO review of Phase-1 outputs against task-order QASP criteria | Option exercise / modification / termination | Contract modification (FAR 43) |
| Phase 2 — Implement | 48 months (typical) | Refined-approach implementation; routine M&E (V2.0 Pillars 3–5); mid-term | Implementation outputs + mid-term findings | Phase-2 task order(s) under same IDIQ |
| Mid-Term Evaluation Gate | Decision point (~45d) | CO + technical review of mid-term against task-order QASP | Scope modification / continuation / re-design | Contract modification (FAR 43) |
| Evaluate (End of Activity) | 6–12 months | Final evaluation against baseline; lessons-learned; portfolio rollup | Final evaluation + portfolio-learning | Closeout task order under same IDIQ |
FAR Part 16.504 IDIQ task-order architecture preserves R&I's stop/go discipline while migrating it into a USDA-native contracting model. Sister-program execution template: USDA Food for Progress portfolio-rollup methodology (Kevin Latner's direct execution lane). USDA Food for Progress remains the closest in-house USDA structural analog and the recommended migration template.
House 22 CFR → USDA Regulatory Crosswalk
Per-section USAID 22 CFR (Parts 211 / 226 / 228) → USDA Title 7 + 2 CFR 200 + FAR-AGAR mapping with gap flags. Replaces a regulatory transition that has historically been handled ad hoc with a documented section-by-section inheritance disposition.
PWS Anchor: Programmatic Infrastructure Guide (Deliverable 10, HSG-proposed acceleration to Month 10 from PWS Month 11). Crosswalk is the methodologically most consequential single output of the deliverable — drives every downstream USDA regulatory determination on FFP.
Bench Credibility Anchor
Jelani House
Engagement Manager · COR Liaison · Training & Handover Lead
18 years of federal-financial-advisory regulatory execution at HUD/FHA Office of Asset Sales (2006–2024) at Novad and Guidehouse within a 20-year federal-advisory career. Anchored on 2 CFR Part 200 (Uniform Guidance) administration, FAR Part 25 (Buy American + foreign acquisition), and Department-specific regulatory supplement work — the same family of crosswalk operations the FFP transition requires at the USAID 22 CFR → USDA Title 7 / 2 CFR 200 / FAR-AGAR interface.
Federal-Defensibility Anchors
- ›2 CFR Part 200 (OMB Uniform Administrative Requirements) — USDA-internal grants administration baseline
- ›FAR Part 25 — federal acquisition foreign-source / origin rules
- ›AGAR Subpart 425 — USDA acquisition supplement Buy American implementation
- ›AGAR 452.203-71 — Anti-Discrimination and DEI Compliance certification
- ›OMB M-25-21 / M-25-22 (April 2025) — federal AI acquisition framework
- ›Executive Order 14179 (April 2025) — Removing Barriers to American Leadership in AI
- ›GAO-17-224 — audit-readiness baseline
- ›Section 508 of the Rehabilitation Act (29 USC § 794d) — federal IT accessibility
Operational Problem the Framework Solves
Programmatic Infrastructure is the most under-discussed dimension of the FFP transition and arguably the most consequential. USAID's 22 CFR Parts 211 / 226 / 228 are not USDA-internal regulations — they do not transfer mechanically when authority moves. Procurement decisions, monetization rules, grant administration to PVOs, source/origin classification, Cargo Preference interaction, ADS 300 operational substrate — all of these require explicit USDA-equivalent treatment. Without a per-section crosswalk, USDA contracting officers and grant administrators face a Department-wide regulatory ambiguity surface that invites OIG findings, partner-compliance disputes, and operational delay.
Analytical Innovation
USAID's 22 CFR Parts 211 / 226 / 228 govern commodity donation, grant administration, and procurement source/origin — the regulatory substrate FFP operated under. USDA does not operate under 22 CFR. The House 22 CFR Crosswalk classifies every USAID-side section as INHERITS UNCHANGED (statutory authority transfers directly), INHERITS WITH MODIFICATION (substantive coverage exists at USDA but supplemental guidance required), REPLACES VIA USDA-EQUIVALENT (USDA-internal regulation supersedes), or GAP (no USDA-side coverage; new rulemaking or AGAR amendment required). Each classification carries a defensibility anchor and a recommended USDA-side migration vehicle (Departmental Regulation series, AGAR amendment, internal guidance memorandum). The crosswalk eliminates the ad hoc 'figure it out as we go' regulatory posture that creates compliance ambiguity through the transition.
Framework Pillars
PILLAR 01
22 CFR Part 211 — Commodity Donation Rules
Governs all Title II commodity donations: programs, distribution and use, sale proceeds (monetization). USDA-equivalent: new USDA framework required — recommend Departmental Regulation series with FAS-internal directive layer. No existing 7 CFR coverage. Vehicle: Departmental Regulation + Federal Register rulemaking on key provisions; interim USDA-issued guidance memorandum authority for transition continuity.
PILLAR 02
22 CFR Part 226 — Grant Administration to PVOs
Pre-award eligibility and post-award compliance for PVO partners. USDA-equivalent: 2 CFR Part 200 (Uniform Guidance) covers most subject matter directly + USDA-internal grants policy supplements. Vehicle: 2 CFR 200 inheritance + USDA-grants-policy supplement targeting FFP-specific provisions. ADS 303 (USAID grants policy) maps to USDA Departmental Regulation series.
PILLAR 03
22 CFR Part 228 — Procurement Source / Origin
Source-eligibility, Cargo Preference interaction, specialty-rule waivers. USDA-equivalent: FAR Part 25 + AGAR Subpart 425 substantially cover the framework; specialty rules (RUTF, fortified blends) require USDA-internal guidance. Geographic Code 935 → FAR / AGAR foreign-source eligibility framework. Vehicle: FAR Part 25 inheritance + AGAR amendment if needed + USDA-internal specialty-rules guidance.
PILLAR 04
ADS Series 300 — Operational Substrate
USAID Automated Directives System — operational handbook for Acquisition & Assistance. USDA-equivalent: USDA Departmental Regulation series + AGAR + USDA-internal directives. Per-ADS-chapter mapping required (303 Grants, 308 Public International Orgs, 312 Commodity Eligibility, 313 Procurement Source/Origin, 314 Sales Contracts, 315 Country and Geographic Codes, 317 Acquisition and Assistance Risk Management, 320 Branding). Vehicle: USDA-internal directive series + AGAR amendments where needed.
Sample Matrix
Per-Section Crosswalk (USAID source → USDA equivalent → status)
| USAID Source | Subject | USDA Equivalent | Status Flag | Vehicle |
|---|---|---|---|---|
| 22 CFR Part 211 | Commodity donation rules | (none — new USDA framework required) | GAP | Departmental Regulation + FR rulemaking |
| 22 CFR § 226.21 | Grant award financial management | 2 CFR § 200.302 | INHERITS UNCHANGED | Direct 2 CFR 200 reference |
| 22 CFR § 226.25 | Cost-sharing or matching | 2 CFR § 200.306 | INHERITS UNCHANGED | Direct 2 CFR 200 reference |
| 22 CFR § 226.40–.49 | Procurement standards | 2 CFR § 200.317–326 | INHERITS UNCHANGED | Direct 2 CFR 200 reference |
| 22 CFR § 226.50–.53 | Reports and records | 2 CFR § 200.327–344 | INHERITS WITH MODIFICATION | 2 CFR 200 + FFP-specific supplement |
| 22 CFR Part 228 | Procurement source / origin | FAR Part 25 + AGAR Subpart 425 | INHERITS WITH MODIFICATION | FAR 25 + AGAR + specialty guidance |
| 22 CFR § 228.10 (waivers) | Source-rule waivers | FAR 25.1101 + AGAR 425.1101 | REPLACES VIA USDA-EQUIVALENT | AGAR amendment + USDA internal guidance |
| ADS 303 | Grants and Cooperative Agreements | USDA Departmental Regulation 2018-704 series | REPLACES VIA USDA-EQUIVALENT | Departmental Regulation |
| ADS 308 | Awards to Public International Orgs | (USDA-internal directive required) | GAP | Departmental Regulation + WFP MOU |
| ADS 312 | Eligibility of Commodities | (USDA-internal directive required) | GAP | Departmental Regulation + AGAR if needed |
| ADS 313 | Procurement Source/Origin | FAR Part 25 + AGAR Subpart 425 | REPLACES VIA USDA-EQUIVALENT | FAR / AGAR |
| ADS 315 | Country and Geographic Codes | FAR 25.003 + AGAR equivalent | INHERITS WITH MODIFICATION | FAR + AGAR amendment |
| ADS 317 | A&A Risk Management | OMB Circular A-123 + AGAR | INHERITS WITH MODIFICATION | OMB / AGAR + House Country-Tier framework |
| ADS 320 | Branding and Marking | (USDA-internal directive required) | GAP | Departmental Regulation + Section 508 |
Per-section crosswalk methodology — production version covers full 22 CFR Parts 211 / 226 / 228 line by line plus full ADS 300 series (303, 308, 312, 313, 314, 315, 317, 320). Status flags: INHERITS UNCHANGED (statute or rule transfers directly), INHERITS WITH MODIFICATION (substantive USDA coverage exists; FFP-specific supplement required), REPLACES VIA USDA-EQUIVALENT (USDA-internal regulation supersedes), GAP (no USDA-side coverage; new rulemaking or AGAR amendment required). Each USAID provision gets exactly one flag + vehicle recommendation.
Four-Stage Graduation Pathway
Four-stage country classification (acute → sustained → recovery → graduation) operationalizing NOFO Reform 3's off-boarding-and-graduating doctrine — the analytical bridge from FFP 1.5 (NOFO baseline) toward FFP 2.0 (bilateral co-investment).
PWS Anchor: Geography & Commodity Prioritization (Country Selection Guide, Deliverable 6, due Month 2 — the earliest substantive deliverable) and Cross-Cutting Non-Emergency Programming (Deliverable 9). Provides the country-stage classification methodology that drives every downstream programming-intensity, reporting-cadence, and graduation-trigger decision.
Bench Credibility Anchor
Diana L. Caley
Senior M&E Advisor and Training Lead
Author of the USAID FFP Emergency Indicator Handbook (199 indicators) — the predecessor framework from which the FY25 NOFO's nine standard performance indicators descend — and co-author of the BHA M&E Technical Guidance. $920M FFP portfolio M&E oversight in DRC, Uganda, and Bangladesh; direct field experience in three of the seven FY25 NOFO priority countries (DRC, Kenya, Rwanda); active U.S. Government Top Secret clearance. Diana co-leads with Maurice House.
Federal-Defensibility Anchors
- ›FY25 NOFO §1.1 (Reform 3 verbatim) — 'USDA will regularly monitor and evaluate projects on the ground with the goal of off-boarding and graduating projects, ensuring that Title II funding prioritizes emergency and in-need geographies rather than forever aid countries.'
- ›FY25 NOFO §3.2 — seven priority country baseline (DRC, El Salvador, Ethiopia, Guatemala, Haiti, Kenya, Rwanda)
- ›FY25 NOFO §4.2 — nine standard performance indicators + custom indicators authority
- ›FY25 NOFO §4.2.4 — Sphere 2018 ration standards (2,100 kcal/person/day) anchor for Stage 1 acute response
- ›IPC (Integrated Food Security Phase Classification) — UN-system phase scale anchor (Stage 1 entry = IPC Level 3 or above)
- ›UNHCR refugee status declarations — Stage 1 entry trigger (sudden-onset humanitarian crisis)
- ›USAID FFP M&E Policy V2.0 — operational substrate Diana authored predecessor documents for
Operational Problem the Framework Solves
NOFO Reform 3 commits USDA to ending 'forever aid countries' but does not specify the methodology by which a country is classified as ready for off-boarding or graduation. Without an explicit stage-classification framework, USDA faces the same ad hoc country-by-country judgment that produced the forever-aid pattern Reform 3 is designed to terminate. The Four-Stage Graduation Pathway provides the methodology: stage entry criteria anchored on UN-system and U.S.-government classifications, stage exit triggers documented at program-design time, and reporting cadence calibrated to stage so USDA can demonstrate against Congressional and OIG inquiry that the graduation discipline is being executed.
Analytical Innovation
Title II country selection has historically been a list-based judgment: countries are on the list, or not, by the appropriations cycle's political negotiation. The Four-Stage Graduation Pathway re-frames country selection as a stage-classification methodology: each country has a documented stage profile (acute / sustained / recovery / graduation), entry criteria anchored on non-discretionary externally-documented designations (IPC Level 3, sudden-onset declarations, UNHCR refugee thresholds), reporting cadence calibrated to stage (quarterly / semi-annual / annual / closeout), and a documented graduation trigger that moves a country off the active Title II commitment list. The pathway operationalizes NOFO Reform 3 verbatim — the off-boarding-and-graduating doctrine becomes a methodology USDA can execute, audit, and defend, rather than a policy commitment without execution architecture.
Framework Pillars
PILLAR 01
Stage 1 — Acute Emergency
Country / sub-region facing sudden-onset humanitarian crisis. Entry triggers: IPC Level 3 or above, UNHCR sudden-onset declaration, or NOFO-eligibility statutory criterion satisfied. Programming intensity: maximum (full Title II commodity response anchored on Sphere 2018 ration standards, 2,100 kcal/person/day per FY25 NOFO §4.2.4). Reporting cadence: quarterly with nine NOFO standard indicators + acute-emergency custom indicators per NOFO §4.2. Field-office posture: maximal direct support. Example CY2026: Haiti, DRC (selected sub-regions).
PILLAR 02
Stage 2 — Sustained Emergency
Long-running food insecurity where Stage 1 conditions persist beyond a single award cycle. Programming intensity: maintained (full commodity response continues; programming begins to integrate Stage 3 transition planning). Reporting cadence: semi-annual with nine NOFO standard indicators + sustained-emergency tracking indicators. Strategic-alignment overlay (Enhanced Bellmon Framework Tier 3) maintained to track whether the recipient country's status has shifted relative to U.S. strategic interest. Example CY2026: Ethiopia, DRC (broader portfolio).
PILLAR 03
Stage 3 — Recovery
Acute conditions resolving; recipient country agricultural and food-system capacity rebuilding. Programming intensity: declining commodity quantity; increasing capacity-building, Title V Farmer-to-Farmer integration, and bilateral co-investment readiness scoring (FFP 2.0 trajectory). Reporting cadence: annual with NOFO standard indicators + recovery-transition tracking indicators (recipient-country counterpart contribution capacity, agricultural-capacity rebuilding milestones). Cooperator-program framework activates. Example CY2026: Rwanda, El Salvador, Guatemala, Kenya (recovering regions).
PILLAR 04
Stage 4 — Graduation
Documented exit. Recipient country meets graduation criteria established at program-design time: agricultural-capacity threshold, counterpart-contribution viability, market-anchored food-security indicators sustained over prior cycle. Programming: closeout phase with multi-year transition support if FFP 2.0 bilateral co-investment agreement structures a counterpart-funded continuation. Reporting cadence: closeout report + retrospective evaluation. The off-boarding-and-graduating discipline NOFO Reform 3 commits USDA to is operationalized at this stage. No country exits without explicit Stage 3 → Stage 4 documentation.
Sample Matrix
FY25 NOFO Seven-Country Stage Classification (illustrative)
| Country | Current Stage | Stage Anchors | Reporting Cadence | Graduation Horizon |
|---|---|---|---|---|
| DRC | Stage 1 (acute) + Stage 2 (sustained components) | IPC Level 4 sub-regions; ongoing conflict; $920M historical Title II | Quarterly | Multi-cycle; Stage 3 transition tied to security resolution |
| El Salvador | Stage 3 (recovery) | IPC Level 2; high host-gov cooperation; strong agricultural capacity | Annual | Within 2 NOFO cycles; FFP 2.0 bilateral co-investment candidate |
| Ethiopia | Stage 2 (sustained) | IPC Level 3 in select regions; growing soy production; regional recovery | Semi-annual | Multi-cycle; sub-national Stage 3 transitions emerging |
| Guatemala | Stage 3 (recovery) | IPC Level 2; high host-gov cooperation; agricultural and CAFTA-DR ties | Annual | Within 2 NOFO cycles; FFP 2.0 bilateral co-investment candidate |
| Haiti | Stage 1 (acute) + extended Stage 2 | Political instability; insecurity; gang control of distribution channels | Quarterly | Multi-cycle; conditional on political resolution |
| Kenya | Stage 2 → Stage 3 transition | IPC Level 2–3 in select regions; strong host-gov; agricultural capacity | Semi-annual | Within 2 NOFO cycles for graduating regions |
| Rwanda | Stage 3 (recovery) → Stage 4 (graduation candidate) | IPC Level 1–2; very high host-gov cooperation; market-anchored capacity | Annual | Within 1–2 NOFO cycles; strongest FFP 2.0 bilateral co-investment candidate |
Stage classifications illustrative for methodology demonstration only. Production methodology re-runs classification quarterly against documented entry triggers (IPC scale, UN declarations, NOFO statutory criteria) so each classification is reproducible and auditable. Graduation horizon estimates are conditional on the entry triggers persisting at their classified state.
Why Named Frameworks Matter
Auditable methodological objects, not consulting-speak.
Federal advisory work that survives OIG, Congressional, and public scrutiny needs methodological objects that are nameable, reproducible, and auditable. Generic process descriptions do not survive any of those tests. Each Enhanced Framework above is structured to:
- ›Have a defined analytical innovation — something a USDA analyst can point to as structurally different from ad hoc decision-making
- ›Anchor on a specific named senior bench member with a documented career record backing the credibility — not an abstract HSG team
- ›Defer every classification decision to externally-documented Government designations (OFAC, FTA, State Travel Advisory, DoD NDS, MNNA) so the framework requires zero discretionary judgment to apply
- ›Map directly to PWS scope language so each framework operationalizes a specific deliverable rather than floating as an unanchored consulting concept
USDA inherits these frameworks at engagement closeout. The training curriculum (PWS 3.7) drills USDA staff on each framework against a 90% competency threshold. The post-engagement reference archive contains the methodology specifications, the sample matrices, and the AI/Expert Reconciliation Log evidence trail per framework application during the engagement.