Transition Architecture

What USAID Did Under Title II — And What USDA Must Now Build

The Food for Peace transition is not a planning exercise. It is already running on an interim-IAA basis with active commodity-procurement decisions in motion and no permanent institutional architecture yet in place. This page consolidates HSG's public-record research and primary-source intelligence from Maurice House (38-year USDA FAS Senior Foreign Service Minister Counselor) into a single architectural picture of the inheritance.

$452M

Feb 3, 2026 USDA-WFP MOU

211K MT

US commodities to 7 countries

$1.2B

FY26 FFP enacted appropriation

$489M

Food aid at risk per USAID OIG (Feb 10, 2025)

Why USDA Is the Structurally Right Home

CCC + FAS = supply-and-request loop USAID administered open for 60 years

SUPPLY SIDE

The Commodity Credit Corporation is already under USDA.

The CCC is the federal financial mechanism that has held US commodity surpluses since 1933. It functions as a price-floor for US producers, accumulating federal inventory whenever market prices remain below the loan rate, and reports excess commodities to Congress and USDA. Title II without CCC is unsourced; CCC without Title II loses one of its principal exit-channels for surplus commodities.

REQUEST SIDE

FAS Attachés receive the country-level requests.

Foreign government allocation requests for P.L. 480 commodities flow primarily through US embassies — and at most major embassies the resident US agricultural representation is a USDA FAS Agricultural Attaché, not a USAID officer. FAS sits at the request-intake end of the system the same way CCC sits at the supply end.

Placing programmatic decision authority at USDA closes the supply-and-request loop. USDA absorption is not displacement — it is structural alignment.

Named USDA Principals on the FFP Transition

Luke Lindberg

Under Secretary for Trade and Foreign Agricultural Affairs

Named USDA principal on FFP transition; led Feb 3, 2026 USDA-WFP MOU announcement ($452M / 211K MT to 7 countries)

Michelle Bekkering

Deputy Under Secretary, Trade and Foreign Agricultural Affairs

Quoted on May 13, 2026 NOFO release; programmatic-framing voice on America First International Food Assistance

The Transition Timeline

Operative facts: Dec 24 IAA → Feb 3 first major obligation → May 13 NOFO → Jun 12 apps → permanent transfer pending.

Dec 24, 2025

USDA / State / OMB Interagency Agreement

IAA

Transferred FFP to USDA for FY2025–FY2026 on interim basis. ~$500M unallocated FY25 + $1.2B FY26.

Feb 3, 2026

USDA-WFP MOU announcement

First obligation

$452M for 211,000 MT of US commodities to DRC, El Salvador, Ethiopia, Guatemala, Haiti, Kenya, Rwanda. First major USDA-led FFP obligation under interim authority.

May 13, 2026

USDA FAS Food for Peace NOFO published

NOFO

Second tranche of funding. Applications due June 12, 2026 5:00 PM EDT. Eligible: public or private organizations including intergovernmental/multilateral orgs.

May 27, 2026

HSG quote due (this RFQ)

RFQ submission

HSG submission for Technical Advisory Support Services on the operational transition. 12-month engagement.

Jun 12, 2026

FFP NOFO applications due

Apps due

Second-tranche programming proposals due to USDA FAS.

Pending

Permanent transfer legislation

Legislation

Farm, Food, and National Security Act of 2026 (H.R. 7567, 119th Congress) — House Agriculture Committee one-pager outlines case for permanent FAS administration.

USAID BHA at Peak — The Inheritance Baseline

8 offices · 3 geographic + 5 technical · approximately 1,000–1,300 staff worldwide across 45+ countries. 90%+ furloughed Feb 2025; dissolved 2025.

Office of Africa (OA)

Geographic

Five geographic divisions: East Africa, Central Africa, Sudans, West Africa, Southern Africa

Office of Asia, Latin America & Caribbean (ALAC)

Geographic

Three geographic divisions: LAC; East Asia & Pacific; South & Central Asia

Office of Middle East, North Africa, Europe (MENAE)

Geographic

MENA + Europe geographic coverage

Office of Technical and Program Quality (TPQ)

Technical

Cross-cutting technical guidance and sectoral expertise; absorbed FFP's technical division

Office of Humanitarian Business and Management Operations

Technical

Financial / grants management and operations

Office of Global Policy, Partnerships, Programs and Communication

Technical

Policy and partnerships

Office of Response and Resilience

Technical

Surge capacity, Disaster Assistance Response Teams (DARTs), Response Management Teams (RMTs)

Office of Humanitarian Operations

Technical

Pipeline and logistics

Sources: CRS R45779 (Transformation at USAID); USAID/BHA 2020 design materials; CSIS 2025 humanitarian-capability retrospective; USAID OIG Feb 10, 2025 advisory.

What's Transferring vs. Terminating

Operational specifics — which Title II functions transfer to USDA, which terminate, which remain ambiguous.

Title II in-kind commodity procurement

USDA AMS ICPD / FSA KCCO already run the commodity buy mechanics — USDA picks up programming-decision authority

transferring

Cargo Preference compliance (46 USC § 55305)

MARAD role unchanged; coordination shifts to FAS

continuing

Food Aid Consultative Group (FACG)

Statutorily preserved under 7 USC § 1725; operationally suspended pending USDA reconstitution

preserved

Bill Emerson Humanitarian Trust (BEHT)

Statutorily preserved under 7 USC § 1736f; already USDA-administered

preserved

McGovern-Dole + Food for Progress

Already USDA FAS-administered — no change

unchanged

DFSA / RFSA grant management (active awards)

Partners report 6-12 month obligation disruption during transition

transferring with discontinuity

FFP M&E Policy V2.0 framework

USDA NOFO uses different structure; M&E architecture rebuild likely

ambiguous

BHA TPM contracts (YMELP II, IMRC, Forcier, Acacia)

Contracts have option-year horizons through April 2029 (YMELP II); USDA novation strategy needed

ambiguous

FFP Bellmon analytical contract (Fintrac/BEST)

Required by statute; USDA must either novate or recompete

ambiguous

BHA Disaster Assistance Response Teams (DARTs)

Terminated at BHA-scale; State PRM retains skeleton

terminated

Resilience programming (RFS/REFS legacy)

RFS dissolved; technical doctrine fragmented

terminated

Counter-terrorism vetting unit (CTU)

OIG noted CTU told not to report to work early 2025; vetting at near-zero

compromised

FAQR (Tufts) academic cycle

Phase III concluded July 2021; USDA inherits launch responsibility for FAQR IV

concluded

USDA Has vs. USDA Must Build

The capability matrix that defines the engagement scope.

USDA Already Has

FAS Office of Capacity Building & Development (OCBD)

Administers McGovern-Dole + Food for Progress NOFOs; NOFO management muscle and PVO grant administration

FAS Office of Global Analysis (OGA)

Commodity supply/demand analytics; WASDE / ICEC; satellite imagery + Attaché reports — direct Bellmon market-disincentive analytics input

FAS Office of Trade Programs

Manages export credit and Food for Progress; statutory and policy framing

FAS Foreign Service Agricultural Attachés (~95 posts)

Resident commodity-market intel; embassy access; Mission-level Title II analytics and partner liaison

USDA AMS Commodity Procurement / ICPD

International Commodity Procurement Division — buys US-produced food aid commodities

USDA FSA Kansas City Commodity Office (KCCO)

Solicits and awards commodity contracts; licenses port facilities (Form WA-50); Title II operations execution

USDA OBPA / OCFO / OIG

Departmental budget, financial management, independent audit

USDA CCC (Commodity Credit Corporation)

Commodity inventory + financing authority; BEHT operations; the financial substrate the entire program runs on (1933)

USDA Must Build

PVO grant management at Title II scale

McGovern-Dole + FFPr together ~$400M/yr vs. Title II ~$1.7-2B; staff scaling needed

Bellmon analytical contract / methodology custody

Tied to Fintrac/BEST + FANTA technical support; needs novation or recompete

DFSA / RFSA closeout + M&E + ARR review

M&E Policy V2.0 is BHA's; USDA must adopt or rebuild

TPM in conflict zones (Yemen, Syria, Sudan, Somalia, NE Ethiopia)

USDA has no operational TPM contract architecture

Counter-terrorism vetting at FFP scale

USDA has no equivalent of USAID CTU (now compromised)

Mission-level FFP-officer presence in non-FAS-served countries

FAS Attachés don't cover every Title II country (South Sudan, Yemen had USAID FFP without FAS Attaché)

Pipeline / commodity tracking system

FFPMIS lives in USAID systems; USDA needs equivalent

FFPIB-equivalent policy-guidance series

USAID FFPIBs need USDA-issued analog

Grantmaking Discipline — The Operating-Model Fit Title II Actually Requires

Title II is grant-based humanitarian aid for the worst-off populations on earth. Approximately 70% of obligations flow to emergency response in failed-state contexts (Sudan, Yemen, Somalia, S. Sudan, DRC, Afghanistan, Haiti). The center of gravity is grantmaking discipline at scale, not commercial trade.

What Title II Structurally Demands of USDA

  • Solicit partner applications via Notice of Funding Opportunity (NOFO)
  • Negotiate cooperative agreements with PVOs and WFP under 2 CFR Part 200
  • Verify indirect-cost rate agreements; manage federal financial reporting
  • Run partner performance-reporting review cycles
  • Validate beneficiary-counting submissions
  • Maintain Single Audit Act compliance posture
  • Monitor partner field activity (direct + third-party)
  • Process amendments, no-cost extensions, close-outs

This is not commodity-trade work in the traditional FAS sense. It is federal grant administration in the foreign-assistance sense. The question is whether USDA already operates that discipline at scale, with the partner ecosystem Title II actually uses.

USDA Already Runs This Operation — At $480M/yr — With The Same Partners

Through the FAS Office of Capacity Building and Development, USDA today administers approximately $480 million per year in cooperative agreements with Private Voluntary Organizations and the World Food Programme under the same 2 CFR Part 200 Uniform Guidance framework that governs Title II.

McGovern-Dole

$240M FY26 enacted

48 active multi-year projects, 35 low-income countries, 2.7M children reached/yr

Food for Progress

$148M commodity value FY25

460K MT US commodities, 8 projects, 6 countries

Section 416(b) + BEHT

Surplus + 1.4M MT reserve

Activated on emergency triggers under 7 USC § 1736f

The grantees are the same legal entities Title II relies on. Catholic Relief Services, Save the Children, World Vision, Mercy Corps, CARE — the top-5 Title II implementing PVOs that collectively hold the majority of non-emergency Title II awards — all already hold McGovern-Dole and/or Food for Progress cooperative agreements through this same USDA FAS office. Same indirect-cost rate agreements. Same Single Audit Act compliance posture. Same federal-grants personnel at the partner orgs interfacing with USDA contracting officers.

And the World Food Programme — the largest single implementer of Title II emergency programming (~60% of historical Title II emergency tonnage) — both receives McGovern-Dole awards through USDA FAS today and is the named counterparty on the February 3, 2026 USDA-WFP $452M MOU. The USDA-WFP financial relationship is active and operational at this moment.

The structural fit

Absorbing Title II into USDA's existing grantmaking operation is not building a new federal-grant-administration capability. It is scaling an existing $480M/yr operation to ~$1.7B/yr — a ~3-4× scaling factor. The operating model, partner ecosystem, regulatory framework, federal-financial-management posture, and multilateral counterparty relationship are unchanged from what USDA already operates today. This is the structural fit Title II actually requires, and it is the structural fit USDA already provides.

Producer-Aid Integration — A Secondary Benefit in the Development-Programming Tail

A tail-dimensional benefit available in ~10-15% of Title II programming — not the program's center of gravity.

Where The Producer-Aid Loop Does Not Apply

The center of gravity of Title II is emergency humanitarian response in failed-state or active-conflict environments — Sudan, Yemen, Somalia, DRC, S. Sudan, Afghanistan, Burkina Faso, Haiti. In these contexts, the U.S. agricultural cooperator network has essentially no commercial-trade presence. There is no functioning consumer market for U.S. Wheat Associates to develop. There is no commercial buyer for the U.S. Grains Council to engage. The food aid is delivered, the people are fed, and the program does what it is structurally for — relieve immediate human suffering. No commercial-market-development overlay applies in this ~85% of the program.

Where The Producer-Aid Loop Does Apply (~10-15% Of The Program)

In the smaller tail of Title II programming that operates in fragile-but-functional middle-income contexts — Bangladesh (SHOUHARDO IV development food security activity), Honduras and Guatemala (parts of the seven-country February 3, 2026 USDA-WFP delivery package and historical DFSAs), Ethiopia non-emergency programming, Madagascar resilience programming, parts of the Sahel non-emergency portfolio — U.S. cooperator activity has meaningful commercial presence.

In these specific contexts, the FAS Office of Capacity Building and Development can coordinate non-emergency Title II programming with parallel FAS MAP / FMD market-development work — building long-term consumer preference for U.S. agricultural commodities in markets that will, as their economies develop, transition from food-aid recipients to commercial customers for U.S. producers. This is what HSG calls the Producer-Aid Loop. It is real, it is structurally only possible under USDA administration, and it applies in approximately the development-programming tail of the Title II portfolio.

Enhanced Bellmon Framework — Honest Treatment

HSG's Enhanced Bellmon Framework treats this dimension appropriately. The framework's first three tiers — statutory market-disincentive screen (P.L. 480 § 403), commercial trade displacement analysis, strategic-alignment classification — apply across the full Title II portfolio, emergency and non-emergency alike. A proposed Tier 4 Producer-Aid Integration dimension applies only to non-emergency Title II programming in contexts where commercial U.S. cooperator activity is present. For emergency programming in failed-state environments, Tier 4 returns null and the program is evaluated on the first three tiers plus core humanitarian-impact metrics. The Enhanced Bellmon Framework is honest about where the Producer-Aid Loop applies and where it does not.

The FFP 2.0 Optioning Framework — Three Trajectories

The FFP transition is not a binary inherit-or-redesign decision. It is a structured option space across three trajectories — Continuity (FFP 1.0), Adaptation (FFP 1.5, the NOFO baseline), and Redesign (FFP 2.0, the deeper structural pivot Reform 3 points toward). The May 13, 2026 NOFO establishes FFP 1.5 as the current operational reality and commits USDA to evolve toward FFP 2.0 over subsequent cycles via the off-boarding-and-graduation doctrine. The Country Selection Guide methodology, the Enhanced Bellmon Framework, and the four-stage graduation pathway are designed to work across all three trajectories.

Continuity

FFP 1.0 — Continuity

Inherit the USAID-era operating model with minimum modification.

FFP 1.0 holds the operational substrate substantially intact as USDA assumes administration. Title II PVOs (CRS, Save the Children, World Vision, Mercy Corps, CARE, and the broader cooperator community) continue under the FAS cooperator-program framework. The M&E architecture Diana L. Caley authored at USAID Office of Food for Peace and the Bureau for Humanitarian Assistance — the Emergency Indicator Handbook, the BHA M&E Technical Guidance, the Performance Indicator Reference Sheets — remains the operating substrate. USDA Departmental Regulations are issued where 22 CFR Parts 211/226/228 inheritance is structurally awkward, but the operating logic of Title II is preserved. This option treats the transition as administrative reassignment rather than programmatic redesign.

Implementation Horizon

Already substantially in place; mostly an administrative wrapper question.

NOFO Relationship

Weakly aligned. The May 13, 2026 NOFO is itself a step beyond pure inheritance — its three reform priorities (100% U.S. origin commodities, strict accountability, off-boarding-and-graduation) move beyond strict continuity. FFP 1.0 is the baseline against which the NOFO's reforms are themselves a partial departure.

AdaptationCurrent Baseline

FFP 1.5 — Adaptation (NOFO Baseline)

Inherit the operational substrate; overlay the three NOFO reform priorities.

FFP 1.5 is the option USDA has actually selected via the May 13, 2026 Notice of Funding Opportunity. The PVO cooperator community, the M&E indicator architecture, and the multilateral channel (the $452M FY25 USDA-WFP MOU) remain the operational backbone — but three substantive reforms are layered on. Reform 1 mandates 100% U.S. origin commodities with cash transfers and food vouchers foreclosed. Reform 2 imposes strict accountability against fraud, waste, abuse, and diversion; Diana L. Caley's authored 199-indicator handbook is the methodological substrate for this. Reform 3 commits USDA to off-boarding and graduating projects rather than maintaining 'forever aid countries' — operationalized through the four-stage graduation pathway HSG proposes. The seven priority countries (DRC, El Salvador, Ethiopia, Guatemala, Haiti, Kenya, Rwanda) are the proof-of-concept tranche. This is the option in flight today, and HSG's engagement is built primarily to support this option.

Implementation Horizon

In flight now (May 13, 2026 NOFO published; applications due June 12, 2026; first USDA-administered award cycle commences after June 2026).

NOFO Relationship

This option IS the NOFO. The three reform priorities, the seven priority countries, the nine standard indicators, the 50% commodity-and-freight budget floor, the Sphere 2018 ration standards, and the off-boarding-and-graduation commitment are all the operational embodiment of FFP 1.5.

Redesign

FFP 2.0 — Redesign (Bilateral Co-Investment Architecture)

Restructure Title II commodity programming as bilateral deal architecture.

FFP 2.0 is the deeper structural redesign option — operationally analogous to the State Department's America First Global Health Strategy template that has produced 31 bilateral Memoranda of Understanding (CY 2026, $20.6 billion in total program value including $7.8 billion in recipient-country co-investment, a 38% counterpart-contribution share). Under FFP 2.0, Title II commodity programming becomes the contributing instrument inside time-bound, jointly-financed bilateral agreements with recipient-country counterpart commitments and explicit graduation pathways. U.S. commodities are economic instruments inside the deal — donated grain, soy, specialty soy products, RUTF, and fortified blended foods are priced contributions toward a jointly-financed program with documented recipient counterparts, not unilateral transfers. Country selection becomes deal-readiness assessment; communications becomes value-chain articulation; non-emergency programming integrates as a complementary deal track. This option requires legislative and regulatory work to operationalize fully and operates on a 24–36 month horizon. It is the structural redesign Reform 3's off-boarding-and-graduation commitment points toward.

Implementation Horizon

24-36 months minimum for full operational implementation; requires legislative and regulatory groundwork. Some elements (graduation-pathway framework, counterpart-readiness scoring) can begin within the current advisory engagement.

NOFO Relationship

FFP 2.0 is the destination Reform 3 points toward. The May 13 NOFO establishes the off-boarding-and-graduation commitment as canonical policy; FFP 2.0 is the structural redesign that operationalizes that commitment fully. The Country Selection Guide methodology HSG delivers under FFP 1.5 — the four-stage graduation pathway, the bilateral co-investment readiness scoring sub-methodology — is the analytical bridge from FFP 1.5 to FFP 2.0.

FFP 1.0 — Continuity

Detailed view

Inherit the USAID-era operating model with minimum modification.

Key Characteristics

  • Title II PVO cooperator community continues largely as-is
  • M&E framework, indicator handbook, and reporting cadence inherited substantially intact
  • Country selection logic anchored to historical Title II programming patterns plus the IPC Level 3 baseline
  • Multilateral channel (WFP) preserved on the existing operational model
  • Cash transfers and food vouchers — historically permitted modalities — would have continued (though the FY25 NOFO has now foreclosed this at the policy level)

Optimizes For

  • Speed of program continuity — beneficiaries do not lose access during the transition
  • Lowest operational disruption risk for the PVO cooperator community
  • Preservation of M&E continuity for ongoing evaluations and longitudinal indicators
  • Minimum congressional oversight friction during the transition window

Evidence Already In Place

USAID Office of Food for Peace M&E V2.0 framework

Continues to govern Title II M&E in the interim period under USDA stewardship; Diana L. Caley authored and co-authored the predecessor documents.

Title II PVO award footprint

Active DFSAs / RFSAs continue under their existing terms during the interim authority window (FY25 + FY26 per the December 24, 2025 USDA/State/OMB interagency agreement).

Risks

  • Misalignment with the administration's stated reform priorities — could be read as 'USAID with a USDA hat on,'
  • Does not surface the off-boarding-and-graduation discipline NOFO Reform 3 commits USDA to operationalizing
  • Misses the bilateral co-investment doctrine the administration has operationalized elsewhere (State Department 31-MOU Global Health Strategy template, $20.6B program value with 38% recipient counterpart share)

HSG's Role Under This Option

HSG's process guides under PWS §§3.1–3.7 work in this option as documentation-and-codification deliverables — formalizing the inherited substrate under USDA authority. Diana L. Caley's authored M&E architecture is the institutional voice carrying the operational substrate forward without rupture.

FFP 1.5 — Adaptation (NOFO Baseline)

Detailed view

Inherit the operational substrate; overlay the three NOFO reform priorities.

Key Characteristics

  • 100% U.S.-origin commodity sourcing as a hard requirement per NOFO Reform 1; no cash transfers or food vouchers
  • FY25 NOFO nine standard performance indicators + custom indicators per NOFO §4.2 — all descending from Diana L. Caley's predecessor framework
  • Four-stage graduation pathway (acute / sustained / recovery / graduation) tracking each country's trajectory across NOFO cycles
  • Seven-country proof-of-concept tranche with the ongoing-vet methodology refreshing the list at future NOFO cycles
  • $452M USDA-WFP MOU (Feb 3, 2026) preserves the multilateral channel — the largest single Food for Peace counterpart arrangement now operating under USDA stewardship
  • FAS cooperator-program framework continues to administer PVO-managed activities

Optimizes For

  • Operational executability inside the 12–18 month timeline before legislative permanence
  • Defensibility against Congressional and OIG scrutiny — every methodology element anchored in NOFO language
  • Continuity for current PVO awardees while signaling the policy reform trajectory
  • Bipartisan defensibility — the 'reform' framing reads to both farm-state and humanitarian constituencies
  • Compatibility with the administration's America First posture without requiring full structural redesign

Evidence Already In Place

FY25 Food for Peace NOFO (USDA FAS, May 13, 2026)

$357M total funding, 7-14 awards expected at $20-200M each, 18-24 month POP, application deadline June 12, 2026 at 5:00 PM EDT. Three reform priorities established as canonical USDA language.

USDA-WFP MOU ($452M, Feb 3, 2026)

Under Secretary Luke Lindberg announcement: $452M for 211,000 MT U.S. commodities to the seven priority countries. The largest single Food for Peace counterpart arrangement now operating under USDA stewardship.

USDA/State/OMB Interagency Agreement (Dec 24, 2025)

FY25 + FY26 interim authority transferring FFP to USDA administration.

Risks

  • Implementation timing — the NOFO's 18-24 month POP means many awards land in the period after the administration is up for review; programmatic momentum could slip in the interregnum
  • Title II is operationally slow regardless of reform layer (Diana's read: 'food is not gonna be on people's tables for two years'); reform commitments could outrun execution
  • Some FY25 NOFO design elements (e.g., the specific seven-country selection logic) reflect deliberate priorities that future administrations may want to refresh — the ongoing-vet methodology is HSG's hedge

HSG's Role Under This Option

HSG's eleven deliverables are designed to operationalize FFP 1.5 explicitly. Diana L. Caley as Senior M&E Advisor and Training Lead leads the M&E architecture and 90-day staff-training-and-handover workstreams; the senior FAS bench (Maurice House, Kevin Latner) leads the FAS-facing process guides; HSG W-2 Senior Analyst & Designated Alternate POC Olivia Till provides near-continuous on-site coverage (paired with Emax Generalist Analyst capacity for full five-business-day coverage); the Enhanced Bellmon Framework anchors the Country Selection Guide methodology; the four-stage graduation pathway operationalizes Reform 3; the M&E architecture authorship credential underpins Reform 2; the America First framing under the three-reform anchor operationalizes Reform 1. This is the option HSG primarily structures the engagement to support.

FFP 2.0 — Redesign (Bilateral Co-Investment Architecture)

Detailed view

Restructure Title II commodity programming as bilateral deal architecture.

Key Characteristics

  • Bilateral co-investment deal architecture replacing unilateral commodity-grant logic
  • Recipient-country counterpart contribution as a scoring dimension in country selection
  • Glide-path exits to graduation as default structural assumption — not exceptional pathway
  • Pooled procurement scenarios across adjacent countries with similar program profiles
  • U.S.-side commercial value chain explicitly named in the deal architecture (U.S. farmer, processor, exporter, taxpayer named as parties to the U.S. side of the agreement)
  • Market-anchored exit criteria — each agreement defines, at signing, the recipient-country agricultural-capacity threshold that triggers program graduation and counterpart-funded continuation
  • Title II + non-emergency programming integrated under a single deal-architecture envelope

Optimizes For

  • Strategic alignment with the administration's bilateral co-investment doctrine across foreign assistance
  • Reform 3 fully operationalized — off-boarding and graduation become the default trajectory, not the exception
  • U.S. commercial benefit accountable as part of the U.S. side of the agreement, not a side-effect
  • Multilateral burden-sharing through pooled procurement and joint financing
  • Long-horizon defensibility against 'forever aid' critique

Evidence Already In Place

State Department America First Global Health Strategy (CY 2026)

31 bilateral MOUs executed; $20.6B total program value; $7.8B recipient counterpart contribution (38% share); declining U.S. financial share over a glide path; explicit movement of partner countries toward self-reliance. The operational template FFP 2.0 generalizes.

NOFO Reform 3 graduation commitment

'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 §1.1, verbatim.)

Audrey McGuire's deal-architecture credential

40 years of federal capital-markets advisory across MHPI / PPV / enhanced-use lease / federal portfolio management — the same structural template that underpins the State Department bilateral MOU program. Direct credential for FFP 2.0 design.

Risks

  • Legislative timing — full implementation likely requires Farm Bill or P.L. 480 reauthorization action and is contingent on the next appropriations and authorizations cycles
  • Title II PVO cooperator community may resist the structural change — though many PVOs already operate in the bilateral-co-investment-adjacent space (McGovern-Dole, Food for Progress) and could adapt
  • Country-level political readiness for counterpart-contribution commitments is uneven — Diana's field experience confirms the political-feasibility variance across the seven NOFO priority countries
  • Risk of 'aid washing' critique — programs framed as bilateral co-investment but operationally indistinguishable from grants. The four-stage graduation pathway and the documented counterpart-readiness scoring are HSG's guardrails against that critique.

HSG's Role Under This Option

HSG positions FFP 2.0 as the destination the FFP 1.5 NOFO methodology points toward — not as an alternative path. The Country Selection Guide methodology, the Enhanced Bellmon Framework, and the four-stage graduation pathway all work across FFP 1.5 and FFP 2.0. HSG's analytical infrastructure lets USDA defend FFP 1.5 today and pivot toward FFP 2.0 across subsequent NOFO cycles without throwing out the methodological substrate.

Comparison Across the Three Trajectories

Dimension-by-dimension comparison. The current operational reality is the middle column (FFP 1.5, the NOFO baseline). The left column shows what continuity-only would have produced; the right column shows the destination Reform 3 points toward.

DimensionFFP 1.0 ContinuityFFP 1.5 Adaptation (NOFO Baseline)FFP 2.0 Redesign

Commodity sourcing posture

How U.S. agricultural commodities are sourced and what alternative modalities (cash, vouchers) are permitted.

100% U.S. origin preferred; cash transfers and food vouchers permitted in defined operational scenarios (USAID-era flexibility).100% U.S. origin REQUIRED per NOFO Reform 1; cash transfers and food vouchers FORECLOSED. Hard policy floor.100% U.S. origin REQUIRED + pooled-procurement scenarios across adjacent recipient countries; commodities priced as economic instruments inside the bilateral deal.

Country selection logic

How priority countries are identified, prioritized, and refreshed across NOFO cycles.

Historical Title II programming continuity; IPC Level 3 as baseline; country list updated on an ad hoc cycle.Seven NOFO priority countries as empirical baseline; three statutory eligibility triggers (IPC Level 3, sudden-onset conditions, UNHCR declaration); ongoing-vet methodology refreshes the list at each NOFO cycle.Seven priority countries + bilateral co-investment readiness scoring sub-methodology; graduation-pathway stage classification drives entry/exit; counterpart-contribution capacity is a primary input.

Reporting and accountability

Performance measurement, indicator architecture, and accountability against fraud/waste/abuse/diversion.

M&E V2.0 framework; Diana L. Caley's authored Emergency Indicator Handbook (199 indicators) as the operational substrate.FY25 NOFO nine standard indicators + custom indicators per NOFO §4.2; Reform 2's strict-accountability commitment; Diana's predecessor framework explicitly cited.Nine NOFO standard indicators + counterpart-contribution accounting indicators + graduation-pathway transition indicators. Indicator architecture extended to measure deal-architecture outcomes.

Stakeholder ecosystem

Title II PVO cooperator community, multilateral channels, and U.S. agricultural producer engagement.

PVO cooperator community continues under USAID-era terms; WFP relationship preserved; U.S. ag producer engagement on the periphery.PVO cooperator community continues + FAS cooperator-program framework absorbed; WFP relationship migrated to USDA stewardship under the $452M MOU; U.S. ag producer voice named in the value chain per America First framing.PVO cooperators continue as implementing partners but operate inside bilateral co-investment deal structures; WFP becomes a multilateral counterpart; U.S. ag producers are NAMED PARTIES to the U.S. side of bilateral agreements.

Funding mechanism

The financial-flow architecture from U.S. Treasury through to beneficiaries.

Unilateral grant-based commodity transfer; recipient-country contribution is informal where it occurs.Unilateral grant-based commodity transfer (no change) + 50% minimum commodity-and-freight budget floor per NOFO §2.5; cost-share encouraged but not required (bonus 2 points).Bilateral co-investment agreement with explicit U.S. and recipient counterpart contributions; pooled procurement across adjacent countries; graduation-pathway-triggered transitions to recipient-funded continuation.

Strategic alignment

How the program is positioned relative to U.S. national-security and trade-policy framings.

Humanitarian framing primary; trade-policy and strategic-alignment dimensions secondary.America First framing primary; humanitarian dimension preserved; Enhanced Bellmon Tier 3 strategic-alignment overlay added at the commodity-decision level.America First framing primary + bilateral co-investment doctrine + explicit strategic-partner classification driving country-level deal architecture; full integration with State Department / DoD / Treasury policy frameworks.

Implementation horizon

Time required to operationalize fully.

Already in place; mostly administrative wrapper question.In flight now (May 13, 2026 NOFO active); first USDA-administered awards land Q3 2026.24-36 month minimum; requires legislative / regulatory groundwork; some elements (graduation framework, counterpart-readiness scoring) can begin within the current advisory engagement.

Defensibility risk profile

Primary critique vectors and their exposure under each option.

Congressional and administration critique: 'USAID with a USDA hat on'; forever-aid pattern preserved by default.Congressional critique vector minimized through Reform 2 + 3 commitments; PVO-community critique vector minor (cooperators continue).Congressional critique vector minimized further (full Reform 3 operationalization); PVO-community resistance is the primary critique vector; aid-washing critique is the secondary vector.

HSG's Posture

HSG structures the choice for USDA — we do not substitute our judgment for USDA's.

The FFP transition is not a binary inherit-or-redesign decision. It is a structured option space across three trajectories — Continuity (FFP 1.0), Adaptation (FFP 1.5, the NOFO baseline), and Redesign (FFP 2.0, the deeper structural pivot Reform 3 points toward). The May 13, 2026 NOFO establishes FFP 1.5 as the current operational reality and Reform 3 as the policy commitment to evolve toward FFP 2.0 over subsequent cycles.

HSG's eleven deliverables under this contract are designed to support that trajectory across all three options. The Country Selection Guide methodology, the Enhanced Bellmon Framework, the four-stage graduation pathway, the FY25 NOFO nine-indicator architecture, and the AI-augmented production discipline all work whether USDA holds at FFP 1.5 or evolves toward FFP 2.0 across the next two NOFO cycles. The methodology is intentionally option-agnostic where possible and option-specific where the analytical infrastructure must commit.

We do not lock USDA into an option pre-emptively. Per Diana L. Caley's operational guidance, the right posture at this transition stage is to build for adaptability: 'I wouldn't contort yourself too much in this early stage of needing to get too far down that road. I just think being clear that we would work with the right folks to determine what are the important criteria for the U.S. government to decide who their key and strategic partners are.' The optioning framework is explicitly flexible — designed to be refined and challenged by FAS career program staff during the engagement.

USDA owns the choice. HSG provides the analytical infrastructure that lets USDA defend whichever choice it makes, document the evidentiary case, and move along the option trajectory at the cadence that fits USDA's operational reality.

The optioning framework is explicitly designed to be refined and challenged by FAS career program staff during the engagement. USDA owns the trajectory choice; HSG provides the analytical infrastructure.

Inheritance Decision Matrix

Each Must-Build function has up to four paths: Novate (take over USAID contract / system) · Recompete (new USDA-issued solicitation) · Build In-House (federal staff inside an existing USDA office) · Federal Partner (lean on a peer agency). HSG's engagement work makes these choices explicit, defensible, and documented. Click any item below to see the full analysis.

8 Must-Build items1 Day-1 risk4 need new procurement2 build in-house5 hybrid path1 extend existing USDA
#01

PVO Grant Management at Title II Scale

Operational Capacity
Build In-HouseQ1 Priority

What it is

Awarding and administering approximately $1.7–2 billion per year of grants and cooperative agreements to ~18 active Title II implementing PVOs (CRS, Save the Children, World Vision, Mercy Corps, CARE, ADRA, IRC, ACDI/VOCA, Land O'Lakes Venture37, NCBA CLUSA, Food for the Hungry, etc.) plus approximately 200 IFRP sub-awardees.

What USAID had

USAID FFP/BHA HQ Country Backstop officers + Agreement Officers + Award Officers. Pre-2020 dedicated FFP grants team; post-2020 distributed across BHA Office of Technical and Program Quality + Office of Humanitarian Business and Management Operations.

The Options

Build In-House

Build In-House (FAS OCBD scale-up)

HSG Recommended

Scale up USDA FAS Office of Capacity Building & Development (OCBD) to absorb Title II at 4–5× current capacity.

Pros

  • Leverages existing USDA NOFO + grants-administration muscle (McGovern-Dole + Food for Progress ~$400M/yr)
  • Permanent federal-staff function, no contractor dependency
  • USDA-aligned grant-administration culture and oversight

Cons

  • Requires 12–18 additional FTEs (hiring, training, security clearances)
  • Build period 6–12 months before steady state
Novate

Novate USAID Title II awards

Take over active USAID Title II awards via Transfer Authorization mechanism; USDA Agreement Officers replace USAID counterparts on existing agreements.

Pros

  • Preserves partner muscle memory and active programming
  • No procurement gap

Cons

  • Inherits USAID-shaped scope; cannot fully reorient under USDA priorities
  • Legal complexity of novation across ~25–30 active DFSAs/RFSAs
Recompete

Recompete all Title II programming

End existing awards on FY close; issue new USDA-shaped NOFOs for next cycle.

Pros

  • Clean USDA-shaped programmatic priorities
  • Market refresh; potential cost savings

Cons

  • 6–12 month obligation gap; partner operational disruption
  • Loss of in-progress program continuity

HSG Recommendation

Build in-house — scale FAS OCBD to absorb Title II at 4–5× current capacity

FAS OCBD already runs McGovern-Dole + Food for Progress at approximately $400M/yr — the muscle memory, NOFO architecture, and grants-administration capability is in place. Scaling that to Title II scale is materially cheaper than standing up a parallel structure or maintaining USAID-shaped legacy awards under USDA management. The 12–18 FTE scale-up cost is approximately $3–4M/yr loaded — versus indefinite contractor overhead.

USDA Office Already Operating This Function Today

FAS Office of Capacity Building & Development — International Food Assistance Division

This office already directs 48 active multi-year McGovern-Dole projects across 35 low-income countries ($1.3B active commitments, 2.7M children reached annually) plus 8 active Food for Progress projects (~$148M FY25 commodity value). Absorbing FFP scales the active grants portfolio from ~$480M to ~$1.7B — a 3-4× growth path under the same NOFO + cooperative agreement + 2 CFR Part 200 framework already in operation. The team grows from approximately 20 program officers to 35-50. HSG support: position descriptions drafted to OPM classification standards for the 15-30 new program officer positions, workload-allocation analysis for absorbing scope into existing staff, organizational-design memo. HSG bench credential: USDA APHIS Exceptional PPQ (combined org design + position classification + comp/budget mapping); active Alameda County DA (58 classifications, 411 positions), Calabasas LVMWD (105 classifications), Greenwood County SC (157 classes), Modesto, Jefferson City MO classification-and-compensation engagements.

What USDA must do

  • 12–18 additional FAS OCBD FTEs (Grants Officers, Agreement Officers, Country Backstop equivalents)
  • Position descriptions and hiring authority through USDA Human Resources
  • T2 Public Trust clearance pipeline for new hires
  • Internal Departmental Regulation defining FAS OCBD scope expansion
  • Transition plan for active USAID Title II awards (Transfer Authorization assignment by Q1 FY27)

HSG bench credibility anchor

Kevin Latner — 25-year FAS cooperator-program career provides direct OCBD-adjacent execution lineage. Jelani House — federal grants-administration discipline from HSG corporate engagements.

Proposal section: Volume I, Factor 1 (Staffing Plan) + Factor 2 (Technical Capability — Inheritance Architecture)PWS: PWS 3.5 Stakeholder + 3.6 Coordination
#02

Bellmon Analytical Contract / Methodology Custody

Analytical Infrastructure
HybridQ2 Priority New procurement

What it is

Country-specific market-disincentive studies executed before Title II monetization or large in-kind commodity decisions. Statutory under P.L. 480 § 403 (Bellmon Amendment, 1977). Analytical execution has historically been contracted out.

What USAID had

Bellmon Estimation for Title II (BEST) program awarded to Fintrac, Inc. (August 2008). Fintrac executed country-specific studies for Burkina Faso (2009), Guatemala (2011), South Sudan (multi-year), Nepal, Malawi, and others. USAID OIG performance audits FY2018-2020 publicly available.

The Options

Novate

Novate Fintrac BEST contract

Take over the existing USAID-Fintrac BEST contract under USDA management.

Pros

  • Preserves analytical continuity
  • No procurement-cycle gap

Cons

  • Inherits any USAID-Fintrac pricing premium
  • Misses market refresh opportunity
  • Does not reflect Enhanced Bellmon Framework scope expansion
Recompete

Recompete under new USDA RFP

Issue new USDA-issued RFP for "USDA Bellmon Analytical Services" — open to Fintrac and other analytical firms. Scope explicitly covers Enhanced Bellmon Framework Tiers 2 (commercial-displacement) and 3 (strategic-alignment).

Pros

  • Refreshes market and pricing
  • Scope explicitly Enhanced Bellmon Framework-aligned
  • Multiple eligible analytical firms in market (Fintrac, ACDI/VOCA, Banyan Global, IBTCI analytical arm)

Cons

  • 6–9 month procurement cycle; need bridging mechanism for any pending Bellmon studies
  • Vendor change risk
Build In-House

Build into FAS Office of Global Analysis

Absorb Bellmon analytical custody into FAS OGA, which already runs WASDE / ICEC commodity supply-demand analytics with 75-analyst headcount.

Pros

  • Aligns analytical center of gravity with FAS OGA
  • Eliminates contractor dependency
  • Methodology preservation under federal staff

Cons

  • Requires FAS OGA scope expansion + staff training on Bellmon methodology
  • Build period 12–18 months before steady state

HSG Recommendation

Recompete the analytical contract (Year 1) with explicit transition pathway to absorb methodology into FAS Office of Global Analysis (Year 2–3)

Pure novation perpetuates inherited Fintrac premium and misses the Enhanced Bellmon Framework scope expansion opportunity. Pure in-house build is right structurally — FAS OGA already runs WASDE and ICEC analytics — but the 12–18 month build period leaves a gap. The hybrid path runs a recompete for Year 1 analytical support while standing up FAS OGA's Bellmon methodology custody in parallel; by Year 3 the methodology lives at FAS OGA and contractor support is supplementary rather than primary. This is also the cleanest path to operationalizing Enhanced Bellmon Tiers 2 and 3 inside USDA's analytical center of gravity.

USDA Office Already Operating This Function Today

FAS Office of Global Market Analysis (Maurice House's prior seat as Deputy Administrator, 2008-2010)

This office today runs WASDE production estimates for 110+ commodities × 200+ countries, leads the Interagency Commodity Estimates Committees (ICEC), and produces country market briefs that already perform Bellmon-equivalent commercial-displacement analysis for Food for Progress monetization decisions. Absorbing FFP Bellmon Analysis is incremental analytical workload (~6 additional FTE economists) on existing infrastructure, not new institutional capability. The Enhanced Bellmon Framework's three tiers (statutory + commercial-displacement + strategic-alignment) integrate directly into the WASDE/ICEC analytical cycle this office already runs. Enhanced Bellmon Tier 4 (proposed): Producer-Aid Integration scoring — for each candidate country, scores whether MAP-funded or FMD-funded cooperator programming is active in that market and whether emergency-aid design can coordinate with commercial-market-development work for long-term U.S. producer benefit. HSG support: position descriptions for the 6 new economist positions; methodology-transition plan for the Year 2-3 in-house migration.

What USDA must do

  • New RFP for USDA Bellmon Analytical Services (scope: statutory Tier 1 + Enhanced Bellmon Tiers 2 + 3)
  • Bridging mechanism for any pending Bellmon studies during procurement cycle (6–9 months)
  • FAS OGA organizational-design memo for Bellmon methodology custody
  • Methodology-transition plan (Year 1: contractor + FAS shadowing; Year 2: split execution; Year 3: FAS-primary)

HSG bench credibility anchor

Maurice House — Deputy Administrator, FAS Office of Global Analysis (2008–2010, 75-analyst supervision) provides the direct organizational-design lineage. Kevin Latner — Food for Progress monetization market-assessment work is structurally identical methodology.

Proposal section: Volume I, Factor 2 (Enhanced Bellmon Framework section) + Country Selection Guide deliverablePWS: PWS 3.4 Geography & Prioritization

New procurement required

New USDA-issued RFP for Bellmon Analytical Services

#03

DFSA / RFSA Partner Closeout + M&E Framework + ARR Review

Programmatic Infrastructure
HybridQ2 Priority New procurement

What it is

Monitoring & Evaluation architecture for ~25–30 active DFSAs/RFSAs (Bangladesh SHOUHARDO IV, Ethiopia SPIR II, Niger LAHIA II, Burkina Faso ViMPlus, Uganda Apolou/Nuyok, Mali HARANDE, Zimbabwe TAKUNDA, Mozambique Tomalia, Guatemala RVI, etc.); Annual Results Report review cycle for all partners; baseline / midline / endline evaluation methodology.

What USAID had

USAID FFP M&E Policy & Guidance V2.0 (9 pillars) + FANTA technical-support contract (Tufts Friedman School + ACDI/VOCA partnership, concluded 2021) + TOPS / IDEAL platforms for partner technical assistance. FAQR cycles (Phase I 2009-11 / II 2011-16 / III 2014-2021 through Tufts Friedman).

The Options

Novate

Adopt M&E V2.0 unchanged + recompete FANTA-equivalent

Preserve M&E Policy V2.0 substrate; recompete the lapsed FANTA-equivalent technical-support contract to refresh academic-partner relationship.

Pros

  • Maximum partner muscle memory preservation
  • Refreshes academic-partner relationship

Cons

  • No USDA-grade adaptation; OIG-defensibility risk under USDA scrutiny
Hybrid

Adopt V2.0 substrate + USDA-grade overlay + recompete technical-support

HSG Recommended

Keep core 9-pillar V2.0 architecture (Strategic Frameworks → Data Quality Assessments) but layer USDA-grade controls (OMB Circular A-123 + A-11 § 185 statistical-model validation). Recompete FANTA-equivalent contract.

Pros

  • Preserves partner muscle memory + USDA-grade audit defensibility
  • Refreshes academic-partner relationship
  • Aligns with GAO-17-224 closure baseline

Cons

  • 6–12 month methodology adaptation + documentation work
Recompete

Build new USDA M&E framework + recompete technical-support

Author USDA-issued M&E framework from scratch; recompete academic-partner contract under USDA-shaped terms.

Pros

  • Fully USDA-shaped methodology
  • No legacy V2.0 inheritance

Cons

  • Massive partner-disruption — partners are operating on V2.0 indicator architecture
  • 12–18 month build before steady state

HSG Recommendation

Adopt M&E V2.0 substrate with USDA-grade overlay; recompete FANTA-equivalent technical-support contract

M&E V2.0 is the operational substrate the 18 active Title II PVOs report into. Building from scratch would force a multi-year partner-disruption that doesn't pay for itself. But pure adoption leaves USDA exposed under OIG scrutiny — the V2.0 architecture doesn't meet USDA-grade internal-controls standards out of the box. The hybrid layers OMB A-123 internal controls and A-11 § 185 statistical-model validation on top of V2.0, preserving partner familiarity while closing the GAO-17-224 audit-baseline gap. Recompeting the FANTA-equivalent technical-support contract (now lapsed) refreshes the academic-partner relationship — Tufts Friedman School is the natural incumbent given FAQR Phases I-III execution, but the recompete opens market.

USDA Office Already Operating This Function Today

FAS Office of Capacity Building & Development — International Food Assistance Division + FAS Office of Global Programs

The same office that manages McGovern-Dole and Food for Progress partner M&E architecture today. McGovern-Dole partners already submit Annual Results Reports through this office under M&E V2.0-equivalent structure; absorbing the FFP partner cohort (top-5 PVOs already hold McGovern-Dole / FFPr awards under the same legal framework) is incremental coverage expansion. The FANTA-equivalent academic-partner contract recompete refreshes the technical-support relationship (Tufts Friedman School is the natural incumbent given FAQR Phases I-III execution).

What USDA must do

  • M&E framework documentation (V2.0 substrate + USDA-grade overlay)
  • New RFP for FANTA-equivalent technical-support contract (academic-partner relationship)
  • Decision on Tufts Friedman School engagement (institutional continuity vs market refresh)
  • Partner-facing transition guidance memo
  • FAQR IV launch plan (no active cycle since Phase III July 2021)

HSG bench credibility anchor

Kevin Latner — FAS cooperator-program reporting cycle execution. Jelani House — federal grants M&E discipline from HSG engagements.

Proposal section: Programmatic Reporting Guide + Volume I Factor 2 (M&E Inheritance section)PWS: PWS 3.5 Programmatic Reporting + Stakeholder

New procurement required

New RFP for academic-partner technical-support contract (FANTA-equivalent)

#04

Third-Party Monitoring (TPM) in Conflict Zones

Risk Management
HybridQ1 Priority New procurement

What it is

Independent monitoring of Title II programs where USDA cannot directly access activity sites — Yemen (especially Houthi-controlled areas, FTO-designated Jan 2025), Syria, Sudan (RSF/SAF), Somalia, NE Ethiopia, Afghanistan (Taliban). TPM verifies partner self-reporting against ground truth in environments where standard diligence is unavailable.

What USAID had

Yemen Monitoring Evaluation and Learning Program II (YMELP II) — IBTCI, April 2024 to April 2029 (5-year, ~$5M+/yr) covering all BHA-funded Yemen programming; iMMAP Information Management Resource Center (IMRC) under BHA — Syria + multi-country; Forcier Consulting — South Sudan, Somalia, Sahel; Mercy Corps Risk Management Unit (RMU) — Yemen, Syria; Acacia Consultants — Horn of Africa.

The Options

Novate

Novate all BHA TPM contracts

Take over IBTCI / iMMAP / Forcier / Mercy Corps RMU / Acacia contracts under USDA management — preserve operational continuity across all conflict zones.

Pros

  • Maximum operational continuity in critical-risk theaters
  • Preserves established field relationships and methodologies

Cons

  • Inherits any USAID-shaped pricing and scope; no market refresh
Recompete

Recompete all TPM contracts on natural endings

Let existing contracts run their option years; issue new USDA-shaped TPM RFPs at natural cycle endings. Refresh the entire TPM contractor architecture under USDA terms.

Pros

  • Full market refresh + USDA-shaped scope
  • Refreshes contractor accountability cycle

Cons

  • YMELP II runs to April 2029 — recompete-only path means 4-year inheritance window anyway; contractor disruption in critical-risk theaters during recompete cycles
Hybrid

Novate time-limited + recompete on natural endings

HSG Recommended

Novate YMELP II (4-year runway, IBTCI Yemen) to preserve continuity; recompete iMMAP / Forcier / Acacia / Mercy Corps RMU at their natural cycle endings.

Pros

  • Preserves continuity in highest-risk theater (Yemen)
  • Refreshes other TPM contracts on natural cycle
  • Avoids Yemen oversight gap during transition

Cons

  • Two-track contract management for 4 years

HSG Recommendation

Novate YMELP II (preserves 4-year Yemen continuity); recompete iMMAP / Forcier / Acacia / Mercy Corps RMU on natural cycle endings

YMELP II is the most critical TPM artifact — Yemen Houthi-FTO operating environment is the most acute Title II oversight challenge in the entire portfolio, and IBTCI has 18+ months of in-country execution muscle. Letting YMELP II lapse during transition would create a catastrophic oversight gap that OIG and Congress would absolutely flag. Other TPM contracts have shorter horizons and natural cycle endings — those can be recompeted with less risk. Critical proposal point: HSG's Risk Management Guide deliverable explicitly addresses YMELP II novation strategy as a concrete operational artifact.

USDA Office Already Operating This Function Today

FAS Office of Foreign Affairs (overseas post network) + AMS Commodity Procurement Contracting

FAS Foreign Affairs directs the network of approximately 150 Foreign Service officers at 90+ overseas posts globally — already responsible for country-level commodity tracking, partner monitoring trips, embassy coordination across all existing FAS-CCC international programs (McGovern-Dole, Food for Progress, MAP/FMD/EMP). Absorbing FFP TPM oversight is an incremental scope-of-work expansion for the existing post network. AMS Contracting executes the novation legal work and future USDA-issued TPM RFP templates.

What USDA must do

  • Contract novation legal work (USAID-to-USDA novation for YMELP II)
  • USDA-equivalent TPM contract architecture (RFP template, statement-of-work standards) for future recompetes
  • TPM decision tree (when to trigger TPM, criteria, decision authority)
  • Coordination MOU with iMMAP / Forcier / Acacia / Mercy Corps RMU on transition continuity

HSG bench credibility anchor

Maurice House — First US wheat export to Taliban-led Afghanistan (1995-98, Islamabad post) is the canonical Tier 3-4 risk-management precedent. Kevin Latner — FAS execution under acute-risk environments. Jelani House — federal-grade risk-management discipline from HSG HUD OAS quality-control work.

Proposal section: Risk Management Guide + Volume I Factor 2 (Inheritance Architecture)PWS: PWS 3.3 Non-Traditional Operating Environments

New procurement required

Novation legal work + future USDA TPM RFP template

#05

Counter-Terrorism Vetting at FFP Scale

Risk Management
Build In-HouseDay-1 Risk

What it is

Pre-award + ongoing partner screening to ensure Title II funds do not reach designated terrorist organizations. Includes FTO (Foreign Terrorist Organization) screening, SDGT (Specially Designated Global Terrorist) screening, OFAC SDN (Specially Designated Nationals) list screening, and partner-organization beneficial-ownership review. Required by Anti-Terrorism Certification (ATC) regime applicable to all federal foreign-assistance grants.

What USAID had

Dedicated Counter-Terrorism Vetting Unit (CTU) at USAID HQ. Per USAID OIG advisory dated February 10, 2025: CTU "told not to report to work" early 2025 — partner vetting is at near-zero state as of this writing. This is the most acute current-state risk in the entire FFP transition.

The Options

Build In-House

Embed in FAS Office of Capacity Building & Development

HSG Recommended

Integrate vetting into FAS OCBD's grant-award workflow. No dedicated USDA CTU office; vetting becomes a step in the standard NOFO + award-administration cycle.

Pros

  • Lowest overhead — embedded in existing federal-staff workflow
  • Natural pairing with grant-award process (vetting at the decision moment)
  • No new procurement

Cons

  • Requires database-access agreements with State CT Bureau, Treasury OFAC, etc.
  • FAS OCBD staff need CT-vetting training
Build In-House

Stand up dedicated USDA CTU office

HSG Recommended

Build a dedicated USDA counter-terrorism vetting unit modeled on USAID CTU.

Pros

  • Dedicated specialist function
  • Mirrors USAID-era institutional architecture

Cons

  • High overhead for a function that can be embedded
  • Hiring + standing up 6-12 month build period
Federal Partner

Outsource to State CT Bureau + Treasury OFAC + DOJ

Lean on existing federal CT-vetting infrastructure at State, Treasury, and DOJ rather than USDA-internal capability.

Pros

  • Leverages existing federal capability at scale
  • No USDA build cost

Cons

  • Coordination overhead; USDA-side vetting decisions slowed by inter-agency cycle
  • Risk of vetting at non-USDA priority

HSG Recommendation

Embed vetting into FAS OCBD grant-award workflow with State CT Bureau + Treasury OFAC database-access agreements as backstop

Dedicated CTU office is overhead-heavy for a function that can be embedded into the standard grant-award workflow. State CT Bureau and Treasury OFAC already maintain the authoritative designation databases (FTO list, SDGT list, SDN list) — USDA needs access agreements, not parallel infrastructure. The embedded-in-OCBD approach pairs vetting with the natural award-decision moment and avoids the institutional overhead of a separate USDA CTU. Critical near-term remediation priority: OIG flagged that CT vetting is at near-zero state as of February 10, 2025 — USDA must flag this as a Day-1 risk in the transition plan and stand up the embedded vetting capability before any new FY26 NOFO awards.

USDA Office Already Operating This Function Today

USDA Office of General Counsel + AMS Commodity Procurement Contracting Office

USDA OGC provides legal review for federal grant and contract partner-vetting policy across all USDA international programs. AMS Contracting executes vetting at award through existing 2 CFR Part 200 procedures and federal contractor-vetting database access (SAM.gov exclusion list, OFAC SDN, State FTO list). Embedding FFP-scale Anti-Terrorism Certification (ATC) requirements into the existing USDA NOFO + award workflow is procedural integration, not new institutional capability.

What USDA must do

  • Database-access MOU with State CT Bureau (FTO list, SDGT list)
  • Database-access MOU with Treasury OFAC (SDN list, sanctions programs)
  • Database-access MOU with DOJ where applicable
  • FAS OCBD staff CT-vetting training
  • Documented vetting decision-tree integrated into NOFO + award workflow
  • Anti-Terrorism Certification (ATC) compliance documentation

HSG bench credibility anchor

Maurice House — interagency global food-crisis task force co-chair (2007-09) provides cross-Department coordination lineage. Jelani House — federal-compliance discipline from HSG HUD OAS work.

Proposal section: Risk Management Guide + Volume I Factor 2 (Day-1 Risk section)PWS: PWS 3.3 Non-Traditional Operating Environments + 3.5 Stakeholder
#06

Mission-Level FFP-Officer Presence in Non-FAS-Served Countries

Operational Capacity
HybridQ1 Priority

What it is

In-country humanitarian-program oversight presence at US embassies in countries where USDA FAS has no resident Agricultural Attaché. Examples: South Sudan, Yemen, Somalia, Afghanistan all had USAID FFP Officers but no parallel FAS Attaché. These officers managed partner liaison, monitoring trips, Bellmon coordination at post, and embassy / State coordination.

What USAID had

Senior FFP Officers (FS-02/01 equiv.) + Mission FFP Officers (FS-03/04 equiv.) at FFP-only countries. Post-2021 BS-70 Humanitarian Assistance Officer Foreign Service job code combined FFP + OFDA functions.

The Options

Build In-House

Build new FAS Attaché posts in missing countries

Stand up new FAS Attaché positions in South Sudan, Yemen, Somalia, Afghanistan, etc.

Pros

  • Permanent FAS-resident coverage
  • USDA-aligned reporting structure

Cons

  • Each new FAS post is approximately $1–2M/yr in cost (housing, transportation, FSL benefits, security)
  • Hiring + post-establishment 12–18 month timeline
  • Recurring annual cost
Extend Existing USDA

Third-country FAS Attaché coverage

Have nearest-regional FAS Attaché cover the missing country (e.g., Cairo or Riyadh FAS covers Yemen; Addis Ababa FAS covers Somalia or South Sudan).

Pros

  • No new posts required
  • Leverages existing FAS Attaché capability
  • Lower cost

Cons

  • Travel-based oversight rather than resident coverage
  • Coverage attenuates in highest-risk environments where third-country FAS may not travel
Federal Partner

State Department Foreign Service economic-officer backstop

Lean on State Department Foreign Service economic officers at FFP-only countries to provide in-country backstop on USDA's behalf.

Pros

  • Resident coverage via State's permanent embassy presence
  • No new USDA hiring

Cons

  • State officers are not USDA-specialized; depth of FFP-specific knowledge limited
  • Requires USDA-State coordination MOU on duties + authorities

HSG Recommendation

Third-country FAS Attaché coverage (primary) + State Department Foreign Service backstop (in-country presence)

Building new FAS posts in conflict zones is operationally expensive (~$1–2M/yr per post, recurring) and slow (12–18 month establishment). The hybrid path uses third-country FAS Attaché coverage for analytical and policy work (nearest-regional FAS travels for Bellmon coordination and partner monitoring trips) while State Department Foreign Service economic officers provide in-country embassy backstop on day-to-day matters. This requires explicit USDA-State coordination MOU defining what State officers absorb on USDA's behalf. Avoids the cost spiral of new FAS post-establishment while preserving operational coverage.

USDA Office Already Operating This Function Today

FAS Office of Foreign Affairs (overseas post network) + US Mission to UN Agencies in Rome

FAS Foreign Affairs directs the 90+ overseas post network and the ~150 Foreign Service Officer corps that already coordinates with US embassies on FAS-CCC programming across all major FFP geographies. The US Mission Rome — anchored by a Senate-confirmed Permanent Representative and a recently-appointed Minister-Counselor for International Food and Agriculture Organizations — already operates as the diplomatic coordination point for the USDA-WFP relationship (Feb 3 2026 $452M MOU). Third-country FAS Attache coverage plus State Department Foreign Service backstop in non-FAS-served countries leverages existing federal-staff capacity rather than requiring new FAS post-establishment.

What USDA must do

  • USDA-State coordination MOU on backstop duties + authorities
  • FAS Attaché position re-scoping memo (nearest-regional Attaches inheriting FFP coverage scope)
  • Travel-budget supplement for third-country FAS coverage
  • Contractor-based gap coverage option in highest-priority countries (e.g., Yemen-specific contractor coordinator)
  • Document operational handoff with State Department's Bureau of Population, Refugees, and Migration (PRM) which is currently handling residual humanitarian functions

HSG bench credibility anchor

Maurice House — 38-year FAS Foreign Service career across Beijing, Brussels, Bangkok, Islamabad, Lagos, Algiers includes operating in coverage configurations parallel to this hybrid approach. Kevin Latner — FAS post execution at major-market environments.

Proposal section: Stakeholder Relations Guide + Volume I Factor 2 (Mission Architecture section)PWS: PWS 3.3 Non-Traditional Operating Environments + 3.5 Stakeholder
#07

Pipeline / Commodity Tracking System (FFPMIS Replacement)

IT Infrastructure
Extend Existing USDAQ1 Priority New procurement

What it is

End-to-end commodity tracking system from USDA procurement through mill packaging through port loading through ocean carrier through recipient port through in-country distribution through beneficiary registration. Tracks tonnage, cost, ITSH, Section 202(e) institutional support, and partner reporting. Also handles monetization pricing and proceeds tracking.

What USAID had

Food For Peace Management Information System (FFPMIS) as a USAID-internal system (catalog.data.gov registry entry). Lives in USAID IT infrastructure; data feeds include Partner Reporting Tool inputs, USDA AMS commodity-procurement feeds, USDOT MARAD cargo-preference compliance data.

The Options

Novate

Acquire / migrate FFPMIS

Take ownership of FFPMIS; host on USDA infrastructure; retain functionality unchanged.

Pros

  • Preserves all FFP-era data and workflows
  • Continuous tracking across transition

Cons

  • FFPMIS is a USAID-purpose-built system; technical debt + obsolescence likely
  • USDA assumes maintenance burden for legacy system
  • Section 508 + OMB M-25-21 + NIST AI RMF compliance gaps likely
Recompete

Build new system from scratch (new USDA-purpose-built)

Issue RFP for USDA-purpose-built commodity-tracking system; replace FFPMIS entirely.

Pros

  • Modern federal IT architecture
  • USDA-shaped functionality
  • Section 508 + AI compliance from Day 1

Cons

  • 12–24 month build before steady state
  • High cost ($5–15M+ build budget)
  • Data-migration complexity
Extend Existing USDA

Extend existing USDA AMS / KCCO commodity-tracking systems

HSG Recommended

USDA AMS Commodity Procurement / International Commodity Procurement Division + USDA FSA Kansas City Commodity Office already operate the upstream commodity-tracking IT infrastructure. Extend those systems with FFP-specific functionality (partner reporting, beneficiary counts, ITSH financial tracking) and selectively migrate FFPMIS data feeds.

Pros

  • Leverages existing USDA IT capability
  • Lower cost than new build (~$2–4M extension scope vs $5–15M new build)
  • Aligns with USDA AMS / KCCO operational center of gravity
  • Preserves continuity of upstream commodity-tracking already in USDA hands

Cons

  • AMS / KCCO IT integration scope larger than initially apparent
  • Requires Section 508 WCAG 2.1 AA conformance verification + OMB M-25-21/22 + NIST AI RMF compliance for any AI / automation layer

HSG Recommendation

Extend existing USDA AMS / KCCO commodity-tracking systems with FFP-specific functionality; selectively migrate FFPMIS data feeds

This is the single most-consequential infrastructure decision in the transition. Building from scratch wastes 12–24 months and $5–15M+ on a system that duplicates capability USDA already operates. FFPMIS as a standalone system is operationally orphaned post-USAID — maintaining it as USDA-resident creates a permanent legacy-system burden without strategic value. The right answer is to extend USDA AMS Commodity Procurement / ICPD + USDA FSA Kansas City Commodity Office (KCCO) IT systems with the FFP-specific functionality FFPMIS used to provide. AMS / KCCO already operates the upstream commodity-procurement IT — extending it for FFP-specific partner reporting, beneficiary counts, and ITSH financial tracking is materially more efficient than running two parallel systems. Selective data migration from FFPMIS captures the historical pipeline data, partner reporting baseline, and beneficiary counts USDA AMS / KCCO doesn't already have. Section 508 WCAG 2.1 AA + OMB M-25-21 + M-25-22 + NIST AI RMF compliance baked into the system-extension RFP from Day 1.

USDA Office Already Operating This Function Today

AMS Commodity Procurement Program — International and Service Contracting Division + USDA Office of the Chief Information Officer

AMS ICPD's International and Service Contracting Division already issues commodity-procurement solicitations under the AMS Master Solicitation framework for all USDA international food-assistance programs (McGovern-Dole, Food for Progress, BEHT, Section 416). The FSA Kansas City Commodity Office operates a single procurement pipeline that already procures for FFP-equivalent flows — FY25 volumes ~621K MT (McGovern-Dole 56K + FFPr 460K + FFP-WFP $452M MOU ~105K). USDA OCIO provides enterprise IT architecture governance. Extending existing AMS/KCCO commodity-tracking IT for FFP-specific functionality (partner reporting, beneficiary counts, ITSH financial tracking) is materially more efficient than maintaining FFPMIS or building from scratch.

What USDA must do

  • System-extension RFP (USDA AMS / KCCO IT integration scope)
  • FFPMIS data-migration plan (selective: pipeline data, partner reporting baseline, beneficiary counts)
  • Section 508 WCAG 2.1 AA conformance specification
  • OMB M-25-21 / M-25-22 federal AI acquisition compliance baseline
  • NIST AI RMF 1.0 + Generative AI Profile (NIST AI 600-1) integration
  • AI/Expert Reconciliation Log architecture for AI-assisted system layers
  • USDA OCIO governance review

HSG bench credibility anchor

Jelani House — federal-grade IT infrastructure execution (GovCert.ai, multiple HSG portals, Section 508 WCAG 2.1 AA compliance baseline, AI integration consistent with OMB M-25-21/22 and NIST AI RMF). Audrey McGuire — 27-year platform-grade portfolio-management discipline at Emax on HUD OAS provides the federal-program-infrastructure lineage at scale.

Proposal section: Programmatic Infrastructure Guide + Volume I Factor 2 (IT Infrastructure section)PWS: PWS 3.5 Programmatic Infrastructure

New procurement required

USDA AMS / KCCO system-extension RFP

#08

FFPIB-Equivalent Policy-Guidance Series

Policy Infrastructure
HybridQ2 Priority

What it is

USAID FFP Information Bulletins (FFPIBs) — the de facto FFP operating handbook accumulated since 2010 with approximately 50+ bulletins covering Bellmon estimation (FFPIB 13-03, 23-01), monetization pricing (17-04), Refine and Implement guidance (14-01, 19-01), Resilience Programming (19-02), M&E updates (18-01), Country Specific Information (16-02), Programmatic Reporting (16-01), Performance Indicators (20-01), and the BHA renaming transition notice (21-01). USDA needs the USDA-issued analog.

What USAID had

FFPIB series published by USAID FFP, maintained on USAID public archive. Reconstructing the inventory post-USAID dissolution is underway via Internet Archive captures, InterAction / FANTA practitioner archives, and USDA FAS records.

The Options

Novate

Inherit FFPIB series as-is

Maintain USAID-issued FFPIBs under USDA stewardship without re-issuance.

Pros

  • Zero rulemaking work
  • Preserves partner familiarity

Cons

  • FFPIBs cite USAID authority not USDA authority — applicability ambiguous
  • No mechanism for USDA-shaped policy direction
Build In-House

Republish all FFPIBs as USDA Departmental Regulations

Convert all 50+ FFPIBs into USDA-issued Departmental Regulations.

Pros

  • Full USDA-shaped policy posture
  • Clear USDA authority

Cons

  • Massive rulemaking workload — 50+ Departmental Regulations through USDA clearance process
  • 12–18 months minimum
Hybrid

Selective re-issue (FFPIB Disposition Matrix)

HSG Recommended

Inventory all FFPIBs; classify each as re-issue / modify / sunset under USDA authority; re-publish operative subset as USDA Departmental Regulations.

Pros

  • Efficient — avoids re-issuing all 50+
  • USDA-shaped policy direction for operative bulletins
  • Documented sunset reasoning for retired bulletins

Cons

  • Requires up-front inventory + applicability assessment

HSG Recommendation

Selective re-issue via FFPIB Disposition Matrix — inventory all FFPIBs, classify each, re-publish operative subset under USDA Departmental Regulation series

Inheriting FFPIBs as-is leaves USDA exposed on regulatory authority (FFPIBs cite USAID authority that no longer exists). Republishing all 50+ as Departmental Regulations is excessive — many FFPIBs cover narrow procedural matters that are no longer operative or that are superseded by other USDA-internal directives. The selective re-issue path uses HSG's FFPIB Disposition Matrix methodology (already in the Communications Strategy Guide + Programmatic Infrastructure Guide solutions) to classify each bulletin and re-publish only the operative subset. This is materially the most efficient path — typically only 20–30% of FFPIBs are operative-and-relevant under USDA. No new procurement needed — this is internal Departmental Regulation drafting work.

USDA Office Already Operating This Function Today

USDA Office of General Counsel + FAS Administrator's Office

USDA OGC provides legal review and clearance for USDA Departmental Regulations across all programs. FAS Administrator's office coordinates regulatory codification for FAS-managed programs. Adding FFPIB-derived USDA Departmental Regulations to the existing FAS regulatory portfolio is incremental drafting work (~10–15 operative regulations after FFPIB Disposition Matrix triage) on existing regulatory-drafting capability. No new institutional capability required.

What USDA must do

  • Full FFPIB inventory (reconstructed from USAID public archive + Internet Archive + practitioner archives)
  • Applicability assessment per FFPIB (re-issue / modify / sunset)
  • USDA Departmental Regulation drafting for operative subset (~10–15 bulletins anticipated)
  • Sunset notice for retired bulletins (for partner-facing transparency)
  • FAS General Counsel clearance for Departmental Regulation series

HSG bench credibility anchor

Maurice House — FAS Departmental coordination history. Kevin Latner — FAS cooperator-program directive experience. Jelani House — federal regulatory-analysis depth.

Proposal section: Communications Strategy Guide + Programmatic Infrastructure Guide + Volume I Factor 2 (FFPIB Disposition section)PWS: PWS 3.1 Communications + 3.5 Programmatic Infrastructure

The number of new procurements USDA actually needs to issue is materially smaller than it first appears — most items resolve through internal-staff scale-up, system extension into existing USDA AMS/KCCO/FAS infrastructure, federal-partner MOUs, or selective re-issuance under USDA Departmental Regulations.

HSG's Role: Build the Bridge

The 12-month engagement contemplated by USDA RFQ 12314426Q0118 is precisely the analytical and process-development work that fills the gap between what USDA already has and what it must build. The seven PWS scope areas map directly to seven distinct functional architectures USAID operated and USDA is now constructing.

Read the 8 process guides

Solutions Library

See HSG's methodology

Enhanced Frameworks

Meet the bench

Team

Sources

Public-record research compiled from: USAID public archives (usaid.gov), GAO reports (GAO-17-224, GAO-17-640, GAO-15-666, GAO-22-104612), USAID OIG (Feb 10, 2025 advisory; Fintrac performance audits), Congressional Research Service (R45779 Transformation at USAID, R45879 FFP Nonemergency Programs, R45422 IFA Overview, IF13162 IFA Primer), CSIS 2025 humanitarian-capability retrospective, Tufts Friedman School FAQR project, USDA FAS press releases (Feb 3, 2026 + May 13, 2026), Devex, USDA AMS Commodity Procurement records, USDOT MARAD Cargo Preference reporting, House Agriculture Committee FY2026 FFP one-pager, H.R. 7567 (Farm, Food, and National Security Act of 2026). Primary-source intelligence from Maurice W. House (38-year USDA FAS Senior Foreign Service Minister Counselor; FAS posts Beijing, Brussels, Bangkok, Islamabad, Lagos, Algiers; Deputy Administrator, FAS Office of Global Analysis 2008–2010).