Chapter 8 Agency Comments and Our Evaluation
United States Government Accountability Office
We provided a draft of this report to USDA, DOD, HHS, OPM, DHS, and Interior for their review and comment. USDA, DOD, OPM, DHS, and Interior generally agreed with the recommendations.
HHS generally concurred with the report but not with one finding we reported regarding FDA's veterinarian workforce. Also, all departments provided technical comments, which we incorporated as appropriate.USDA agreed that it should periodically assess whether its level of inspection resources dedicated to food safety and humane slaughter activities is sufficient and believes that FSIS is already doing this assessment as a part of its budget formulation process. However, we made this recommendation in 2004, and are repeating it now, because FSIS has yet to demonstrate that they have done this assessment. USDA also reported that because APHIS and FSIS employ the majority of veterinarians within the department, these component agencies will work together, with departmental consultation, as needed, to develop solutions to shared problems. We continue to believe that a departmentwide assessment is necessary. In addition, the department commented that it will track veterinarian workforce trends and devise strategies to train, recruit, and retain veterinarians in order to mitigate attrition and maintain progress toward the department's mission to protect the public health. Furthermore, USDA reported that APHIS and FSIS are already taking steps to revise their pandemic plans to overcome many of the gaps we identified to help ensure the USDA veterinarian workforce can carry out essential functions during a pandemic. USDA's written comments and our evaluation appear in appendix III.
DOD stated that efforts are under way to finalize the Army's pandemic influenza plan and that the implementation date will be determined based on current mission priorities.
DOD's written comments and our evaluation appear in appendix IV.HHS reported that veterinarians are essential to protecting the health of the American people. In addition, the department commented that veterinarians are a valuable resource at CDC and conducting workforce assessments, as recommended in our report, will ensure that HHS maintains a sufficient capacity for outbreak response. HHS further reported that all operating staff division heads are required to have workforce plans in place for their organizations by September 2009. Once the plans are completed, the HHS Office of Human Resources will look across the plans to identify opportunities for collaboration with regard to strategic recruitment, development, and retention. The department also plans to strengthen its oversight of the operating divisions to ensure that they are implementing their workforce plans, focusing on those occupations critical to the success of their missions. While veterinarians are not currently identified as a department-level Mission Critical Occupation, largely because they represent less than 1 percent of the HHS workforce, the department plans to review its Mission Critical Occupations in the coming year using criteria that are more risk-based. However, HHS did not agree with a statement in our report that references a 2007 FDA Advisory Committee report claiming that CVM is in a state of crisis. The department stated that, given the broad nature of the 2007 Advisory Committee report, it is not applicable to veterinarians. However, we reported information pertaining directly to veterinarians—information we obtained from an interview with an author of the Advisory Committee report. Furthermore, HHS stated that CVM has made great strides in the past few years assessing its workforce needs and that the 2007 report is outdated. Our report identifies many of the efforts CVM has recently undertaken, such as hiring additional veterinarians and beginning an effort to analyze the gap between current resources and needs.
It also notes that, according to FDA officials, the agency is undertaking significant reforms to address fundamental concerns in the 2007 report. However, as our report also states, FDA did not tell us how these efforts address the identified veterinarian skill gap specifically. HHS's written comments and our evaluation appear in appendix V.OPM informed us that it has established a team to research and analyze data to determine the feasibility of issuing a governmentwide direct-hire authority for veterinarians under its statutory and regulatory authority. OPM did not provide further details except to say that a decision is expected early in 2009. Until this study is completed, OPM relies on individual agencies to make such requests when they have encountered a severe shortage of candidates or a critical hiring need for veterinarians. In addition, OPM informed us that on November 25, 2008, it approved USDA's request for direct-hire authority. OPM also commented that, in 2003, the agency approved direct-hire authority for temporary and term positions, including veterinarians, to help protect the health or safety of the U.S. food supply during a pandemic or other declared emergency situation. OPM's written comments and our evaluation appear in appendix VI.
DHS recommended that the federal government enhance efforts to identify the veterinarian workforce needed during catastrophic events. They stated that this could be achieved through an OPM pursuit of a multidepartment assessment of veterinary manpower requirements. They further recommended that agencies develop plans that identify how veterinarians will continue essential functions during additional catastrophic events, taking into consideration the potential for absenteeism that exceeds the level of 40 percent estimated for a pandemic. In addition, DHS stated that, once a governmentwide veterinarian workforce need is determined, effective recruitment and retention programs should be developed that are consistent across all agencies.
However, DHS disagreed with our finding that the estimate produced from one of its efforts to identify the workforce needed during a catastrophic outbreak of foot-and-mouth disease is not relevant. We continue to believe, as does DHS, that this effort is based on an infeasible assumption. Therefore, we do not agree that this estimate is relevant to any response that could reasonably be implemented during such an outbreak. DHS's written comments and our evaluation appear in appendix VII.Interior commended GAO for conducting a well-researched examination of the federal veterinarian workforce. The department emphasized the importance of including wildlife disease expertise in a strategy for protecting human and animal health. The department also identified the importance of detecting and preventing non-native invasive infectious diseases from entering U.S. borders via imported wildlife as important to protecting human and animal health. Interior's written comments and our evaluation appear in appendix VIII.
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If you or your staff have any questions about this report, please contact me at (202) 512-3841 or shamesl@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made contributions to this report are listed in appendix IX.
Sincerely yours,
Lisa Shames
Director, Natural Resources and Environment