The F in FDA: Both Funding and Reforms Needed to Improve Food Programs

Food programs at FDA are underfunded relative to the agency’s responsibilities. We have carried that message since the Alliance was founded in 2007. Much progress (in funding, personnel, and infrastructure) has been achieved since then, but the need for resources for FDA food programs continues to far outstrip what is available within the agency.

From food stakeholders, Alliance members, Congress, and the Commissioner, we hear general agreement that human food programs need reform. Much of the emphasis and attention within the food community is rightfully focused on shortcomings in transparency, priority setting, and decision-making structure.

Alongside that, resources play a necessary and critical role in fixing areas that need improvement. In the Alliance’s Reagan-Udall Foundation testimony (link) and in other discussions, we have emphasized that addressing any one problem may not require more funding. Addressing a set of problems will.

While the Alliance has no mandate to get into the specifics of policy reforms or to make judgments about how FDA is structured, we accept that reform is needed. Our advocacy for more food funding rests on our belief that reform efforts will be undertaken in “good faith” and will lead to improvements in how the FDA food program carries out its mission.

The fact that the agency may operate more efficiently or effectively under a reformed structure in the near future, however, does not diminish the urgent need to address the funding shortfall that CFSAN, CVM, and ORA face right now.

We hear, understand, and appreciate the calls for “change first, more funding later.” At the same time, as a practical matter, funding needs to be addressed concurrently. FDA must have resources to maintain the integrity of existing programs while evolving new ones. Otherwise, the lack of incremental funding opens up enormous vulnerabilities for existing food safety and nutrition programs.

If food stakeholders defer funding advocacy until reforms are complete, the FY 2024 appropriation cycle will pass them by. Working simultaneously on substance and resources allows for the possibility of additional resources being available by October 1, 2023, a year earlier.

Between the time that the Alliance would be first asking Congress for more resources (February-March 2023) and the earliest time for Congressional action (May - June 2023), there will be many opportunities to judge whether FDA’s commitment to change is genuine and the food community satisfied. If not, there is a strong likelihood that appropriations committees would be open to incorporating such concerns into report language.

The Alliance’s objective is for the entire FDA, including the foods programs, to have the resources required to accomplish the agency’s mission. Throughout FDA, we support increased transparency and better integration of multi-center priorities (such as CFSAN, CVM, and ORA).

Properly resourcing the food safety components of FDA would allow the agency to develop and maintain a system that is intentionally excellent. Why would anyone want anything less?


Editorial Note: This week’s Analysis and Commentary section was written by the Alliance’s Executive Director, Steven Grossman.