The F in FDA: Part 2

Last week’s Analysis and Commentary was entitled “The F in FDA: Both Funding and Reforms Needed to Improve Food Programs.” It explained why “more resources for food programs is an essential complement to the reforms sought by food stakeholders.” (For a good overview of the reform effort, we recommend reading Food Fix’s analysis).

As a practical matter, FDA must have resources to maintain the integrity of programs while evolving new ones. Otherwise, the lack of incremental funding opens enormous vulnerabilities for existing food safety and nutrition programs.

Also, working simultaneously on substance and resources allows for the possibility of additional funding being available by October 1, 2023, a year earlier than if funding advocacy is deferred until reforms are completed.

This week’s follow-up column starts to explore CFSAN and CVM resource needs, an area we expect to be of concern to Congress in 2023 and prominent in the Alliance’s FY 24 “ask.”

As a general matter, FDA oversees more than $2.5 trillion of goods and services, about 20% of consumer spending in the U.S. Its mission and responsibilities are grower larger, more diverse, and more complex every year. This can be expected to continue. No federal agency is more affected by changes in science, technology, innovation, commerce, and social trends than FDA.

As a result, every part of FDA needs additional resources—larger budgets, more well-trained staff, and modernization of data and IT systems.

However, each part of FDA needs those additional resources in differing amounts for different purposes. Once reforms are underway in the food area (e.g., better decision-making structures, more transparency of agency actions and priorities, and transparency on allocation/use of monies), funding will be needed to strengthen an array of programs.

Here is what we told Congress about the Alliance’s food funding priorities for FY 23:

Food Safety – For FY 23, we urge Congress to consider:

More robust and rapid Food Safety Modernization Act (FSMA) implementation, including increased cooperation with states, finalization of guidances, and a focus on produce safety, import safety, and training/education;Enhanced funding of systems for surveillance of foodborne illnesses and outbreak response;Upgrades to the public health laboratories network;Strengthening the scientific capabilities of the Center for Food Safety and Applied Nutrition (CFSAN), the Center for Veterinary Medicine (CVM), and the National Center for Toxicological Research (NCTR); andStarting the development and implementation of initiatives contained in the agency’s New Era of Smarter Food Safety.Funding should also be considered for: FDA’s recall initiatives, nutrition education, safety of cosmetics and dietary supplements, antimicrobial resistance, CBD, and standards of identity/food labeling and product claims.

This is far from a complete list. We are strong advocates for more investment in state programs that stretch inspection and compliance capacity beyond FDA’s in-house capabilities.

The only way to increase FDA food program funding is to document the need and illustrate how increased appropriated funding could be spent to meet that need. The more specific we can be, the more likely Congress will see the needs are substantial and ought not to be delayed. We need to stay focused on tying documented needs to food program funding. Spurious comparisons to medical products really do not tell us anything about what is needed to make our food supply safer.

With agency reform, budget transparency, and documented agency needs, we will be positioned to convince Congress to allocate additional appropriated dollars. Join us in making that happen!