Veterinarian Workforce
Actions Are Needed to Ensure Sufficient Capacity for Protecting Public and Animal Health Gao ID: GAO-09-178 February 4, 2009Veterinarians are essential for controlling zoonotic diseases--which spread between animals and humans--such as avian influenza. Most federal veterinarians work in the Departments of Agriculture (USDA), Defense (DOD), and Health and Human Services (HHS). However, there is a growing national shortage of veterinarians. GAO determined the extent to which (1) the federal government has assessed the sufficiency of its veterinarian workforce for routine activities, (2) the federal government has identified the veterinarian workforce needed during a catastrophic event, and (3) federal and state agencies encountered veterinarian workforce challenges during four recent zoonotic outbreaks. GAO surveyed 24 federal entities about their veterinarian workforce; analyzed agency workforce, pandemic, and other plans; and interviewed federal and state officials that responded to four recent zoonotic outbreaks.
The federal government lacks a comprehensive understanding of the sufficiency of its veterinarian workforce. More specifically, four of five component agencies GAO reviewed have assessed the sufficiency of their veterinarian workforce to perform routine activities and have identified current or future concerns. This includes USDA's Animal and Plant Health Inspection Services (APHIS), Food Safety and Inspection Service (FSIS), and Agricultural Research Service (ARS); and DOD's Army. Current and future shortages, as well as noncompetitive salaries, were among the concerns identified by these agencies. HHS's Food and Drug Administration (FDA) does not perform such assessments and did not identify any concerns. In addition, at the department level, USDA and HHS have not assessed their veterinarian workforces across their component agencies, but DOD has a process for doing so. Moreover, there is no governmentwide effort to search for shared solutions, even though 16 of the 24 federal entities that employ veterinarians raised concerns about the sufficiency of this workforce. Further exacerbating these concerns is the number of veterinarians eligible to retire in the near future. GAO's analysis revealed that 27 percent of the veterinarians at APHIS, FSIS, ARS, Army, and FDA will be eligible to retire within 3 years. Efforts to identify the veterinarian workforce needed for a catastrophic event are insufficient. Specifically, agencies' plans lack important elements necessary for continuing essential veterinarian functions during a pandemic, such as identifying which functions must be performed on-site and how they will be carried out if absenteeism reaches 40 percent--the rate predicted at the height of the pandemic and used for planning purposes. In addition, one federal effort to prepare for the intentional introduction of a foreign animal disease is based on the unrealistic assumption that all affected animals will be slaughtered, as the United States has done for smaller outbreaks, making the resulting veterinarian workforce estimates irrelevant. A second effort lacks crucial data, including data on how the disease would spread in wildlife. If wildlife became infected, as they have in the past, response would be greatly complicated and could require more veterinarians and different expertise. Officials from federal and state agencies involved in four recent zoonotic disease outbreaks commonly cited insufficient veterinarian capacity as a workforce challenge. However, 10 of the 17 agencies that GAO interviewed have not assessed their own veterinarian workforce's response to individual outbreaks and are thus missing opportunities to improve future responses. Moreover, none of the entities GAO reviewed has looked across outbreaks to identify common workforce challenges and possible solutions.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-09-178, Veterinarian Workforce: Actions Are Needed to Ensure Sufficient Capacity for Protecting Public and Animal Health
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Report to the Chairman, Subcommittee on Oversight of Government, the
Federal Workforce, and the District of Columbia, Committee on Homeland
Security and Governmental Affairs, U.S. Senate:
United States Government Accountability Office:
GAO:
February 2009:
Veterinarian Workforce:
Actions Are Needed to Ensure Sufficient Capacity for Protecting Public
and Animal Health:
GAO-09-178:
GAO Highlights:
Highlights of GAO-09-178, a report to the Chairman, Subcommittee on
Oversight of Government Management, the Federal Workforce, and the
District of Columbia, Committee on Homeland Security and Governmental
Affairs, U.S. Senate.
Why GAO Did This Study:
Veterinarians are essential for controlling zoonotic diseases”which
spread between animals and humans”such as avian influenza. Most federal
veterinarians work in the Departments of Agriculture (USDA), Defense
(DOD), and Health and Human Services (HHS). However, there is a growing
national shortage of veterinarians. GAO determined the extent to which
(1) the federal government has assessed the sufficiency of its
veterinarian workforce for routine activities, (2) the federal
government has identified the veterinarian workforce needed during a
catastrophic event, and (3) federal and state agencies encountered
veterinarian workforce challenges during four recent zoonotic
outbreaks. GAO surveyed 24 federal entities about their veterinarian
workforce; analyzed agency workforce, pandemic, and other plans; and
interviewed federal and state officials that responded to four recent
zoonotic outbreaks.
What GAO Found:
The federal government lacks a comprehensive understanding of the
sufficiency of its veterinarian workforce. More specifically, four of
five component agencies GAO reviewed have assessed the sufficiency of
their veterinarian workforce to perform routine activities and have
identified current or future concerns. This includes USDA‘s Animal and
Plant Health Inspection Services (APHIS), Food Safety and Inspection
Service (FSIS), and Agricultural Research Service (ARS); and DOD‘s
Army. Current and future shortages, as well as noncompetitive salaries,
were among the concerns identified by these agencies. HHS‘s Food and
Drug Administration (FDA) does not perform such assessments and did not
identify any concerns. In addition, at the department level, USDA and
HHS have not assessed their veterinarian workforces across their
component agencies, but DOD has a process for doing so. Moreover, there
is no governmentwide effort to search for shared solutions, even though
16 of the 24 federal entities that employ veterinarians raised concerns
about the sufficiency of this workforce. Further exacerbating these
concerns is the number of veterinarians eligible to retire in the near
future. GAO‘s analysis revealed that 27 percent of the veterinarians at
APHIS, FSIS, ARS, Army, and FDA will be eligible to retire within 3
years.
Efforts to identify the veterinarian workforce needed for a
catastrophic event are insufficient. Specifically, agencies‘ plans lack
important elements necessary for continuing essential veterinarian
functions during a pandemic, such as identifying which functions must
be performed on-site and how they will be carried out if absenteeism
reaches 40 percent”the rate predicted at the height of the pandemic and
used for planning purposes. In addition, one federal effort to prepare
for the intentional introduction of a foreign animal disease is based
on the unrealistic assumption that all affected animals will be
slaughtered, as the United States has done for smaller outbreaks,
making the resulting veterinarian workforce estimates irrelevant. A
second effort lacks crucial data, including data on how the disease
would spread in wildlife. If wildlife became infected, as they have in
the past, response would be greatly complicated and could require more
veterinarians and different expertise.
Officials from federal and state agencies involved in four recent
zoonotic disease outbreaks commonly cited insufficient veterinarian
capacity as a workforce challenge. However, 10 of the 17 agencies that
GAO interviewed have not assessed their own veterinarian workforce‘s
response to individual outbreaks and are thus missing opportunities to
improve future responses. Moreover, none of the entities GAO reviewed
has looked across outbreaks to identify common workforce challenges and
possible solutions.
What GAO Recommends:
GAO is making recommendations to help ensure sufficient veterinarian
capacity to protect public and animal health. In commenting on a draft
of this report USDA, DOD, OPM, DHS, and Interior generally agreed with
our recommendations. HHS generally concurred with the report, but
disagreed with a 2007 FDA Advisory Committee report GAO cited, which
said that FDA‘s Center of Veterinary Medicine is in a state of crisis.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-09-178]. For more
information, contact Lisa Shames at (202) 512-3841 or shamesl@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
The Federal Government Lacks a Comprehensive Understanding of the
Sufficiency of Its Veterinarian Workforce:
Efforts to Identify the Veterinarian Workforce Needed during a Pandemic
and Large-Scale Animal Disease Outbreak Are Insufficient:
Federal and State Agencies Are Missing Important Opportunities to
Ensure Efficient Use of Veterinarians During Disease Outbreaks:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Location and Responsibilities of Veterinarians in the
Federal Government:
Appendix II: Scope and Methodology:
Appendix III: Comments from the Department of Agriculture:
Appendix IV: Comments from the Department of Defense:
Appendix V: Comments from the Department of Health and Human Services:
Appendix VI: Comments from the Office of Personnel Management:
Appendix VII: Comments from the Department of Homeland Security:
Appendix VIII: Comments from the Department of the Interior:
Appendix IX: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Agency Concerns about Sufficiency of the Federal Veterinarian
Workforce:
Table 2: Four Recent Zoonotic Outbreaks We Analyzed:
Figures:
Figure 1: Percentage of Veterinarian Grade Levels by Key USDA Agencies
in Fiscal Year 2008:
Figure 2: Mean Veterinarian Salaries by Key USDA Agencies, Fiscal Years
2003-2007:
Figure 3: Mean Veterinarian Base Salaries at 19 Component Agencies or
Federal Entities in Fiscal Year 2008:
Abbreviations:
APHIS:Animal and Plant Health Inspection Service:
ARS: Agricultural Research Service:
CDC: Centers for Disease Control and Prevention:
CSREES: Cooperative State Research, Education, and Extension Service:
CVM: Center for Veterinary Medicine:
DHS: Department of Homeland Security:
DOD: Department of Defense:
FDA: Food and Drug Administration:
FEMA: Federal Emergency Management Agency:
FSIS: Food Safety and Inspection Service:
HHS: Department of Health and Human Services:
HSPD: Homeland Security Presidential Directive:
Interior: Department of the Interior:
NADC: National Animal Disease Center:
NAFV: National Association of Federal Veterinarians:
NIH: National Institutes of Health:
OIG: Office of Inspector General:
OPM: Office of Personnel Management:
SES: Senior Executive Service:
USDA: Department of Agriculture:
USGS: U.S. Geological Survey:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
February 4, 2009:
The Honorable Daniel K. Akaka:
Chairman:
Subcommittee on Oversight of Government Management, the Federal
Workforce, and the District of Columbia:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
Dear Mr. Chairman:
Veterinarians play a vital role in the defense against animal diseases-
-whether naturally or intentionally introduced--and these diseases can
cause serious harm to human health and the economy. For example,
veterinarians were at the forefront of the response to the 2001 United
Kingdom outbreak of foot-and-mouth disease, which resulted in the
slaughter of more than 4 million animals to control the outbreak,
losses of over $5 billion to the food and agriculture sectors, and
comparable losses to the tourism industry. Veterinarians are also
essential for controlling zoonotic diseases, which are diseases that
spread between animals and humans. Zoonotic diseases are of particular
concern because, in recent years, about 75 percent of the newly
emerging infectious diseases affecting humans have originated in
animals. For example, over the past few years, a highly pathogenic
strain of avian influenza has killed millions of wild and domestic
birds worldwide and infected over 400 people, more than half of whom
have died. Health experts are concerned that this virus could cause a
pandemic if it develops the ability to spread efficiently from human to
human. Veterinarians also help prevent foodborne illness, which humans
can acquire, for example, from meat contaminated with viruses or
bacteria. Each year, about 76 million Americans contract foodborne
illnesses, and about 5,000 die.
However, there is a growing shortage of veterinarians nationwide,
particularly of veterinarians who care for animals raised for food,
serve in rural communities, and have training in public health,
according to several professional associations. This shortage has,
according to the American Veterinary Medical Association, placed the
nation's food supply at risk and could hinder efforts to protect humans
from zoonotic diseases. The veterinarian shortage is expected to
worsen, partly as a result of space constraints at the country's 28
veterinary colleges, which can graduate only about 2,500 students a
year combined, according to the American Association of Veterinary
Medical Colleges. The demand for veterinarians is expected to increase,
however. For example, the Bureau of Labor Statistics predicts that
demand will increase by 35 percent from 2006 to 2016--from 62,000 full-
time jobs to 84,000. Subsequently, the Congress enacted two pieces of
legislation that address these concerns. In 2003, it enacted the
National Veterinary Medical Services Act directing the Secretary of
Agriculture to carry out a program to help repay school loans for
veterinarians who agree to work in areas of need. In August 2008, the
Congress passed the Higher Education Opportunity Act, which has
provisions intended to increase the number of veterinarians in the
workforce.
The federal government employs more than 3,000 veterinarians. Although
this number represents a small portion of the federal workforce, these
veterinarians play a crucial role in helping to protect people and the
economy from animal diseases. More than 2,900 federal veterinarians
work for component agencies within the Departments of Agriculture
(USDA), Defense (DOD), and Health and Human Services (HHS). The 1,771
veterinarians at USDA have numerous functions, including the following:
* Animal and Plant Health Inspection Service (APHIS) veterinarians help
protect and maintain the health of American livestock and poultry
during production, and monitor wildlife populations for critical
endemic and foreign animal diseases;
* Food Safety and Inspection Service (FSIS) veterinarians inspect
animals at slaughter plants to help ensure the safety of meat and
poultry products, and they also oversee the humane treatment of
livestock during slaughter; and:
* Agricultural Research Service (ARS) veterinarians research critical
endemic and foreign animal diseases.
DOD employs 841 veterinarians, the majority of whom work for the Army
as active duty veterinarians or as part of the Army's veterinary
reserve corps. These veterinarians are responsible for caring for
service and research animals, ensuring food safety at military
installations, and conducting intelligence work related to
bioterrorism, among other things.
HHS employs 316 veterinarians, whose functions include the following:
* Food and Drug Administration (FDA) veterinarians are responsible for
ensuring that animal drugs are safe and effective, that animal feed is
safe, and that food from medically treated animals is safe to eat. They
also help ensure the safety of food, drugs, and cosmetics, among other
things;
* Centers for Disease Control and Prevention (CDC) veterinarians help
promote human health by conducting research and investigating human
disease outbreaks of animal origin. They also oversee the welfare of
animals used in such research, as required by federal regulation.
Veterinarians work in other departments, such as the Department of the
Interior (Interior), whose 24 veterinarians play a role in researching,
diagnosing, and responding to wildlife diseases. The Department of
Homeland Security (DHS) also employs veterinarians to, among other
things, help develop national policy for defending the nation's
agriculture and food supply against terrorist attacks and other
emergencies. See appendix I for a list of veterinarian roles and
responsibilities within the federal government.
As this list of responsibilities indicates, the federal veterinarian
workforce plays a critical role in ensuring the safety of the U.S. food
supply. However, we testified in 2008 that the staffing levels at FSIS-
-where veterinarians play an important role in helping to ensure the
safety of our food supply and the humane treatment of animals during
slaughter--have declined since 1995 despite an increasing budget, and
some districts have experienced high vacancy rates among inspectors.
This could impair enforcement of the Humane Methods of Slaughter Act of
1978 and of food safety regulations generally.[Footnote 1] In addition,
we have designated the federal oversight of food safety as a high-risk
area of government operations because the current system is fragmented,
causing inconsistent oversight, ineffective coordination, and
inefficient use of resources.[Footnote 2]
As with all professions in the federal government, departments and
their component agencies are responsible for hiring and maintaining a
veterinarian workforce sufficient to meet their missions. High-
performing public organizations have found that maintaining a quality
workforce requires them to systematically assess current and future
workforce needs and formulate a long-term strategy to attract, retain,
develop, and motivate employees.[Footnote 3] The Office of Personnel
Management (OPM) provides guidance and leadership intended to help
build a high-quality and diverse federal workforce. Our prior work has
identified the need for OPM to use its leadership position to help
departments and agencies recruit and retain a capable and committed
workforce.[Footnote 4]
In this context, you asked us to determine the extent to which (1) the
federal government has assessed the sufficiency of its veterinarian
workforce for routine program activities, (2) the federal government
has identified the veterinarian workforce needed during a catastrophic
event, and (3) federal and state agencies encountered veterinarian
workforce challenges during four recent zoonotic outbreaks.
To address the first objective, we identified and surveyed departments,
component agencies, and other federal entities employing veterinarians
to determine, among other things, the number, salaries, and roles and
responsibilities of veterinarians, as well as the sufficiency of this
workforce. We then selected component agencies within three departments
for further analysis to determine the extent to which they assessed the
sufficiency of their veterinarian workforce. We selected USDA, DOD, and
HHS because these departments employ about 96 percent of federal
veterinarians. Within these departments, we focused our veterinarian
workforce assessment review on APHIS, FSIS, Army, and FDA, because
these component agencies employ the most veterinarians. We also
selected ARS for further review because it is USDA's chief scientific
research agency and conducts research to solve agricultural problems of
high national priority. We interviewed officials involved in workforce
planning, as well as those that carry out program activities such as
veterinarians working in slaughter plants. To address the second
objective, we analyzed agency plans for continuing essential functions
during a pandemic, and compared them with DHS national planning
guidance, which identifies essential elements that federal departments
and agencies should consider. We also reviewed veterinarian workforce
outcomes from DHS's nationwide effort to assess the nation's
preparedness for multiple, intentional introductions of foot-and-mouth
disease. We selected a pandemic and intentional foot-and-mouth disease
outbreak because these are two potential catastrophic events the White
House Homeland Security Council has deemed critical for planning
purposes. To address the third objective, we conducted semistructured
interviews with selected officials from 17 federal and state agencies
involved in responding to the following four recent zoonotic outbreaks:
* bovine tuberculosis in Michigan: a bacterial disease that spreads
from deer to cattle;
* exotic Newcastle disease in California: a highly infectious virus
that spread rapidly throughout poultry;
* monkeypox in Wisconsin: a virus not seen in the United States until
2003, when there was an outbreak in exotic pets and humans; and:
* West Nile virus in Colorado: a disease that spread rapidly across the
United States, infecting numerous species.
We focused our review on these outbreaks because they were most
frequently recommended by federal officials as examples of zoonotic
diseases, are still occurring or occurred since 2001, and affected
various types of animals, among other things. Additional details about
our scope and methodology are presented in appendix II.
We conducted this performance audit from September 2007 to February
2009, in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
Results in Brief:
Despite a growing shortage of veterinarians, the federal government
does not have a comprehensive understanding of the sufficiency of its
veterinarian workforce for routine program activities. Specifically,
although four of five component agencies we reviewed have assessed
their veterinarian workforces, little has been done to gain a broader,
departmentwide perspective, and no assessment has been conducted
governmentwide.
* At the component agency level, APHIS, FSIS, ARS, and Army assessments
have each identified actual or potential veterinarian shortages. First,
APHIS reported it has filled all of its veterinary positions but has
identified a potential future shortage of, for example, veterinary
pathologists, who diagnose animal diseases. In addition, 30 percent of
APHIS' veterinarians will be eligible to retire by the end of fiscal
year 2011. Second, FSIS has not been fully staffed over the past
decade, according to agency officials. In fiscal year 2008, it had a
goal of employing 1,134 veterinarians to carry out its mission of
ensuring the safety of meat and poultry products, but it had 968 as of
the end of that fiscal year--a 15 percent shortage. FSIS veterinarians
working in slaughter plants told us that a lack of veterinarians has
impaired the agency's ability to meet its food safety responsibilities,
but FSIS headquarters officials told us this was not the case. In 2004,
we recommended that FSIS periodically assess whether the level of
resources dedicated to humane handling and slaughter activities is
sufficient, but the agency has yet to demonstrate that they have done
so. Third, ARS reported a 12 percent shortage of veterinarians.
Officials told us the agency needed 65 veterinarians--most of them with
a Ph.D.--to conduct critical animal disease research, such as detecting
avian influenza and developing vaccines against it. However, in fiscal
year 2008, ARS had only 57. Fourth, while the Army has filled all of
its active-duty veterinarian positions, officials reported that the
veterinary reserve corps is 12 percent short of its goal and identified
an increasing demand for veterinary pathologists and medical
intelligence specialists. In contrast to these four agencies, FDA does
not regularly assess the sufficiency of its veterinarian workforce. FDA
officials told us the agency has enough veterinarians to meet its
responsibilities, despite a 2007 internal review that found its
scientific workforce, including veterinarians, is inadequate and that
FDA's Center for Veterinary Medicine is in a state of crisis.
* At the department level, neither USDA nor HHS has assessed its
veterinarian workforce to gain a departmentwide perspective on trends
and shared issues, whereas DOD has a process for doing so. USDA does
not perform such assessments because, according to department-level
officials, workforce planning is the responsibility of the component
agencies. As a result, USDA's agencies compete against one another for
a limited number of veterinarians. According to FSIS officials, APHIS
is attracting veterinarians away from FSIS because the work at APHIS is
more appealing, there are more opportunities for advancement, and the
salaries are higher. HHS officials told us they do not assess
veterinarian workforce needs departmentwide because veterinarians are
not deemed mission critical for the department, even though they are
critical to the missions of its component agencies that employ
veterinarians.
* Governmentwide, no integrated approach exists for assessing the
current and future sufficiency of the veterinarian workforce. Yet
officials from 16 of the 24 component agencies and other federal
entities that employ veterinarians told us they are concerned about the
sufficiency of their veterinarian workforce. This includes four of the
five key agencies where we focused our agency-level review. Further
exacerbating these concerns is the number of veterinarians eligible to
retire in the near future. Our analysis revealed that 27 percent of the
veterinarians at APHIS, FSIS, ARS, Army, and FDA will be eligible to
retire within 3 years. OPM officials told us they will initiate a
governmentwide effort to address this issue if the departments
demonstrate that a shortage exists. This could include allowing
departments to expedite the hiring of veterinarians, as OPM has done in
the past in the case of doctors and nurses.
We are making several recommendations to improve the federal
government's ability to meet its routine veterinary responsibilities.
The federal government has undertaken efforts to identify the
veterinarian workforce needed during two catastrophic events--a
pandemic and multiple intentional introductions of foot-and-mouth
disease. However, these efforts are insufficient because they are
either incomplete, based on an infeasible planning assumption, or
lacking in adequate data.
* Four of the five agencies we reviewed--APHIS, FSIS, ARS, and FDA--
have developed pandemic plans that identify how they will continue
essential functions, including those that veterinarians perform, during
a pandemic that severely reduces the workforce. However, each plan
lacks elements that DHS has deemed necessary. For example, FDA's plan
does not identify which functions its veterinarians must perform on
site, which can be performed remotely, or how the agency will conduct
essential functions if a pandemic renders its leadership and essential
staff unavailable. FDA officials told us they are updating their plan
and will consider such gaps. The Army is still in the process of
getting its pandemic plan approved and, therefore, we have not
evaluated it.
* DHS has two efforts under way that involve identifying the workforce
needed during a catastrophic outbreak of foot-and-mouth disease, which
would require veterinarians to quickly diagnose and control the fast-
moving disease in a large number of animals. The first effort is
hindered by an infeasible planning assumption. Specifically, DHS is
coordinating a long-term national effort that is based on the
assumption, set forth by a White House Homeland Security Council
working group, that the United States would slaughter all potentially
exposed animals, as it has during smaller outbreaks of foreign animal
diseases. However, DHS and USDA officials consider this approach
infeasible for such a large outbreak and told us that although the
planning effort is a valuable exercise for understanding the enormity
of the resources needed to respond to such an event, any workforce
estimates produced from this effort are not relevant. The second effort
is hindered by a lack of information. Specifically, DHS is modeling
various foot-and-mouth disease outbreak scenarios in order to estimate
the number and type of personnel needed for responding to foot-and-
mouth disease by using vaccines, among other things. Vaccinating
animals instead of slaughtering them to control the outbreak is a new
strategy, which DHS and USDA officials believe may play an important
role in controlling a catastrophic outbreak. However, the details of
how this vaccine-based strategy would be implemented are not yet
formalized, reducing the likelihood that workforce estimates will be
accurate. In addition, the models do not yet factor in the potential
for the disease to spread between livestock and wildlife. If wildlife
became infected, as they have in some past outbreaks, control and
eradication strategies would be greatly complicated and could require
more veterinarians and different expertise. Agency officials recognize
the importance of including wildlife for controlling and eradicating
foot-and-mouth disease but told us that the data on how wildlife and
livestock interact are limited.
We are making recommendations to improve the federal government's
ability to identify the veterinarian workforce needed during a pandemic
and to respond to a large-scale outbreak of foot-and-mouth disease.
The veterinarian workforce challenge most commonly cited by federal and
state agencies involved in the four recent zoonotic outbreaks we
reviewed was insufficient veterinarian capacity. Specifically,
officials we interviewed at 12 of the 17 agencies involved in the
recent outbreaks told us they did not have enough veterinarians to
address these outbreaks while continuing to carry out their routine
activities. Officials at numerous state agencies attribute this
insufficient capacity to difficulty recruiting and retaining
veterinarians because, among other things, the salaries they are able
to offer are lower than those offered in the federal or private
sectors. In addition, to control a demanding outbreak of exotic
Newcastle disease in poultry in California in 2003, APHIS had to borrow
more than 1,000 veterinarians from federal and state agencies around
the country, as well as the private sector. This reduced the number of
veterinarians available to respond to outbreaks of bovine tuberculosis
in Michigan, monkeypox in Wisconsin, and West Nile virus in Colorado.
Despite reports of insufficient veterinarian capacity during the four
outbreaks, the agencies have not taken full advantage of two key
opportunities to learn from past experience. First, 10 of the 17
agencies have not assessed their own veterinarian workforce's response
to individual outbreaks, which our prior work has identified as a
useful tool for improving response.[Footnote 5] Second, none of the
agencies have looked across outbreaks to identify common challenges.
Consequently, the agencies are missing the opportunity to identify
workforce challenges that have arisen during outbreaks and ways to
address them in the future. Federal and state agency officials we spoke
with generally agreed that it would be beneficial to conduct
postoutbreak assessments. However, some agency officials told us that
they are already having difficulty meeting their responsibilities and
have not had time to do so. We are making recommendations to improve
the ability of the federal government to help ensure the efficient and
effective use of the veterinarian workforce during future zoonotic
disease outbreaks.
In commenting on a draft of this report, USDA, DOD, OPM, DHS, and
Interior generally concurred with the report's recommendations.
However, DHS did not agree that veterinarian workforce estimates
produced from one of its planning efforts are not relevant. HHS
generally concurred with our report but disagreed with a 2007 FDA
Advisory Committee report GAO cited, which said that FDA's Center of
Veterinary Medicine is in a state of crisis. USDA, DOD, HHS, OPM, DHS,
and Interior also provided additional information, comments, and
clarifications on the report's findings that we have addressed, as
appropriate, throughout the report.
Background:
High-performing public organizations have found that maintaining a
quality workforce requires them to systematically assess current and
future workforce needs and formulate a long-term strategy to attract,
retain, develop, and motivate employees. While simple in theory,
strategic planning can be difficult to carry out. Managers must, for
example, acquire accurate information on the workforce, set goals for
employee performance, and develop ways to measure that performance.
According to our previous work, strategic workforce planning should
involve certain key principles. Among these principles is the need to
involve top management, employees, and other stakeholders in
developing, communicating, and implementing a strategic workforce plan.
Other principles include determining the critical skills that will be
needed, developing strategies to address any gaps in these skills,
building the capability needed to address educational and other
requirements important to support workforce planning strategies, and
monitoring and evaluating progress toward workforce goals.[Footnote 6]
However, federal agencies have for years lacked a strategic approach to
workforce management. Consequently, since 2001, we have identified
human capital management as a high-risk area needing urgent attention
and transformation.[Footnote 7]
OPM provides information and guidance on a wide range of strategies
that departments and agencies can use to help strategically plan for
and maintain a workforce sufficient to accomplish their missions. This
includes standard retention and recruitment payments, such as
recruitment incentives and student loan repayments. OPM can also
authorize departments to use additional strategies to address workforce
shortage situations should standard strategies prove insufficient. For
example, OPM can approve higher salaries for individual positions in an
occupation if the agency has difficulty staffing a position requiring
an extremely high level of expertise that is critical to the agency's
successful accomplishment of an important mission.
In addition to maintaining a workforce sufficient for routine
functions, departments and agencies are directed by the President to
ensure they can carry out essential functions during a "catastrophic
event." Such a catastrophic event is any natural or man-made incident,
including terrorism, that results in extraordinary levels of mass
casualties, damage, or disruption severely affecting the population,
infrastructure, environment, economy, national morale, and/or
government functions. To do so, agencies must develop continuity of
operation plans for emergencies that disrupt normal operations.
Continuity planning includes identifying and establishing procedures to
ensure vital resources are safeguarded, available, and accessible to
support continuity operations. Vital resources are personnel,
equipment, systems, infrastructures, supplies, and other assets
required to perform an agency's essential functions. DHS's Federal
Emergency Management Agency (FEMA) provides direction to the federal
executive branch for developing continuity plans and programs,
including pandemic plans.
For one type of catastrophic event, a pandemic that severely reduces
the workforce, DHS has developed guidance that identifies specific
elements agencies should consider as they plan to maintain essential
services and functions. FEMA concluded that planning for a pandemic
requires a state of preparedness that goes beyond normal continuity of
operations planning. On March 1, 2006, FEMA first issued guidance to
assist departments and agencies in identifying special considerations
for protecting the health and safety of employees and maintaining
essential functions and services during a pandemic. The Implementation
Plan for the National Strategy for Pandemic Influenza recommends that
organizations plan for a 40 percent absenteeism rate at the height of a
pandemic. In addition, it called for department and agency pandemic
plans to be completed by March 31, 2006.
Departments and agencies must also plan for other events that could
place extraordinary demands on their workforce, such as a catastrophic
outbreak of a foreign animal disease. In December 2003, the President
issued a Homeland Security Presidential Directive (HSPD-8) to establish
national policy to strengthen the preparedness of the United States to
prevent and respond to terrorist attacks, major disasters, and other
emergencies. As part of its efforts to meet HSPD-8, a White House
Homeland Security Council working group developed National Planning
Scenarios for 15 major events, including a biological attack with a
foreign animal disease, foot-and-mouth disease. According to the
scenario, terrorists introduce the disease in several locations and
states simultaneously. The transportation of livestock spreads the
contagious virus to surrounding states and, within 10 days of the
attack, more than half of the states may be affected. Ultimately,
almost half the nation's beef, dairy, and swine would be affected.
These scenarios serve as the basis for assessing the nation's
preparedness for such an event by defining tasks that may be required
and the capabilities needed governmentwide to perform these tasks.
Although not a prescription for the resources needed to achieve these
capabilities, they are intended to help identify such resource needs
and guide planning efforts. No single jurisdiction or agency will be
expected to perform every task, so the response to a catastrophic event
will require coordination among all levels of government. State and
local agencies are typically the first to respond, but federal agencies
become involved if state resources are overwhelmed. In certain
catastrophic events, it becomes the responsibility of DHS to coordinate
the federal response.
The Federal Government Lacks a Comprehensive Understanding of the
Sufficiency of Its Veterinarian Workforce:
Four of the five key agencies that employ veterinarians--APHIS, FSIS,
ARS, and Army--regularly assess the sufficiency of their veterinarian
workforces for routine program activities, and all four identified
existing or potential shortages. FDA does not perform such assessments.
At the department level, USDA and HHS have not assessed their
veterinarian workforces across their component agencies, whereas DOD
has delegated this task to the Army. Finally, there is no
governmentwide assessment of the veterinarian workforce. Specifically,
OPM has not conducted a governmentwide effort to address current and
future veterinarian shortages identified by component agencies, and
efforts by the Congress to address the national shortage have thus far
had minimal impact.
Four of Five Agencies Have Identified Existing and Potential
Veterinarian Shortages:
APHIS, FSIS, ARS, and Army conduct regular workforce assessments. While
APHIS reported it does not currently have a shortage, it identified a
potential future shortage. FSIS, ARS, and Army have identified both
existing and potential future shortages. FDA does not conduct such
assessments, but officials there told us the veterinarian workforce is
adequate to meet its responsibilities. Our work has shown that agencies
should be held accountable for the ongoing monitoring and refinement of
human capital approaches to recruit and hire a capable and committed
federal workforce.
APHIS:
APHIS reported that none of its six units that employ veterinarians has
identified a current shortage, but officials told us they are concerned
about the future size and skills of the veterinarian workforce. First,
the agency reported that 30 percent of its veterinarians will be
eligible to retire by the end of fiscal year 2011, potentially creating
a serious shortage. This is consistent with our previous work where we
reported that one-third of federal career employees on board at the end
of fiscal year 2007 are eligible to retire between spring 2008 and
2012.[Footnote 8] In addition, APHIS is concerned that it will be
unable to maintain an adequate workforce of veterinary pathologists.
This is consistent with a report by the United States Animal Health
Association, which found a shortage of over 40 percent nationwide. An
APHIS laboratory director told us that veterinary pathologists are
integral to work conducted in APHIS diagnostic laboratories, including
work on diseases that threaten animal and human health. For example,
APHIS veterinary pathologists work on bovine spongiform encephalopathy,
a fatal degenerative disease--commonly known as mad cow disease--that
has been linked to at least 165 human deaths worldwide. APHIS also
identified a need to maintain a veterinarian workforce with sufficient
expertise to help protect livestock and the nation's food supply from
foreign animal diseases. We reported in 2005 that many U.S.
veterinarians lack the training needed to identify such diseases,
whether naturally or intentionally introduced.[Footnote 9] Finally,
after the terrorist attacks of 2001, USDA's responsibilities were
broadened to enhance the ability of the United States to manage
domestic incidents. As such, in addition to being the lead for
coordinating any response efforts to incidents involving an animal
disease, APHIS will now also play a supporting role in incidents not
directly related to animal diseases. For example, APHIS veterinarians
may be called upon to assist in ensuring the safety and security of the
commercial food supply or for caring for livestock stranded in
hurricanes and floods. These increased responsibilities raise concerns
about the ability of veterinarians to respond to multiple, simultaneous
events, according to agency officials.
APHIS has supported training opportunities to help overcome some of
these projected skill gaps. The agency has also set a goal of
recruiting at all veterinary colleges and working with universities to
help them include relevant training in their course offerings. In
addition, APHIS uses bonuses to attract and maintain its veterinarian
workforce. During the first 9 months of fiscal year 2008, it provided
one retention and one relocation bonus to veterinarians, totaling
$41,654.
FSIS:
Over the past decade, FSIS has not had a sufficient number of
veterinarians and remains unable to overcome this shortage, according
to FSIS officials. The agency's goal was to have 1,134 veterinarians on
staff in fiscal year 2008, but it fell short of that by 166
veterinarians, or 15 percent. Moreover, since fiscal year 2003, the
FSIS veterinarian workforce has decreased by nearly 10 percent--from
1,073 to 968. The majority of these veterinarians work in slaughter
plants. Federal law prohibits slaughtering livestock or poultry at a
plant that prepares the livestock or poultry for human consumption for
use in interstate commerce unless the animals have been examined by
USDA inspectors and requires the humane slaughtering and handling of
livestock at such plants. In implementing federal law, each slaughter
plant is covered by one or more FSIS veterinarians to, among other
things, ensure the safety and quality of meat and poultry products and
the humane treatment of livestock during slaughter. Agency data from
the past 5 years reveal that vacancy rates for veterinarian positions
in slaughter plants vary by location and year, from no vacancy to as
many as 35 percent of the positions vacant.
FSIS headquarters officials and veterinarians working in slaughter
plants differed on the impact of this shortage. Headquarters officials
told us that, despite the shortage, the agency has been able to meet
its food safety and other responsibilities by redistributing the
workforce. For example, in some cases, FSIS has assigned one
veterinarian to several slaughter plants or assigned only one to plants
that previously had two. In contrast, several veterinarians working in
slaughter plants told us that, because of inadequate staffing, they are
not always able to meet their responsibilities and perform high-quality
work. For example, veterinarians told us they cannot always verify
crucial sanitation and security checks of the plant or promptly log
data on animal diseases and welfare.
In early 2008, veterinarians also told us they did not always have time
to ensure the humane treatment of livestock. Inhumane treatment
triggered an investigation that led to the largest beef recall in U.S.
history. More specifically, in February 2008, the Humane Society of the
United States released videos to the public that documented abuse of
cattle awaiting slaughter at a plant in Chino, California. These
alleged abuses, which took place in the fall of 2007, included
electrically shocking nonambulatory "downer" cattle, spraying them with
high-pressure water hoses, and ramming them with a forklift in an
apparent attempt to force them to rise for slaughter. These acts are
not only cruel, they pose a risk to the safety of the food supply,
because downer animals are known to be at greater risk for bovine
spongiform encephalopathy. FSIS regulations require that downer cattle
be separated to await disposition by an inspector, even if they become
nonambulatory after an inspector has approved the animal for slaughter
during the preslaughter inspection. On February 1, 2008, the plant
voluntarily ceased operations pending investigation by FSIS into the
alleged abuses. On February 17, 2008, the plant announced that it was
voluntarily recalling approximately 143 million pounds of raw and
frozen beef products because of its failure to notify FSIS of the
downer cows and the remote possibility that the beef being recalled
could cause adverse health effects if consumed. The release of the
videos by the Humane Society led congressional committees and USDA to
question how such events could have occurred at a plant in which FSIS
inspectors were assigned. At the request of the Secretary of
Agriculture, USDA's Office of Inspector General (OIG) is leading a
criminal investigation that is ongoing at the time of this report. In
addition, OIG conducted an audit of FSIS's controls over preslaughter
activities and reported in November 2008 that controls to demonstrate
the sufficiency and competency of FSIS' personnel resources could be
strengthened to minimize the chance that such events could recur, among
other things.[Footnote 10]
Veterinarians and other FSIS officials we interviewed told us that, at
the time of the incident, only one veterinarian was assigned to the
plant that was the source of the recall, whereas two had been assigned
in past years. Two veterinarians were needed, according to these
officials, because the plant processed "cull" dairy cows, which are no
longer used for milk production. These cows are generally older and in
poorer condition than other livestock and thus require more frequent
veterinary inspection. In the wake of this incident, FSIS required
veterinarians to spend more time verifying the humane treatment of
animals. However, veterinarians told us that this exacerbated the
difficulty of completing their other work. In 2004, we made
recommendations aimed at ensuring that FSIS can make well-informed
estimates about the inspection resources--including veterinarians--
needed to enforce the Humane Methods of Slaughter Act of 1978.[Footnote
11] Specifically, we recommended that FSIS periodically assess whether
the level of resources dedicated to humane handling and slaughter
activities is sufficient, but the agency has yet to demonstrate that
they have done so.
FSIS officials told us that there are several reasons for the agency's
ongoing shortage of veterinarians. For example, most veterinarians do
not want to work in the unpleasant environment of a slaughterhouse.
Furthermore, veterinarians are trained to heal animals, but FSIS
veterinarians are hired to oversee the slaughter of animals. The job
can also be physically and emotionally grueling, and many of the plants
are in remote and sometimes undesirable locations. In addition, as a
result of staff shortages, there is little opportunity to take time off
for training that could lead to promotion. Finally, FSIS veterinarians
told us that their salaries do not sufficiently compensate for the
working conditions and are low relative to those of other
veterinarians. According to OPM's Central Personnel Data File, the mean
annual salary for FSIS veterinarians in 2007 was $77,678; in contrast,
the mean salary for private-practice veterinarians was $115,447 in
2007, according to the most recent data from the American Veterinary
Medical Association. In commenting on a draft of this report, FSIS
officials added that there is a lack of public health and food-safety
emphasis in veterinary schools.
FSIS has taken several steps to address the shortage. For example, it
awarded 35 recruitment bonuses totaling more than $583,000 in the first
9 months of fiscal year 2008. FSIS also has internship programs that
have, according to agency officials, increased awareness and generated
interest in veterinarian work at the agency. For example, over the past
5 years, FSIS has established agreements with 16 veterinary schools to
provide volunteer training opportunities to veterinary students with an
interest in food safety and public health. In fiscal year 2008, there
were 26 participants in the program, compared with only 1 when the
program began in 2003. Two participants have thus far returned to FSIS
for full-time employment after graduation. FSIS also has a paid
veterinary student program that is designed to provide experience
directly related to the student's educational program and career goals.
Since 2002, when FSIS began tracking this program, 77 students have
participated, and 6 have become full-time employees. In addition, FSIS
has sought special hiring authorities from OPM. For example, in July
2008, the agency was delegated authority to hire a limited number of
retirees at full salary instead of at the reduced salary required for
those with annuity income. Officials told us they hope this will
encourage retired veterinarians to join FSIS, but, as of the date of
this report, no retirees have been hired through this program. FSIS
intends to track the effectiveness of this special hiring authority.
Moreover, FSIS has proposed implementing a demonstration project that
would allow the agency to test a pay system that offers more
competitive salaries to veterinarians, among others. OPM requires that
agencies undertaking such a project provide OPM with an analysis of the
impact of the project results in relation to its objectives. OPM
officials told us the project may be implemented in July 2009. Finally,
OPM has in the past granted FSIS the ability to make immediate job
offers to veterinarians without following prescribed competitive
procedures, which can slow the hiring process. This "direct-hire
authority" expired in 2007 and was not renewed at that time because,
according to FSIS officials, USDA did not provide the expiration
notification to FSIS. We were recently informed that USDA received
approval from OPM on November 25, 2008, for direct hire for FSIS
veterinarians lasting through December 31, 2009. However, FSIS
officials raised concerns about the length of time of the authority,
among other things, stating that it takes 5 to 6 months to renew this
authority.
ARS:
ARS employed 57 veterinarians in fiscal year 2008, 12 percent short of
its goal of 65. It has reported similar shortages throughout the last 5
years. Although veterinarians represent a small share of the ARS
workforce (about 1 percent of more than 4,300 scientists and research
technicians), the agency considers them critical to its mission.
According to ARS officials, a sufficient veterinarian workforce is
important to the quality and breadth of research ARS is able to
conduct. For example, ARS would not have been able to conduct its
research on the detection of avian influenza and development of
vaccines against it, or on the transmission of bovine tuberculosis,
without its veterinarians' skills and experience.
ARS officials told us it is difficult to attract and retain
veterinarians because the agency requires its research veterinarians
and senior program leaders who are veterinarians to have a Ph.D. in
animal sciences or a related field, as well as a veterinary degree, and
there is a limited pool of candidates for these positions. A recent
report by the National Academy of Sciences identified a declining
interest in veterinary research among veterinary students as a cause of
a shortage of Ph.D. veterinarians. In addition, ARS officials told us
the agency cannot compete with many of the salaries offered in the
private sector. In 2007, the mean salary for ARS veterinarians was
$102,081, according to OPM's Central Personnel Data File. This is about
$28,000 less than the mean salary reported by the American Veterinary
Medical Association for veterinarians with a Ph.D. working at
universities and colleges and about $96,000 less than those working in
industry with similar qualifications, such as at pharmaceutical
companies.
To address its shortage of Ph.D. veterinarians, ARS provided six
recruitment or retention bonuses to its veterinarians totaling $48,313
in the first 9 months of fiscal year 2008. The agency also created a
tuition program in 2003, but participation has been limited. Only four
individuals have been hired through the tuition program, and only two
remained with the agency, according to officials. Under this program,
ARS hires veterinarians without a Ph.D. and pays tuition and other
educational costs while they earn this degree. Officials told us that
the lack of success is most likely due to low salaries at ARS. In
addition, the agency is reluctant to use this program because it
diverts funding from the hiring of employees already qualified and
ready to work.
Army:
The Army reported that it filled its 446 authorized active-duty
veterinarian positions, but that its veterinary reserve corps is not at
full strength. Specifically, the Army only filled 173 of its 197
reserve positions in fiscal year 2008, a 12 percent shortage. According
to the Army's analysis, the reserve corps has been at less than full
strength since fiscal year 2005. These veterinarians commit to part-
time training and to being deployed to full-time active duty when
needed. The shortage means there is not a sufficient pool of
veterinarians that can be called into active duty as the need arises.
This is a concern, according to the official responsible for assessing
Army veterinarian workforce needs, because the Army's need for
veterinarian services is increasing due to growing concerns over
bioterrorism, intentional contamination of the food supply, emerging
zoonotic diseases, and due to operational requirements, such as
agricultural reconstruction in Afghanistan and Iraq, among other
things. This official told us that recruitment into the reserves has
been a problem because of the length, frequency, and uncertainty of
deployments, which, in some cases has also resulted in veterinarians
losing their jobs or suffering financial hardships. However, he told us
that recent changes to the reserve corps program--such as decreasing
the length of deployment from 1 year to 180 days, and making additional
incentives available to veterinarians in the reserves--have helped
strengthen the capacity of the veterinary reserve corps.
Officials also told us they are concerned about a growing need for
certain special veterinary skills. For example, there is an increasing
demand for Army veterinary pathologists, who are essential for
interpreting test results from animals used in drug and vaccine
research. The official responsible for assessing Army veterinarian
workforce needs told us the Army has yet to formally assess this need.
Other Army veterinarians conduct medical intelligence work for DOD's
Defense Intelligence Agency, where officials told us they are concerned
about the difficulty of recruiting veterinarians with appropriate
skills to meet a growing need to, among other things, collect and
analyze data on animal diseases that could be used in a terrorist
attack. Veterinarians are important to such work because, according to
these officials, the majority of diseases considered to be potential
bioterrorism agents are animal diseases that could also affect humans.
They told us that while the agency is working to expand its workforce
capabilities to address bioterrorism, there is a concern that the
growing demand for veterinarian capabilities may outpace the growth of
the Army's workforce.
The primary reason for the Army's success in maintaining its active-
duty veterinarian workforce is a scholarship program, according to the
official responsible for assessing Army veterinarian workforce needs.
This program targets veterinary students and pays their tuition and
fees to veterinary school in exchange for a commitment to (1) serve as
a veterinarian in the Army for 3 years and (2) serve an additional 5
years either in active duty or in the Army reserve program. In fiscal
year 2008, the Army reported it had 106 qualified applicants for 47
scholarships. According to the official, the program is successful
because it targets students before they accumulate school-related debt.
Veterinary students graduate with more than $106,000 in debt, on
average, according to the American Veterinary Medical Association. In
addition, the funding for this program is directed specifically by
congressional committees, separate from funds the Army uses to hire
veterinarians.
FDA:
FDA officials reported that the agency has not assessed the sufficiency
of its veterinarian workforce, but they told us that the workforce is
sufficient to meet its responsibilities. However, a 2007 report by an
FDA Advisory Committee found that FDA cannot fulfill its mission
because of an insufficient scientific workforce.[Footnote 12] More
specifically, the report states that FDA's scientific workforce has
remained static while its workload has increased, and that FDA's Center
for Veterinary Medicine (CVM) is in a state of crisis. This center
employs nearly two-thirds of FDA's 152 veterinarians and is responsible
for ensuring the safety of veterinary drugs and regulating animal feed,
among other things. An author of the report told us that veterinarians
enter FDA employment lacking necessary skills and experience to examine
the wide variety of veterinary products that require FDA approval and
that FDA needs to better train its veterinarians to review the many
diverse products under its jurisdiction. FDA officials told us the
agency is currently undertaking significant reforms to address
fundamental concerns in the report. For example, FDA reported it hired
more than 1,000 scientists in order to build a more robust workforce,
and it created the position of Chief Scientist to improve coordination
of science planning and execution across the agency. However, FDA did
not tell us how these reforms address the identified veterinarian skill
gaps.
Although FDA officials said the veterinarian workforce is sufficient,
CVM officials recently told us that as a result of new obligations, the
center hired 26 veterinarians in 2008 to fill vacancies. This
represents a 17 percent increase in FDA's overall veterinarian
workforce in 2008, and it plans to hire more. The additional staff will
enhance FDA's ability to review generic animal drug submissions, among
other things, according to these officials. In addition, in commenting
on a draft of this report, OPM informed us that it is currently
reviewing a request for direct-hire authority from FDA to fill
veterinary positions. According to OPM, this request is based on a
severe shortage of candidates and it is projected that this authority
may be granted through December 31, 2010. CVM also plans to develop an
internship program for entry-level veterinarians and other scientists
in order to develop a qualified talent pool from which to draw
permanent employees. Further, these officials said that, as a result of
recent participation in interagency efforts to protect the nation's
food supply, CVM has begun to analyze the gap between its current
resources and its needs.
Departments Have Done Little to Assess the Sufficiency of Their
Veterinarian Workforces across Their Component Agencies:
Even though their component agencies identified concerns about their
veterinarian workforces, officials from both USDA and HHS told us that
they have not undertaken a departmentwide assessment of these
workforces to gain a broader perspective on trends and shared issues.
In contrast, DOD has a process for such an assessment. Our prior work
has found that top-level management needs to be involved in order for
strategic workforce planning to be effective.[Footnote 13]
USDA:
Although USDA regularly collects veterinarian workforce data from its
component agencies that employ veterinarians, it does not use this
information to assess the sufficiency of the veterinarian workforce
departmentwide. Department officials told us that workforce assessment
is the responsibility of the agencies. Because USDA delegates this
responsibility, it appears to be unaware of the scope of the workforce
problems facing its agencies. For example, in its fiscal year 2007
human capital management report, USDA reported that its agencies had
met or surpassed certain veterinarian workforce goals but made no
mention of the shortages that FSIS and ARS identified in their
workforce reports. USDA officials agreed that the report did not
capture this critical information and that future reports should
address the shortages.
One result of this lack of department-level involvement is that USDA
agencies compete against one another for veterinarians instead of
following a departmentwide strategy to balance the needs of the
agencies. According to FSIS officials, APHIS is attracting
veterinarians away from FSIS because the work at APHIS is more
appealing, there are more opportunities for advancement, and the
salaries are higher. Indeed, our analysis shows that veterinarians are
more concentrated in lower grade levels at FSIS than at APHIS (see
figure 1). Moreover, according to OPM's Central Personnel Data File,
the mean annual salary for veterinarians at FSIS in 2007 was about
$78,000, the lowest among the three key USDA agencies (see figure 2).
According to an APHIS human resources official, the agency hired 75
veterinarians from FSIS between fiscal years 2003 and 2007, 17 percent
of total new APHIS veterinarians hired.
Figure 1: Percentage of Veterinarian Grade Levels by Key USDA Agencies
in Fiscal Year 2008:
[Refer to PDF for image]
This figure is a multiple vertical bar graph depicting the following
data:
Grade level: GS-9-10;
APHIS: 0;
ARS: 5.45%;
FSIS: 0.
Grade level: GS-11;
APHIS: 2.44%;
ARS: 7.27%;
FSIS: 7.6%,
Grade level: GS-12;
APHIS: 41.16%;
ARS: 25.45%;
FSIS: 69.5%,
Grade level: GS-13;
APHIS: 21.95%;
ARS: 20%;
FSIS: 18.95%.
Grade level: GS-14;
APHIS: 28.35%;
ARS: 12.73%;
FSIS: 2.74%.
Grade level: GS-15;
APHIS: 5.18%;
ARS: 16.36%;
FSIS: 0.61%.
Grade level: GS-16+;
APHIS: 0.91%;
ARS: 12.73%;
FSIS: 0.61%.
Source: GAO analysis of agency survey responses.
Note: Federal agency grade levels represent ascending rates of basic
pay, from GS-1 through GS-15, above which is the Senior Executive
Service (SES).
[End of figure]
Figure 2: Mean Veterinarian Salaries by Key USDA Agencies, Fiscal Years
2003-2007:
[Refer to PDF for image]
This figure is a multiple line graph depicting the following data:
Fiscal year: 2003;
FSIS: $68,663;
APHIS: $75,731;
ARS: $88,024.
Fiscal year: 2004;
FSIS: $70,661;
APHIS: $80,126;
ARS: $89,643.
Fiscal year: 2005;
FSIS: $73,021;
APHIS: $84,310;
ARS: $95,450.
Fiscal year: 2006;
FSIS: $75,830;
APHIS: $88,137;
ARS: $97,752.
Fiscal year: 2007;
FSIS: $77,678;
APHIS: $90,629;
ARS: $102,081.
Source: GAO analysis of Central Personnel Data File data.
Note: Data in this figure contains locality pay.
[End of figure]
HHS:
HHS neither assesses veterinarian workforce needs departmentwide nor
has it instructed any of its component agencies that employ
veterinarians--FDA, CDC, and the National Institutes of Health (NIH)--
to assess their own workforces. HHS is thus not fully aware of the
status of the veterinarian workforce at these component agencies and
cannot strategically plan for future veterinarian needs. If it were
able to provide such planning, it might be able to help FDA address
workforce concerns raised in the 2007 FDA Science and Mission at Risk
report. However, senior HHS strategic workforce planning officials we
spoke with were unaware of the report.
HHS officials told us that departmental leadership in workforce
planning is important. In fact, they said the department is in the
preliminary stages of developing a strategic departmentwide approach to
workforce planning for certain professions. This effort will initially
focus on workforce assessments for specific occupations, such as nurses
and medical doctors. HHS officials told us they will not initially
include veterinarians in this effort, because veterinarians are not
deemed mission critical for the department, even though they are
critical to the missions of FDA, CDC, and NIH. However, HHS officials
said that this effort does not preclude agencies from assessing their
own veterinarian workforce needs and sharing that information with the
department. HHS officials also told us that because the department is
expected to provide veterinary medical care and support during public
health and medical disasters that warrant a coordinated federal
response, it is critical that appropriate veterinary resources are
identified and maintained. Furthermore, these officials told us that
efforts are under way at the component agency level to address the
national veterinary shortage. Specifically, CDC, in collaboration with
Emory University, has developed a residency program designed to provide
comprehensive training in laboratory animal medicine to better prepare
veterinarians for working in laboratory research facilities at CDC and
across the nation. In addition, in 2006 and 2008 CDC sponsored a
"Veterinary Student Day" to promote public health careers for
veterinarians.
DOD:
Unlike USDA and HHS, DOD has a process for assessing veterinarian
workforce needs departmentwide. It has given this responsibility to the
Army, which employs 89 percent of DOD veterinarians, with the remaining
veterinarians working as public health officials for the Air Force. The
Army assesses not only the number and type of veterinarians it will
need but also what will be needed for the other services. For example,
Army veterinarians are routinely assigned to care for working dogs and
other animals at Army, Navy, Air Force, and Marine bases. Army
veterinarians also conduct medical intelligence activities at the
Defense Intelligence Agency. As the executive agency charged with
assessing veterinarian workforce requirements for DOD, the Army takes
all of these needs into consideration, then forwards the assessment
results to DOD, which integrates them with overall workforce planning.
There Is No Governmentwide Assessment of the Veterinarian Workforce:
No effort is being made to assess the sufficiency of the veterinarian
workforce governmentwide. This is problematic because the majority (67
percent) of the 24 component agencies and other federal entities that
employ veterinarians told us they have concerns about their
veterinarian capabilities. OPM has not conducted a governmentwide
effort to address current and future veterinarian shortages identified
by component agencies, as it has done for other professions, and
efforts by the Congress to address the national shortage have thus far
had minimal impact.
Sixteen of the 24 component agencies and other entities employing
veterinarians reported concerns about their veterinarian workforce (see
table 1). For example, several agencies reported that they lack
veterinarian expertise required to fully meet agency responsibilities,
such as addressing wildlife disease outbreaks.
Table 1: Agency Concerns about Sufficiency of the Federal Veterinarian
Workforce:
Department: Department of Agriculture;
Component agency/other federal entity: Animal and Plant Health
Inspection Service;
Examples of concerns reported by component agency/other federal entity:
Thirty percent of its veterinarians will be eligible to retire by the
end of fiscal year 2011, and it may be difficult to maintain enough
veterinarians with expertise in pathology and foreign animal disease in
the future. Responsibilities have also increased in recent years,
raising concerns that there will not be sufficient veterinarian
capacity if multiple emergencies occur at once.
Department: Department of Agriculture;
Component agency/other federal entity: Food Safety and Inspection
Service;
Examples of concerns reported by component agency/other federal entity:
Veterinarian workforce falls short of agency goal by 15 percent due, in
part, to unpleasant environment, grueling work, and low salary.
Department: Department of Agriculture;
Component agency/other federal entity: Agricultural Research Service;
Examples of concerns reported by component agency/other federal entity:
Veterinarian workforce falls short of agency goal by 12 percent. There
is a limited number of qualified veterinarians and agency salaries are
not competitive with private sector.
Department: Department of Agriculture;
Component agency/other federal entity: Cooperative State Research,
Education, and Extension Service;
Examples of concerns reported by component agency/other federal entity:
One of the four veterinarian positions is vacant, stressing the
agency's ability to oversee funds for a national network of
laboratories that diagnose and track animal diseases.
Department: Department of Defense;
Component agency/other federal entity: Army;
Examples of concerns reported by component agency/other federal entity:
Veterinary reserve corps falls short by 12 percent. Also, the number of
active-duty veterinarian positions has remained relatively static
despite increasing demands across the Army's mission, including in
medical intelligence, food safety and defense, agricultural
reconstruction efforts in Iraq and Afghanistan, and emerging zoonotic
diseases.
Department: Department of Defense;
Component agency/other federal entity: Air Force;
Examples of concerns reported by component agency/other federal entity:
Not enough veterinarians choose to join the Air Force because of the
service commitment, and the salary is not competitive. Air Force
officials are concerned they might not be able to fully meet the
agency's public health mission, which includes ensuring food safety and
tracking infectious diseases on Air Force bases.
Department: Department of Health and Human Services;
Component agency/other federal entity: Food and Drug Administration;
Examples of concerns reported by component agency/other federal entity:
No concerns reported.
Department: Department of Health and Human Services;
Component agency/other federal entity: National Institutes of Health;
Examples of concerns reported by component agency/other federal entity:
Agency faces challenges recruiting veterinarians that specialize in
laboratory animal medicine and veterinary pathology, who make up the
majority of veterinary positions at the agency. Both specialties are
reporting significant shortages that are not forecast to improve for at
least 10 years, which will hinder the agency's ability to recruit
qualified veterinarians.
Department: Department of Health and Human Services;
Component agency/other federal entity: Centers for Disease Control and
Prevention;
Examples of concerns reported by component agency/other federal entity:
Veterinarian expertise in agriculture and animal health contribute
significantly to human health programs and could be enhanced.
Department: Department of Health and Human Services;
Component agency/other federal entity: Office of the Assistant
Secretary for Preparedness and Response;
Examples of concerns reported by component agency/other federal entity:
The Office reported that more than two full-time veterinarians are
needed to help develop effective response programs to public health
emergencies. Department officials did not support this statement, but
said that veterinarians are integral to its response strategy and their
continued engagement is essential.
Department: Department of Veterans Affairs;
Component agency/other federal entity: Office of Research and
Development;
Examples of concerns reported by component agency/other federal entity:
No concerns reported.
Department: Department of the Interior;
Component agency/other federal entity: U.S. Geological Survey;
Examples of concerns reported by component agency/other federal entity:
Salaries are not competitive with the private sector. The agency faces
difficulty hiring veterinarians to address wildlife diseases, including
those that kill many animals in a single local outbreak.
Department: Department of the Interior;
Component agency/other federal entity: U.S. Fish and Wildlife Service;
Examples of concerns reported by component agency/other federal entity:
Agency has too few veterinarians to monitor diseases in wildlife,
nationally and internationally.
Department: Department of the Interior;
Component agency/other federal entity: National Park Service;
Examples of concerns reported by component agency/other federal entity:
Agency has too few veterinarians to address wildlife diseases and
survey outbreaks in the vast park system of 84 million acres.
Department: Department of Homeland Security;
Component agency/other federal entity: Office of Health Affairs;
Examples of concerns reported by component agency/other federal entity:
Agency has too few veterinarians to effectively develop the
capabilities to respond to catastrophic food, agriculture, and
veterinary events.
Department: Department of Homeland Security;
Component agency/other federal entity: Directorate for Science and
Technology;
Examples of concerns reported by component agency/other federal entity:
No concerns reported.
Department: Department of Homeland Security;
Component agency/other federal entity: Directorate for National
Protection and Programs;
Examples of concerns reported by component agency/other federal entity:
No concerns reported.
Department: Smithsonian;
Component agency/other federal entity: National Zoo;
Examples of concerns reported by component agency/other federal entity:
Salaries are not competitive; American Veterinary Medical Association-
specialty boarded status is necessary to perform responsibilities, but
compensation for this additional training is not available; too few
veterinarians to fully conduct agency wildlife health and surveillance
studies.
Department: Environmental Protection Agency;
Component agency/other federal entity: [Empty];
Examples of concerns reported by component agency/other federal entity:
No concerns reported.
Department: U.S. Agency for International Development;
Component agency/other federal entity: Bureaus for Economic Growth,
Agriculture and Trade; for Global Health; and for Africa;
Examples of concerns reported by component agency/other federal entity:
No concerns reported.
Department: Department of Commerce;
Component agency/other federal entity: National Oceanic and Atmospheric
Administration;
Examples of concerns reported by component agency/other federal entity:
Too few veterinarians available to investigate major or multiple
outbreaks, or single events that kill many animals, when they occur in
marine animals.
Department: National Aeronautics and Space Administration;
Component agency/other federal entity: Office of the Chief Health and
Medical Officer;
Examples of concerns reported by component agency/other federal entity:
No concerns reported.
Department: Department of Energy;
Component agency/other federal entity: Lawrence Livermore National
Laboratory;
Examples of concerns reported by component agency/other federal entity:
There is a limited number of veterinarians with the expertise to
develop models and conduct analyses to identify the resources agencies
will need to respond to animal disease outbreaks, among other things.
Department: Department of Justice;
Component agency/other federal entity: Federal Bureau of Investigation;
Examples of concerns reported by component agency/other federal entity:
No concerns reported.
Source: Agency survey responses and interviews.
[End of table]
These current challenges are likely to worsen because a large number of
federal veterinarians are eligible to retire in the near future. These
retirements would exacerbate the veterinarian shortage and possibly
increase interagency competition. Our analysis found that 697
veterinarians at FSIS, APHIS, ARS, Army, and FDA--27 percent of the
combined veterinarian workforce of these agencies--are eligible to
retire over the next 3 years. As the shortage grows, agencies across
the federal government may experience a situation similar to the
competition between FSIS and APHIS, and agencies with higher salaries
for veterinarians are likely to gain an advantage. As figure 3
illustrates, mean veterinarian base salaries vary widely across
agencies, from just under $70,000 at Interior's National Park Service
to just about $122,000 at DHS's Office of Health Affairs. Salaries for
individual veterinarians range from $35,000 for those in the residency
program at the National Zoo to $205,000 for the highest paid
veterinarian at NIH.
Figure 3: Mean Veterinarian Base Salaries at 19 Component Agencies or
Federal Entities in Fiscal Year 2008:
[Refer to PDF for image]
This figure is a multiple vertical bar graph depicting the following
data:
Component agency/federal entity[A]: Food Safety and Inspection
Service[B] (USDA);
Mean veterinarian salary: $70,354.
Component agency/federal entity[A]: Animal and Plant Health Inspection
Service (USDA);
Mean veterinarian salary: $81,195.
Component agency/federal entity[A]: Agricultural Research Service (USDA);
Mean veterinarian salary: $90,432.
Component agency/federal entity[A]: Cooperative State Research,
Education, and Extension Service (USDA);
Mean veterinarian salary: $114,036.
Component agency/federal entity[A]: Air Force (DOD);
Mean veterinarian salary: $69,588.
Component agency/federal entity[A]: Army (DOD);
Mean veterinarian salary: $69,588.
Component agency/federal entity[A]: Food and Drug Administration (HHS);
Mean veterinarian salary: $83,028.
Component agency/federal entity[A]: Centers for Disease Control and
Prevention[B] (HHS);
Mean veterinarian salary: $90,736.
Component agency/federal entity[A]: National Institutes of Health (HHS);
Mean veterinarian salary: $117,713.
Component agency/federal entity[A]: National Park Service (Interior);
Mean veterinarian salary: $68,689.
Component agency/federal entity[A]: U.S. Fish and Wildlife Service (Interior);
Mean veterinarian salary: $75,522.
Component agency/federal entity[A]: U.S. Geological survey (Interior);
Mean veterinarian salary: $85,229.
Component agency/federal entity[A]: National Oceanic and Atmospheric
Administration;
Mean veterinarian salary: $80,579.
Component agency/federal entity[A]: Environmental Protection Agency;
Mean veterinarian salary: $84,194.
Component agency/federal entity[A]: National Zoo;
Mean veterinarian salary: $89,694.
Component agency/federal entity[A]: National Aeronautics and Space
Administration;
Mean veterinarian salary: $93,730.
Component agency/federal entity[A]: Department of Veterans Affairs;
Mean veterinarian salary: $93,840.
Component agency/federal entity[A]: U.S. Agency for International
Development;
Mean veterinarian salary: $94,608.
Component agency/federal entity[A]: Office of Health Affairs;
Mean veterinarian salary: $121,588.
Source: GAO analysis of agency data.
Note: Salaries do not include locality pay and stipends. In addition,
we do not display mean salary for those agencies with fewer than four
veterinarians due to the small number of employees represented. This
includes the Departments of Energy and Justice; HHS's Office of the
Assistant Secretary for Preparedness and Response; and DHS's
Directorate for National Protection and Programs. In addition, DHS's
Science and Technology was unable to provide base salary information in
time for this report and, therefore, is not included.
[A] We relied on officials from these federal entities to identify mean
salaries of all veterinarians employed, including civil and military
service employees, contractors, and other, regardless of job title.
Because data are means reported by agencies, we could not assess the
underlying distribution for outliers or skewness.
[B] This does not include the salaries of the United States Public
Health Service Commissioned Corps veterinarians stationed at these
agencies. The Commissioned Corps is a uniformed service that belongs to
HHS but fills public health leadership and service roles at several
federal agencies.
[End of figure]
Some agencies, such as those within HHS and the Department of Veterans
Affairs, can augment base salaries for veterinarians using special
statutory authorities.[Footnote 14] Agencies can use these authorities
to hire veterinarians when standard hiring practices, including the use
of recruitment incentives, are impracticable, less effective, or have
been exhausted. In addition, DOD can provide all of its veterinarians
with a $100 per month stipend, as well as up to an additional $5,000
per year of special pay if they have met the education and training
standards of an American Veterinary Medical Association-recognized
specialty college.[Footnote 15] There is no similar authority for USDA
veterinarians.
OPM's mission is to ensure the federal government has an effective
civilian workforce, but it has not conducted a governmentwide effort to
address current and potential veterinarian shortages, as it has done
for other professions. For certain professions, OPM has initiated
governmentwide direct-hire authority, which allows expediting hiring
during a time of critical need or a severe shortage of candidates. For
example, in 2003, OPM authorized departments to immediately hire
doctors, nurses, and other types of medical professionals without
following prescribed competitive procedures. OPM officials told us
their agency issued this authority based in part on department and
agency concerns. OPM can also hold interagency forums to discuss
workforce concerns but has not done so for veterinarians. According to
OPM officials, interagency forums are open to all senior human capital
representatives from all departments, including USDA and HHS. The
forums provide an opportunity to discuss concerns, exchange ideas, and
explore solutions to governmentwide staffing issues. OPM officials told
us that no department has requested a discussion about veterinarian
workforce concerns. Further, officials told us that the agency will
facilitate a governmentwide solution, such as an interagency forum, if
the departments demonstrate that a shortage exists. Our prior work has
identified the need for OPM to use its leadership position to provide
assistance to departments and agencies efforts to recruit and retain a
capable and committed workforce.[Footnote 16]
OPM officials told us the agency has taken some steps that could
improve veterinarian recruitment and retention. During the course of
our review, OPM created a Personnel Action Team to determine whether a
governmentwide direct-hire authority should be granted for all
veterinarians. OPM did not provide further details other than to state
that a decision is expected in early 2009. In addition, OPM recently
changed the federal classification of veterinarians. OPM raised the
entry grade level for newly hired veterinarians from GS-9 to GS-11 and
expanded the description of the federal veterinarian occupation to
include areas of specialization, such as toxicology and pathology. OPM
officials believe this will help attract more veterinarians into
federal service. Agency officials also told us that they meet
periodically with departments to ensure occupation classifications meet
department needs. This was the first change of the veterinarian
classification in over 20 years and was initiated at USDA's request.
The Congress has taken steps that address the broader, national
veterinarian shortage, but its efforts thus far have had minimal
impact. The National Veterinary Medical Services Act enacted in 2003,
directs the Secretary of Agriculture to carry out a program to help
veterinarians repay their school loans when they agree to work in areas
of need. Although USDA is responsible for implementing the act, it has
been delayed in doing so. USDA's Undersecretary for Research,
Education, and Economics testified before the Congress that this was
because the Cooperative State Research, Education, and Extension
Service (CSREES)--the USDA agency in charge of implementation--does not
have experience with complex loan repayment programs. The Congress
provided initial funding for the act in fiscal year 2006. In August
2008, CSREES began holding public hearings to solicit stakeholder
input. Officials from USDA and veterinary associations told us that the
$1.8 million allocated thus far for the program is insufficient and
would have minimal impact on the shortage. With veterinary student debt
averaging $106,000 upon graduation, $1.8 million would cover about 17
students with loans. Moreover, the program targets veterinarians who
already have their degree and may not have the skill set the federal
government is seeking. To be effective, officials from professional
veterinary associations told us, the program would have to provide
guarantees and target students early in veterinary school. The Congress
also enacted the Higher Education Opportunity Act in August 2008, which
has provisions intended to increase the number of veterinarians in the
workforce through a competitive grant program that can increase
capacity at veterinary colleges. According to the American Veterinary
Medical Association, however, these grants will be capped at $500,000
per school, which will not be enough to increase capacity to meet
veterinarian demands.
Efforts to Identify the Veterinarian Workforce Needed during a Pandemic
and Large-Scale Animal Disease Outbreak Are Insufficient:
Four of the five key agencies we reviewed--APHIS, FSIS, ARS, and FDA--
have plans intended to detail how essential functions and services,
including those that veterinarians perform, would continue during a
pandemic that has the potential to severely reduce the workforce.
However, each lacks elements that FEMA considers important for
effective planning. The Army is still in the process of getting its
plan approved and, therefore, we have not evaluated it. In addition,
DHS's efforts to identify the veterinarian workforce needed to address
a catastrophic nationwide outbreak of foot-and-mouth disease are based
on an unrealistic assumption and limited information.
Agency Planning to Ensure Continuity of Essential Veterinary Functions
during a Pandemic Is Incomplete:
FEMA's pandemic guidance assists agencies in identifying special
considerations for maintaining essential functions and services during
a pandemic outbreak that may cause absenteeism to reach 40 percent. For
example, the guidance directs agencies to identify in their pandemic
plans how operations will be sustained until normal business activity
can be reconstituted, which may be longer than the 30 days usually
planned for other types of emergencies. Agency plans are also to
identify the essential functions that must be continued on-site and
those that can be conducted from a remote location. They also should
take into consideration the need for logistical support, services, and
infrastructure that help an agency achieve and maintain essential
functions and services. To account for the expected high rate of
absenteeism at the peak of a pandemic, FEMA guidance also directs
agencies to identify at least three people who can carry out each
responsibility and identify how the agency will continue to operate if
leadership and essential staff are unavailable. Finally, agencies are
directed to test their pandemic plans, including the impacts of reduced
staffing on facilities and essential functions and services.
APHIS has developed pandemic plans for its headquarters, regional
offices, and three laboratories that employ veterinarians, but these
plans are missing elements in FEMA's guidance and are not well-
organized. For example, they do not explain how animal care, disease
investigation, and other essential functions and services would
continue if leadership and essential staff are unavailable. Moreover,
pieces of these pandemic plans are spread throughout a large number of
documents and are not well linked. For example, APHIS officials
provided us with an undated pandemic plan that they told us was an
appendix to the headquarters continuity of operations plan. But this
continuity of operations plan made no reference to such an appendix,
and officials were never able to provide us with a document that made
reference to such an appendix. USDA recently hired a new emergency
preparedness director to revise APHIS's pandemic plans, among other
things. The director told us that APHIS recognizes the importance of
easily locating the plans and quickly implementing them in the event of
a pandemic, and he acknowledged that the current documents are not an
effective plan. APHIS is now combining its plans into one comprehensive
document that will cover APHIS headquarters, regional offices, and
laboratories. In addition, the director told us the new plan, to be
completed by early 2009, will better adhere to FEMA guidance.
FSIS has developed a pandemic plan that addresses many of the elements
in FEMA's guidance, but it lacks some crucial details. Importantly, the
plan takes into account the work that veterinarians do at private
slaughter plants. However, it does not address the logistics of how
FSIS will work with industry to ensure veterinarians and other
employees are available in the event of a pandemic so that food
production can continue. FSIS officials told us that they have
discussed this logistic with industry and expect, based on these
discussions, that some plants would not be able to operate during a
pandemic, as a result of FSIS or plant personnel absenteeism. The
agency would maintain close communication with industry during a
pandemic in order to determine how best to allocate available
veterinarians and other FSIS inspection personnel so that slaughter
plants could continue to operate. Veterinarians would be allocated to
plants based on considerations such as the location of the outbreak and
the type of slaughter plant affected. For instance, poultry plants may
receive priority consideration because birds can only be slaughtered at
a very specific weight. That is, the equipment for processing birds is
designed for birds of a very specific size, and industry would not be
able to process them if they were permitted to grow too large. However,
such logistics are absent from FSIS's plan, effectively postponing any
decisions until the middle of a crisis. Similarly, the plan does not
mention how FSIS would work with APHIS, even though the agencies have
formally agreed to jointly plan for critical activities related to
surveillance of animal diseases. In addition, the plan does not
consider the impact of local quarantines on access to plants.
ARS has developed pandemic plans for all of its 12 laboratories where
veterinarians work. We reviewed plans for the two laboratories that
employ the most veterinarians: the Southeast Poultry Research
Laboratory and the National Animal Disease Center (NADC). These plans
are important because they spell out the site-specific details needed
to ensure that essential functions at each laboratory can continue.
However, the plans lack crucial details, such as how the laboratories
will continue operations if absenteeism reaches 40 percent.
Specifically, neither of the plans take into account how the
laboratories would continue to conduct essential functions and services
if leadership and essential staff are unavailable. Agency officials
told us they would temporarily suspend projects to account for
increased absenteeism, but there is no mention of this in the plans;
nor is there mention of how the agency will select projects for
suspension or what would trigger suspension. Ensuring a sufficient
veterinarian workforce at these laboratories during a pandemic is
important because veterinarians carry out critical research and must be
available to ensure the proper care of research animals. In addition,
NADC is part of a USDA research complex that is transitioning to joint
ARS and APHIS support services, including veterinary care for research
animals. However, ARS and APHIS have yet to jointly plan for continuity
of operations for any type of emergency.
FDA has also developed a pandemic plan, but it is high-level plan that
does not address several of FEMA's elements, leaving it unclear if
consideration has been given to how veterinarians would carry out any
essential functions and services during a pandemic. For example, it
does not identify which essential functions--whether they be the
responsibility of the veterinarian or others--must be performed on-site
and which can be performed remotely. Nor does it explain how
veterinarians, or others, will continue operations if absenteeism
reaches 40 percent by, for example, delegating authority to three
individuals capable of carrying out each of the agency's essential
functions. The plan omits other important details, such as contact
information for individuals who could assume authority should essential
staff and leadership become unavailable. FDA officials told us they
will take these gaps into consideration when they update their plan in
2009.
The Army is still in the process of getting its pandemic plan approved
and, therefore, we have not evaluated it. According to Army officials,
the agency has developed a pandemic plan that has been validated by the
U.S. Army Northern Command, but it has not yet been formally referred
for approval to the Army's senior leadership, and it does not contain
details of how essential functions would continue. According to DOD
officials, subordinate divisions within the Army intend to develop
detailed plans, but the division responsible for veterinary services
(Veterinary Command) has yet to do so. However, DOD officials told us
that the Army has been instrumental in helping the United States plan
for an outbreak of highly pathogenic avian influenza in birds.
Controlling the outbreak in birds reduces the opportunity for the virus
to mutate into a strain that could cause a pandemic in humans.
FEMA guidance also directs agencies to test how well their pandemic
plans might maintain essential functions and services given reduced
staffing levels. FSIS and FDA are the only agencies we reviewed that
have done so. In March 2007, FSIS conducted a "tabletop" pandemic
exercise where key personnel discuss simulated scenarios in an informal
setting in order to test their plans, policies, and procedures. In a
summary report, FSIS officials noted that, among other things,
additional exercises were needed to improve coordination with industry.
FSIS subsequently conducted a similar tabletop exercise with industry
in November 2008, but the summary report on lessons learned has yet to
be published. FDA conducted an operational exercise in October 2008--a
drill to test how well it could continue operations under a staffing
shortage. As part of this exercise, FDA tested its ability to reassign
tasks, but it is not clear if tasks performed by veterinarians were
among those reassigned. FDA officials told us that they plan to issue a
report with lessons learned from the exercise in early 2009 and will
incorporate that information into FDA's pandemic plan. ARS and APHIS
have not tested their plans to see how well their agencies might
maintain essential functions and services in the event of reduced
staffing levels, but officials told us they intend to do so.
An Infeasible Assumption and Limited Information Hinder Veterinarian
Workforce Planning Efforts for a Catastrophic Outbreak of Foot-and-
Mouth Disease:
DHS has two efforts under way that involve identifying the veterinarian
workforce needed to quickly perform rapid diagnoses and other essential
activities during a large-scale outbreak of foot-and-mouth disease, but
both efforts have shortcomings. The first is a long-term national
effort that DHS is coordinating to assess the nation's preparedness for
multiple, intentional introductions of foot-and-mouth disease. This
effort includes identifying the veterinarian workforce and other
capabilities that would be needed to best respond to such an outbreak.
For example, it has identified the need for 750 veterinarians
nationwide to conduct animal health epidemiological investigations and
surveillance. It has also identified the need for teams of six
livestock and six companion animal veterinarians in each affected state
and local jurisdiction to implement disease containment measures,
provide animal welfare, and euthanize and dispose of animals.
However, this effort is based on a national planning scenario that USDA
and DHS officials' say includes an infeasible assumption. The scenario,
developed by a White House Homeland Security Council working group in
2006, involves the mass slaughter of all potentially exposed animals.
This "stamping out" method is the same one the United States has used
in the past for eradicating smaller outbreaks of foreign animal
diseases, but under this scenario, it would result in the slaughter of
almost half the nation's beef, dairy, and swine. DHS and USDA
officials, as well as state officials who have conducted large-scale
foot-and-mouth disease exercises, consider this stamping out method
infeasible because, among other things, it would lead to serious
logistical and environmental concerns, would not be tolerated by the
public, and could wipe out a viable livestock industry. As a result,
DHS and USDA officials told us, any workforce estimates produced from
this effort are not relevant. However, these officials told us it has
helped them better understand the enormity of the workforce response
and the coordination that would be required for such a catastrophic
event.
DHS and USDA officials told us that to arrive at more relevant
workforce estimates, the United States would have to consider
alternatives to stamping out for outbreaks as large as the one depicted
in the national planning scenario. For example, some countries protect
against and control foot-and-mouth disease using vaccines. There are
numerous reasons the United States has not used this approach,
including limitations to vaccine technology.[Footnote 17] However USDA,
DHS, and state officials recognize that newer, more promising vaccines
may play an important role in controlling a catastrophic outbreak. DHS
officials also told us that they are looking into revising the Homeland
Security Council's planning scenario to make it a more useful planning
tool.
For its second effort to identify the veterinarian workforce needed
during a foot-and-mouth disease outbreak, DHS has contracted with the
Department of Energy's Lawrence Livermore National Laboratory to create
a decision support system that models various foot-and-mouth disease
outbreak scenarios. This effort includes estimating the number and type
of workforce needed for responding to outbreaks, both with and without
vaccination. However, according to the project leader, modeling efforts
could be improved if certain information were available. For example,
in order to model workforce needs for a response that includes the use
of vaccines without subsequent stamping out, known as "vaccinate to
live," it is important to know what segments of the livestock industry
might use such a strategy, and under what circumstances, and how
animals and animal products would be identified and their movement
tracked. Because the concept of vaccinate to live is new in the United
States, USDA has yet to detail in contingency response plans how it
would employ this concept, according to agency officials. In the
absence of such plans, the project leader, a veterinarian who took part
in the response to the 2001 United Kingdom foot-and-mouth disease
outbreak, told us that she is left to base her modeling assumptions on
personal knowledge and experience, as well as conversations with agency
subject matter experts.
Moreover, data limitations make it difficult for any computer modeling
effort to accurately predict the spread of the disease. Specifically,
modelers must estimate the number and location of animals, as well as
their interaction with other segments of industry, because the United
States does not have a mandatory, national system that identifies the
location and tracks the movement of livestock.[Footnote 18] Instead,
modelers currently use outdated county-level data from USDA's National
Agricultural Statistical Survey census, reducing the accuracy of
predictions about the spread of foot-and-mouth disease. Also, without
knowing the exact location of livestock, it is difficult to understand
the interaction between livestock and wildlife. Limited data and
information on the number and movement of wildlife and the
susceptibility of wildlife populations to the virus further complicates
matters, according to agency officials. This is an important gap, since
foot-and-mouth disease has been known to spread from livestock to
wildlife in past outbreaks. In fact, the last time the United States
had an outbreak was in California in the 1920s, when the virus spread
from pigs to cattle and black-tailed deer. It took 2 years and the
slaughter of 22,000 deer to eradicate the disease from a local deer
population in one national park. In areas where livestock graze
extensively, there is potential for interaction with susceptible
species, such as deer and feral pigs. According to the project leader,
as well as USDA and DHS officials, control and eradication strategies
would be greatly complicated if wildlife became infected and could
require more veterinarians and different expertise. Given the important
role wildlife can play in disease outbreak, officials agree it is
important to better understand the interaction between livestock and
wildlife. In fact, new technologies, such as global positioning
systems, have been developed that can, for example, help determine the
number and movement of animals, making it possible to gather this type
of data, according to a USDA Wildlife Services official. A DHS official
told us that, as a first step, it would be important for those agencies
with responsibility for overseeing the health of humans, wildlife, and
livestock to discuss how wildlife data can be gathered to most
accurately model the spread of disease in wildlife.
Federal and State Agencies Are Missing Important Opportunities to
Ensure Efficient Use of Veterinarians During Disease Outbreaks:
During four recent zoonotic disease outbreaks, the veterinarian
workforce challenge cited most often by federal and state officials was
having too few veterinarians to control the outbreak while also
adequately carrying out other routine activities. Specifically,
officials from 3 of 4 federal agencies--APHIS, CDC, and Interior's U.S.
Geological Survey (USGS)--and 9 of 13 state agencies cited this
challenge. See table 2 for the 17 agencies that were identified as
playing an important role, those that cited insufficient veterinarian
capacity as a challenge, and other details about these outbreaks.
Table 2: Four Recent Zoonotic Outbreaks We Analyzed:
Disease: Bovine tuberculosis;
Location: Michigan;
Date outbreak began: Fall 1994;
Date outbreak ended: Outbreak is ongoing;
Animals infected: Wildlife, cattle;
Number of human cases in the identified location: 2[C];
Number of veterinarians involved in outbreak[A]: 218[D];
Total size of workforce involved in outbreak[A]: 412;
Federal and state agencies involved in outbreak (agencies in bold cited
insufficient veterinarian capacity as a challenge)[B]:
APHIS;
Michigan Department of Agriculture (bold);
Michigan Department of Community Health;
Michigan Department of Natural Resources;
Michigan State University.
Disease: Exotic Newcastle disease;
Location: California;
Date outbreak began: October 2002;
Date outbreak ended: September 2003;
Animals infected: Poultry and other susceptible avian species;
Number of human cases in the identified location: 2[C];
Number of veterinarians involved in outbreak[A]: 1,250[D];
Total size of workforce involved in outbreak[A]: 6,039;
Federal and state agencies involved in outbreak (agencies in bold cited
insufficient veterinarian capacity as a challenge)[B]:
APHIS (bold);
California Animal Health and Food Safety Laboratory (bold);
California Department of Food and Agriculture (bold);
California Department of Public Health (bold).
Disease: Monkeypox;
Location: Wisconsin;
Date outbreak began: May 2003;
Date outbreak ended: August 2003;
Animals infected: Prairie dogs, Gambian giant rats, dormice, rope
squirrels;
Number of human cases in the identified location: 27[C];
Number of veterinarians involved in outbreak[A]: 39;
Total size of workforce involved in outbreak[A]: 560;
Federal and state agencies involved in outbreak (agencies in bold cited
insufficient veterinarian capacity as a challenge)[B]:
APHIS;
CDC;
FDA;
USGS;
Wisconsin Department of Agriculture, Trade and Consumer Protection
(bold);
Wisconsin Division of Public Health (bold).
Disease: West Nile virus;
Location: Colorado;
Date outbreak began: June 2003;
Date outbreak ended: November 2003[E];
Animals infected: Birds, horses;
Number of human cases in the identified location: 2,947[F];
Number of veterinarians involved in outbreak[A]: 27;
Total size of workforce involved in outbreak[A]: 150;
Federal and state agencies involved in outbreak (agencies in bold cited
insufficient veterinarian capacity as a challenge)[B]:
APHIS (bold);
CDC;
Colorado Department of Agriculture (bold);
Colorado Department of Public Health and the Environment (bold);
Colorado Division of Wildlife;
Colorado State University (bold).
Source: GAO.
[A] Estimates provided by agency officials. Includes veterinarians
across agencies.
[B] The agencies listed are those identified as playing an important
role in the outbreak, although additional agencies were involved.
[C] Number of confirmed human cases, as provided by state departments
of public health.
[D] These estimates include private-sector veterinarians who worked on
the outbreaks as contractors or temporary employees.
[E] West Nile virus is endemic to the United States. There have been
seasonal outbreaks across the country every year since 1999.
[F] Number of CDC confirmed human cases. CDC also reports that the
number of confirmed nationwide human cases in 2003 for monkeypox and
West Nile virus was 51 and 9,862, respectively.
[End of table]
Two primary reasons emerged for this insufficient capacity. First,
according to federal and state officials, veterinarian capacity was
insufficient because most of the agencies involved in the four
outbreaks had difficulty recruiting and retaining veterinarians in
general. For example, officials at many of the public health agencies
and diagnostic laboratories we spoke with said that it has been
challenging to hire or retain veterinarians with the specialized
qualifications they need--public health and pathology skills,
respectively. According to 2008 survey results from the American
Association of Veterinary Laboratory Diagnosticians, it takes most
diagnostic laboratories more than 6 months to fill vacancies for
veterinary pathologists. In addition, numerous state agency officials
told us that the salaries they offer are not competitive with those of
the federal or private sectors. Moreover, officials told us that it has
been particularly challenging recruiting veterinarians to work in
remote areas or in areas with a high cost of living.
Second, in 2002 and 2003 many veterinarians went to California to
address a particularly demanding outbreak of exotic Newcastle disease,
limiting the number of veterinarians available to respond to other
outbreaks. The exotic Newcastle disease outbreak quickly exhausted
California's supply of veterinarians, both at state agencies and APHIS,
because so many backyard birds--which are kept as a hobby or for
personal consumption--were affected. Responders had to spend valuable
time going door-to-door trying to locate potentially infected birds in
densely populated urban areas. APHIS called in over 1,000 federal,
state, and private-sector veterinarians from outside California to help
with the response. But, even with a task force of over 6,000, it took
almost a year to control the outbreak. Moreover, because so many
veterinarians converged on California, the number available to work on
the other three outbreaks--located in Michigan, Wisconsin, and
Colorado--was insufficient, according to federal and state agency
officials. In part because of the strain on veterinarian resources
during the four outbreaks, officials from 16 federal and state agencies
expressed concern that they will not have sufficient veterinarian
capacity for multiple outbreaks in the future. FDA assisted in one of
the four outbreaks and was the only agency not to express concerns
about veterinarian capacity. Some federal officials said that the
United States has never been tested with two major outbreaks occurring
at once, such as simultaneous outbreaks of foot-and-mouth disease and
highly pathogenic avian influenza--two highly infectious foreign animal
diseases. They said that should this happen, the effects on animal and
public health could be devastating.
Federal and state agency officials reported several consequences of
this insufficient veterinarian capacity. Examples are as follows:
* Michigan state agency officials told us they had trouble testing
enough cattle during the bovine tuberculosis outbreak. Over a 6-1/2
year period, veterinarians struggled to test more than a million cows-
-an average of more than 3,500 a week--but the state has yet to
eradicate the disease.
* Some Michigan officials told us that APHIS and the Michigan
Department of Agriculture did not have enough veterinarians to both
respond to bovine tuberculosis and address other animal diseases, such
as E. coli. In fact, during all four outbreaks, veterinarians at some
point had to delay important work on other diseases, in part because
there were not enough veterinarians.[Footnote 19]
* During the 2003 West Nile virus outbreak in Colorado, a lack of
sufficient veterinarians to track and control the disease, among other
things, may have allowed the virus to infect more people and animals
than it otherwise would have.[Footnote 20]
* The volume of work required to control and eventually eradicate
exotic Newcastle disease in California physically and emotionally
exhausted veterinarians to the extent that, once the outbreak was over,
they needed significant time off to recover, further delaying work on
routine activities.
* The demanding nature of the exotic Newcastle disease and bovine
tuberculosis outbreaks may have caused some veterinarians to seek
employment elsewhere.
Despite reports of insufficient veterinarian capacity during these four
outbreaks, the agencies have not taken full advantage of two important
opportunities to learn from past experience. First, 10 of the 17
agencies have not assessed how well their own veterinarian workforces
responded to individual outbreaks. Our prior work has shown that
agencies can improve response by conducting postoutbreak assessments
[Footnote 21]. One outcome of such an assessment might be a better
understanding of how to most efficiently use veterinarians. For
example, APHIS--one of the agencies that has performed postoutbreak
assessments--found that it had difficulty locating veterinarians with
the specialized expertise needed for addressing the exotic Newcastle
disease outbreak. As a result, APHIS is developing a national list
identifying veterinarians and their credentials to call upon in the
future. In addition, federal and state agencies working on bovine
tuberculosis in Michigan meet periodically to assess what strategies
are working and what they need to change in order to better control the
disease. APHIS also conducts periodic reviews of its efforts and the
state's efforts to address bovine tuberculosis.
Moreover, none of the 17 agencies have come together to share their
experiences across the outbreaks in order to identify workforce
challenges that they may have had in common, including veterinarian
workforce challenges. Consequently, the agencies are missing the
opportunity to identify and address challenges they are likely to face
in the future. The majority of the federal and state agency officials
we spoke with agreed that it would be useful for agencies not only to
conduct assessments of their own workforce response but also to
periodically meet to identify common workforce challenges across
multiple outbreaks and discuss strategies for overcoming these
challenges. However, some agencies told us that their veterinarian
workforce is already facing heavy workload demands that make it
difficult for them to meet their existing responsibilities, and thus
they have not had time to conduct postoutbreak assessments.
Bovine tuberculosis:
Figure: Photographs of a cow and a deer (Source: USDA).
[Refer to PDF for image]
[End of figure]
Bovine tuberculosis is a contagious disease that can be transmitted
from livestock to humans and all other warm-blooded vertebrates. It is
a chronic disease, and symptoms are often not apparent until it has
reached an advanced stage. Inhalation is the most common route of
infection for farm and ranch workers and veterinarians who work with
diseased livestock. Calves, hogs, and humans can also contract bovine
tuberculosis when they drink unpasteurized milk from infected cows.
Livestock are more likely to infect each other when they share a common
watering place. The disease‘s presence in humans has been reduced as a
result of a national eradication program, advances in sanitation and
hygiene, the discovery of effective drugs, and pasteurization of milk.
Exotic Newcastle disease:
Figure: Photograph of a rooster (Source: USDA).
[Refer to PDF for image]
[End of figure]
Exotic Newcastle disease is caused by a highly contagious virus
affecting birds of all species. The virus is spread primarily through
direct contact with birds and their bodily discharges. It can also be
transmitted through contact with certain objects contaminated with the
disease such as vehicles, equipment, shoes, and clothing. It spreads
rapidly among birds kept in confinement, such as commercially raised
chickens. Many birds die without showing any signs of the disease;
however, there are symptoms including, among other things, nasal
discharge, coughing, depression, drop in egg production, and swelling
around the eyes and neck. Exotic Newcastle disease is only mildly
zoonotic in humans, with conjunctivitis being the most common symptom.
Other human symptoms include headache, discomfort, and slight chills.
Monkeypox:
Figure: Photographs of a rodent (Source: U.S. Fish and Wildlife
Service), and a person with the virus (Source: CDC).
[Refer to PDF for image]
[End of figure]
Monkeypox is a rare viral disease that first appeared in the United
States in 2003 when a shipment of exotic, wild animals from Ghana,
including infected Gambian rats, dormice, and rope squirrels, entered
the country. The infected animals then transmitted the virus to prairie
dogs when they were collocated at an animal distributor. The prairie
dogs were later sold as exotic pets and, in turn, transmitted the
disease to humans. People can get monkeypox through a bite or direct
contact with the infected animal‘s blood, body fluids, or lesions. It
is thought to be spread person-to-person through large respiratory
droplets during direct and prolonged face-to-face contact. In addition,
monkeypox can be spread by direct contact with body fluids of an
infected person or with virus-contaminated objects, such as bedding or
clothing. In humans, the signs and symptoms of monkeypox are similar to
those of smallpox and include rash, fever, headache, muscle aches,
backache, swollen lymph nodes, a general feeling of discomfort, and
exhaustion.
West Nile virus:
Figure: Photographs of birds (Source: U.S. Fish and Wildlife Service).
[Refer to PDF for image]
[End of figure]
West Nile virus was recently introduced in wild birds and poses a
potentially serious threat to people and horses. The virus spread
quickly across the United States between 1999 and 2003. Experts believe
it is now established as a seasonal epidemic in North America, flaring
up in the summer and continuing into the fall. The virus is most often
spread when mosquitoes bite infected birds (such as house sparrows or
robins), acquire the virus, and then pass it on to other animals or to
humans. However, West Nile virus is fatal to many species of wild birds,
such as crows, which are then only minimally involved in the spread of
the infection. Many people infected with the virus do not become ill.
Some experience mild symptoms, including fever, headache, body aches,
nausea, vomiting, swollen lymph nodes, or a skin rash. About 1 in 150
develop severe illness and have symptoms that include high fever,
headaches, neck stiffness, stupor, disorientation, coma, tremors,
convulsions, muscle weakness, vision loss, numbness, and paralysis.
Conclusions:
Veterinarians are a small but vital part of the federal workforce,
playing important roles in protecting people from zoonotic and
foodborne diseases, ensuring the health and humane treatment of food
animals, and helping to keep America's food system safe. The nation is
facing a growing shortage of veterinarians, and component agencies and
other federal entities have already identified insufficiencies in their
veterinarian workforces. At FSIS, for example, the veterinarian
workforce is finding it difficult to adequately carry out its
responsibilities for ensuring food safety and the humane treatment of
animals. In 2004, we recommended that FSIS periodically assess whether
it has enough inspection resources, including veterinarians, dedicated
to humane handling and slaughter activities, but the agency has yet to
demonstrate that they have done so. Nor has the federal government
conducted the broader assessments and planning activities necessary to
address veterinarian workforce problems at FSIS and beyond. Unless USDA
and HHS conduct departmentwide assessments of their veterinarian
workforces, they will not fully understand the size and nature of the
challenges they face in recruiting and retaining veterinarians with the
appropriate skills. This will leave their component agencies without a
high-level solution to problems they have so far been unable to solve
on their own. Moreover, without a governmentwide effort to identify
shortcomings in veterinarian capabilities, the federal government may
be missing opportunities to find common solutions for attracting
veterinarians into federal service.
In addition, unless component agencies complete and test their pandemic
plans in keeping with FEMA guidance, they will not be fully prepared to
carry out essential veterinarian functions in the face of high rates of
absenteeism. Until USDA details how responders would control a foot-
and-mouth disease outbreak using vaccines, the nation will not have a
complete understanding of the veterinarian workforce needed to control
such an outbreak. Similarly, until more information is gathered on the
spread of foot-and-mouth disease in wildlife, agencies will not be able
to more accurately model the number and type of veterinarians that
would be needed if the disease were to spread beyond livestock. Failure
to understand the workforce needed during a catastrophic event--whether
a pandemic or an attack on the food supply--could unnecessarily
increase the scope and severity of the crisis. Finally, unless
component agencies involved in responding to outbreaks of zoonotic
disease regularly review their own performance and collectively assess
opportunities for improvement, they cannot be assured they are using
veterinarians as efficiently as possible. They are, therefore, more
likely to face an insufficient veterinarian workforce capacity during
future outbreaks, which may cause an unnecessary increase in the
severity of the outbreaks and worsen the threat to public health.
Recommendations for Executive Action:
We are making nine recommendations to improve the ability of the
federal veterinarian workforce to carry out routine activities, prepare
for a catastrophic event, and respond to zoonotic disease outbreaks.
To help ensure the federal veterinarian workforce is sufficient to meet
the critical responsibilities it carries out on a routine basis, we
recommend that:
1. The Secretary of Agriculture direct FSIS to periodically assess
whether its level of inspection resources dedicated to food safety and
humane slaughter activities is sufficient, and:
2. The Secretary of Agriculture conduct a departmentwide assessment of
USDA's veterinarian workforce--based, for example, on workforce
assessments by its component agencies--to identify current and future
workforce needs (including training and employee development) and
departmentwide solutions to problems shared by its agencies. When the
Secretary completes the assessment, the results should be forwarded to
the Director of the Office of Personnel Management.
3. We also recommend that the Secretary of Health and Human Services
direct the department's component agencies that employ veterinarians to
conduct regular workforce assessments and that the Secretary then
conduct a departmentwide assessment of HHS's veterinarian workforce to
identify current and future workforce needs (including training and
employee development) and solutions to problems shared by its agencies.
When the Secretary completes the assessment, the results should be
forwarded to the Director of the Office of Personnel Management.
4. Finally, we recommend that the Director of the Office of Personnel
Management determine, based on USDA's and HHS's departmentwide
veterinarian workforce evaluations, whether a governmentwide effort is
needed to address shortcomings in the sufficiency of the current and
future veterinarian workforce.
To help the veterinarian workforce continue essential functions during
a pandemic, we recommend that:
5. The Secretaries of Agriculture, Defense, and Health and Human
Services ensure that their component agencies that employ veterinarians
complete pandemic plans that contain the necessary elements put forth
in DHS's continuity of operations pandemic guidance, including
periodically testing, training, and exercising plans.
To improve estimates of the veterinarian workforce needed to respond to
a large-scale foot-and-mouth disease outbreak, we recommend that:
6. The Secretary of Agriculture detail in a contingency response plan
how a response using vaccines would be implemented, and:
7. The Secretary of Homeland Security coordinate an interagency effort
to identify the data necessary to model the spread of disease in
wildlife and how best to gather these data.
To improve the ability of the federal veterinarian workforce to respond
to zoonotic outbreaks in the future while also effectively carrying out
routine activities, we recommend that the Secretaries of those
departments most likely to be involved in response efforts--such as
USDA, HHS, and Interior--ensure that their agencies:
8. Conduct postoutbreak assessments of workforce management; and:
9. In coordination with relevant federal, state, and local agencies,
periodically review the postoutbreak assessments to identify common
workforce challenges and strategies for addressing them.
Agency Comments and Our Evaluation:
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.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 22 days
from the report date. At that time, we will send copies to the
Secretaries of Agriculture, Commerce, Defense, Energy, Health and Human
Services, Homeland Security, Interior, Justice, Smithsonian
Institution, and Veterans Affairs; the Director of the Office of
Personnel Management; the Administrators of the Environmental
Protection Agency, National Aeronautics and Space Administration, and
U.S. Agency for International Development; appropriate congressional
committees; and other interested parties. The report also will be
available at no charge on the GAO Web site at [hyperlink,
http://www.gao.gov].
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,
Signed by:
Lisa Shames:
Director, Natural Resources and Environment:
[End of section]
Appendix I: Location and Responsibilities of Veterinarians in the
Federal Government:
Table 3:
Number of veterinarians by department: Department of Agriculture;
1,771;
Number of veterinarians by component agency or other entity[A]: Animal
and Plant Health Inspection Service; 667;
Examples of veterinarian responsibilities: Protect American livestock
and poultry health through diagnosis, control and eradication of animal
diseases, and partnering with state officials to manage and eradicate
disease outbreaks. Some are employed overseas.
Number of veterinarians by department: Department of Agriculture;
1,771;
Number of veterinarians by component agency or other entity[A]:
1,043[B];
Examples of veterinarian responsibilities: Inspect livestock and
poultry at slaughter plants to identify and examine diseased animals,
and prevent their entry into the nation's food supply; determine the
significance of disease conditions and their potential hazard to public
health; and may oversee total inspection operations.
Number of veterinarians by department: Department of Agriculture;
1,771;
Number of veterinarians by component agency or other entity[A]:
Agricultural Research Service; 57;
Examples of veterinarian responsibilities: Conduct critical research to
develop solutions for high-priority agricultural problems, such as
highly pathogenic avian influenza.
Number of veterinarians by department: Department of Agriculture;
1,771;
Number of veterinarians by component agency or other entity[A]:
Cooperative State Research, Education, and Extension Service; 4;
Examples of veterinarian responsibilities: Plan, develop, organize, and
manage animal health related research, education, and extension
programs in coordination with other federal agencies and national and
international efforts.
Number of veterinarians by department: Department of Defense; 841;
Number of veterinarians by component agency or other entity[A]:
Army[C]; 753;
Examples of veterinarian responsibilities: Ensure food safety at
Department of Defense locations; develop medical defenses against
chemical and biological warfare threat agents; conduct intelligence
work; and care for service animals.
Number of veterinarians by department: Department of Defense; 841;
Number of veterinarians by component agency or other entity[A]: Air
Force; 88;
Examples of veterinarian responsibilities: Track infectious diseases
among Air Force personnel, oversee the health of Air Force personnel
for deployment, and ensure food safety at Air Force bases.
Number of veterinarians by department: Department of Health and Human
Services[D]; 316;
Number of veterinarians by component agency or other entity[A]: Food
and Drug Administration; 152;
Examples of veterinarian responsibilities: Ensure that animal food and
drugs are safe and effective; that food from medically treated animals
is safe to eat; and help ensure the safety of food, drugs, and
cosmetics, among other things.
Number of veterinarians by department: Department of Health and Human
Services[D]; 316;
Number of veterinarians by component agency or other entity[A]:
National Institutes of Health; 85;
Examples of veterinarian responsibilities: Support all animal aspects
of its intramural research program by providing regulatory oversight of
research animals, providing disease surveillance and diagnostics,
managing the agency compliance office, and conducting basic scientific
and translational research.
Number of veterinarians by department: Department of Health and Human
Services[D]; 316;
Number of veterinarians by component agency or other entity[A]: Centers
for Disease Control and Prevention; 77;
Examples of veterinarian responsibilities: Work to identify, prevent,
and control public health threats through applied epidemiology,
laboratory animal medicine and toxicology, technical assistance and
consultation, surveillance, field and clinical investigations, and
human-animal interface research; support public health training and
activities among state, local, tribal, and global health programs;
provide expertise in public health emergency preparedness and provide
surge capacity following public health disasters, global disease
outbreaks, and terrorist attacks; and prevent importation at ports of
entry of animals/animal products that pose human health risks.
Number of veterinarians by department: Department of Health and Human
Services[D]; 316;
Number of veterinarians by component agency or other entity[A]: Office
of the Assistant Secretary for Preparedness and Response; 2;
Examples of veterinarian responsibilities: Identifies, coordinates, and
provides qualified veterinary medical personnel for events requiring
emergency and disaster-related veterinary medical care services to
impacted animal populations (including household pets and service
animals) in or outside of shelter locations until local infrastructures
are reestablished.
Number of veterinarians by department: Department of Veterans Affairs;
37;
Number of veterinarians by component agency or other entity[A]: Office
of Research and Development; 37;
Examples of veterinarian responsibilities: Conduct research to improve
the health of veterans and oversee the health and welfare of animals
used in research.
Number of veterinarians by department: Department of the Interior; 24;
Number of veterinarians by component agency or other entity[A]: U.S.
Geological Survey; 16;
Examples of veterinarian responsibilities: Investigate, diagnose,
develop control methods, and develop databases for wildlife diseases;
provide training to wildlife biologists and resource managers in
wildlife disease identification and control; conduct clinical
veterinary research on wildlife diseases; and oversee the health and
welfare of experimental and wild animals used in research, including
research on wildlife diseases.
Number of veterinarians by department: Department of the Interior; 24;
Number of veterinarians by component agency or other entity[A]: U.S.
Fish and Wildlife Service; 4;
Examples of veterinarian responsibilities: Perform fish health
management and diagnostic activities; conduct wildlife disease
surveillance, diagnostics, and outbreak investigations; provide
technical expertise; and draft policy, regulation, and management
action plans.
Number of veterinarians by department: Department of the Interior; 24;
Number of veterinarians by component agency or other entity[A]:
National Park Service; 4;
Examples of veterinarian responsibilities: Prepare surveillance and
contingency response plans for addressing important wildlife diseases
in the park system; formulate policies for management of wildlife
diseases.
Number of veterinarians by department: Department of Homeland Security;
16;
Number of veterinarians by component agency or other entity[A]: Office
of Health Affairs; 8;
Examples of veterinarian responsibilities: Provide professional
veterinary expertise and leadership to defend human and animal health
and the nation's agriculture and food supply against terrorist attacks,
major disasters, and other emergencies.
Number of veterinarians by department: Department of Homeland Security;
16;
Number of veterinarians by component agency or other entity[A]:
Directorate for Science and Technology; 6;
Examples of veterinarian responsibilities: Utilize knowledge and skills
of disease movement, risk, and economic impacts of diseases to oversee
programs regarding the safety of U.S. agriculture and food supply.
Number of veterinarians by department: Department of Homeland Security;
16;
Number of veterinarians by component agency or other entity[A]:
Directorate for National Protection and Programs; 2;
Examples of veterinarian responsibilities: Identify technologies and
capabilities that can be used to help assure the protection of the
nation's agriculture and food supply from a terrorist attack.
Number of veterinarians by department: Smithsonian; 16;
Number of veterinarians by component agency or other entity[A]:
National Zoo; 16;
Examples of veterinarian responsibilities: Protect the health of
endangered species under the auspices of the National Zoo and oversee
the health of animals housed at the National Zoo; study disease
dynamics and pathology of disease in endangered species; conduct
research in endangered species conservation and propagation, and
surveillance and research in emerging diseases of nondomestic animals
including wildlife; train veterinarians and advance veterinary medical
knowledge regarding zoo and wild animal species in the United States
and abroad; administer International Veterinary Training program.
Number of veterinarians by department: Environmental Protection Agency;
13;
Number of veterinarians by component agency or other entity[A]: 13;
Examples of veterinarian responsibilities: Assess the risks of
pesticide use to humans and domestic animals, research the cancer risk
of environmental chemicals, and improve the process for managing
potential environmental carcinogens.
Number of veterinarians by department: U.S. Agency for International
Development; 8;
Number of veterinarians by component agency or other entity[A]: Bureaus
for Economic Growth, Agriculture and Trade; for Global Health; and for
Africa; 8;
Examples of veterinarian responsibilities: Provide guidance on issues
related to management of highly pathogenic avian influenza outbreaks
and recovery; identify opportunities to share and leverage resources
for avian influenza response efforts with international and domestic
health agencies and universities.
Number of veterinarians by department: Department of Commerce; 9;
Number of veterinarians by component agency or other entity[A]:
National Oceanic and Atmospheric Administration; 9;
Examples of veterinarian responsibilities: Conduct audits of seafood
plants and products as part of the Seafood Inspection Program; provide
guidelines and oversight of the Marine Mammal Health and Stranding
Response Program, Aquatic Animal Health Program, disease surveillance,
health monitoring, outbreak investigations, and
contaminants/pathogen/toxin/health research.
Number of veterinarians by department: National Aeronautics and Space
Administration; 5;
Number of veterinarians by component agency or other entity[A]: Office
of the Chief Health and Medical Officer; 5;
Examples of veterinarian responsibilities: Provide and coordinate
animal care at agency research facilities; one veterinarian is an
astronaut.
Number of veterinarians by department: Department of Energy; 1;
Number of veterinarians by component agency or other entity[A]:
Lawrence Livermore National Laboratory; 1;
Examples of veterinarian responsibilities: Oversees the laboratories'
Food and Agricultural Security program, which includes the work on
modeling animal disease to determine workforce resources that will be
needed for response to outbreaks.
Number of veterinarians by department: Department of Justice; 1;
Number of veterinarians by component agency or other entity[A]: Federal
Bureau of Investigation; 1;
Examples of veterinarian responsibilities: Provide veterinary expertise
in the investigation of an intentional disease outbreak.
Source: GAO analysis of agency survey responses and interviews.
[A] We relied on federal agency officials to identify all veterinarians
employed--civil and military service employees, contractors, and other-
-regardless of job title. The number of veterinarians reported for all
agencies are as of June 30, 2008, except for the following: The Food
Safety Inspection Service (FSIS) and the Army veterinary reserve corps
are current as of the end of fiscal year 2008 and November 2008,
respectively.
[B] The number of veterinarians listed for FSIS include 968 veterinary
medical officers, the majority of whom work at slaughter plants, as
well as approximately 75 veterinarians who work in other occupations.
[C] The Army veterinarian workforce consists of 446 active duty; 173
reserve corps; and 134 other.
[D] The number of veterinarians listed for the Department of Health and
Human Services does not include those United States Public Health
Service Commissioned Corps veterinarians working at the FSIS and the
Environmental Protection Agency because they are counted as employees
of those agencies.
[End of table]
[End of section]
Appendix II: Scope and Methodology:
To determine the extent to which the federal government has assessed
the sufficiency of its veterinarian workforce for routine activities,
we interviewed officials and collected documents from the American
Veterinary Medical Association, the National Association of Federal
Veterinarians (NAFV), and the Association of American Veterinary
Medical Colleges to identify general concerns about the federal
veterinarian workforce. NAFV also provided a review it had conducted in
1996 that identified federal departments and agencies that employ
veterinarians. We expanded this list of departments and component
agencies based on referrals and experience from our past reports,
resulting in a list of 24 component agencies and other federal
entities. We then surveyed these 24 entities to obtain information on
the federal veterinarian workforce--including the number of
veterinarians employed, their grade level, salaries, roles and
responsibilities, number of vacancies, and sufficiency of the
workforce. We conducted this self-administered electronic survey in
October 2007 and then requested an update of this survey information in
July 2008. We achieved a 100 percent response rate both times. However,
one entity was unable to provide some of the specific salary
information we requested, and we noted this in our report.
Because this was not a sample survey, but rather a survey of the
universe of respondents, it has no sampling errors. However, the
practical difficulties of conducting any survey may introduce errors,
commonly referred to as nonsampling errors. For example, respondents
may have difficulty interpreting a particular question, the sources of
information available to respondents may introduce errors or
variability, and analysts may introduce errors when entering data into
a database or analyzing these data. We took steps in developing the
questionnaire, collecting the data, and analyzing them to minimize such
nonsampling error. For example, we pretested the survey to ensure that
the questions were relevant, clearly stated, and easy to understand.
To obtain salary information for Department of Agriculture (USDA)
agencies over the past 5 years, we used data from the Office of
Personnel Management's (OPM) Central Personnel Data File. We did not
independently verify these data for the years we reviewed; however, in
a 1998 report, we found that governmentwide data from this file for the
key variables in this study (agency, birth date, service computation
date, occupation, and retirement plan) were 99 percent accurate or
better.[Footnote 22] Therefore, we feel these data were sufficiently
reliable for the purposes of this review.
On the basis of information we received in our survey of these
component agencies and other entities, we then analyzed the workforce
assessment efforts of USDA, the Department of Defense (DOD), and the
Department of Health and Human Services (HHS). We selected these
departments because they employ the majority of federal veterinarians
(96 percent) identified in our survey. Within these three departments,
we further focused our review on five component agencies--the Animal
and Plant Health Inspection Service (APHIS), FSIS, Army, and the Food
and Drug Administration (FDA)--to determine the extent to which they
assessed the sufficiency of their veterinarian workforce. We also
selected the Agricultural Research Service (ARS) for further review
because it is USDA's chief scientific research agency and conducts
research to solve agricultural problems of high national priority. We
conducted our assessment by reviewing department and agency documents,
such as workforce plans, human capital management reports, workforce
models, and gap assessments. We then compared workforce assessment
efforts of the three departments and five component agencies with GAO
workforce planning guidance. We also conducted semistructured
interviews with workforce planning and veterinarian program officials.
In addition, we interviewed an author of the report FDA Science and
Mission at Risk regarding the report's findings and their relation to
FDA veterinarian skill gaps. Further, we visited one poultry and two
beef slaughter plants of varying sizes to observe conditions and
interview veterinarians and other FSIS officials. We also interviewed
FSIS officials working at the slaughter plant that was the subject of
the nation's largest beef recall. We selected these plants on the basis
of proximity to the sites of the four recent zoonotic disease outbreaks
we reviewed, and recommendations from FSIS officials. Moreover, other
veterinarians contacted us to relay concerns about the sufficiency of
the FSIS veterinarian workforce. We interviewed officials from the OPM
to determine the agency's role in workforce planning for federal
veterinarians and to identify recruitment and retention authorities
available to agencies and departments. Finally, we interviewed experts
from the Council of State and Territorial Epidemiologists, the National
Association of State Public Health Veterinarians, the American College
of Veterinary Pathologists, the American Association of Wildlife
Veterinarians, the American Association of Veterinary Laboratory
Diagnosticians, and the National Academy of Sciences to identify
workforce needs for veterinary specialties including public health,
wildlife veterinarians, veterinary laboratory diagnostics, and
veterinary pathology.
To determine the extent to which the federal government has identified
the veterinarian workforce needed during a catastrophic event, we
analyzed workforce planning efforts for two potential large-scale
national incidents that the White House Homeland Security Council
deemed critical for planning purposes: a pandemic and a foot-and-mouth
disease outbreak. For the first, we compared pandemic plans from APHIS,
FSIS, ARS, Army, and FDA to guidance the Department of Homeland
Security's (DHS) Federal Emergency Management Agency provided to
departments and agencies for identifying special considerations for
maintaining essential functions and services under such conditions.
[Footnote 23],[Footnote 24] These agencies were selected for the
reasons described above. We interviewed agency officials to discuss
identified gaps and determine the extent to which the plans were being
updated and tested. Furthermore, we interviewed HHS officials to
understand their review of state pandemic plans, which are under
development to ensure continuity of the food supply system and the
ability to respond to agriculture emergencies. For the second, we
reviewed veterinarian workforce outcomes from DHS's nationwide effort
to assess the nation's preparedness for multiple, intentional
introductions of foot-and-mouth disease. In addition to interviewing
the DHS official responsible for coordinating the animal health
emergency capability, we also interviewed state officials who have
conducted large-scale exercises simulating a response to foot-and-mouth
disease, as well as USDA officials with responsibility for such an
event, to determine the feasibility of the response depicted in the
scenario. Because vaccine use was suggested as an alternative strategy
to the slaughter of animals infected with foot-and-mouth disease, we
also interviewed USDA's Chief Veterinary Officer, and DHS and USDA
officials at Plum Island Animal Disease Center to determine the status
of foot-and-mouth disease vaccine development and the feasibility, as
well as practicality, of their use. Finally, at the recommendation of
DHS, we interviewed the Department of Energy official responsible for
overseeing the development of a decision support system that models
various foot-and-mouth disease outbreak scenarios in order to estimate
the number and type of workforce needed for responding to outbreaks.
The Department of Energy is performing this work under contract for
DHS. We also interviewed USDA, DHS, and Department of the Interior
(Interior) officials to determine the extent to which agencies are
including the possible spread of foot-and-mouth disease in wildlife in
their planning efforts.
To determine the extent to which federal and state agencies encountered
veterinarian workforce challenges during four recent zoonotic
outbreaks, we conducted semistructured interviews with 17 federal and
state agencies involved in these outbreaks. We relied on federal and
state officials to identify those agencies that played an important
role in outbreak response. Based on this information, we then
interviewed officials from USDA, HHS, Interior, state public health
departments, state agriculture and wildlife agencies, state diagnostic
laboratories, and one county public health agency. We also interviewed
other individuals involved in the outbreaks, including researchers from
Northwestern University, the University of California at Davis, and
Western University of Health Sciences. We selected the four outbreaks
in our review--bovine tuberculosis in Michigan, exotic Newcastle
disease in California, monkeypox in Wisconsin, and West Nile virus in
Colorado--because these outbreaks were most frequently recommended by
federal officials as examples of recent zoonotic diseases; are ongoing
or have occurred since 2001; and have affected various types of
animals, including livestock, wildlife, pets, and exotic animals. In
addition, we chose these four outbreaks for review because of the
unique nature of the outbreaks in these states. Specifically, we
selected Michigan as the state for the bovine tuberculosis review
because the ongoing outbreak is the longest outbreak of this disease in
the United States in recent history. We chose California because it
experienced the greatest number of animal infections for the exotic
Newcastle disease outbreak. We selected Wisconsin because it
experienced the most human monkeypox infections. We selected Colorado
for West Nile virus because the number of human infections in Colorado
in 2003 was the highest for a single state. In addition to the
interviews, we also analyzed federal, state, and county documents, such
as after action reports, in order to (1) understand the extent to which
agencies formally assessed the management of their veterinarian
workforces during these outbreaks and (2) identify any workforce-
related challenges and steps agencies took to address these challenges.
[End of section]
Appendix III: Comments from the Department of Agriculture:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
USDA:
United States Department of Agriculture:
Office of the Secretary:
Washington, D.C. 20250:
January 16, 2009:
Ms. Lisa Shames:
Director:
Natural Resources and Environment:
United States Government Accountability Office:
441 G Street N.W. Mail Room 2T23A:
Washington, DC 20548:
Dear Ms. Shames:
Thank you for allowing the United States Department of Agriculture
(USDA) the opportunity to comment on the GAO draft report "Veterinarian
Workforce: Actions Are Needed to Ensure Sufficient Capacity for
Protecting Public and Animal Health" (09-178). We are providing
comments to the Recommendations for Executive Action for USDA.
Recommendation #1:
To help ensure the federal veterinarian workforce is sufficient to meet
the critical responsibilities it carries out on a routine basis, GAO
recommends that the Secretary of Agriculture direct FSIS to
periodically assess whether its level of inspection resources dedicated
to food safety and humane slaughter activities is sufficient.
USDA agrees with the recommendation and already regularly assesses the
level of inspection resources it needs. As part of the budget
formulation process, the Food Safety and Inspection Service (FSIS)
annually assesses its needs for the inspection and veterinary resources
sufficient to meet the statutory mandates for food safety and the
humane handling of livestock. Also, as mentioned in the GAO report,
FSIS is continually taking steps to enhance veterinary and inspection
capacities and to better allocate its resources to protect the public
health. [See comment 1]
In addition, in the course of operations FSIS managers conduct regular
assessments to determine the number of Public Health Veterinarians
(PHV) positions needed in specific establishments, primarily by
considering the geographic location or proximity of other federal
establishments, the size of the establishment, the production volume of
plant operations (which determines the number of on-line inspection
personnel), and the number of approved operational shifts. Multiple
slaughter plants located in close proximity can be assigned a single
PHV on a patrol basis while slaughter establishments in more remote
locations may require a PHV at each plant. In slaughter plants with
extremely high production volume, FSIS may assign an additional PHV.
In addition to the above response, we have further general comments
pertaining to GAO's analysis of FSIS operations and activities for
publication in the final report. These general comments are contained
in the attached appendix.
Recommendation #2:
To help ensure the federal veterinarian workforce is sufficient to meet
the critical responsibilities it carries out on a routine basis, GAO
recommends that the Secretary of Agriculture conduct a departmentwide
assessment of USDA's veterinarian workforce-based, for example, on
workforce assessments by its component agencies-to identify current and
future workforce needs (including training and employee development)
and departmentwide solutions to problems shared by its agencies. When
USDA completes its assessment, it should forward the results to the
Director of OPM.
USDA agrees with this recommendation. However, given that the majority
of USDA's veterinary workforce is located in two agencies--the Animal
and Plant Health Inspection Service (APHIS) and FSIS (40 percent and 57
percent, respectively), and that each has both the staff as well as the
expertise to conduct the assessments and analyze the data, APHIS and
FSIS will conduct veterinary workforce analyses for their respective
agencies and work together, with Departmental consultation, as needed,
to develop solutions to problems shared by both agencies. Agency-
specific problems will be addressed separately within the respective
agency. Veterinary workforce trends will be tracked, and training,
recruitment and retention strategies devised to mitigate attrition and
maintain progress toward the Department's mission to protect the public
health. Assessment results will then be forwarded to the Director of
OPM. [See comment 2]
Recommendation #5:
To help the veterinarian workforce continue essential functions during
a pandemic, GAO recommends that the Secretaries of Agriculture, Defense
and Health and Human Services ensure that their component agencies that
employ veterinarians complete pandemic plans that contains the
necessary elements put forth in DHS's continuity of operations pandemic
guidance, including periodically testing, training, and exercising
plans.
USDA agrees with this recommendation. The active Pandemic Plan (Plan)
was written in January 2007 by APHIS. However, that Plan is now
currently being updated and modernized based upon the Department of
Homeland Security's (DHS) Pandemic Plan checklist that was published in
July of 2008. The checklist was developed by DHS to assist Departments
and Agencies in creating a complete and workable Pandemic Plan based on
ensuring that the primary essential functions of an agency, in this
case APHIS, will continue to be performed. Included among the
provisions of that checklist is the requirement for periodic testing,
training and exercising of the Plan. The revised Plan is expected to be
ready for internal review, coordination, and collaboration with the
regions, programs, and various stakeholders by the end of January 2009
with a final document in place by March 2009.
Recommendation #6:
To improve estimates of the veterinarian workforce needed to respond to
a large-scale foot-and-mouth disease outbreak, GAO recommends that the
Secretary of Agriculture detail in a contingency response plan how a
response using vaccines would be implemented.
USDA agrees with this recommendation. USDA has issued contingency plans
for use of foot-and-mouth disease (FMD). Specifically, APHIS has issued
contingency plans for use of FMD vaccine as a sponsor of the North
American Foot-and-Mouth Disease Vaccine Bank (NAFMDVB). The NAFMDVB
holds FMD concentrated antigens, which can be finished into vaccine in
the event of a FMD outbreak in one of the member countries (United
States, Canada and Mexico). In addition, APHIS' Foreign Animal Disease
Preparedness and Response Plan includes a decision tree which outlines
the decision-making process that would lead to the use of vaccine as an
aid in the control and eradication of FMD in North America. [See
comment 3]
Policy decisions as to who may administer the vaccine will be made
based upon the circumstances of the outbreak. If the outbreak is FMD
and a vaccination strategy is chosen, multiple options exist. The
considerations include activating the National Animal Health Emergency
Response Corps; federalizing private veterinarians who have pre-
qualified; utilizing the federally accredited veterinarian workforce in
addition to regulatory (federal and State) veterinarians; or allowing
animal owners to vaccinate, under appropriate veterinary supervision
with respect to State laws.
Looking to the future, USDA and DHS are actively supporting the
development and application of new vaccine technologies, like molecular
based vaccines, that do not require expensive, high-containment
production facilities and can be produced safely in the United States.
Recommendation #8:
To improve the ability of the federal veterinarian workforce to respond
to zoonotic outbreaks in the future while also effectively carrying out
routine activities, GAO recommends that the secretaries of those
departments most likely to be involved in response efforts-such as
USDA, HHS, and the Interior-ensure that their agencies conduct post-
outbreak assessments of workforce management.
USDA agrees with this recommendation. USDA has conducted or
commissioned assessments of the response workforce and used findings to
direct its response planning. This has generated the development and
utilization of a resource ordering and status system, based on the
Forest Service tool that allows for real-time management of resources,
including trained personnel, to either support the response or maintain
regular functions. Internal evaluations of response team deployments
and activities have led to a more integrated team approach which will
be introduced in 2009. Another approach to adequately address surge
needs in a response effort that has been highly successful and merits
possible expansion is the utilization of 3D (depopulation, disposal and
decontamination) contractors. Companies contracted by APHIS and trained
in advance have arrived on-the-scene within 24 hours, freeing
veterinarians to work on incident management, surveillance or
epidemiological studies.
Recommendation #9:
To improve the ability of the federal veterinarian workforce to
response to zoonotic outbreaks in the future while also effectively
carrying out routine activities, GAO recommends that the secretaries of
those departments most likely to be involved in response efforts-such
as USDA, HHS and the Interior-ensure that their agencies in
coordination with relevant federal, state, and local agencies,
periodically review the post-outbreak assessments to identify common
workforce challenges and strategies for addressing them.
USDA agrees with this recommendation. Specifically, USDA agrees that
commonalities exist among response agencies when faced with an animal
or public health emergency that creates immediate needs for trained and
ready personnel. We will continue to collaborate with the agencies
listed in support of mutual goals, such as the requirements of Homeland
Security Presidential Declarations and ensuring a workforce adequate to
manage crises.
Sincerely,
Signed by:
Bruce I. Knight:
Under Secretary:
Marketing and Regulatory Programs:
Appendix to USDA Response on "Veterinarian Workforce: Actions Are
Needed to Ensure Sufficient Capacity for Protecting Public and Animal
Health" (09-178):
General Comments On GAO's Analysis Of FSIS Operations And Activities:
Page 14, 1st sentence, last paragraph: It states that that "FSIS has
never had a sufficient number of veterinarians..."
USDA Comment: This is misleading. It would be more accurate to state
that "Many FSIS veterinarian positions have gone unfilled due to a lack
of candidates. In the past decade, FSIS has never been fully staffed
with veterinarians..." On page 15, where it discusses vacancy rates, it
would be more accurate and more in line with the information on page 14
to state that vacancy rates "varied by location and year, ranging from
a very small percentage to as high as 35 percent of the total
positions." Also, as GAO notes on page 15, FSIS has been able to
reallocate veterinary resources sufficient to meet its statutory
mandates for food safety and humane handling of livestock. [See comment
4]
Page 15, 2nd sentence, last paragraph: This sentence states that
"Inhumane treatment of livestock contributed to the largest beef recall
in US history, in February 2008."
USDA Comment: As written, this sentence is factually incorrect. FSIS
obtained evidence that the establishment did not consistently contact
the FSIS public health veterinarian in situations in which cattle
became non-ambulatory after passing ante-mortem inspection, which is
not compliant with FSIS regulations. Such circumstances require that an
FSIS public health veterinarian reassess the non-ambulatory cattle,
which are either condemned and prohibited from the food supply, or
tagged as suspect. It was this evidence that directly led to the
voluntary recall by the Chino firm on February 17, 2008. The inhumane
treatment was not the basis for the recall, but, rather, resulted in a
suspension of operations which occurred on February 4, 2008. The
inhumane treatment allegations were what led to the investigation into
plant practices by USDA. [See comment 5]
Page 16, 2nd paragraph: This paragraph discusses instances of local
veterinary shortages, and increased verification of humane handling.
USDA Comment: Although FSIS has not been able to hire as many
veterinarians in some locations as would be ideal, work is prioritized
to ensure food safety tasks are performed. The full paragraph on p.16
should not give the impression that food safety is compromised by
intermittent local veterinarian shortages. Veterinarians in FSIS are
instructed to prioritize their time with food safety (which includes
ante-mortem activities such as humane handling), then food defense
activities being the highest priority. In the last few years, FSIS has
placed supervisory consumer safety inspectors in many large slaughter
plants. These employees directly report to the veterinarian, and
provide significant relief to the supervisory activities of the
veterinarian. This enables the veterinarians to focus their time on
food safety related activities. From 2003 until 2008, FSIS increased
staffing for the number of SCSI's almost four fold, from 57 to 207.
This paragraph also notes that "In the wake of this incident, FSIS
required veterinarians to spend more tome verifying the humane
treatment of animals". Although technically correct, as noted in FSIS
Notice 17-08, this increased focus w for only a 60 day period between
March 10 and May 6, 2008. During this brief period, it was important
that humane handling activities took priority over other duties.
There is also much emphasis on the incidents at a plant in Chino, CA.
This is attributed to having only one veterinarian assigned to the
plant. It should be noted, however, that the incidents at this plant
are not representative of FSIS regulatory control at comparable plants.
FSIS is similarly staffed at comparable plants, but these incidents
have not been replicated. In their recent audit report, OIG found no
evidence of systematic humane handling oversight problems. It is
important to note, that the last time two veterinarians were assigned
to the facility was in the early 1990's. Simply because the plant
slaughters cull cows is not a sufficiently justifiable reason to assign
two veterinarians to a plant, especially following the ban on slaughter
of downer cattle in late 2003 because the ante-mortem and post-mortem
examination of downers was labor intensive. [See comment 6]
Page 16, last two sentences, 2nd paragraph: These last two sentences
reference a recommendation made in a 2004 GAO report "... that ISIS
periodically assess whether the level of resources dedicated to humane
handling and slaughter activities is sufficient but the agency has yet
to demonstrate that they have done so."
USDA Comment: This same recommendation is repeated in the first
paragraph on page 47 and again on page 48. It is our understanding that
the recommendation from the 2004 GAO report, "Humane Methods of
Slaughter Act: USDA Has Addressed Some Problems but Still Faces
Enforcement Challenges", has been closed. As stated in the response to
the recommendation, FSIS already annually assesses its needs for the
inspection and veterinary resources sufficient to meet its statutory
mandates for food safety and the humane handling of livestock, as part
of the budget formulation process. In addition, since the initial 2004
GAO report, FSIS has taken a number of actions in regard to ensuring
the verification of compliance with the humane handling requirements.
FSIS implemented the HATS database which is used by FSIS Public Health
Veterinarians and other in-plant program personnel to report their time
and data for specific humane handling activities. District Veterinary
Medical Specialists (DVMS) routinely verify the accuracy of the data
entered. For FY2008, FSIS inplant personnel spent approximately 120 FTE
staff years, or 250,000 person-hours, verifying humane handling
activities at the 800 livestock slaughter plants under Federal
Inspection. Approximately 47% of this humane handling verification time
was conducted by PHVs. Eighty-six humane handling related suspensions
were effected at 65 of these livestock slaughter plants. [See comment
7]
Page 17: The first and second paragraphs on this page provide a
comparison between the mean annual salary for FSIS veterinarians as
compared to the mean salary, for private practice veterinarians and
discusses the steps FSIS has taken to address veterinary shortages.
USDA Comment: We believe it should be noted that overtime work pushes
the FSIS salaries closer to those in the private sector. We also
believe, when discussing recruitment initiatives, the following should
be included: "In April 2003 the FSIS and the Public Health Service
(PHS) entered into a Memorandum of Agreement which significantly
expanded the number of PHS Commissioned Corps Officers detailed to
FSIS. The Commissioned Corps has a variety of occupations, including
veterinarians, which help promote FSIS' public health mission. PHS
Officers work as permanent staff members alongside their FSIS
counterparts, and this has proven to be a valuable alternative method
to fill vacant Veterinary Medical Officer positions."
Page 18, last sentence, 1st paragraph: This sentence states that the
"direct-hire authority" expired in 2007 and was not renewed.
USDA Comment: On page 18, direct-hire information is outdated and
incomplete. USDA submitted a request to resume using direct-hire
authority, and the request was approved by OPM, on a limited basis, on
November 25, 2008. FSIS will continue using this limited direct-hire
authority for veterinarians at least through its December 31, 2009
expiration date. If recruitment difficulties continue, FSIS plans to
request an extension of its direct-hire authority, without the
limitations currently imposed. Currently, FSIS is limited to a total of
150 hires using this authority, and may only use it in locations where
there are fewer than three eligible candidates. Given that it takes 5
to 6 months to obtain OPM approval, we will need to reinitiate our
direct-hire request in July or August 2009 in hopes to have it approved
prior to the December 31, 2009 expiration date. It would be more
advantageous to the Agency if OPM would approve Government-wide direct
hire authority for veterinarians without limitations and for a longer
period of time than just one year. [See comment 8]
Page 26, Table 1: The table indicates that the veterinarian workforce
falls short of Agency goals due to the unpleasant environment and
grueling work.
USDA Comment: The challenges faced by FSIS are not adequately
highlighted. Recruitment difficulties result from more than the nature
of the work and the work environment. In addition to what is already
stated, it would be helpful to note that FSIS highlighted a wide
variety of factors that have a negative impact on their recruitment
efforts, including salary, lack of public health and food safety
emphasis in Veterinary Colleges, and remote duty stations. [See comment
9]
Page 30, 1st paragraph: This paragraph discusses the change in the
entry grade level for newly hired veterinarians and OPM 's review of
veterinarian classification initiated at USDA 's request.
USDA Comment: It should be noted that FSIS provided staff resources to
expedite the development and implementation of the classification and
qualification standards. The revised qualification standards were
developed by an FSIS senior human resources specialist with input from
all participating federal agencies. Additionally, during the
development of the classification standard FSIS and APHIS veterinarians
participated in focus groups, and both agencies reviewed the draft
material in-depth at several stages. We recommend a minor change to the
second sentence in the first paragraph: "This change paralleled the
revised qualification standard for the veterinary occupation which
raised the entry grade level for newly hired veterinarians from GS-9 to
GS-11..." In addition, FSIS has been able to attract more veterinarians
through the use of hiring flexibilities, such as superior
qualifications, direct-hire authority and recruitment incentives."
Page 30, 2nd paragraph: This paragraph discusses NVMSA authority.
USDA Comment: USDA funding under the NVMSA was rescinded 6/19/08. FSIS
absorbed the student loan repayment obligations to the five individuals
hired while under the NVMSA. Over a three-year period, it will cost the
Agency a total of $150,000.
Page 31, 5th sentence, 2nd paragraph: This sentence states that FEMA
guidance directs agencies to identify three people who can carry our
each responsibility and identify how the agency will continue to
operate if leadership and essential staff are unavailable.
USDA Comment: FSIS Human Pandemic Operations Plan (HPOP), Annex D shows
that all program areas have identified at least 3 people who can carry
out program responsibilities and ensure delivery of essential functions
to the maximum extent possible with available personnel during an
expected high rate of absenteeism during a pandemic. Section 2.1 of the
HPOP details the essential functions of the program areas and alternate
personnel (by job titles) who can take over the functions.
Page 32, 3rd sentence, 2nd paragraph: The sentence stales that FSIS'
plan does not address the logistics on how FSIS will work with industry
to ensure veterinarians and other employees are available in the event
of a pandemic so that food production can continue.
USDA Comment: FSIS is finalizing a Pandemic Resource Management
Strategy developed in collaboration with the Food Sector Coordinating
Council which outlines what the Agency and the Industry will do at the
different stages of a pandemic to ensure food production is sustained
to the maximum extent possible. FSIS actions include among other
measures, the development of quick immersion training for veterinarians
and other employees to ensure to the maximum extent possible that
inspection services are provided that will allow the industry to
produce food under continuous inspection. Priority allocation of
resources to the slaughter inspection of certain species (poultry) may
become necessary based on need identified through active communication
with the industry. The Strategy will be added as an Annex to the HPOP.
Page 33, 4th sentence, 1st paragraph: The sentence states that FSIS'
plan does not mention how it would work with APHIS on activities
related to surveillance of animal diseases.
USDA Comment: In a pandemic, FSIS, as part of its essential inspection
functions will continue to report foreign animal diseases, including
BSE, that are of interest to APHIS as part of their surveillance
program as per FSIS Directive 6000.1 (8/4/06) Responsibilities Related
to Foreign Animal Diseases (FADS) and Reportable Conditions. Specific
language will be added to the HPOP as part of its revision/update that
is in progress.
Page 33, last sentence, 1st paragraph: the sentence slates that FSIS'
plan does not consider the impact of local quarantine on access to
plants:
USDA Comment: In a pandemic, FSIS does not intend to deploy inspection
personnel from a non-pandemic area to a pandemic area. If quarantine is
in effect however for a certain area, plant personnel will likewise be
prevented from access to facilities therefore inspection services would
not be needed. According to the Department guidance, FSIS inspection
personnel may be granted special permission to enter local/State
quarantine areas if deployment is deemed necessary, critical, and
appropriate to provide inspection services.
The following are GAO's comments on the Department of Agriculture's
letter dated January 16, 2009.
GAO Comments:
1. USDA commented that FSIS already regularly assesses the level of
inspection resources it needs, as we recommended in 2004. However, as
our report states, FSIS has yet to demonstrate that they have done so.
We regularly follow up to request evidence that agencies have
implemented our recommendations, and FSIS has not provided such
evidence.
2. USDA reported the majority of its veterinarian workforce is located
within two agencies, APHIS and FSIS, and each has the staff and
expertise to conduct veterinarian workforce analyses for their
respective agencies. Therefore, these two agencies will work together,
with departmental consultation, as needed, to develop solutions to
problems shared by both agencies. We continue to believe that a
departmental assessment, not a consultation, is necessary, particularly
in light of the competition between the two agencies. As we reported,
APHIS is attracting veterinarians away from FSIS because the work at
APHIS is more appealing, there are more opportunities for advancement,
and the salaries are higher. Furthermore, ARS continues to experience
difficulties recruiting and retaining highly qualified veterinarians to
carry out critical research of national importance, yet there is no
mention of ARS in USDA's comments.
3. USDA commented that it has contingency plans and a decision tree for
use of foot-and-mouth disease vaccine from the North American Foot-and-
Mouth Disease Vaccine Bank. We acknowledge that USDA has these plans.
In fact, we reviewed a draft plan titled, Response to the Detection of
Foot-and-Mouth Disease in the United States, dated October 2007, that
USDA officials told us was their new response plan that considered
alternative response strategies, including "vaccinate to live."
However, this plan does not detail how a policy of this nature would be
implemented. USDA further commented that policy decisions as to who may
administer the vaccine will be made based on the circumstances of the
outbreak. While we recognize that each outbreak is unique, this should
not preclude USDA from identifying a plausible scenario or scenarios
and detailing how a vaccinate to live strategy would be carried out in
order to enhance preparation, response, and recovery in a time of
crises.
4. We modified our report to reflect that USDA would like to change
their statement from FSIS has "never" had a sufficient number of
veterinarians to "over the past decade." USDA also asserts that our
report says that FSIS has been able to reallocate veterinary resources
sufficient to meet its statutory mandates for food safety and humane
handling of livestock. However, our report only presents this as the
view of FSIS headquarters officials. We raise this point to illustrate
that FSIS headquarters officials and veterinarians working in slaughter
plants differ on the impact of this shortage.
5. We modified our report to reflect more clearly the relationship
between the events at a Chino, California, plant and the February 2008
beef recall.
6. USDA commented that that our report emphasizes the incident at a
plant in Chino, California. We raise the point because some
veterinarians told us they did not have time to ensure the humane
treatment of livestock, and this example illustrates inhumane treatment
occurred despite the presence of FSIS inspectors. USDA further
commented that we attribute this incident to having only one
veterinarian. We do not state this in our report. We use this and other
statements about resources to illustrate the need for FSIS to
periodically assess whether the level of resources dedicated to humane
handling and slaughter activities is sufficient. They have yet to do
so. In addition, USDA commented that the USDA Inspector General did not
find systematic problems associated with oversight of humane handling
at slaughter facilities that process cull cows. However, the Inspector
General did conclude that there is inherent vulnerability at the other
plants in the scope of its audit, and that inhumane handling could
occur and not be detected by FSIS inspectors due to lack of continuous
surveillance.
7. USDA commented that GAO has closed the 2004 recommendation that FSIS
periodically assess whether the level of resources dedicated to humane
handling and slaughter activities is sufficient. We recognize that FSIS
has taken actions in response to a number of recommendations made in
the 2004 report and have documented implementation of these
recommendations. However, with regard to periodic assessment, we closed
this recommendation because enough time had passed that we considered
it unlikely to be implemented. As our report states, FSIS has yet to
demonstrate that it has been implemented. Based on our current work, we
continue to believe that periodic assessment is needed, and we make a
recommendation to that effect.
8. We modified our report to include the recent approval of USDA's
direct-hire authority and noted that USDA has raised some concerns.
9. We modified our report to include the concern about veterinary
schools and enhanced the chart to include the concern for salary.
[End of section]
Appendix IV: Comments from the Department of Defense:
Department Of The Army:
Headquarters, U.S. Army Medical Command:
2050 Worth Road:
Fort Sam Houston, Texas 78234-6000:
Reply To Attention Of:
January 6, 2009:
Ms. Lisa Shames:
Director, Natural Resources and Environment:
Government Accountability Office:
441 G Street, N.W.
Washington, D.C. 20548:
Ms Shames:
This is the Department of Defense (DoD) response to the GAO Draft
Report, GAO-09-178, "Veterinarian Workforce: Actions Are Needed to
Ensure Sufficient Capacity for Protecting Public and Animal Health,"
dated December 16, 2008 (GAO Code 360855).
We have enclosed comments regarding the report and recommendation five.
My point of contact is COL Gary Vroegindewey, 703-681-3062, or email:
gary.vroegindewey@us.army.mil.
Sincerely,
Signed by:
William H. Thresher:
GAO Draft Report Dated December 16, 2008:
GAO-09-178 (GAO Code 360855):
"Veterinarian Workforce: Actions Are Needed To Ensure Sufficient
Capacity For Protecting Public And Animal Health"
Department Of Defense Comments To The GAO Recommendation:
Recommendation: In report recommendation number 5 the GAO recommends
that the Secretary of Defense ensure that the component agencies that
employ veterinarians complete pandemic plans that contain the necessary
elements put forth in the Department of Homeland Security's continuity
of operations pandemic guidance, including periodically testing,
training, and exercising plans.
DOD Response: Concur. As reflected in the draft report, DoD is
currently working with component agencies that employ veterinarians to
complete pandemic plans that contain the necessary elements of the
Department of Homeland Security's continuity of operations pandemic
guidance (including periodically testing, training, and exercising
plans). Efforts are underway to finalize the Army Pandemic Influenza
(PI) Plan. The Emergency Preparedness and Response Branch,
Headquarters, US Army MEDCOM, plans to hold a 2nd Quarter, FY 2009
conference/teleconference for all concerned parties to adjust the
current Army plan to meet the NORTHCOM-directed PI response phases. The
implementation date of the final PI plan will be determined based on
current mission priorities.
[End of section]
Appendix V: Comments from the Department of Health and Human Services:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
Department Of Health & Human Services:
Office Of The Secretary:
Assistant Secretary for Legislation:
Washington, DC 20201:
January 14, 2009:
Lisa Shames:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street N.W.
Washington, DC 20548:
Dear Ms. Shames:
Enclosed are comments on the U.S. Government Accountability Office's
(GAO) report entitled: "Veterinarian Workforce: Actions Are Needed to
Ensure Sufficient Capacity for Protecting Public and Animal Health"
(GAO-09-178).
The Department appreciates the opportunity to review this report before
its publication.
Sincerely,
Signed by:
Jennifer R. Luong, for:
Craig Burton:
Acting Assistant Secretary for Legislation:
Attachment:
Comments Of The Department Of Health And Human Services (HHS) On The
Government Accountability Office's (GAO) Draft Report Entitled:
Veterinarian Workforce Actions Are Needed To Ensure Sufficient Capacity
For Protecting Public And Animal Health (GAO-09-178):
The Department of Health and Human Services (HHS) appreciates the
opportunity to review and comment on the General Accountability
Office's (GAO) Draft Report entitled, "Veterinarian Workforce Actions
Are Needed to Ensure Sufficient Capacity for Protecting Public and
Animal Health (GAO-09-178)." We recognize that veterinarians are
essential to protecting the health of the American people.
General Comments:
While the veterinary series is not currently identified as a Department
level Mission Critical Occupation (MCO) due largely to veterinarians
representing less than one (1) percent of the HHS workforce, the
Department plans to review its MCOs in the coming year according to a
more risk based set of criteria.
In an agency as decentralized and diverse as HHS, HHS has taken an
operating-division-centric approach to workforce planning. All
operating and staff division heads are required to have workforce plans
in place for their organizations by September 2009. 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.
The Department however, disagrees with GAO's premise that controlling
zoonotic diseases is solely dependent on the capacity of the
veterinarian workforce. [See comment 1] CDC's zoonotic outbreak
response strategy is robust and is not limited to veterinarians
(DVM/VMD), but also involves persons with other professional degrees
(MPH, PhD, MD). Likewise, veterinarians as well as these professionals
from other disciplines serve in various roles as epidemiologists,
health communicators, laboratorians, animal care technicians, and
public health advisors. In the Technical Comments, we provide
clarification that insufficient veterinarian capacity was not a
workforce challenge in the responses to the monkeypox and West Nile
virus outbreaks. That being said, veterinarians are a valuable resource
at CDC and conducting regular workforce assessments, as recommended in
the GAO report, will ensure that we maintain a sufficient capacity for
outbreak responses. [See comment 2]
The same example holds true in the Office of the Assistant Secretary
for Preparedness and Response (ASPR). ASPR ensures a coordinated
approach to public health emergencies and medical disaster preparedness
and response capability by leading and coordinating the relevant
activities of the HHS Operating Divisions on behalf of, and subject to
the authority of, the Secretary.
ASPR also leads the Department for Emergency Support Function (ESF)
#8 - Public Health and Medical Services (ESF #8), in the event of a
public health emergency or medical disaster, ASPR coordinates the
provision of federal public health and medical assistance (via HHS
assets and ESF#8 partner/supporting agencies, departments,
organizations) to fulfill the requirements identified by the affected
state and local authorities in several areas, including veterinary
and/or animal health issues.
Disaster and emergency response programs are developed by teams of
subject matter experts with a variety of skills and technical
backgrounds (not only veterinarians) including microbiologists,
epidemiologists, physicians, etc., whose training and expertise may
include areas overlapping with those of veterinarians. Veterinarians
may bring additional expertise and should be sought for enhancing the
overall perspective and depth of response planning.
The mission of ASPR's Emergency System for Advance Registration of
Volunteer Health Professionals (ESAR-VHP) program is to establish and
maintain a national network of state-based systems for advance
registration of health professionals for the purpose of verifying the
credentials, licenses, accreditations, and hospital privileges of such
professionals, when, during public health emergencies, the
professionals volunteer to provide health services. This national
network of systems allows for the management of volunteer health
professionals at all tiers of response (local, state, regional, and
federal). All state ESAR-VHP systems are required to have the ability
to register and collect the credentials and qualifications of
veterinarians.
Successful recruitment of veterinarians at NIH poses an additional
hurdle that the report did not identify - board specialization in
laboratory animal medicine. Achieving specialty in laboratory animal
medicine is very difficult (-40% pass rate). Also, very few
veterinarians are interested in accruing additional debt immediately
upon graduation from veterinary school in order to enter a residency
program. [See comment 3]
The Department does not agree with the statement cited on page 21,
referencing the 2007 Science Board report, characterizing the FDA's
Center for Veterinary Medicine (CVM) as being "in a state of crisis."
Given the broad nature of the 2007 Science Board report (i.e., the
report addressed, among other things, CVM's scientific workforce in
general), the suggestion that these conclusions necessarily applied to
CVM's veterinary workforce in particular is a misstatement.
Furthermore, CVM has made great strides in the past few years in
assessing its workforce needs and has implemented effective strategies
for recruiting and retaining the finest workforce possible. The
conclusions of the report are out of date in that they do not take into
account the many workforce-related activities undertaken by CVM since
2007. [See comment 4]
As a participant in the comprehensive Agency Food Protection Plan and
Import Strategy initiatives for protecting the nation's food supply,
CVM has outlined its needs to close the resource gap in order to
function at full potential. In addition, as part of the Animal Drug
User Fee Act (ADUFA) and the Animal Generic Drug User Fee Act (AGDUFA)
analysis, CVM outlined the resources needed to meet statutory review
timeframes and meet industry and public expectations. Finally, this
past year CVM completed a gap analysis for all of its programs to
measure the "gap" between current and optimal performance and the
resources required to close the gap. This ensures CVM resources are
appropriately aligned with current and future needs.
Through an integrated and coordinated process, CVM has built alliances
and partnerships with private and governmental groups and has developed
a recruitment process, which includes attending job fairs at
universities and trade shows. These activities have enabled CVM to
exceed the Agency's Hiring Surge goals.
With the enactment of AGDUFA, CVM is hiring staff to enhance the
performance of the generic new animal drug review process. This will
reduce the time required for safe and effective generic animal drugs to
reach the marketplace, which provides consumers a lower cost
alternative to pioneer drugs. Under AGDUFA, the new hires help FDA to
meet specified performance goals over five (5) years for review of
certain submissions.
Over a five (5) year period (FY2004 - FY2008) CVM hired 56 Full Time
Equivalent Employees, which helped CVM meet or exceed all of its ADUFA
performance goals for applications and submissions each year. In
FY2008, for the first time in over a decade, CVM met and surpassed all
its statutory timeframes.
Moreover, the Department does not agree with the statement in reference
to (Page 21) the report that "veterinarians enter FDA employment
lacking necessary skills and experience to examine the wide variety of
veterinary products that require FDA approval and that FDA needs to
better train its veterinarians to review the many diverse products
under its jurisdiction."
CVM has been very successful in attracting, hiring, and retaining
highly qualified veterinarians. Veterinarians hired by CVM qualify
under a variety of "occupational series" and many of them come to CVM
with significant scientific and clinical experience as well as advanced
educational backgrounds in addition to the Doctor of Veterinary
Medicine degree (e.g., Ph.D., M.P.H., M.B.A., J.D.).
CVM's Succession Plan offers a wide variety of programs for new and
current employees to support them in their efforts to reach their
maximum potential by strengthening and increasing their professional
competencies. The CVM Succession Plan is embedded into a Competency
Model, a tool that helps CVM determine what skills are required in
particular job roles/functions to meet the present requirements of the
organization, and most importantly, the needs of the future.
Furthermore, all CVM employees have access to a robust training program
made available through CVM's Staff College. The CVM Staff College
directs the development and implementation of the competency-based
management and leadership development programs. The extensive
scientific and regulatory curricula that include veterinary drug law
bring CVM veterinarians and scientists up to speed on applying the
appropriate regulatory law to the drug review process of veterinary
products. The Staff College collaborates with outside experts from
industry and the academia such as the University of Maryland,
Baltimore, who keep CVM scientists and veterinary reviewers informed on
emerging science and technology. The Staff College continues to expand
its training initiatives as seen with its collaboration with other FDA
Centers and federal agencies requiring similar skill sets and sharing
similar issues. The CVM Staff College also makes every effort to obtain
accreditation for continuing education credits from the Maryland State
Board for Veterinary Medicine for all scientific and emerging
technology seminars offered.
The Department would like to clarify the statements in reference to
(Page 21) of the report indicating that "Although FDA officials said
the veterinary workforce is sufficient, CVM officials recently told us
that the Center hired 26 veterinarians in 2008 to fill vacancies" (17%
increase in FDA's overall veterinarian workforce) "and it plans to hire
more."
In responding to survey questions provided as part of the GAO study
that focused primarily on the adequacy of the veterinary workforce for
responding to zoonotic disease outbreaks, CVM did indicate that it had
a sufficient number of veterinarians to respond to such occurrences. As
described in the survey question response, FDA's veterinary expertise
resides primarily at FDA headquarters with the greatest concentration
within CVM. If an issue regarding a zoonotic disease arises, the
veterinary resources in the Agency are tapped as needed to address the
issue. This approach has proven to be an effective means for utilizing
this expertise when the need arises. Furthermore, the primary role of
FDA veterinarians in responding to zoonotic disease outbreaks is to
provide technical/scientific advice and to coordinate FDA's activities
with those of other federal, state, and local agencies. In light of
their role as coordinators and consultants in such situations, we
believe FDA has a sufficient number of veterinarians on staff that
could be temporarily reassigned as needed to respond to such an event.
Subsequent to responding to the aforementioned survey question, CVM
proceeded with its ongoing efforts to assess its resource needs to
address changes in its current workforce (e.g., backfill
vacancies/attrition) and to address new workforce demands associated
with newly acquired responsibilities. In particular, during this
timeframe CVM took on a number of new obligations including those
associated with the agency's Food Protection Plan, the FDA Amendments
Act, and the Animal Generic Drug User Fee Act. Therefore, the
significant increase observed in CVM's veterinarian workforce was
primarily in response to these new obligations. CVM plans to continue
its workforce assessment and gap analysis to determine staffing that
may be required to support workload related to other emerging issues
and technologies (e.g., nanotechnology, biotechnology). [See comment 5]
GAO made nine (9) Recommendations for Executive Action to improve the
ability of the federal veterinarian workforce to carry out routine
activities, prepare for a catastrophic event, and respond to zoonotic
disease outbreaks. We offer general comment(s) regarding four (4) GAO
recommendations, which specifically address the Department (pages 48
and 49 of the draft report).
Third, Eighth and Ninth GAO recommendation - that the Secretary of HHS
direct the department's component agencies that employ veterinarians to
conduct regular workforce assessments, and that the Secretary then
conduct a department-wide assessment of HHS's veterinarian workforce to
identify current and future workforce needs (including training and
employee development) and solutions to problems shared by its agencies.
When HHS completes its assessment, it should forward the results to the
Director of OPM.
In a department as decentralized and diverse as HHS, HHS has taken an
operating division centric approach to workforce planning. All
operating and staff division heads are required to have workforce plans
in place for their organizations by September 2009. Once the plans are
in 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.
Fifth GAO recommendation - The Secretaries of Agriculture, Defense, and
Health and Human Services ensure that their component agencies that
employ veterinarians complete pandemic plans that contain the necessary
elements put forth in DHS's continuity of operations pandemic guidance,
including periodically testing, training, and exercising plans.
HHS concurs with this recommendation. Work currently underway at the
HHS Food and Drug Administration (FDA) provides an illustration of how
HHS is addressing this recommendation through one of its component
agencies.
As part of FDA's follow-up and after actions to the October 2008 FDA
Pandemic Influenza Functional Exercise, the agency will be updating its
FDA Pandemic Influenza Emergency Response Plan. The update will include
addressing the necessary elements put forth in DHS's continuity of
operations pandemic guidance. The specific elements that will be
addressed include:
* identifying what essential functions performed by veterinarians must
be performed on-site;
* delegation of authority to three individuals capable of carrying out
each essential function performed by veterinarians;
* contact information for individuals who could assume authority should
essential veterinarian staff and leadership become unavailable; and;
* testing, training, and exercising of plans. Projected date for
completion of updating the plan is September, 2009.
As a side note, the FDA Pandemic Influenza Operational Annex to the HHS
Pandemic Influenza Operational Plan provides extensive guidance to
agency officials on ways to mitigate the impact of high absenteeism and
to ensure continued operations and coverage for essential functions.
Examples from the Annex include:
* Re-employment of annuitants;
* SES Limited Emergency Appointments; and;
* One-year temporary emergency need appointments.
The following are GAO's comments on the Department of Health and Human
Services' letter dated January 14, 2009.
GAO Comments:
1. HHS commented that a premise of our report is that the control of
zoonotic diseases is solely dependent on the capacity of the
veterinarian workforce. Our report does not state this. The scope of
this report, as described in the introduction, was to review the
sufficiency of the federal veterinarian workforce.
2. Our report does not identify the Centers for Disease Control and
Prevention (CDC) as having too few veterinarians to control the 2003
West Nile virus outbreak while also adequately carrying out other
routine activities. However, CDC officials we interviewed who were
involved with the 2003 monkeypox outbreak in Wisconsin told us there
were too few veterinarians during this outbreak.
3. We modified our report to reflect the new information about the
difficulty the National Institutes of Health has recruiting
veterinarians.
4. Our report states conclusions from the FDA Advisory Committee
report: that FDA "cannot fulfill its mission" because its scientific
workforce has remained static while its workload has increased, and
that FDA's Center for Veterinary Medicine (CVM) is "in a state of
crisis." We discussed with an author of the Advisory Committee report
how that report's findings specifically related to veterinarians.
Consequently, our report also states that an author of the FDA Advisory
Committee report told us that veterinarians enter FDA employment
lacking necessary skills and experience to examine the wide variety of
veterinary products that require FDA approval and that FDA needs to
better train its veterinarians to review the many diverse products
under its jurisdiction. HHS further stated that CVM has made great
strides in the past few years in assessing its workforce needs and that
the conclusions of the Advisory Committee report are out of date. Our
report identifies several of the efforts CVM has recently undertaken,
such as hiring additional veterinarians and beginning efforts 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 states, FDA did not tell us how these efforts address the
identified veterinarian skill gap specifically.
5. We modified our report to add a statement that the increase observed
in CVM's veterinarian workforce was primarily in response to new
obligations.
[End of section]
Appendix VI: Comments from the Office of Personnel Management:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
The Director:
United States Office Of Personnel Management:
Washington, DC 20415:
"Our mission is to ensure the Federal Government has an effective
civilian workforce"
[hyperlink, http://www.opm.gov]
[hyperlink, http://www.usajobs.gov]
January 15, 2009:
Ms. Lisa Shames:
Director, Agriculture and Food Safety Issues:
Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Shames:
Thank you for providing the U.S. Office of Personnel Management (OPM)
the opportunity to comment on the Government Accountability Office
draft report, "Veterinarian Workforce, Actions are Needed to Ensure
Sufficient Capacity for Protecting Public and Animal Health." We
appreciate the opportunity to update you about OPM's efforts since this
draft report was prepared.
In relation to statements on pages 6, 7, 13, 25, 29, and 47 concerning
the lack of Governmentwide effort to address shortages in the
veterinarian workforce, OPM has established a team to research and
analyze data to determine the feasibility of issuing a Governmentwide
Direct-Hire Authority (DHA) for veterinarians under our statutory and
regulatory authority. We anticipate completing our study and making a
determination early in 2009. [See comment 1]
Until this study is completed, OPM relies on the individual agencies to
request DHA when they have encountered a severe shortage of candidates
or a critical hiring need for specific occupations. The criteria for
issuing a DHA under 5 CFR 337, which implements the statute at 5 U.S.C.
3304(a)(3), is purposefully stringent. While retaining the public
notice requirement, a DHA bypasses the basic tenets of Federal
competitive examinations, i.e., selections based on merit and veterans'
preference. The data and justification must ensure that all other
alternatives have been tried and proven inadequate to address the
hiring problem, given the suspension of these basic tenets.
The United States Department of Agriculture (USDA), Food Safety and
Inspection Service (FSIS), met this criteria in their DHA request to
fill 150 Veterinary Medical Officer positions at the GS-11 and 12 grade
levels. OPM approved a DHA on November 25, 2008, for these positions
nationwide and in U.S. overseas territories, Puerto Rico, Guam, and the
Virgin Islands. This DHA is available in those locations for which a
recruitment, retention, or relocation incentive is authorized and after
public notice has been available for 21 calendar days. [See comment 2]
In relation to filling USDA positions during a pandemic or other
declared emergency situation, in 2003, OPM approved a DHA for positions
necessary to protect the health or safety of the U.S. food supply. This
DHA allows the USDA to fill temporary and term positions in a variety
of occupational categories, including Veterinary Medical Officers at
the GS-9 through 13 grade levels. This DHA is limited to non-permanent
positions because these excess employees would no longer be needed upon
recovery from the pandemic or termination of the emergency.
We also note that under 5 CFR 213.3102(i)(3), OPM may allow agencies to
temporarily appoint individuals in the excepted service during a
pandemic or emergency situation. OPM permitted agencies to use this
authority to immediately staff emergency positions in the aftermaths of
September 11, 2001, and Hurricanes Katrina and Rita.
Technical comments to the draft report are enclosed. Unless otherwise
noted, the suggested revisions are meant to provide technical accuracy
and conform to terminology applicable to the Federal service.
Please contact Mr. David Cushing on (202) 606-4660 should your office
require additional information.
Again, my thanks to your office for providing this opportunity to
update and clarify information in the draft report.
Sincerely,
Signed by:
Michael W. Hager:
Acting Director:
Enclosure:
The following are GAO's comments on the Office of Personnel
Management's letter dated January 15, 2009.
GAO Comments:
1. We modified our report to reflect OPM's establishment of a team to
determine the feasibility of issuing a governmentwide direct-hire
authority for veterinarians.
2. We modified our report to include OPM's recent approval of USDA's
direct-hire authority request.
[End of section]
Appendix VII: Comments from the Department of Homeland Security:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
U.S. Department of Homeland Security:
Washington, DC 20525:
[hyperlink, http://www.dhs.gov]
January 14, 2009:
Ms. Lisa Shames:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Shames:
RE: Draft Report GAO-09-178, Veterinarian Workforce: Actions Are Needed
to Ensure Sufficient Capacity for Protecting Public and Animal Health.
Thank you for the opportunity to review and comment on the Government
Accountability Office's (GAO's) Draft Report GAO-09-178 entitled
Veterinarian Workforce: Actions Are Needed to Ensure Sufficient
Capacity for Protecting Public and Animal Health. We concur with the
recommendation that applies to the Department of Homeland Security. We
have included comments and additional recommendations for your
consideration.
General Comments:
GAO states that they are making several recommendations to improve the
federal government's ability to meet its routine veterinary
responsibilities.
The report states: "The federal government has undertaken efforts to
identify the veterinarian workforce needed during two catastrophic
events-a pandemic and multiple intentional introductions of foot-and-
mouth disease. However, these efforts are limited in their usefulness
because they are either incomplete, based on an infeasible planning
assumption, or lacking adequate data." DHS concurs in part, and
proposes the following additional language:
"We recommend that the federal government enhance efforts to identify
the veterinary workforce. This may be achieved through an OPM pursuit
of a multi-department assessment of veterinary manpower requirements to
include an all-hazards approach with regards to requirements for
prevention, preparation, response, and recovery."
In section, Pandemic: the report states, " Four of the five agencies we
reviewed-APHIS, FSIS, ARS, and FDA - have developed plans that identify
how they will continue essential functions, including those that
veterinarians perform, during a pandemic that severely reduces the
workforce. However, each plan lacks elements that DHS has deemed
necessary." DHS concurs in part, and proposes the following additional
language:
"We recommend that agencies develop plans that identify how they will
continue essential functions during additional catastrophic events,
taking into consideration the potential for greater than the estimated
40 percent absenteeism during a pandemic. We also recommend, that once
an overall government-wide veterinary manpower needs determination is
made, that the government directs its efforts to developing effective
recruitment and retention programs."
Under the section, Foot-and-mouth disease outbreak the report refers to
an infeasible planning assumption that the United States would
slaughter all potentially exposed animals as it has during smaller
outbreaks of foreign animal diseases, and that the resultant workforce
estimates (required to implement the infeasible planning assumption)
are not relevant. DHS does not concur that the workforce estimates are
not relevant; the current policy requires slaughter of all potentially
exposed animals and therefore the projected manpower requirement is
relevant. [See comment 1]
DHS agrees that this approach may be infeasible for a large foot-and-
mouth outbreak. Procedures that accurately describe a catastrophic foot-
and-mouth disease incident and appropriate response would be
beneficial. DHS proposes that the following language be deleted:
"However, DHS and USDA officials consider this approach infeasible for
such a large outbreak and told us that although the planning effort is
a valuable exercise for understanding the enormity of the resources
needed to respond to such an event, any workforce estimates produced
from this effort are not relevant."
DHS proposes that the following language is inserted:
"Even though DHS and USDA officials consider this approach infeasible
for a catastrophic foot-and-mouth disease incident, the planning effort
is necessary because the slaughter of all potentially exposed animals
remains the currently accepted response to a foot-and-mouth disease
outbreak."
In the chart on Homeland Security, column on Examples of Concerns, DHS
proposes that the following language be deleted: [See comment 2]
"Pool of candidates with the skills necessary to help plan for the
defense of the nation's food supply is small; office lacks the
resources to offer salaries sufficient to attract such veterinarians."
DHS proposes that the following language is inserted:
"Veterinary expertise contributes to agriculture, animal health and
human health. The agency has too few veterinarians to effectively
develop the capabilities to respond to catastrophic food, agriculture,
and veterinary events."
Following that chart, the report states that retirement within the next
3 years would be approximately 27 percent which would exacerbate the
shortage of veterinarians in the federal agencies. DHS concurs and
proposes the following additional language:
"Based on these figures, we recommend that the government direct its
efforts to develop effective recruitment and retention programs."
DHS Office of Health Affairs (OHA) submits the following background
information. OHA stood up on March 31, 2007. The OHA mission includes
developing a robust biological threat awareness capacity and
information sharing with food and agriculture communities, enhancing
local response capabilities for agro-defense and collaborating with
other federal agencies to prevent introduction of foreign animal and
plant pathogens into this country. In order to accomplish this mission,
OHA, filled senior level veterinary positions first with the intention
of filling entry level positions later. When this is accomplished, OHA
average salaries will be within range of other agency veterinary
positions in the Washington D.C. metropolitan area.
Referring to the paragraph after Figure 3 and Note: the report states:
"Some agencies, such as those within HHS and the Department of Veterans
Affairs, can augment base salaries for veterinarians using special
statutory authorities." DHS concurs and proposes the following
additional language:
"OPM should consistently apply incentive programs across all agencies
for recruitment and retention of veterinarians."
Technical comments have been provided under separate cover.
Sincerely,
Signed by:
Jacqueline L. Lacasse, for:
Jerald E. Levine:
Director:
Departmental GAO/OIG Liaison:
The following are GAO's comments on the Department of Homeland
Security's letter dated January 14, 2009.
GAO Comments:
1. DHS stated that current policy requires slaughter of all potentially
exposed animals and, therefore, the projected manpower requirement is
relevant. We agree that this estimate is relevant to this method. As
our report notes, the United States has used this "stamping out" method
in the past for eradicating smaller outbreaks of foreign animal
diseases. However, DHS and USDA officials told us, and DHS reiterates
in its comments, that stamping out is infeasible for a large-scale
outbreak of foot-and-mouth disease. Therefore, we do not agree that
this estimate is relevant to a catastrophic outbreak, which was the
scope of this section of our report. Indeed, as we note, DHS and USDA
officials we interviewed during the course of our review told us that
the estimate was not relevant.
2. We modified our report to clarify the Office of Health Affairs'
concerns about the sufficiency of its veterinarian workforce.
[End of section]
Appendix VIII: Comments from the Department of the Interior:
United States Department of the Interior:
Office Of The Secretary:
Washington, DC 20240:
January 15, 2009:
Ms. Lisa Shames:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, N.W.
Washington, D.C. 20548:
Dear Ms. Shames:
Thank you for providing the Department of the Interior the opportunity
to review and comment on the draft Government Accountability Office
Report entitled, "Veterinarian Workforce: Actions Are Needed to Ensure
Sufficient Capacity for Protecting Public and Animal Health" (GAO-09-
178).
The GAO staff is to be commended for conducting a well-researched
examination of the nation's veterinary workforce capacity. We agree
with the recommendations and wish to emphasize the importance of
including wildlife disease expertise and resources into the national
strategy protecting human and animal health. We believe that additional
emphasis needs to be placed on determining capacity, including
expertise, training and resources in the area of wildlife disease that
is needed at the Federal level to support emergency response and other
needs.
The enclosure provides comments from the Department of the Interior. We
hope these comments will assist you in preparing the final report. If
you have any questions, or need additional information, please contact
Dr. Susan Haseltine (703) 648-4050 or Dr. Patricia Bright at (703) 648-
4058.
Sincerely,
Signed by:
Kameran L. Onley:
Acting Assistant Secretary for Water and Science:
Enclosure:
Comments from the Department of the Interior on the U.S. Government
Accountability Office (GAO) draft report entitled, "Veterinarian
Workforce: Actions Are Needed to Ensure Sufficient Capacity for
Protecting Public and Animal Health" Report Number GAO-09-178:
We agree with the recommendations and wish to emphasize the importance
of including wildlife disease expertise and resources into the strategy
for protecting human and animal health.
DOI's veterinarians and disease experts bring to bear a diverse array
of scientific expertise that compliment and enhance the work of other
agencies. DOI leadership in wildlife health activities helps assure a
truly integrated approach to protecting the health of human and wild
and domestic animals. A comprehensive approach that includes wildlife
is critical for facilitating early detection and timely intervention of
emerging infectious diseases, which can impact humans.
Emerging zoonotic diseases such as the West Nile Virus and Ebola
appeared first in wildlife, gaining a foothold in wildlife populations
before spilling over into humans. Interior wildlife disease
surveillance and infrastructure proactively address wildlife disease.
The Department of Homeland Security has expressed concern that wildlife
could be used by terrorists as potential "delivery systems" for the
introduction of pathogens into human and domestic animal populations.
Current DOI wildlife disease activities and research such as DOI's
Avian Influenza surveillance in migratory wild birds could also
potentially detect intentionally introduced pathogens and/or help
discern naturally occurring disease events from intentional
introductions.
A related topic that is not addressed in the GAO report but that we
feel is key to protecting human, animal, and ecosystem health as well
as economic interests within the U.S. borders is the detection and
prevention of non-native invasive infectious agents from entering U.S.
borders via imported wildlife. The recent Monkey Pox outbreak
illustrates how quickly an infectious disease from imported animals can
be disseminated around the country. Interior's FWS port inspection
program is key to detecting and containing pathogens before an imported
animal enters the country providing the best opportunity for preventing
disease outbreaks.
During the importation process a single sick animal has the potential
to infect a large number of animals in the same shipment. In addition,
the mixing of animals during the importation process also provides an
ideal environment for "new" diseases to develop. Diseases such as
Ebola, HIV/AIDS and Mad Cow disease all developed as a result of
pathogen moving from its normal host species into a new species.
To adequately address these areas Interior needs to evaluate workforce
needs that could support: (1) Research - including identifying and
developing alternative methods such as risk assessments for screening
animals when diagnostic tests are not available or not feasible, (2)
testing and/or necropsying suspect animals when appropriate, and (3)
providing the U.S. Ports of Entry and Border Offices additional
personnel and training to detect and sample for disease in wildlife
species.
At the Federal level we recommend that a part of the workforce planning
be focused on capacity building including specialized,
multidisciplinary training for wildlife veterinarians including
clinical diseases of wildlife, ecology, wildlife epidemiology, and
environmental health. We also recommend that predictive disease models,
such as those developed for Foot and Mouth disease and plague, include
wildlife species when appropriate. As the GAO report correctly points
out, models that address only captive animals will be inadequate.
Disease prevention and control methods developed for use in
captive/controlled agriculture will likely be ineffective and not
feasible if free ranging wildlife are involved in the outbreak. For
that reason it is critical to have wildlife disease specialists
including ecologists, and epidemiologists involved in the development
of the disease models and the response plans.
[End of section]
Appendix IX: GAO Contact and Staff Acknowledgments:
GAO Contact:
Lisa Shames, (202) 512-3841, or shamesl@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, Charles Adams, Assistant
Director; Mary Denigan-Macauley; Jennifer Gregory; Terry Richardson;
Benjamin Shouse; and Michelle K. Treistman made key contributions to
this report.
Other important contributors included Kevin Bray; Candace Carpenter;
Nancy Crothers; William Doherty; Joyce Evans; Brian Friedman; Katheryn
Hubbell; Judith Kordahl; Jena Sinkfield; and Gloria Sutton.
[End of section]
Footnotes:
[1] GAO, Humane Methods of Handling and Slaughter: Public Reporting on
Violations Can Identify Enforcement Challenges and Enhance
Transparency, [hyperlink, http://www.gao.gov/products/GAO-08-686T]
(Washington, D.C.: April 17, 2008).
[2] GAO, High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-09-271] (Washington, D.C.: January
2009).
[3] GAO, Human Capital: Key Principles for Effective Strategic
Workforce Planning, [hyperlink, http://www.gao.gov/products/GAO-04-39]
(Washington, D.C.: Dec. 11, 2003).
[4] GAO, Human Capital: Transforming Federal Recruiting and Hiring
Efforts, [hyperlink, http://www.gao.gov/products/GAO-08-762T]
(Washington, D.C.: May 8, 2008).
[5] GAO, Emergency Preparedness and Response: Some Issues and
Challenges Associated with Major Emergency Incidents, [hyperlink,
http://www.gao.gov/products/GAO-06-467T] (Washington, D.C.: Feb. 23,
2006).
[6] See GAO-04-39; GAO, Human Capital: Insights for U.S. Agencies from
Other Countries' Succession Planning and Management Initiatives,
[hyperlink, http://www.gao.gov/products/GAO-03-914] (Washington, D.C.:
Sept. 15, 2003).
[7] See [hyperlink, http://www.gao.gov/products/GAO-09-271].
[8] See GAO, Older Workers: Federal Agencies Face Challenges, But Have
Opportunities to Hire and Retain Experienced Employees, [hyperlink,
http://www.gao.gov/products/GAO-08-630T] (Washington, D.C.: April 30,
2008).
[9] GAO, Homeland Security: Much Is Being Done to Protect Agriculture
from a Terrorist Attack, but Important Challenges Remain, [hyperlink,
http://www.gao.gov/products/GAO-05-214] (Washington, D.C.: Mar. 8,
2005).
[10] USDA, Office of Inspector General, Great Plains Region, Audit
Report: Evaluation of FSIS Management Controls Over Pre-Slaughter
Activities, 24601-0007-KC (Washington, D.C.: November 2008).
[11] GAO, Humane Methods of Slaughter Act: USDA Has Addressed Some
Problems but Still Faces Enforcement Challenges, [hyperlink,
http://www.gao.gov/products/GAO-04-247] (Washington, D.C.: Jan. 30,
2004).
[12] FDA Science Board, Subcommittee on Science and Technology, FDA
Science and Mission at Risk, a special report prepared at the request
of the Food and Drug Administration (November 2007).
[13] See [hyperlink, http://www.gao.gov/products/GAO-04-39];
[hyperlink, http://www.gao.gov/products/GAO-03-914].
[14] E.g. 38 U.S.C. § 7405; 42 U.S.C. § 209(f).
[15] 37 U.S.C. § 303.
[16] See [hyperlink, http://www.gao.gov/products/GAO-08-762T].
[17] For more information on why the United States has not used
vaccines, see [hyperlink, http://www.gao.gov/products/GAO-05-214].
[18] To understand the issues and our recommendations for helping the
United States implement an animal identification system, see GAO,
National Animal Identification System: USDA Needs to Resolve Several
Key Implementation Issues to Achieve Rapid and Effective Disease
Traceback, [hyperlink, http://www.gao.gov/products/GAO-07-592]
(Washington, D.C.: July 6, 2007).
[19] Insufficient laboratory resources also affected veterinarians' and
other responders' abilities to control outbreaks in a timely manner,
according to numerous federal and state agency officials.
[20] CDC officials told us that additional veterinarians may have been
beneficial in getting more horses vaccinated. In addition, they said
difficulties implementing effective mosquito control programs and
getting residents to adopt effective personal protection could also
have contributed to a higher number of animal and human infections.
[21] See [hyperlink, http://www.gao.gov/products/GAO-06-467T].
[22] GAO, OPM's Central Personnel Data File: Data Appear Sufficiently
Reliable to Meet Most Customer Needs, [hyperlink,
http://www.gao.gov/products/GAO/GGD-98-199] (Washington, D.C.: Sept.
30, 1998).
[23] To learn more about federal guidance for pandemic planning, see
[hyperlink, http://www.pandemicflu.gov/plan/federal/index.html].
[24] GAO has a separate review under way that is looking at federal
agency plans for protecting the workforce while maintaining their
essential functions during a pandemic.
[End of section]
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