MGD Q&A Responses 6.11-6.17.pdf

McGovern-Dole FY2026 Notice of Funding Opportunity

Questions and Answers

6/11/26-6/17/26

1. The guidance for the Processing or Packaging section (7 CFR 1599.5(d)(2)(viii)) requires applicants to describe any reprocessing or repackaging of requested U.S.

commodities prior to distribution, sale, monetization, or barter. If an applicant intends to process U.S. commodities in the recipient country to produce a nutritionally dense product for distribution, should the costs associated with that in-country processing be charged to the U.S. commodity budget or to the Local and Regional Procurement budget?

A: If an Applicant intends to process U.S. commodities in the recipient country to produce a nutritionally dense product for distribution, this would be considered part of the U.S. commodity use, and the associated costs should not be considered a Local and Regional Procurement (LRP) budget.

2. McGovern-Dole program guidance requires recipients to monitor commodity management at the school level. For programs proposing operation in very high numbers of schools, conducting monthly in-person physical inventory visits to every targeted school may not be operationally feasible without a substantial increase in staffing costs. Would USDA consider remote monitoring mechanisms as acceptable alternatives or complements to in-person physical inventory visits?

A: USDA’s FY 2026 McGovern-Dole NOFO emphasizes in multiple places the importance of “clear oversight and monitoring of activities to reduce fraud, waste, and abuse” and requires applicants to include a routine project monitoring plan in their application. The NOFO does not specify a monitoring frequency or specifics on use of remote monitoring mechanisms. Applicants are expected to propose routine and effective commodity management monitoring. Applications that combine strategic in-person visits with remote monitoring mechanisms—such as but not limited to digital photo evidence of inventories, electronic data submissions, and virtual check-ins—are acceptable, provided they are justified, documented in the Monitoring & Evaluation section, and ensure data integrity, transparency, and oversight in compliance with program requirements.

3. Given the volatility in global markets, could USDA clarify whether commodity costs and ocean freight costs may be adjusted during negotiations and/or over the life of the award?

A: Yes, commodity and freight budgets can be adjusted during negotiation and will reflect both updated price estimates and take into account a reasonable degree of inflation over time to ensure the commodity and freight budget amounts are sufficient over the life of the award. While USDA/FAS has sometimes made cost amendments during the life of awards to account for unforeseeable commodity and ocean freight shortfalls, this is rare and not guaranteed. Under 48 CFR 470.201, USDA/FAS seeks the lowest landed cost for commodities and related freight at the time when commodities and transport are purchased over the course of the award.

Applications should include up-to-date cost estimates.

4. The NOFO recommends 8–14 activities. Could you please clarify whether applicants may merge or integrate activities where appropriate? For example, would it be acceptable to include the provision of energy-saving stoves under a broader activity such as Building/Rehabilitation: Kitchens?

A: The NOFO does not prohibit merging or integrating activities if it makes sense for project design - is clearly described, measurable, and aligns with McGovern-Dole objectives.

5. Could USDA provide further guidance on how to estimate commodity prices for the following three (3) commodities? Per USDA’s previous guidance, we have consulted the Agricultural Marketing Service (AMS) reports. However, none of these commodities appear in the price lists, though they are on the approved list of commodities in the NOFO in Appendix H. (Fortified Rice (2/7 Long Grain, Well Milled), Super Cereal Plus, Nonfat, Non-fortified Milk)

A: Applicants should follow USDA’s guidance in Appendix H of the NOFO by sourcing commodity prices from the Agricultural Marketing Service (AMS) market data. If a commodity is not directly listed, applicants may use the closest AMS equivalent or latest procurement data, documenting the rationale and source in your budget justification.

6. Thank you for clarifying that applicants are not required to identify disaggregates or provide disaggregated targets in the proposal for LRP indicators or any proposed indicator. Could USDA please confirm whether this guidance applies to all proposal-stage indicators, including standard MGD indicators with required disaggregates in the McGovern-Dole Indicator Handbook, such as MGD 30?

Specifically, should applicants provide only aggregate annual and life-of-project targets for each indicator in the proposal, while omitting disaggregated targets? Or are applicants still expected to include the full set of Indicator Handbook disaggregates for certain standard indicators at the proposal stage? If disaggregated targets are not required, should applicants still include selected key disaggregates where they help clarify linkages between activities, participant groups, and expected results?

A: USDA confirms that Applicants are not required to identify disaggregates or provide disaggregated targets for any indicator in the application. Applicants are required to provide aggregate annual and life-of-project targets for each indicator in the application. Applicants are not prohibited from providing selected key disaggregates where they help clarify linkages between activities, participant groups, and expected results, within the page limit of the performance indicator table.

7. The organizational capacity and staffing section has a page limit of 8 pages. The current page allocation (6 for staffing plan, 1 for organizational chart, and 1 for registration) does not allow any space to provide the following information that the NOFO also requires in this 8-page limit:

- Applicants must clearly describe organizational capabilities to develop, manage, implement, monitor, report, and provide for accountability and sustainability for the proposed project in the target country. Applicants must also describe their technical capabilities and experience implementing food assistance projects (e.g., experience with food distribution, nutrition, logistics and procurement) and education/literacy projects, including experience within the country.

-Applicants must describe their organization’s capacity to mitigate and manage risks, including the following information:

-An explanation of the project’s structure and process for assessing and managing the risks of fraud, waste, abuse or other misuse of U.S. Government resources;

- A summary of the policies and training the Applicant will have in place to mitigate risk of fraud, waste, and abuse. Examples may include but are not limited to conflict-of-interest policies, whistleblower protections, and ethics training. If training is proposed, the Applicant must indicate who will receive the training and the frequency of any refresher training;

- A brief description of on the ground compliance monitoring and its planned frequency;

and -An explanation of how they will ensure that any Subrecipients have the necessary internal controls in place to mitigate the risk of fraud, waste and abuse per 2 CFR 200.332.

Can USDA please confirm that applicants may allocate the remaining six pages to cover both organizational capacity and staffing at their discretion?

A: Yes, Applicants may allocate the six-page Staffing Plan to cover both the organizational capacity and staffing requirements at their discretion. Applicants may also utilize unused space from the in-country registration page, if available, to continue addressing this material.

8. In FAIS, can USDA please clarify under which category of file type (performance indicators, evaluation plan, or project framework) should the Monitoring and Evaluation sections be submitted? Our interpretation of NOFO requirements is that these documents should be submitted as one attachment. Please confirm or clarify if they should be submitted as individual attachments with the following breakdown: 1) Project-Level Results Framework - Project Framework file type, 2) Performance Indicator Table - Performance Indicators file type, 3) M&E Brief - Evaluation Plan file type

A: USDA/FAS recommends submitting the three Monitoring & Evaluation components as separate attachments in FAIS, each placed under the specific FAIS category that best aligns with its content. For example:

• Project‑Level Results Framework -> uploaded as the Project Framework attachment

• Performance Indicator Table -> uploaded as Performance Indicators attachment

• Narrative M&E brief -> uploaded as Evaluation Plan.

9. In FAIS, one of the required attachments is a CV. Our understanding is that the Key Personnel CV should be included as part of the Organizational Capacity and Staffing section. Can USDA please confirm?

A: Applicants are only required to submit the CV of the Project Lead at the application stage, and reviewers will take the CV into account when reviewing the Organizational Capacity and Staffing section. The required CV can be uploaded into FAIS under the “Other Attachments” section, separate from the Organizational Capacity and Staffing narrative, and the CV is not counted within that section’s page limit.

10. In FAIS, there is only the option for SF424 as a file type. Can USDA please confirm that applicants may submit SF424 and SF424a as a combined document under this file type?

A: USDA’s FAIS portal offers a single attachment slot labeled “SF‑424”, which is intended to encompass both the SF‑424 (Application for Federal Assistance) and the SF‑424A (Budget Information) forms. Applicants have the option to submit a combined document under this file type.

11. FAIS indicates "Single Audit" as a required attachment. Can USDA please clarify what should be submitted as the Single Audit attachment?

A: For all attachments that FAIS is indicating as “REQUIRED” for submission, but are not requirements per the NOFO, such as the “Single Audit”, applicants should submit a blank document that allows the application to move forward to submission.

Please note that USDA/FAS removed the need for applicants to submit their most recently completed “Single Audit” (defined as necessary for those organizations subject to audit under 2 CFR 200 Subpart F - those that expended $1 million or more in federal awards during the last fiscal year) with the intention of reducing the burden on applicants of providing a document that USDA/FAS can locate independently on the Federal Audit Clearinghouse.

Per the NOFO Section 5.3 on Submission Instructions (page 33), applicants are advised to make their submissions 1-2 days before the deadline in case of computer problems.

12. FAIS does not offer a "Plan of Operation," "Organizational Capacity and Staffing," or "Commodity Management" option for file types. Should these proposal sections be submitted as a "generic" attachment?

A: Yes, the “Plan of Operation,” “Organizational Capacity and Staffing,” or “Commodity Management” sections can be submitted as generic attachments using the “Other Attachments” slot (sometimes labeled “Supporting Documents”) in FAIS. To ensure clarity for reviewers, applicants should label each file appropriately (e.g. “Plan of Operation,” “Org Capacity & Staffing,” “Commodity Management”) before uploading.