The Lacuna Project

lacuna (n.) a gap in a record where something should be

Independent research. Not affiliated with any government, agency, or company.

Agency

U.S. Department of Agriculture

Documented positions

  • Courtney Knupp: Senior policy adviser to the Secretary and Deputy Secretary; chief-of-staff roles, U.S. Department of Agriculture (earlier – present); Director of global supply chain, National Security Council (earlier – 2026-09); Chief executive, United Soybean Board (2026-10-01 – present)

Documented money flows

Findings that rest on exhibits naming this entity

  • AGR-1.12: FDA and USDA published a joint request for information on 25 July 2025 stating there is "no single, universally accepted definition" of ultra-processed food. The comment period was extended to 23 October 2025.
  • AGR-1.13: A proposed federal definition of ultra-processed food went to OMB review as a white paper on 3 August 2026, according to OIRA's review record, and had not been released as of 13 October 2026. The Philadelphia Inquirer, carrying a Bloomberg article, reported on 10 August 2026 that food-company executives lobbied the Trump administration to delay or block its release, according to people familiar with the discussions. STAT reported on 22 October 2026 that the planned release was canceled at the last minute.
  • AGR-2.9: The 2003 WHO/FAO report on diet and chronic disease set a population goal of under 10 percent of energy from free sugars and described that goal as controversial. In March and April 2003, according to AP, CSPI and the Guardian, the Sugar Association's president wrote to WHO that the association would ask Congress to challenge U.S. funding, a food-industry coalition asked HHS Secretary Tommy Thompson to intervene on 20 March, and Senators Larry Craig (R-ID) and John Breaux (D-LA) made a further request to Thompson on 28 March. AP also reports that the senators wrote Agriculture Secretary Ann Veneman.
  • AGR-3.1: ERS reports $27.9 billion in direct government payments to farm operations in 2025 and forecasts $47.4 billion for 2026, the largest nominal total in its series, which begins in 1933. The payments were 7.9 percent of net farm income in 2024 and are forecast at 29.9 percent in 2026.
  • AGR-3.2: From 2003 through 2011 USDA paid more than $46 billion in direct payments based on historical acreage and production, and $10.6 billion of it went to producers who did not grow the associated crop in the payment year.
  • AGR-3.3: GAO reported that federal crop insurance premium subsidies in 2022 totaled $12 billion, averaged about 62 percent of premiums, and were set by Congress regardless of income. RMA’s table for crop year 2024 shows $8.89 billion, 63 percent of premiums.
  • AGR-3.4: In 2022 the government paid private insurance companies about $3.7 billion to deliver crop insurance, and from 2011 through 2022 their return on retained premiums averaged 16.8 percent against a market-based 10.2 percent.
  • AGR-3.5: In FSA’s calendar-2025 payment files, summed by payee name and address, the top 10 percent of 1,030,230 payees received 64.2 percent of $24.39 billion and the bottom half received 3.6 percent.
  • AGR-3.6: ERS reports that farms with at least $1 million in gross cash farm income received nearly 11 percent of commodity program payments in 1991 and 34 percent in 2015, and describes the shift as similar to the shift in production value.
  • AGR-3.7: Crop insurance premium subsidies and indemnities have no payment limit and sit outside the actively engaged in farming test. For the programs that apply the test, GAO reported in 2004, 2013 and 2020 that the management standard is broad and that FSA’s compliance reviews were late or not monitored.
  • AGR-3.8: In 2024 nine program crops received 84 percent of crop insurance premium subsidy and fruit, vegetable and tree-nut crops 7 percent, while the two groups made up 56 percent and 23 percent of crop cash receipts. FSA’s table of 2021 ARC and PLC payments lists no fruit or vegetable.
  • AGR-3.9: In 2019 the Market Facilitation Program paid specialty crops about 2 percent and nonspecialty crops about 94 percent of $14.4 billion. USDA’s 2025 Farmer Bridge Assistance program is $11 billion with $1 billion more available, and its program for specialty crops that the first did not cover is $1.625 billion.
  • AGR-3.10: USDA distributed over $23 billion in Market Facilitation Program payments for 2018 and 2019 to more than 715,000 producers. GAO estimated that 2019 payments to corn producers were about $3 billion more than USDA’s own estimate of trade damage to corn.
  • AGR-3.11: FSA paid $163.4 million of Market Facilitation Program payments to 883 high-income farms and 1,164 farmers with adjusted gross incomes over $900,000, and discontinued its 2019 compliance review. USDA’s inspector general estimated that FSA overpaid 150,313 producers by a total of more than $57.2 million, about 0.25 percent of the $23.18 billion paid.
  • AGR-3.12: P.L. 119-21 (4 July 2025) set higher statutory reference prices from crop year 2025, allocated up to 30,000,000 additional base acres, raised the payment limit from $125,000 to $155,000 with inflation indexing, and defined partnerships, S corporations and LLCs as qualified pass-through entities. It also raised the premium subsidy for area-based crop insurance coverage from 65 to 80 percent and raised five other premium support rates by 3 to 5 percentage points.
  • AGR-3.13: CBO estimated that Title I of P.L. 119-21 reduces outlays by $121 billion over fiscal years 2025 to 2034, with nutrition changes reducing outlays by $187 billion and other agriculture subtitles adding a net $66 billion. CRS reports that the nutrition title makes up about 72 percent of farm bill mandatory spending in CBO’s February 2026 baseline.
  • AGR-3.14: Economists, including one at ERS, found that farm subsidies had modest and mixed effects on commodity prices and negligible effects on consumer food prices, and attributed growth in high fructose corn syrup use to sugar import policy more than to corn subsidies. ERS reports that the farm share of each dollar spent on domestically produced food was 11.8 cents in 2024.
  • AGR-3.15: Original quarterly lobbying reports naming the farm bill in an activity description came from 716 clients in 2018, 1,003 clients in 2024 and 746 clients in 2025.
  • AGR-3.16: No public USDA or GAO tabulation combines direct payments, crop insurance premium subsidies, indemnities and ad hoc aid by recipient decile or by crop group.
  • AGR-4.1: The 1990 statute requires the Dietary Guidelines every five years, "based on the preponderance of the scientific and medical knowledge," and does not mention advisory committees, their membership or conflicts of interest. The Congressional Research Service records that appropriations language in 1980 and 1987 directed the external review and advisory group that became the standing committee.
  • AGR-4.3: In April 1991 USDA postponed the Food Guide Pyramid after the National Cattlemen's Association and other producer groups protested, and released a revised design one year and one day later. Nestle's account describes the Secretary's stated reason as "widely disbelieved." USDA's own 2011 chronology does not mention the postponement.
  • AGR-4.4: In 2015 the House Appropriations Committee wrote that the advisory committee's report "included extraneous factors and policy recommendations that are outside of the statutory requirement, such as agriculture production practices including sustainability, taxes, food labeling and marketing policies." Public Law 114-113 section 734 then barred release of the 2015-2020 guidelines unless each guideline "is based on significant scientific agreement" and "is limited in scope to nutritional and dietary information." On 6 October 2015 Secretaries Vilsack and Burwell announced that sustainability would not be in the guidelines "because this is a matter of scope."
  • AGR-4.5: The 2015 advisory committee recommended dropping the 300 mg per day dietary cholesterol limit, and the 2015-2020 guidelines dropped it. Both kept a ceiling of 10 percent of calories from saturated fat.
  • AGR-4.7: A peer-reviewed analysis found that 19 of the 20 members of the 2020 advisory committee (95 percent) had at least one tie to an industry actor, counting 720 relationship-year instances, most of them research funding and board seats. The Nutrition Coalition funded the study, and Teicholz is a co-author.
  • AGR-4.8: For the 2020 committee the USDA ethics official found no entry on any of the 20 members' OGE Form 450 that would prevent appointment. For the same cycle HHS and USDA declined NASEM's recommendations for an external third-party screener (cost and time) and a public list of provisional appointees (privacy). A coalition letter states that OGE Form 450 is exempt from public disclosure.
  • AGR-4.9: NASEM's 2017 reports found the selection process "thoughtful" and not transparent, said conflicts of interest cannot always be eliminated entirely on a balanced panel, recommended public disclosure of how conflicts are identified and managed, and found the step from committee report to guidelines in need of public explanation. Presenters raised USDA's role in both supporting agriculture and managing the guidelines.
  • AGR-4.10: The 2020 advisory committee recommended lowering the added-sugars limit from 10 to 6 percent of calories and the limit for men's alcohol intake from two drinks to one. HHS and USDA did not adopt either.
  • AGR-4.11: The 2025 advisory committee disclosed its members' interests collectively, on voluntary ICMJE forms covering the prior 12 months, and stated: "Because its work is collective, the Committee provided its disclosures collectively rather than individually." A letter signed by CSPI and other organizations on 27 January 2023 had asked for individual disclosure.
  • AGR-4.12: In January 2026 HHS and USDA replaced the 2025 advisory committee report as the evidence base with a review by nine external reviewers selected through a federal contracting process. The departments' disclosure table lists funding or fees from beef, pork or dairy organizations for four of the nine.
  • AGR-4.13: No GAO report in the record evaluates the selection or conflict-of-interest process for the Dietary Guidelines Advisory Committee. GAO-24-106130 covers coordination of interagency nutrition research.
  • AGR-5.1: USDA data show that the four largest packers' share of steer and heifer slaughter rose from 36 percent in 1980 to 85 percent in 2019, and their share of hog slaughter rose from 34 percent to 67 percent. In 2019 the four largest firms held 53 percent of broiler chicken and 55 percent of turkey production.
  • AGR-5.2: USDA's Economic Research Service attributes the rise in beef and pork packing concentration mostly to larger plants and says mergers played a limited role. ERS also reports that the farm-to-wholesale beef price spread doubled between 2015 and 2019. GAO estimated that fed cattle prices in 2013 to 2015 may have been about 9 percent higher in areas with less packer concentration than in areas with more, and stated that this evidence alone does not imply anticompetitive or improper behavior.
  • AGR-5.3: USDA rules defining unfair practices under the Packers and Stockyards Act were proposed in 2010, limited by a 2011 appropriations rider, issued in 2016, withdrawn in 2017, finalized in 2020, expanded in 2024 and, for broiler grower payments, delayed in 2026 to December 31, 2027. Administrations and Congresses of both parties acted at each step, and White Houses of both parties described meat processing as insufficiently competitive in January 2022 and September 2026.
  • AGR-5.4: Pilgrim's Pride pleaded guilty to a conspiracy to fix prices and rig bids for broiler chicken products and was sentenced to a criminal fine of $107,923,572 on February 23, 2021. ERS reports that individual defendants in the DOJ broiler cases were acquitted in jury trials. Tyson's filing states that the first civil broiler antitrust jury trial ended in a verdict for the defendants.
  • AGR-5.10: Two seed companies accounted for 72 percent of planted U.S. corn acres and 66 percent of soybean acres in 2018-20. USDA's 2023 seed competition report counts Bayer, Corteva, ChemChina and BASF as owning 95 percent of corn, 84 percent of soybean and 74 percent of cotton plant intellectual property.
  • AGR-5.11: In 2017 and 2018 antitrust agencies cleared ChemChina-Syngenta, Dow-DuPont and Bayer-Monsanto only with divestitures. DOJ called the roughly $9 billion Bayer divestiture to BASF the largest merger divestiture ever required by the United States.
  • AGR-5.13: The average price farmers paid for seed rose 270 percent from 1990 to 2020, against 56 percent for commodity prices and 463 percent for crops grown mostly with genetically modified traits. ERS states that the evidence is mixed on whether concentration caused the rise.
  • AGR-5.19: The Land Report reported in January 2021 that Bill Gates held 268,984 acres in 19 states, 242,000 of them farmland, which is about 0.027 percent of the 896.6 million acres of U.S. land in farms in 2020.

Exhibits naming this entity

  • Exhibit 533 22 October 1990. U.S. Congress: National Nutrition Monitoring and Related Research Act of 1990, sec. 301 (7 U.S.C. 5341): Dietary Guidelines for Americans
  • Exhibit 536 28 March 2023. Congressional Research Service: The Dietary Guidelines for Americans: Overview and Considerations for Congress (R47488)
  • Exhibit 537 1993. Marion Nestle, International Journal of Health Services 23(3):483-496: Food Lobbies, the Food Pyramid, and U.S. Nutrition Policy
  • Exhibit 538 June 2011. USDA Center for Nutrition Policy and Promotion: A Brief History of USDA Food Guides
  • Exhibit 539 14 July 2015. U.S. House Committee on Appropriations: House Report 114-205, Agriculture, Rural Development, FDA and Related Agencies Appropriations Bill, 2016
  • Exhibit 540 18 December 2015. U.S. Congress: Consolidated Appropriations Act, 2016, P.L. 114-113, Division A, secs. 734-735
  • Exhibit 541 31 March 2015. U.S. House of Representatives (Members of Congress): Letter from Reps. Hartzler, Conaway and other House members to Secretaries Vilsack and Burwell
  • Exhibit 542 6 October 2015. Secretaries Vilsack (USDA) and Burwell (HHS): 2015 Dietary Guidelines: Giving You the Tools You Need to Make Healthy Choices
  • Exhibit 543 February 2015. 2015 Dietary Guidelines Advisory Committee: Scientific Report of the 2015 Dietary Guidelines Advisory Committee
  • Exhibit 544 7 January 2016. U.S. Department of Health and Human Services and U.S. Department of Agriculture: Dietary Guidelines for Americans 2015-2020, Eighth Edition
  • Exhibit 549 July 2020. 2020 Dietary Guidelines Advisory Committee: Scientific Report of the 2020 Dietary Guidelines Advisory Committee
  • Exhibit 550 May 2019. Eve Stoody, Designated Federal Officer, 2020 DGAC (USDA CNPP): Responding to the National Academies of Sciences, Engineering, and Medicine Study on the Process to Update the Dietary Guidelines for Americans
  • Exhibit 551 September 2017. National Academies of Sciences, Engineering, and Medicine: Optimizing the Process for Establishing the Dietary Guidelines for Americans: The Selection Process
  • Exhibit 552 December 2017. National Academies of Sciences, Engineering, and Medicine: Redesigning the Process for Establishing the Dietary Guidelines for Americans
  • Exhibit 554 December 2024. 2025 Dietary Guidelines Advisory Committee: Scientific Report of the 2025 Dietary Guidelines Advisory Committee
  • Exhibit 555 7 January 2026. U.S. Department of Health and Human Services and U.S. Department of Agriculture: Dietary Guidelines for Americans, 2025-2030
  • Exhibit 556 8 January 2026. U.S. Department of Health and Human Services and U.S. Department of Agriculture: The Scientific Foundation for the Dietary Guidelines for Americans, 2025-2030
  • Exhibit 557 18 October 2023. U.S. Government Accountability Office: Dietary Guidelines for Americans: Strengthening Interagency Collaboration Could Help Inform Nutrition Research and Future Guidelines (GAO-24-106130)
  • Exhibit 575 25 July 2025. U.S. Food and Drug Administration; U.S. Department of Agriculture: Ultra-Processed Foods; Request for Information (90 FR 35305; Docket FDA-2025-N-1793)
  • Exhibit 576 19 September 2025. U.S. Food and Drug Administration; U.S. Department of Agriculture: Ultra-Processed Foods; Request for Information; Extension of Comment Period (90 FR 45229)
  • Exhibit 577 23 July 2025. U.S. Department of Health and Human Services: HHS, FDA and USDA Address the Health Risks of Ultra-Processed Foods
  • Exhibit 582 October 2026. Greenberg Traurig: More Than Research: Why the Coming Federal Definition of Ultra-Processed Foods Matters
  • Exhibit 593 23 April 2003. Associated Press, via CBS News: Sugar Lobbyists Sour On Study
  • Exhibit 608 June 2023. USDA Economic Research Service (MacDonald, Dong and Fuglie): Concentration and Competition in U.S. Agribusiness (Economic Information Bulletin 256)
  • Exhibit 609 2020 (data through 2019). USDA Agricultural Marketing Service, Packers and Stockyards Division: Packers and Stockyards Division Annual Report 2020
  • Exhibit 610 April 2018. U.S. Government Accountability Office: U.S. Department of Agriculture: Additional Data Analysis Could Enhance Monitoring of U.S. Cattle Market (GAO-18-296)
  • Exhibit 612 22 June 2010. USDA Grain Inspection, Packers and Stockyards Administration: Implementation of Regulations Required Under Title XI of the Food, Conservation and Energy Act of 2008; Conduct in Violation of the Act (75 FR 35338)
  • Exhibit 613 18 November 2011. U.S. Congress: Consolidated and Further Continuing Appropriations Act, 2012, Pub. L. 112-55, Division A, sec. 721
  • Exhibit 614 20 December 2016. USDA Grain Inspection, Packers and Stockyards Administration: Scope of Sections 202(a) and (b) of the Packers and Stockyards Act (81 FR 92566)
  • Exhibit 615 18 October 2017. USDA Grain Inspection, Packers and Stockyards Administration: Scope of Sections 202(a) and (b) of the Packers and Stockyards Act; withdrawal of interim final rule (82 FR 48594)
  • Exhibit 616 11 December 2020. USDA Agricultural Marketing Service: Undue and Unreasonable Preferences and Advantages Under the Packers and Stockyards Act (85 FR 79779)
  • Exhibit 617 6 March 2024. USDA Agricultural Marketing Service: Inclusive Competition and Market Integrity Under the Packers and Stockyards Act (89 FR 16092)
  • Exhibit 618 1 June 2026. USDA Agricultural Marketing Service: Poultry Grower Payment Systems and Capital Improvement Systems; Delay of Effective Date (91 FR 32314)
  • Exhibit 619 3 January 2022. The White House (Biden administration): FACT SHEET: The Biden-Harris Action Plan for a Fairer, More Competitive, and More Resilient Meat and Poultry Supply Chain
  • Exhibit 620 4 September 2026 (published 10 September 2026). The White House (Trump administration): Executive Order 14424: Promoting Fair Competition in Livestock Markets and Expanding Market Access for American Meat Producers (91 FR 57761)
  • Exhibit 621 26 September 2025. DOJ Antitrust Division and USDA: Memorandum of Understanding between the Antitrust Division, Department of Justice, and the Department of Agriculture: Cooperation with Respect to Strengthening Competition for Agricultural Inputs
  • Exhibit 632 March 2023. USDA Agricultural Marketing Service (with USPTO), report under Executive Order 14036: More and Better Choices for Farmers: Promoting Fair Competition and Innovation in Seeds and Other Agricultural Inputs
  • Exhibit 636 May 2012. DOJ Antitrust Division: Competition and Agriculture: Voices from the Workshops on Agriculture and Antitrust Enforcement in our 21st Century Economy and Thoughts on the Way Forward
  • Exhibit 646 February 2021. USDA National Agricultural Statistics Service: Farms and Land in Farms: 2020 Summary
  • Exhibit 647 3 September 2026. U.S. Department of Agriculture, Economic Research Service: Farm Income and Wealth Statistics, data files, September 3, 2026 release (government payments by program, 1933 to 2026 forecast)
  • Exhibit 648 3 September 2026. U.S. Department of Agriculture, Economic Research Service: Webinar Transcript: Farm Income and Financial Forecasts, September 2026 Update
  • Exhibit 649 2025 payments; files posted February 2026. U.S. Department of Agriculture, Farm Service Agency: FSA farm program payment files (Name/Address and Payment), payments dated January to December 2025: recipient distribution
  • Exhibit 650 9 November 2026 (as-of date of the tables). U.S. Department of Agriculture, Risk Management Agency (Federal Crop Insurance Corporation): RMA Summary of Business, nationwide by commodity: premium, subsidy and indemnity, crop years 2022 to 2024
  • Exhibit 651 November 2023. U.S. Government Accountability Office: Crop Insurance: Update on Opportunities to Reduce Program Costs (GAO-24-106086)
  • Exhibit 652 March 2012. U.S. Government Accountability Office: Crop Insurance: Savings Would Result from Program Changes and Greater Use of Data Mining (GAO-12-256)
  • Exhibit 653 July 2012. U.S. Government Accountability Office: Farm Programs: Direct Payments Should Be Reconsidered (GAO-12-640)
  • Exhibit 654 April 2004. U.S. Government Accountability Office: Farm Program Payments: USDA Needs to Strengthen Regulations and Oversight to Better Ensure Recipients Do Not Circumvent Payment Limitations (GAO-04-407)
  • Exhibit 655 September 2013. U.S. Government Accountability Office: Farm Programs: Changes Are Needed to Eligibility Requirements for Being Actively Involved in Farming (GAO-13-781)
  • Exhibit 656 October 2020. U.S. Government Accountability Office: Farm Programs: USDA Has Improved Its Completion of Eligibility Compliance Reviews, but Additional Oversight Is Needed (GAO-21-95)
  • Exhibit 657 18 May 2018 (reissued 5 June 2018). U.S. Government Accountability Office: Farm Programs: Information on Payments (GAO-18-384R)
  • Exhibit 658 21 August 2020. U.S. Government Accountability Office: USDA Market Facilitation Program: Information on Payments for 2019 (GAO-20-700R)
  • Exhibit 659 January 2022. U.S. Government Accountability Office: USDA Market Facilitation Program: Oversight of Future Supplemental Assistance to Farmers Could Be Improved (GAO-22-104259)
  • Exhibit 660 2022. U.S. Government Accountability Office: USDA Market Facilitation Program: Stronger Adherence to Quality Guidelines Would Improve Future Economic Analyses (GAO-22-468)
  • Exhibit 661 9 March 2022. U.S. Department of Agriculture, Office of Inspector General: Market Facilitation Program, Audit Report 03601-0003-31
  • Exhibit 664 15 April 2026. Congressional Research Service: Farm Bill Primer: SNAP and Nutrition Title Programs (CRS IF12255)
  • Exhibit 666 4 July 2025. U.S. Congress (139 Stat. 72): Public Law 119-21 (H.R. 1), Title I, Committee on Agriculture, Nutrition, and Forestry (sections 10101 to 10607)
  • Exhibit 667 November 2017. U.S. Department of Agriculture, Economic Research Service: The Evolving Distribution of Payments From Commodity, Conservation, and Federal Crop Insurance Programs (Economic Information Bulletin 184)
  • Exhibit 668 2026 (application closed 17 April 2026). U.S. Department of Agriculture, Farm Service Agency: Farmer Bridge Assistance (FBA) Program
  • Exhibit 669 2026. U.S. Department of Agriculture, Farm Service Agency: Assistance for Specialty Crop Farmers (ASCF) Program
  • Exhibit 670 25 April 2023. U.S. Department of Agriculture, Farm Service Agency: 2021 PLC, ARC-CO, ARC-IC payments by state and by commodity (as of 25 April 2023)
  • Exhibit 671 Third quarter 2010. J. M. Alston, B. J. Rickard and A. M. Okrent (UC Davis, Cornell, USDA Economic Research Service), published by the Agricultural and Applied Economics Association: Farm Policy and Obesity in the United States (Choices 25(3))
  • Exhibit 672 2026 update (2024 data). U.S. Department of Agriculture, Economic Research Service: Food Dollar: Summary Findings (2024 data)
  • Exhibit 673 2026-11-09. U.S. Congress (Lobbying Disclosure Act database, lda.gov): Lobbying Disclosure Act query: quarterly reports with the phrase 'farm bill' in a lobbying activity description, 2018 and 2024 to 2025
  • Exhibit 931 April 2023 (entries last updated 13 March 2023). U.S. Department of Health and Human Services and U.S. Department of Agriculture (dietaryguidelines.gov): 2025 Dietary Guidelines Advisory Committee Disclosures
  • Exhibit 932 25 May 2023. Sen. Charles E. Grassley: Grassley Calls on Nutrition Advisory Committee to Halt Dietary Recommendations Until Conflicts of Interest Are Resolved (press release)
  • Exhibit 933 25 May 2023. Sen. Charles E. Grassley: Letter, Sen. Grassley to Secretaries Becerra and Vilsack on the 2025 Dietary Guidelines Advisory Committee
  • Exhibit 934 1 March 2019. USDA Office of Ethics: Ethics Review of Appointees to the Dietary Guidelines Advisory Committee (USDA Office of Ethics statement)
  • Exhibit 935 Archived 18 December 2020 (page undated). U.S. Department of Agriculture and U.S. Department of Health and Human Services (dietaryguidelines.gov): Dietary Guidelines for Americans: Most Popular Questions (2020 Advisory Committee process and ethics review)