Formal Comments on USDA Reorganization

(SM 1078-015)

Submitted by: Joseph F. Annelli, DVM, MS 

Executive Vice President National Association of Federal Veterinarians (NAFV)

Date: August 25, 2025

Introduction

On behalf of the National Association of Federal Veterinarians (NAFV), I submit these comments in response to the Secretary of Agriculture’s 2025 memorandum on reorganizing USDA (SM 1078-015). NAFV, founded in 1918 and recognized by OPM as an organization of federal managers and supervisors, represents the interests of veterinarians working across USDA, FDA, CDC, and other federal agencies. Veterinarians are mission-critical professionals within USDA, central to food safety, animal health, disease surveillance, emergency response, and zoonotic disease prevention. Without adequate numbers of trained regulatory veterinarians, trade slows or stops, livestock diseases are not effectively managed, and research into new methods of controlling diseases slows or stops, putting the U.S at a relative trade disadvantage. Any reorganization that diminishes the role, capacity, or morale of federal veterinarians risks undermining both USDA’s mission and the states’ ability to fulfill their public and animal health responsibilities. We urge USDA to recognize that the nation needs more federal veterinarians, not fewer. Reducing this workforce places significant burdens on USDA programs and state veterinary services that rely on USDA leadership and technical capacity.

Comments on Key Points of the Reorganization Plan

Ensure the size of the workforce aligns with resources and priorities 

The veterinary workforce should be based on the risk and needs of our stakeholders. An independent risk assessment prior to a reorganization is vital to determine what organizational structure is best for the livestock industry. The relative low cost of the federal veterinary workforce belies its outsized return on investment that keeps diseases in check, ensures the safety of the food supply, and enhances our trade opportunities. Veterinary medicine is an area of federal service that needs greater investment, not less.

Bring USDA Closer to its Customers by reallocating resources outside of the NCR:

Relocating staff to new hubs will create operational disruptions. For veterinarians engaged in regulatory science, outbreak response, and interagency coordination, proximity to federal leadership and scientific partners in Washington is vital. Forced relocations risk losing experienced veterinarians who cannot move, stripping USDA of institutional knowledge precisely when emerging threats like H5N1 require sustained expertise. On the surface, there appear to be cost savings, but the opposite is true.

Eliminating management layers and Bureaucracy 

Flattening of Management Structures. While eliminating “layers” of management may seem efficient, veterinary oversight structures exist for a reason. Supervisory veterinarians provide technical guidance, ensure regulatory compliance, and serve as liaisons with state partners. Removing these roles risks eroding quality control and overburdening remaining veterinarians with unmanageable spans of responsibility.

Consolidate support functions 

This has been done in the past and only creates gatekeepers in the combined functions and makes things less efficient. Previously USDA consolidated IT support functions and it failed spectacularly. Now employees find it difficult to get in person IT support, decreasing their efficiency while they often wait days or even weeks to remedy work-stoppage issues. Decentralization allows for flexibility and nuanced management to meet regional needs that cannot be done at a centralized service. Consolidation of support functions only makes the USDA less efficient, in direct conflict with this Administration's stated goals.

Conclusion 

Veterinarians are at the very heart of USDA’s mission to safeguard America’s food supply, protect animal health, and respond to zoonotic threats. Any reorganization that results in fewer federal veterinarians will compromise public health, diminish USDA’s capacity, and shift an unsustainable burden onto state partners. NAFV strongly urges USDA leadership to ensure that the reorganization plan: 1. Protects and strengthens the federal veterinary workforce. 2. Recognizes veterinarians as mission-critical to both USDA and state operations. 3. Provides competitive salaries and incentives to attract and retain experienced veterinarians. 4. Addresses the knowledge gaps created by the 20% attrition at APHIS and prevents further erosion of expertise. 

The collective voice of USDA veterinarians and stakeholders resoundingly warns that this reorganization will deepen workforce shortages, erode morale, and compromise public and animal health unless immediate steps are taken. We do not need fewer veterinarians—we urgently need more.

This reorganization, if done as proposed here, will fly in the face of the USDA priorities of: 

1. Promote healthy food choices 

2. Strengthen rural economies 

3. Enhance trade opportunities 

4. Ensure long term success of agriculture 

5. Address animal disease outbreaks

Attached are comments representing approximately 1,200 members of the National Association of Federal Veterinarians, the majority of whom are employed by the United States Department of Agriculture (USDA). Please contact jfannelli@nafv.org  if you have any questions or require further clarification on any of the comments.