this analysis, the current guidelines are fea- sible for LHDs that are enrolled in the Retail Program Standards. We have highlighted eorts to achieve con- formance, including RPS CAP and the Men- torship Program. Funding for these grant programs has drastically increased since the inception of these cooperative agreement programs. Annual funding from FDA for RPS CAP grants increased from $250,000 in 2009 to $3,530,000 in 2012. Significant funding also shifted participation in, and working toward conformance with, the Retail Program Stan- dards from a purely voluntary activity to an eort that required outcomes to secure future funding for food regulatory programming. Other eorts at the national level—includ- ing outreach from FDA Retail Food Special- ists, promotion of Retail Program Standards training and webinars, and other financial incentives—are more di¢cult to account for in this type of analysis. We know that there are also eorts at the local level to improve LHD engagement with the Retail Program Standards, including formal networks that allow LHDs to work together on the stan- dards, informal networks of LHD employees who collaborate across jurisdictional lines, and statewide peer-to-peer mentorship pro- grams. These regional eorts become more successful as more LHDs enroll in the Retail Program Standards, which allow for more collaboration and a decreased workload for any individual agency (NACCHO, 2022). The positive impact of participation in Retail Program Standards grant programs was also clear regarding advancement toward conformance with the standards. While par- ticipation in these programs was not associ- ated with an improvement in timeliness of SA or VA submissions, grant participants were much more likely to achieve conformance with at least one standard and achieved con- formance with more standards than other enrolled LHDs on average. It is important to continue to provide and expand both finan- cial and programmatic support to continue to advance conformance with Retail Program Standards at the local level. The large odds ratios associated with the Mentorship Pro- gram and conformance with at least one stan- dard via SA assessment and VA are important. NACCHO has collected quantitative and qualitative evaluation data during its 10 years leading the Mentorship Program. There are
FIGURE 2
Forest Plot Highlighting the Odds Ratio ( OR ) of Achieving Various Success Outcomes During the Self-Assessment (SA) Cycle
Conformance via SA (Mentorship) Conformance via SA (RPS CAP) Conformance via V A (Mentorship) Conformance via V A (RPS CAP) Submitting SA Update (Mentorship) Submitting SA Update (RPS CAP)
0
1
2
3
4
5
6
7
8
OR (9 5% Confidence Interval)
Note. RPS CAP = Retail Program Standards Cooperative Agreement Program; VA = third-party verification audit.
Table B1). RPS CAP grantees had significantly higher odds of submitting SA updates ( OR = 2.6, 95% CI [1.1, 6.3]). Moreover, RPS CAP grantees compared with non-grantees did not dier on odds of a positive SA ( OR = 1.2, 95% CI [0.4, 4.0]) nor on achieving conformance with at least one standard via VA ( OR = 1.6, 95% CI [0.7, 3.9]). Negative binomial regression was used to predict the impact of these grant programs on the number of standards achieved via SA and VA, as well as the number of SA updates submitted by an LHD. Participation in the Mentorship Program was associated with an increased rate of conformance via SA (IRR = 2.2, 95% CI [1.2, 3.9]), conformance via VA (IRR = 1.7, 95% CI [1.3, 2.1]), and SA update submission (IRR = 1.8, 95% CI [1.3, 2.6]). RPS CAP participation was significantly asso- ciated with an increased rate of conformance via VA (IRR = 1.5, 95% CI [1.1, 2.0]) and associated with an increased rate of confor- mance via SA (IRR = 2.1, 95% CI [0.9, 4.8]) and an increased rate of SA update submis- sion (IRR = 1.6, 95% CI [1.0, 2.4]). Discussion The first objective of our study was to under- stand if the current administrative guidance
is achievable for LHDs that are currently enrolled in the Retail Program Standards. In this analysis, we observed a reduction in the time it takes LHDs to submit SAs and VAs, and submission averages that were close to the guidelines. The data in our study indi- cate that the current guidelines are feasible for current Retail Program Standards enroll- ees and that eorts to promote access to FDA Retail Food Specialists, enrollment, and active participation in the Retail Program Standards have been beneficial. It is also noteworthy that administrative processes in the Retail Program Standards program have changed since its inception. For instance, LHDs that enrolled closer to program inception originally had 36 months to submit a VA following a positive SA, per the original administrative guidelines. These factors are important in framing the conversation regarding the feasibility of the current deadlines for submission of SAs and VAs. While examining the entire population of enrolled programs, it may seem that the current guidelines for submissions are not feasible, especially for those in their first SA cycle; however, our results indicate that LHDs have increasingly been able to meet the deadlines put forth by FDA. Based on
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November 2023 • Journal of Environmental Health
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