Towards a Well-Being Economy: Establishing an American Mental Wealth Observatory


Countries are facing dynamic, multidimensional, and interconnected crises. The pandemic, climate change, rising economic inequalities, food and energy insecurity, political polarization, increasing prevalence of youth mental and substance use disorders, and misinformation are converging, with enormous sociopolitical and economic consequences that are weakening democracies, corroding the social fabric of communities, and threatening social stability and national security. Globalization and digitalization are synchronizing, amplifying, and accelerating these crises globally by facilitating the rapid spread of disinformation through social media platforms, enabling the swift transmission of infectious diseases across borders, exacerbating environmental degradation through increased consumption and production, and intensifying economic inequalities as digital advancements reshape job markets and access to opportunities.

Systemic action is needed to address these interconnected threats to American well-being.

A pathway to addressing these issues lies in transitioning to a Well-Being Economy, one that better aligns and balances the interests of collective well-being and social prosperity with traditional economic and commercial interests. This paradigm shift encompasses a ‘Mental Wealth’ approach to national progress, recognizing that sustainable national prosperity encompasses more than just economic growth and instead elevates and integrates social prosperity and inclusivity with economic prosperity. To embark on this transformative journey, we propose establishing an American Mental Wealth Observatory, a translational research entity that will provide the capacity to quantify and track the nation’s Mental Wealth, generate the transdisciplinary science needed to empower decision makers to achieve multisystem resilience, social and economic stability, and sustainable, inclusive national prosperity.

Challenge and Opportunity

America is facing challenges that pose significant threats to economic security and social stability. Income and wealth inequalities have risen significantly over the last 40 years, with the top 10% of the population capturing 45.5% of the total income and 70.7% of the total wealth of the nation in 2020. Loneliness, isolation, and lack of connection are a public health crisis affecting nearly half of adults in the U.S. In addition to increasing the risk of premature mortality, loneliness is associated with a three-fold greater risk of dementia

Gun-related suicides and homicides have risen sharply over the last decade. Mental disorders are highly prevalent. Currently, more than 32% of adults and 47% of young people (18–29 years) report experiencing symptoms of anxiety and depression. The COVID-19 pandemic compounded the burden, with a 25–30% upsurge in the prevalence of depressive and anxiety disorders. America is experiencing a social deterioration that threatens its continued prosperity, as evidenced by escalating hate crimes, racial tensions, conflicts, and deepening political polarization. 

To reverse these alarming trends in America and globally, policymakers must first acknowledge that these problems are interconnected and cannot effectively be tackled in isolation. For example, despite the tireless efforts of prominent stakeholder groups and policymakers, the burden of mental disorders persists, with no substantial reduction in global burden since the 1990s. This lack of progress is evident even in high-income countries where investments in and access to mental health care have increased. 

Strengthening or reforming mental health systems, developing more effective models of care, addressing workforce capacity challenges, leveraging technology for scalability, and advancing pharmaceuticals are all vital for enhancing recovery rates among individuals grappling with mental health and substance use issues. However, policymakers must also better understand the root causes of these challenges so we can reshape the economic and social environments that give rise to common mental disorders.

Understanding and Addressing the Root Causes 

Prevention research and action often focus on understanding and addressing the social determinants of health and well-being. However, this approach lacks focus. For example, traditional analytic approaches have delivered an extensive array of social determinants of mental health and well-being, which are presented to policymakers as imperatives for investment. These include (but are not limited to):

This practice is replicated across other public health and social challenges, such as obesity, child health and development, and specific infectious and chronic diseases. Long lists of social determinants lobbied for investment lead policymakers to conclude that nations simply can’t afford to invest sufficiently to solve these health and social challenges. 

However, it Is likely that many of these determinants and challenges are merely symptoms of a more systemic problem. Therefore, treating the ongoing symptoms only perpetuates a cycle of temporary relief, diverts resources away from nurturing innovation, and impedes genuine progress.

To create environments that foster mental health and well-being, where children can thrive and fulfill their potential, where people can pursue meaningful vocation and feel connected and supported to give back to communities, and where Americans can live a healthy, active, and purposeful life, policymakers must recognize human flourishing and prosperity of nations depends on a delicate balance of interconnected systems.

The Rise of Gross Domestic Product: An Imperfect Measure for Assessing the Success and Wealth of Nations

To understand the roots of our current challenges, we need to look at the history of the foundational economic metric, gross domestic product (GDP). While the concept of GDP had been established decades earlier, it was during a 1960 meeting of the Organization for Economic Co-operation and Development that economic growth became a primary ambition of nations. In the shadow of two world wars and the Great Depression, member countries pledged to achieve the highest sustainable economic growth, employment, efficiency, and development of the world economy as their top priority (Articles 1 & 2). 

GDP growth became the definitive measure of a government’s economic management and its people’s welfare. Over subsequent decades, economists and governments worldwide designed policies and implemented reforms aimed at maximizing economic efficiency and optimizing macroeconomic structures to ensure consistent GDP growth. The belief was that by optimizing the economic system, prosperity could be achieved for all, allowing governments to afford investments in other crucial areas. However, prioritizing the optimization of one system above all others can have unintended consequences, destabilizing interconnected systems and leading to a host of symptoms we currently recognize as the social determinants of health. 

As a result of the relentless focus on optimizing processes, streamlining resources, and maximizing worker productivity and output, our health, social, political, and environmental systems are fragile and deteriorating. By neglecting the necessary buffers, redundancies, and adaptive capacities that foster resilience, organizations and nations have unwittingly left themselves exposed to shocks and disruptions. Americans face a multitude of interconnected crises, which will profoundly impact life expectancy, healthy development and aging, social stability, individual and collective well-being, and our very ability to respond resiliently to global threats. Prioritizing economic growth has led to neglect and destabilization of other vital systems critical to human flourishing.

Shifting Paradigms: Building the Nation’s Mental Wealth 

The system of national accounts that underpins the calculation of GDP is a significant human achievement, providing a global standard for measuring economic activity. It has evolved over time to encompass a wider range of activities based on what is considered productive to an economy. As recently as 1993, finance was deemed “explicitly productive” and included in GDP. More recently, Biden-Harris Administration leaders have advanced guidance for accounting for ecosystem services in benefit-cost analyses for regulatory decision-making and a roadmap for natural capital inclusion in the nation’s economic accounting services. This shows the potential to expand what counts as beneficial to the American economy—and what should be measured as a part of economic growth.

While many alternative indices and indicators of well-being and national prosperity have been proposed, such as the genuine progress indicator, the vast majority of policy decisions and priorities remain focused on growing GDP. Further, these metrics often fail to recognize the inherent value of the system of national accounts that GDP is based on. To account for this, Mental Wealth is a measure that expands the inputs of GDP to include well-being indicators. In addition to economic production metrics, Mental Wealth includes both unpaid activities that contribute to the social fabric of nations and social investments that build community resilience. These unpaid activities (Figure 1, social contributions, Cs) include volunteering, caregiving, civic participation, environmental restoration, and stewardship, and are collectively called social production. Mental Wealth also includes the sum of investment in community infrastructure that enables engagement in socially productive activities (Figure 1, social investment, Is). This more holistic indicator of national prosperity provides an opportunity to shift policy priorities towards greater balance between the economy and broader societal goals and is a measure of the strength of a Well-Being Economy. 

Figure 1.

Mental wealth is a more comprehensive measure of national prosperity that monetizes the value generated by a nation’s economic and social productivity.

Valuing social production also promotes a more inclusive narrative of a contributing life, and it helps to rebalance societal focus from individual self-interest to collective responsibilities. A recent report suggests that, in 2021, Americans contributed more than $2.293 trillion in social production, equating to 9.8% of GDP that year. Yet social production is significantly underestimated due to data gaps. More data collection is needed to analyze the extent and trends of social production, estimate the nation’s Mental Wealth, and assess the impact of policies on the balance between social and economic production.

Unlocking Policy Insights through Systems Modeling and Simulation

Systems modeling plays a vital role in the transition to a Well-Being Economy by providing an understanding of the complex interdependencies between economic, social, environmental, and health systems, and guiding policy actions. Systems modeling brings together expertise in mathematics, biostatistics, social science, psychology, economics, and more, with disparate datasets and best available evidence across multiple disciplines, to better understand which policies across which sectors will deliver the greatest benefits to the economy and society in balance. Simulation allows policymakers to anticipate the impacts of different policies, identify strategic leverage points, assess trade-offs and synergies, and make more informed decisions in pursuit of a Well-Being Economy. Forecasting and future projections are a long-standing staple activity of infectious disease epidemiologists, business and economic strategists, and government agencies such as the National Oceanic and Atmospheric Administration, geared towards preparing the nation for the economic realities of climate change.

Plan of Action 

An American Mental Wealth Observatory to Support Transition to a Well-Being Economy

Given the social deterioration that is threatening America’s resilience, stability, and sustainable economic prosperity, the federal government must systemically redress the imbalance by establishing a framework that privileges an inclusive, holistic, and balanced approach to development. The government should invest in an American Mental Wealth Observatory (Table 1) as critical infrastructure to guide this transition. The Observatory will report regularly on the strength of the Well-Being Economy as a part of economic reporting (see Table 1, Stream 1); generate the transdisciplinary science needed to inform systemic reforms and coordinated policies that optimize economic, environmental, health and social sectors in balance such as adding Mental Wealth to the system of national accounts (Streams 2–4); and engage in the communication and diplomacy needed to achieve national and international cooperation in transitioning to a Well-Being Economy (Streams 5–6).

This transformative endeavor demands the combined instruments of science, policy, politics, public resolve, social legislation, and international cooperation. It recognizes the interconnectedness of systems and the importance of a systemic and balanced approach to social and economic development in order to build equitable long-term resilience, a current federal interagency priority. The Observatory will make better use of available data from across multiple sectors to provide evidence-based analysis, guidance, and advice. The Observatory will bring together leading scientists (across disciplines of economics, social science, implementation science, psychology, mathematics, biostatistics, business, and complex systems science), policy experts, and industry partners through public-private partnerships to rapidly develop tools, technologies, and insights to inform policy and planning at national, state, and local levels. Importantly, the Observatory will also build coalitions between key cross-sectoral stakeholders and seek mandates for change at national and international levels. 

The American Mental Wealth Observatory should be chartered by the National Science and Technology Council, building off the work of the White House Report on Mental Health Research Priorities. Federal partners should include, at a minimum, the Department of Health and Human Services (HHS) Office of the Assistant Secretary for Health (OASH), specifically the Office of the Surgeon General (OSG) and Office of Disease Prevention and Health Promotion (ODPHP); the Substance Abuse and Mental Health Services Administration (SAMHSA); the Office of Management and Budget; the Council of Economic Advisors (CEA); and the Department of Commerce (DOC), alongside strong research capacity provided by the National Science Foundation (NSF) and the National Institutes of Health (NIH).

Table 1. Blueprint for an American Mental Wealth Observatory
The aim of the American Mental Wealth Observatory is to provide the data and science needed to act systemically to transition to a Well-Being Economy, build multi-system resilience, human flourishing, and national prosperity. The Observatory will have 6 overlapping streams of activity.
Stream 1: Measuring and monitoring the nation’s mental wealth (CEA, OSTP, OMB, DOC)While a number of communities and nations are embracing Well-Being Economy frameworks and tracking progress against a broad range of indicators of individual and societal well-being, an overarching measure of progress is needed. Without it, GDP will remain a privileged indicator that policy levers are trained on. This stream is focused on the further evolution of GDP to be a more holistic topline indicator of the strength of a Well-Being Economy: Mental Wealth. National Mental Wealth will be estimated and reported annually in the establishment phase, followed by quarterly intervals to mirror reporting of GDP. This effort can build on existing frameworks developed by DOC to include natural capital accounting within the system of national accounts, including linking Mental Wealth accounts with national economic accounts, interagency coordination and data standardization and interoperability policy, and organizing the development of a U.S. system of statistics for Mental Wealth decision-making.
Stream 2: Complex systems modeling and simulation (NSF, NIH, OASH, SAMHSA, OSTP, DOC)Advancing from rudimentary analytic and decision support tools to harnessing complex systems modeling and simulation will inform greater alignment of policies across economic, social, and health systems to enhance Mental Wealth (economic and social prosperity). Systems models are platforms for Living Evidence. Developing systems models requires the integration of scientific theory with best available research evidence and diverse data sources in a way that allows decision makers to test alternative policies and initiatives or ask resource allocation questions in a safe virtual environment before implementing them in the real world. As new evidence and data become available, models are updated/refined, becoming more robust over time, and offering significant value as long-term decision support assets.
Stream 3: Strengthening transdisciplinary data ecosystems (SAMHSA, OASH, DOC, OMB, OSTP, CEA, NIH, NSF)Strengthening transdisciplinary data ecosystems by harnessing advances in technology and passive and/or sentinel surveillance is essential, and will provide intelligence to inform coordinated cross-sectoral policy and planning.
This stream will also support early detection and rapid response to system stress and inform both Stream 2 modeling and Stream 4 Brain Capital research program. This program will include the establishment of a U.S. Brain Capital Dashboard and ongoing monitoring of brain capital indicators across three pillars: brain capital drivers (social, digital, economic), brain health (including mental health, well-being, and neurological disorders), and brain skills (cognitive and emotional skills and education metrics.
In addition, innovative protocols are being developed. For example, a protocol for scalable wastewater monitoring of stress hormones like cortisol and cortisone is under development in order to gain near-real-time insights into community stress and inform rapid deployment of resources/infrastructure to support communities through difficult times and prevent social decline before it becomes entrenched.
Stream 4: Brain Capital research program (NSF, NIH, OSTP)Investing in research that prioritizes brain capital enhancement opens doors to understanding and harnessing the economic value of human cognitive abilities (coupled with augmented intelligence offered by generative AI), mental health, and overall brain functioning. Recognizing and nurturing the economic value of brain capital can pave the way for a more prosperous and sustainable future, where individuals and societies thrive both intellectually and economically.
This research program will harness advanced research technologies to answer priority questions such as:

  • What are the likely impacts of AI on the diffusion of productivity gains, wealth, and well-being?

  • What are the projected impacts of early childhood education and care (ECEC) on school readiness, workforce participation, and family income?

  • What is the relationship between social capital infrastructure investment, social connectedness, and mental health in young people?

  • How is AI changing the nature of work, well-being, and productivity?

  • What is the optimal balance of digital technologies and human workforces needed to scale mental health and social care to meet demand?

  • How can employers and educators work together to create workforces and workplaces that are adaptable to changing circumstances by mastering quality, transferable vocational skills?
Stream 5: Knowledge translation / Policy Lab (CEA, OMB, OSTP, external nonprofits and academic research institutions)Shifting entrenched economic narratives and frameworks requires transdisciplinary policy advocacy, knowledge translation, and public communications alongside private stakeholders because stable transition to a Well-Being Economy will require broad scientific, policy, and public support as well as better cooperation between public and private sectors.
Stream 6: Brain Health / Science diplomacy (OSTP, State Department)Nothing less than an ambitious, innovative, transdisciplinary, and coordinated transnational research agenda is needed to enable the transition to a Well-Being Economy. The open sharing of insights, tools, and metrics across global agencies is needed to elevate mental health’s importance as a policy focus and inform policy and advocacy efforts and momentum for change. Therefore, this stream will focus on building bridges between countries through a universal appreciation of the importance of the integrity of the social fabric of nations for a nation’s very stability and resilience. Science diplomacy will also be important in facilitating the sharing of knowledge and innovations across borders, as well as for fostering international cooperation.

Operationalizing the American Mental Wealth Observatory will require an annual investment of $12 million from diverse sources, including government appropriations, private foundations, and philanthropy. This funding would be used to implement a comprehensive range of priority initiatives spanning the six streams of activity (Table 2) coordinated by the American Mental Wealth Observatory leadership. Acknowledging the critical role of brain capital in upholding America’s prosperity and security, this investment offers considerable returns for the American people.

Table 2. Investment needed to actualize an American Mental Wealth Observatory
Budget (US$M)
Stream 1: Measuring and monitoring the Mental Wealth of the nation1.
Stream 2: Complex systems modeling and simulation2.
Stream 3: Strengthening transdisciplinary data ecosystems2.
Stream 4: Brain Capital research program2.
Stream 5: Knowledge translation/Policy Lab1.
Stream 6: Brain Health/Science Diplomacy0.


America stands at a pivotal moment, facing the aftermath of a pandemic, a pressing crisis in youth mental and substance use disorders, and a growing sense of disconnection and loneliness. The fragility of our health, social, environmental, and political systems has come into sharp focus, and global threats of climate change and generative AI loom large. There is a growing sense that the current path is unsustainable. 

After six decades of optimizing the economic system for growth in GDP, Americans are reaching a tipping point where losses due to systemic fragility, disruption, instability, and civil unrest will outweigh the benefits. The United States government and private sector leaders must forge a new path. The models and approaches that guided us through the 20th century are ill-equipped to guide us through the challenges and threats of the 21st century.

This realization presents an extraordinary opportunity to transition to a Well-Being Economy and rebuild the Mental Wealth of the nations. An American Mental Wealth Observatory will provide the data and science capacity to help shape a new generation grounded in enlightened global citizenship, civic-mindedness, and human understanding and equipped with the cognitive, emotional, and social resources to address global challenges with unity, creativity, and resilience.

The University of Sydney’s Mental Wealth Initiative thanks the following organizations for their support in drafting this memo: FAS, OECDRice University’s Baker Institute for Public PolicyBoston University School of Public Health, the Brain Capital Alliance, and CSART.

Frequently Asked Questions
What is brain capital?

Brain capital is a collective term for brain skills and brain health, which are fundamental drivers of economic and social prosperity. Brain capital comprises (1) brain skills, which includes the ability to think, feel, work together, be creative, and solve complex problems, and (2) brain health, which includes mental health, well-being, and neurological disorders that critically impact the ability to use brain skills effectively, for building and maintaining positive relationships with others, and for resilience against challenges and uncertainties.

What is the social benefit of valuing unpaid forms of labor (social production)?

Social production is the glue that holds society together. These unpaid social contributions foster community well-being, support our economic productivity, improve environmental wellbeing, and help make us more prosperous and resilient as a nation.

Social production includes volunteering and charity work, educating and caring for children, participating in community groups, and environmental restoration—basically any activity that contributes to the social fabric and community well-being.

Making the value of social production visible helps us track how economic policies are affecting social prosperity and allows governments to act to prevent an erosion of our social fabric. So instead of just measuring our economic well-being through GDP, measuring and reporting social production as well gives us a more holistic picture of our national welfare. The two combined (GDP plus social production) is what we call the overall Mental Wealth of the nation, which is a measure of the strength of a Well-Being Economy.

As a society, what do we stand to lose by not measuring the Mental Wealth of the nation?

The Mental Wealth metric extends GDP to include not only the value generated by our economic productivity but also the value of this social productivity. In essence, it is a single measure of the strength of a Well-Being Economy. Without a Mental Wealth assessment, we won’t know how we are tracking overall in transitioning to such an economy.

Furthermore, GDP only includes the value created by those in the labor market. The exclusion of socially productive activities sends a signal that society does not value the contributions made by those not in the formal labor market. Privileging employment as a legitimate social role and indicator of societal integration leads to the structural and social marginalization of the unemployed, older adults, and the disabled, which in turn leads to lower social participation, intergenerational dependence, and the erosion of mental health and well-being.

How do well-being frameworks compare to Mental Wealth, and why are you proposing something different?

Well-being frameworks are an important evolution in our journey to understand national prosperity and progress in more holistic terms. Dashboards of 50-80 indicators like those proposed in Australia, Scotland, New Zealand, Iceland, Wales, and Finland include things like health, education, housing, income and wealth distribution, life satisfaction, and more, which help track some important contributors to social well-being.

However, these sorts of dashboards are unlikely to compete with topline economic measures like GDP as a policy focus. Some indicators will go up, some will go down, some will remain steady, so dashboards lack the ability to provide a clear statement of overall progress to drive policy change.

We need an overarching measure. Measurement of the value of social production can be integrated into the system of national accounts so that we can regularly report on the nation’s overall economic and social well-being (or Mental Wealth). Mental Wealth provides a dynamic measure of the strength (and good management) of a Well-Being Economy. By adopting Mental Wealth as an overarching indicator, we also gain an improved understanding of the interdependence of a healthy economy and a healthy society.

Developing a Mentor-Protégé Program for Fintech SBLC Lenders


The Biden Administration has recognized that small businesses, particularly minority-owned small businesses lack adequate access to capital. While SBA has operated its 7(a) Loan Program for multiple decades the program has historically shown poor results reaching minority-owned businesses and those in low- and moderate-income communities. Recently, the SBA has leveraged innovative fintech lenders to help fill this gap. 

While the agency has finalized a rule that would allow fintech companies to participate in the 7(a) Loan Program, there are significant concerns that new entrants would put the program at risk due to a lack of internal controls and transparent evaluation. To help increase lending to low- and moderate-income communities while not increasing the overall risk to the 7(a) Loan Program, SBA should establish a mentor-protégé program and conditional certification regime for innovative financial technology companies to participate responsibly in the SBA’s 7(a) Loan Program and ensure that SBA adequately preserves the safety and soundness of the program.

The Challenge

The Biden Administration has recognized that small businesses, particularly minority-owned small businesses lack adequate access to capital. While SBA has operated its 7(a) Loan Program for multiple decades, the program has historically shown poor results in reaching minority-owned businesses and those in low- and moderate-income communities. According to a 2022 Congressional Research Service report, “[i]n FY2021, 30.1% of 7(a) loan approvals ($10.98 billion of $36.54 billion) were [made] to minority-owned businesses (20.8% Asian, 6.0% Hispanic, 2.6% African American, and 0.7% American Indian)”. 

SBA has made a concerted effort previously to increase 7(a) small business lending to underserved communities by establishing the Community Advantage (CA) 7(a) loan initiative. Launched as a pilot program in 2011 and subsequently reauthorized, the CA loan initiative has been successful in encouraging mission-driven nonprofit lenders to underserved communities; however, the impact has been relatively small when compared to the traditional 7(a) loan program. In FY 2022, the CA Pilot Program approved just 722 loans totaling $114,804; whereas the general SBA 7(a) Loan Program approved 3,501 loans totaling $3,498,234,800–an order of magnitude of difference. 

The COVID-19 pandemic created an unprecedented demand for assistance to the country’s small businesses, as they were forced to close their doors and saw their revenues dwindle. Congress responded to this demand by passing the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which established one of the largest government-backed lending programs ever, the Paycheck Protection Program (PPP). During the PPP, fintech lenders, which for this policy memo includes technology-savvy banks and nonbank financial institutions that operate online and through mobile applications, proved uniquely adept at serving small businesses in traditionally underserved communities, even without specific guidance to do so from the SBA. 

Many of the borrowers assisted by fintech lenders did not have pre-existing borrowing relationships with a financial institution and were therefore deprioritized by traditional financial institutions offering PPP loans, who favored lending to small businesses with existing relationships. Previously published research showed that not only did fintech lenders receive more applications from businesses from Black and Hispanic-owned businesses, but also extended a significant amount of lending to these businesses. Fintech lenders therefore expanded the impact of the PPP to underserved borrowers and successfully bolstered the efforts of mission-driven lenders, such as Community Development Financial Institutions and Minority Depository Institutions. For example, Unity National Bank of Houston, a Minority Depository Institution partnered with Cross River, a tech-focused bank that partners with fintech companies, to increase its lending from 500 loans to nearly 200,000 loans by leveraging Cross River’s lending technology.  Similarly, Accion Opportunity Fund, a large Community Development Financial Institution, partnered with Lending Club, another tech-focused lender, to improve both entities’ lending operations to borrowers that were underserved during the first round of the PPP. However, Community Development Financial Institutions and Minority Depository Institutions often face challenges procuring and implementing the technology needed to help scale their nontraditional lending activities, which limits the efficacy of their mission-driven lending in an increasingly internet-based lending environment. 

In an effort to increase access to capital and build on the efforts of fintech companies that successfully provided capital to small businesses in the Paycheck Protection Program, SBA has proposed lifting its moratorium on non-depository lenders participating in the program. SBA and the Biden Administration have shown real progress in removing the moratorium on Small Business Lending Company (SBLC) licenses to include fintech companies, which would expand the eligible participants in the program for the first time in 40 years. 

Expanding access to capital and support for small businesses is a key priority for the Biden Administration. Specifically, the Administration noted the importance of expanding underserved small business’ access to capital.  They recommended expanding the SBA’s 7(a) program by extending SBLC licenses to nonbank lenders, which include fintech companies, as one promising strategy. To this end, SBA has established a strategy of expanding its lending network by leveraging fintech companies. The SBA previously issued a proposed rulemaking to remove the moratorium on SBLC licenses and add three new categories of SBLC licenses.

However, policymakers and some industry participants have cast serious doubts on fintech companies’ participation in SBA’s 7(a) Loan Program, due to weak internal controls of unpartnered fintech companies and subsequent fraud issues experienced during the Paycheck Protection Program. Further, these critics have cited concerns with the agency’s ability to properly oversee these fintech companies due to a lack of ability to manage the fraud risks associated with developing or expanding a lending program that includes unpartnered fintech companies. Overall, the agency has shown that both it and fintech companies should improve their engagement together to ensure that the many program requirements are adhered to, and that SBA improves its abilities to mitigate potentially new or unique risks to the 7(a) Loan Program.

The Plan of Action

To solve the aforementioned issues, SBA should establish a mentor-protégé program and conditional certification regime for innovative nonbank financial technology companies to participate responsibly in the SBA’s 7(a) Loan Program. By creating a mentor-protégé program and conditional certification regime, SBA can continue to encourage the expansion of the 7(a) Loan Program to lenders that have shown their willingness and ability to lend to traditionally underserved small business borrowers, while ensuring that the agency adequately preserves the safety and soundness of the 7(a) Loan Program.

In the proposed mentor-protégé program, SBA would conduct an initial assessment of the fintech applicant and provide a conditional certification contingent on the fintech’s participation in the mentor-protégé program. To ensure that only the most well-suited fintech companies are allowed to engage in the 7(a) program, SBA should conduct a fair lending assessment. This would include a gap analysis of the company’s lending processes, akin to the existing interagency fair lending examinations conducted by the federal banking regulators. Further, SBA should require fintech companies to complete a “Community Lending Plan” detailing the specific small business lending activities the fintech company intends to complete in traditionally underserved areas. SBA would conduct a review of applications it receives and match them with banks that are established 7(a) lenders. 

To help ensure that both mentors and protégés develop throughout the program, SBA would need to create program criteria for both mentor banks and protégé fintech companies. Mentor criteria should focus on ensuring that mentor banks assist and grow the knowledge of their fintech proteges. Thus, both mentors and protégés should be required to complete periodic progress reports. Further, mentors should conduct their own periodic assessments of the fintech protégé’s compliance and lending processes to ensure that the fintech is able to comply with existing 7(a) Loan Program requirements and not create an undue risk to the program. These criteria should be determined based on the expertise of the Office of Capital Access and Office of Credit Risk Management with advice from SBA’s 8(a) Business Development Program staff. Lastly, to ensure that mentors and protégés can speak candidly about their experience with the other participant, SBA would need to create communication portals for both entities that are walled-off review by either participant. 

Recognizing the potential apprehension existing 7(a) lenders might have to eventually increasing competition to the 7(a) lending market, the SBA would need to incentivize banks to provide mentorship services to fintech companies by providing participating mentor banks with Community Reinvestment Act (CRA) credit and an increased SBA guarantee threshold for the bank’s 7(a) loans. By pursuing these two incentives, the SBA would provide banks with clear business and regulatory benefits from participating in the mentor-protégé program.

Based on a review of the SBA’s 2023 Congressional Budget Justification, SBA has accounted for much of the increased cost that would stem from expanding the 7(a) Lending Program to additional SBLCs. SBA noted that part of its $93.6 million request for fiscal year 2023 was to attract new lenders that participated in the Paycheck Protection Program. Similarly, SBA identified the need to continue building its oversight of Paycheck Protection Program and Community Advantage lenders. To this end, SBA requested an additional $13.9 million in small business lender oversight. Establishing the 7(a) mentor-protégé program would likely require only a small amount of additional funds relative to the 2023 requested amount. To account for the additional programmatic and administrative requirements needed to establish the 7(a) mentor-protégé program, SBA should include an additional $500 thousand to $1 million to its future Congressional Budget Justifications.

Success of the mentor-protégé program depends on robust program requirements and continuous monitoring to ensure the participants are adhering to the goal of responsibly expanding capital access to underserved small businesses. To accomplish this endeavor, SBA should leverage the internal expertise of its Office of Capital Access and Office of Credit Risk Management, while also coordinating with prudential and state financial services regulators to adequately understand the novel business models of fintech companies applying to and participating in the program. Interagency coordination between state and federal regulators will ensure that the 7(a) program’s integrity is maintained at the macro and micro levels.


Expanding small business lending to low- and moderate- income communities is an especially important endeavor. Few opportunities for real social and economic growth exist in these traditionally underserved communities without robust access to small business credit. While the importance of expanding access is clear, SBA has a responsibility to ensure that its flagship 7(a) Loan Program remains safe, sound, and available for the benefit of all small businesses. The recent decision to finalize rulemaking that would expand allowable lenders to the 7(a) Loan Program must come with careful consideration of which lenders should be able to participate. Incorporating fintech lenders presents an opportunity to solve the issues of small business lending to traditionally underserved communities. However, given the concerns identified throughout the rulemaking process and after its finalization, SBA should work diligently to ensure that only the best-suited entities are allowed to become 7(a) lenders. To help ensure that this occurs, they should create a mentor-protégé program that will afford fintech companies the best opportunity to succeed in the program while maintaining the safety and soundness that is so important to the overall success of the 7(a) Loan Program.

Frequently Asked Questions
How might your proposed action fit in within the broader priorities of the administration or relative agencies?

Expanding access to capital and support for small businesses is a key priority for the Biden Administration. Specifically, the Administration noted the importance of expanding underserved small business’ access to capital by expanding the SBA’s 7(a) program through extending SBLC licenses to nonbank lenders, which include fintech companies. To this end, SBA established a strategy of expanding its lending network by leveraging fintech companies. The SBA previously issued and finalized a rulemaking process to remove the moratorium on SBLC licenses and add three new categories of SBLC licenses.

What government agency, office, or body will lead this effort?

Success of the mentor-protégé program depends on robust program requirements and continuous monitoring to ensure the participants are adhering to the goal of responsibly expanding capital access to underserved small businesses. To accomplish this endeavor, SBA should leverage the internal expertise of its Office of Capital Access and Office of Credit Risk Management, while also coordinating with prudential and state financial services regulators to adequately understand the novel business models of fintech companies applying to and participating in the program.

What are the parameters of the program (establishment, oversight, etc.)?

The SBA can conduct an initial assessment of the fintech applicant and provide a conditional certification contingent on the fintech’s participation in the mentor-protégé program. Further, the SBA should develop program criteria for both mentor banks and protégé fintech companies and application portals for both entities. SBA would conduct a review of applications it receives. The SBA would incentivize banks to provide mentorship services to fintech companies seeking to gain SBLC certification by providing CRA credit banks and an increased SBA guarantee threshold for the bank’s 7(a) loans.

Why should we rely on for-profit fintech lenders, rather than non-profit or mission-led lenders to expand funding to underserved communities?

Providing equitable access to capital for underserved communities in our country will require actions beyond the scope of this policy recommendation, including changes to the regulations that govern community banks, fintech lenders, CDFIs, and other mission-driven lenders. Fintech lenders have a proven ability to contribute to this expansion of capital access, given their collective performance as PPP lenders. In addition, fintech lenders have an ability to scale the solutions that they provide quickly, something that CDFIs and other mission-led lenders have traditionally struggled to do well.

Why reform 7(a) as opposed to creating a new, fintech-specific lending program at the SBA?

Fintech lenders compete with conventional lenders for market share; the SBA should take care not to create programs that give one competing group an advantage over another. Creating a bespoke program, tailored to the needs of fintech lenders, would run the risk of creating more than an incidental competitive advantage. Instead, this program proposal advocates for utilizing a mentorship model that helps build strategic partnerships to accelerate access to capital for underserved groups, without creating separate rules or carve-outs.

Leveraging Positive Tipping Points to Accelerate Decarbonization


The Biden Administration has committed the United States to net-zero emissions by 2050. Meeting this commitment requires drastic decarbonization transitions across all sectors of society at a pace never seen before. This can be made possible by positive tipping points, which demarcate thresholds in decarbonization transitions that, once crossed, ensure rapid progress towards completion. A new generation of economic models enables the analysis of these tipping points and the evaluation of effective policy interventions. 

The Biden Administration should undertake a three-pronged strategy for leveraging the power of positive tipping points to create a larger-than-anticipated return on investment in the transition to a clean energy future. First, the President’s Council of Advisors on Science and Technology (PCAST) and the Council of Economic Advisors (CEA) should evaluate new economic models and make recommendations for how agencies can incorporate such models into their decision-making process. Second, federal agencies should integrate positive tipping points into the research agendas of existing research centers and programs to uncover additional decarbonization opportunities. Finally, federal agencies should develop decarbonization strategies and policies based on insights from this research.

Challenge and Opportunity

Climate change brings us closer each year to triggering negative tipping points, such as the collapse of the West Antarctic ice sheet or the Atlantic Meridional Overturning Circulation. These negative tipping points, driven by self-reinforcing environmental feedback loops, significantly accelerate the pace of climate change. 

Meeting the Biden Administration’s commitment to net-zero emissions by 2050 will reduce the risk of these negative tipping points but requires the United States to significantly accelerate the current pace of decarbonization. Traditional economic models used by the federal government and organizations such as the International Energy Agency consistently underestimate the progress of zero-emission technologies and the return on investment of policies that enable a faster transition, resulting in the agency’s “largest ever upwards revision” last year. A new school of thought presents “evidence-based hope” for rapidly accelerating the pace of decarbonization transitions. Researchers point out that our society consists of complex and interconnected social, economic, and technological systems that do not change linearly under a transition, as traditional models assume; rather, when a positive tipping point is crossed, changes made to the system can lead to disproportionately large effects. A new generation of economic models has emerged to support policymakers in understanding these complex systems in transition and identifying the best policies for driving cost-effective decarbonization.

At COP26 in 2021, leaders of countries responsible for 73% of world emissions, including the United States, committed to work together to reach positive tipping points under the Breakthrough Agenda. The United Kingdom and other European countries have led the movement thus far, but there is an opportunity for the United States to join as a leader in implementing policies that intentionally leverage positive tipping points and benefit from the shared learnings of other nations. 

Domestically, the Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA) include some of the strongest climate policies that the country has ever seen. The implementation of these policies presents a natural experiment for studying the impact of different policy interventions on progress towards positive tipping points.

How do positive tipping points work?

Figure 1. Diagram of a system and its positive tipping point. The levers for change on the left push the system away from the current high-emission state and towards a new net-zero state. As the system moves away from the current state, the self-reinforcing feedback loops in the system become stronger and accelerate the transition. At the positive tipping point, the feedback loops become strong enough to drive the system towards the new state without further support from the levers for change. Thus, policy interventions for decarbonization transitions are most crucial in the lead up to a positive tipping point. (Adapted from the Green Futures Network.)

Just as negative tipping points in the environment accelerate the pace of climate change, positive tipping points in our social, economic, and technological systems hold the potential to rapidly accelerate the pace of decarbonization (Figure 1). These positive tipping points are driven by feedback loops that generate increasing returns to adoption and make new consumers more likely to adopt (Figure 2):

The right set of policies can harness this phenomenon to realize significantly greater returns on investment and trigger positive tipping points that give zero-emission technologies a serious boost over incumbent fossil-based technologies.

Figure 2. Examples of positive feedback loops: (a) learning by doing, (b) social contagion, and (c) complementary technology reinforcement.

One way of visualizing progress towards a positive tipping point is the S-curve, where the adoption of a new zero-emission technology grows exponentially and then saturates at full adoption. This S-curve behavior is characteristic of many historic energy and infrastructure technologies (Figure 3). From these historic examples, researchers have identified that the positive tipping point occurs between 10% and 40% adoption. Crossing this adoption threshold is difficult to reverse and typically guarantees that a technology will complete the S-curve.

Figure 3. The historic adoption of a sample of infrastructure and energy systems (top) and manufactured goods (bottom). Note that the sharpness of the S-curve can vary significantly. (Source: Systemiq)

For example, over the past two decades, the Norwegian government helped build electric vehicle (EV) charging infrastructure (complementary technology) and used taxes and subsidies to lower the price of EVs below that of gas vehicles. As a result, consumers began purchasing the cheaper EVs, and over time manufacturers introduced new models of EVs that were cheaper and more appealing than previous models (learning by doing and economies of scale). This led to EVs skyrocketing to 88% of new car sales in 2022. Norway has since announced that it would start easing its subsidies for EVs by introducing two new EV taxes for 2023, yet EV sales have continued to grow, taking up 90% of total sales so far in 2023, demonstrating the difficult-to-reverse nature of positive tipping points. Norway is now on track to reach a second tipping point that will occur when EVs reach price parity with gas vehicles without assistance from taxes or subsidies.

Due to the interconnected nature of social and technological systems, triggering one positive tipping point can potentially increase the odds of another tipping point at a greater scale, resulting in “upward-scaling tipping cascades.” Upward-scaling tipping cascades can occur in two ways: (1) from a smaller system to a larger system (e.g., as more states reach their tipping point for EV adoption, the nation as a whole gets closer to its tipping point) and (2) from one sector to another. For the latter, researchers have identified three super-leverage points that policymakers can use to trigger tipping cascades across multiple sectors:

  1. Light-duty EVs → heavy-duty EVs and renewable energy storage: The development of cheaper batteries for light-duty EVs will enable cheaper heavy-duty EVs and renewable energy storage thanks to shared underlying battery technology. The build-out of charging infrastructure for light-duty EVs will also facilitate the deployment of heavy-duty EVs.
  2. Green ammonia → heavy industries, shipping, and aviation: The production of green ammonia requires green hydrogen as an input, so the growth of the former will spur the growth of the latter. Greater production of green hydrogen and green ammonia will catalyze the decarbonization of the heavy industries, shipping, and aviation sectors, which use these chemicals as fuel inputs.
  3. Traditional and alternative plant proteins → land use: Widespread consumption of traditional and alternative plant proteins over animal protein will reduce pressure on land-use change for agriculture and potentially restore significant amounts of land for conservation and carbon sequestration.

The potential for this multiplier effect makes positive tipping points all the more promising and critical to understand.

Further research to identify positive tipping points and tipping cascades and to improve models for evaluating policy impacts holds great potential for uncovering additional decarbonization opportunities. Policymakers should take full advantage of this growing field of research by integrating its models and insights into the climate policy decision-making process and translating insights from researchers into evidence-based policies. 

Plan of Action

In order for the government to leverage positive tipping points, policymakers must be able to (1) identify positive tipping points and tipping cascades before they occur, (2) understand which policies or sequences of policies may be most cost-effective and impactful in enabling positive tipping points, and (3) integrate that insight into policy decision-making. The following recommendations would create the foundations of this process.

Recommendation 1. Evaluate and adopt new economic models

The President’s Council of Advisors on Science and Technology (PCAST) and the Council of Economic Advisors (CEA) should conduct a joint evaluation of new economic models and case studies to identify where new models have been proven to be more accurate for modeling decarbonization transitions and where there are remaining gaps. They should then issue a report with recommendations on opportunities for funding further research on positive tipping points and new economic models and advise sub agenciessubagencies responsible for modeling and projections, such as the Energy Information Administration within the Department of Energy (DOE), on how to adopt these new economic models.

Recommendation 2. Integrate positive tipping points into the research agenda of federally funded research centers and programs.

There is a growing body of research coming primarily from Europe, led by the Global Systems Institute and the Economics of Energy Innovation and Systems Transition at the University of Exeter and Systemiq, that is investigating global progress towards positive tipping points and different potential policy interventions. The federal government should foster the growth of this research area within the United States in order to study positive tipping points and develop models and forecasts for the U.S. context.

There are several existing government-funded research programs and centers that align well with positive tipping points and would benefit synergistically from adding this to their research agenda:

Recommendation 3. Use insights from positive tipping points research to develop and implement policies to accelerate progress towards positive tipping points

Researchers have already identified three super-leverage points around which the federal government should consider developing and implementing policies. As future research is published, the PCAST should make further recommendations on actions that the federal government can take in leveraging positive tipping points.

Super-Leverage Point #1: Mandating Zero-Emission Vehicles (ZEVs) 

ZEV mandates require car manufacturers to sell a rising proportion of ZEVs within their light duty vehicles sales. Ensuring a growing supply of ZEVs results in falling costs and rising demand. Evidence of the effect of such policies in U.S. states, Canadian provinces, and China and future projections suggest that ZEV mandates are a crucial policy lever for ensuring a full EV transition. Such policies rely on the reallocation of private capital rather than government spending, making it particularly cost-effective. Combined with the investments in EV manufacturing and public charging infrastructure in the IRA and IIJA, a national ZEV mandate could radically boost the EV transition. 

A national ZEV mandate is unlikely to pass Congress anytime soon. However, the recently proposed Environmental Protection Agency (EPA) greenhouse gas emissions standards for passenger cars and trucks would effectively require 67% of car sales to be ZEVs by 2032 in order for car manufacturers to comply with the regulations. The proposed standards would provide regulatory strength behind the Biden Administration’s goal of 50% of new cars sold by 2030 to be ZEVs. The EPA should finalize these standards as soon as possible at or above the currently proposed stringency. 

The proposed EPA standards are projected to result in a 50% reduction in the price of EV batteries by 2035. This will have knock-on effects on the cost of batteries for renewable energy storage and battery electric trucks and other heavy-duty vehicles, which would likely bring forward the cost parity tipping point for these technologies by a number of years.

Super-Leverage Point #2: Mandating Green Ammonia Use in Fertilizer Production 

Ammonia is the primary ingredient for producing nitrogen-based fertilizer and requires hydrogen as an input. Traditionally, this hydrogen is produced from natural gas, and the production of hydrogen for ammonia accounts for 1% of global CO2 emissions. Green hydrogen produced from water and powered by renewable energy would enable the production of green ammonia for nitrogen-based fertilizers.

Based on a DOE tipping point analysis, green ammonia production is one of the most promising areas for initial large-scale deployment of green hydrogen, thanks to its ability to use established ammonia supply chains and economies of scale. Green ammonia production also has one of the lowest green premia in the hydrogen economy. Green ammonia production will enable infrastructure development and cost reductions for green hydrogen to decarbonize other sectors, including shipping, aviation, and heavy industries like steel. 

The Biden Administration should set a target for green ammonia production for domestic fertilizer in the Federal Sustainability Plan similar to India’s draft hydrogen strategy requiring 20% green ammonia production by 2027–2028. The EPA should then propose Clean Air Act carbon emission limits and guidelines for nitrogen-based fertilizer production plants, similar to the recently proposed standards for coal and natural gas power plants, to provide regulatory strength behind that target. These limits would effectively require fertilizer plants to blend a growing percentage of green ammonia into their production line in order to meet emission limits. According to the DOE, the clean hydrogen production tax credit in the IRA has enabled cost parity between green ammonia and fossil-based ammonia, so the EPA should be able to set such limits without increasing food production costs.

Super-Leverage Point #3: Public Procurement to Promote Plant and Alternative Proteins

Shifting protein consumption from meat to plant and alternative proteins can reduce emissions from livestock farming and reduce land use change for meat production. Plant proteins refer to protein-rich plants, such as nuts and legumes, and traditional products made from those plants, such as tofu and tempeh. Alternative proteins currently on the market include plant- and fermentation-based protein products intended to mimic the taste and texture of meat. Studies show that if plant and alternative proteins are able to reach a tipping point of 20% market share, this would ease up 7–15% of land currently used for agriculture to conservation and the restoration of its ability to serve as a carbon sink. 

Public procurement of alternative proteins for federal food programs leverages government spending power to support this nascent market and introduce new consumers to alternative proteins, thus increasing its accessibility and social traction. Last year, the National Defense Authorization Act established a three-year pilot program for the U.S. Navy to offer alternative protein options. The California state legislature also invested $700 million to support schools in procuring more plant-based foods and training staff on how to prepare plant-based meals.

The United States Department of Agriculture (USDA) is a major procurer of food through collaboration between the Agricultural Marketing Service (AMS) and the Food and Nutrition Service (FNS) and distributes the majority of procured food through the Child Nutrition Programs (CNPs), especially the National School Lunch Program (NSLP). Currently, AMS does not procure any traditional or alternative protein products made from plant protein, but USDA guidelines do allow traditional and alternative protein products to fulfill meat/meat alternate requirements for CNPs. The AMS should develop product specifications and requirements for procuring these types of products and assist traditional and alternative protein companies to become USDA food vendors. The FNS should then launch a pilot program spending, for example, 1% of their procurement budget on traditional and alternative protein products. This should be supported by education and training of food service workers at schools that participate in the NSLP on how to prepare meals using traditional and alternative proteins.


The sooner that positive tipping points that accelerate desired transitions are triggered, the sooner that decarbonization transitions will be realized and net-zero goals will be met. Early intervention is crucial for supporting the growth and adoption of new zero-emission technologies. The recommendations above present the foundations of a strategy for leveraging positive tipping points and accelerating climate action.


I’d like to acknowledge Erica Goldman for her generous feedback and advice on this piece and for her thought leadership on this topic at FAS.

FAQs about Leveraging Positive Tipping Points to Accelerate Decarbonization
What are the necessary conditions for a positive tipping point?

The key conditions for triggering a positive tipping point are affordability, attractiveness, and accessibility of new zero-emission technologies compared to incumbents. Affordability is often the most crucial condition: achieving price parity with incumbent technologies (with and then without the support of taxes and subsidies) can unlock rapid growth and adoption. Attractiveness refers to consumer preferences about a new technology’s performance, complementary features, or ability to signal social values. Accessibility refers to whether supporting infrastructure or knowledge, such as charging stations for EVs or recipes for cooking alternative proteins, is commonly available to support adoption. Due to the relative nature of these conditions, policymakers can influence them either by making the new technology more affordable, attractive, and accessible or by making the incumbent technology less affordable, attractive, and accessible. Often, a combination of both approaches is required to achieve the optimal effect.

Are federal policymakers the only actors that can trigger positive tipping points? What about state policymakers?

States can cooperate to identify and coordinate policies that activate upward-scaling tipping cascades into other states and eventually the federal government. A promising example of this is the growing adoption of California’s Advanced Clean Cars II EV sales mandate by Vermont, New York, Washington, Oregon, Rhode Island, New Jersey, Maryland, and soon Colorado, Massachusetts, and Delaware.

What about individuals and social movements?

Social contagion, mentioned above, is a powerful type of feedback loop that can drive the spread of not just technology adoption but also new behaviors, opinions, knowledge, and social norms. Through social contagion, social movement can be formed, capable of wielding greater influence than the sum of individuals. That influence can then translate into demands for government and industry action to decarbonize. A prime example is Greta Thunberg and the Fridays for Future student movement. Another example is the Social Tipping Point Coalition that in 2021 rallied a coalition of over 100 scientists, universities, nongovernmental and grassroots organizations, and other individuals to petition the new Dutch parliament to implement new climate policies.

What about industry stakeholders?

Industry has a direct hand in creating the conditions for a positive tipping point through their business models, technological development, and production. Industries are more likely to invest in adopting and improving low- and zero-carbon technologies and practices if the government clearly signals that it will back the transition, resulting in positive, reinforcing “ambition loops” between government climate policy and industry climate action. Industry coordination is also key to ensuring that new technologies are complementary and that infrastructure supporting a technology is developed alongside the technology itself. For example, coordination between EV companies is necessary to develop compatible charging mechanisms across manufacturers. Coordination between charging companies and EV companies can help charging companies identify which geographies have greatest demand for chargers.

What about international coordination?

International coordination strengthens positive feedback loops and accelerates cost reductions for green technologies. For example, a recent study suggests that if the three largest car markets—the United States, Europe, and China—implement zero-emission vehicle (ZEV) sales mandates (i.e., requirements that an increasing percentage of each car manufacturer’s sales must be EVs), EVs will be able to reach cost parity with gas vehicles five years sooner than in the scenario without those ZEV mandates.

What has the federal government done to identify or accelerate positive tipping points so far?

The U.S. Global Change Research Program’s 2022–2031 Strategic Plan includes tipping points and nonlinear changes in complex systems as two of its research priorities. Specifically, the Strategic Plan highlights the need to investigate “the potential for beneficial tipping points” and incorporate research on nonlinearity in economics-based models to evaluate societal decisions in future National Climate Assessments. However, it will take another four to five years to produce the next National Climate Assessment under this strategic plan. (The fifth National Climate Assessment, which is expected to be published this fall, was drafted before the new strategic plan was published.) Thus, additional executive and agency action is necessary to operationalize positive tipping points in the federal government before the next National Climate Assessment is released.

How can we track progress towards positive tipping points?

The federal government currently collects some data on the sales and adoption rates of the relatively more mature clean energy technologies, such as electric vehicles. A 2022 Bloomberg report attempted to identify “early-stage tipping points” at around 5% adoption for 10 clean energy technologies that reflect when their adoption becomes measurably exponential and compare their adoption curves across countries globally. Beyond adoption rates, a number of additional factors indicate progress towards positive tipping points, such as the number of companies investing in a zero-emission technology or the number of states adopting regulations or incentives that support zero-emission technologies in a sector. Tracking these indicators can help policymakers sense when a system is approaching a positive tipping point. The nonprofit Systems Change Lab currently tracks the adoption of decarbonization technologies and factors that affect decarbonization transitions on a global scale. Philanthropic funding or a public-private partnership with the Systems Change Lab could leverage their existing infrastructure to track tipping point indicators on a national scale for the United States.

What are the risks or potential unintended consequences to consider when crossing a positive tipping point?

Approaching a positive tipping point first requires a system to become destabilized in order to make change possible. Once a positive tipping point is crossed, the system then accelerates towards a new state and begins to restabilize. However, the destabilization during the transition can have unintended consequences due to the rapid shift in how social, economic, and technological systems are organized and how resources are distributed within those systems. Potential risks include economic precarity for people employed in rapidly declining industries and resulting social instability and backlash. This can potentially exacerbate inequality and undesirable social division. As such, policies ensuring a just transition must be implemented alongside policies to accelerate positive tipping points. Research on the interaction between these policies is currently ongoing. It is essential that decisions to develop policies that accelerate movement towards positive tipping points always consider and evaluate the potential for unintended consequences.

Building the Talent Pipeline for the Energy Transition: Aligning U.S. Workforce Investment for Energy Security and Supply Chain Resilience


With the passage of the Infrastructure Investment and Jobs Act (IIJA), the CHIPS and Science Act, and the Inflation Reduction Act (IRA), the United States has outlined a de facto industrial policy to facilitate and accelerate the energy transition while seeking energy security and supply chain resilience. The rapid pace of industrial transformation driven by the energy transition will manifest as a human capital challenge, and the workforce will be realigned to the industrial policy that is rapidly transforming the labor market. The energy transition, combined with nearshoring, will rapidly retool the global economy and, with it, the skills and expertise necessary for workers to succeed in the labor market. A rapid, massive, and ongoing overhaul of workforce development systems will allow today’s and tomorrow’s workers to power the transition to energy security, resilient supply chains, and the new energy economy—but they require the right training opportunities scaled to match the needs of industry to do so.

Policymakers and legislators recognize this challenge, yet strategies and programs often sit in disparate parts of government agencies in labor, trade, commerce, and education. A single strategy that coordinates a diverse range of government policies and programs dedicated to training this emerging workforce can transform how young people prepare for and access the labor market and equip them with the tools to have a chance at economic security and well-being.

Modeled after the U.S. Department of Labor’s (DOL) Trade Adjustment Assistance Community College and Career Training (TAACCCT) program, we propose the Energy Security Workforce Training (ESWT) Initiative to align existing U.S. government support for education and training focused on the jobs powering the energy transition. The Biden-Harris Administration should name an ESWT Coordinator to manage and align domestic investments in training and workforce across the federal government. The coordinator will spearhead efforts to identify skills gaps with industry, host a ESWT White House Summit to galvanize private and social sector commitments, encourage data normalization and sharing between training programs to identify what works, and ensure funds from existing programs scale evidence-based sector-specific training programs. ESWT should also encompass an international component for nearshored supply chains to perform a similar function to the domestic coordinator in target countries like Mexico and promote two-way learning between domestic and international agencies on successful workforce training investments in clean energy and advanced manufacturing.

Challenge and Opportunity

With the passage of the Infrastructure Investment and Jobs Act and the Inflation Reduction Act, the United States has a de facto industrial policy to facilitate and accelerate the energy transition while seeking energy security and supply chain resilience. However, our current workforce investments are not focused on the growing green skills gap. We require workforce investment aligned to the industrial policy that is rapidly transforming the labor market, to support both domestic jobs and the foreign supply chains that domestic jobs depend on. 

Preparing Americans to Power the Energy Transition

The rapid pace of industrial transformation driven by the energy transition will manifest as a human capital challenge. The energy transition will transform and create new jobs—requiring a massive investment to skill up the workers who will power the energy transition. Driving this rapid transition are billions of dollars slated for incentives and tax credits for renewable energy and infrastructure, advanced manufacturing, and supply chain creation for goods like electric vehicle batteries over the coming years. The vast upheaval caused by the energy transition combined with nearshoring is transforming both current jobs as well as the labor market young people will enter over the coming decade. The jobs created by the energy transition have the potential to shift a whole generation into the middle class while providing meaningful, engaging work. 

Moving low-income students into the middle class over the next 10 years will require that education and training institutions meet the rapid pace of industrial transformation required by the energy transition. Education and training providers struggle to keep up with the rapid pace of industrial transformation, resulting in skills gaps. Skills gaps are the distance between the skills graduates leave education and training with and the skills required by industry. Skills gaps rob young people of opportunities and firms of productivity. And according to LinkedIn’s latest Green Economy report, we are facing a green skills gap—with the demand for green skills outpacing the supply in the labor force. Firms have cited skills gaps in diverse sectors related to the energy transition, including infrastructure, direct air capture, electromobility, and geothermal power

Graduates with market-relevant skills earn between two and six times what their peers earn, based on evaluations of International Youth Foundation’s (IYF) programming. In addition, effective workforce development lowers recruitment, selection, and training costs for firms—thereby lowering the transaction costs to scale moving people into the positions needed to power the energy transition. Industrial transformation for the energy transition involves automation, remote sensing, and networked processes changing the role of the technician—who is no longer required to execute tasks but instead to manage automated processes and robots that now execute tasks. This changes the fundamental skills required of technicians to include higher-order skills for managing processes and robots. 

We will not be able to transform industry or seize the opportunities of the new energy future without overhauling education and training systems to build the skills required by this transformation and the industries that will power it. Developing higher-order thinking skills means changing not only what is taught but how teaching happens. For example, students may be asked to evaluate and make actionable recommendations to improve energy efficiency at their school. Because many of these new jobs require higher-order thinking skills, policy investment can play a crucial role in supporting workers and those entering the workforce to be competitive for these jobs. 

Creating Resilient Supply Chains, Facilitating Energy Security, and Promoting Global Stability in Strategic Markets

Moving young people into good jobs during this dramatic economic transformation will be critical not only in the United States but also to promote our interests abroad by (1) creating resilient supply chains, 2) securing critical minerals, and (3) avoiding extreme labor market disruptions in the face of a global youth bulge. 

Supply chain resilience concerns are nearshoring industrial production—shifting the demand for industrial workers across geographies at a shocking scale and speed—as more manufacturing and heavy industries move back into the United States’ sphere of influence. The energy transition combined with nearshoring will rapidly retool the global economy. We need a rapid, massive, and ongoing overhaul of workforce development systems at home and abroad. The scale of this transition is massive and includes complex, multinational supply chains. Supply chains are being reworked before our eyes as we nearshore production. For example, the port of entry in Santa Teresa, New Mexico, is undergoing rapid expansion in anticipation of explosive growth of imports of spare parts for electric vehicles manufactured in Mexico. These shifting supply chains will require the strategic development of a new workforce.

The United States requires compelling models to increase its soft power to secure critical minerals for the energy transition. Securing crucial minerals for the energy transition will again reshape energy supply chains, as the mineral deposits needed for the energy transition are not necessarily located in the same countries with large oil, gas, or coal deposits. The minerals required for the energy transition are concentrated in China, Democratic Republic of Congo, Australia, Chile, Russia, and South Africa. We require additional levers to establish productive relationships to secure the minerals required for the energy transition. Workforce investments can be an important source of soft power. 

Today’s 1.2 billion young people today make up the largest and most educated generation the world has ever seen, or will ever see, yet they face unemployment rates at nearly triple that of adults. Globally the youth unemployment rate is 17.93% vs. 6.18% for adults. The youth unemployment rate refers to young people aged 15–24 who are available for or seeking employment but who are unemployed. While rich countries have already passed through their own baby booms, with accompanying “youth bulges,” and collected their demographic dividends to power economic growth and wealth, much of the developing world is going through its own demographic transition. While South Korea experienced sustained prosperity once its baby boomers entered the labor force in the early 2000s, Latin America’s youth bulge is just entering the labor force. In regions like Central America, this demographic change is fueling a wave of outmigration. In Sub-Saharan Africa, the youth bulge is making its way through compulsory education with increasing demands for government policy to meet high rates of youth unemployment. It is an open question whether today’s youth bulges globally will drive prosperity as they enter the labor market. Policymakers are faced with shaping labor force training, and government policy rooted in demonstrable industry needs to meet this challenge. At the same time, green jobs is already one of the most rapidly growing occupations. The International Energy Agency (IEA) projects that adopting clean energy technologies will generate 14 million jobs by 2030, with 16 million more to retrofit and construct energy-efficient buildings and manufacture new energy vehicles. At the same time, the World Economic Forum’s 2023 future of jobs report cites the green transition as the key driver of job growth. However, the developing world is not making the corresponding investments in training programs for the green jobs that are driving growth. 

Alignment with Existing Initiatives

The Biden-Harris Administration’s approach to the energy transition, supply chain resilience, and energy security must address this human capital challenge. Systemic approaches to building the skills for the energy transition through education and training complement the IRA’s incentivized apprenticeships, and focus investments from the IIJA, by building out a complete technical, vocational, education and training system oriented toward building the skills required for the energy transition. We propose a whole-of-government approach that integrates public investment in workforce training to focus on the energy transition and nearshoring with effective approaches to workforce development to address the growing green skills gap that endangers youth employment, the energy transition, energy security and supply chain resilience. 

The Biden-⁠Harris Administration Roadmap to Support Good Jobs demonstrates a commitment to building employment and job training into the Investing in America Agenda. The Roadmap catalogs programs throughout the federal government that address employment and workforce training authorized in recent legislation and meant to enable more opportunities for workers to engage with new technology, advanced manufacturing, and clean energy. Some programs had cross-sector reach, like the Good Jobs Challenge that reached 32 states and territories authorized in the American Rescue Plan to invest in workforce partnerships, while others are more targeted to specific industries, like the Battery Workforce Initiative that engages industry in developing a battery manufacturing workforce. The Roadmap’s clearinghouse of related workforce activities across the federal ecosystem presents a meaningful opportunity to advance this commitment by coordinating and strategically implementing these programs under a single series of objectives and metrics. 

Identifying evidence-driven training programs can also help fill the gap between practicums and market-based job needs by allowing more students access to practical training than can be reached solely by apprenticeships, which can have high individual transaction costs for grantees to coordinate. Additionally, programs like the Good Jobs Challenge required grantees to complete a skills-gap analysis to ensure their programs fit market needs. The Administration should seek to embed capabilities to conduct skills-gap analyses first before competitive grants are requested and issued to better inform program and grant design from the beginning and to share that learning with the broader workforce training community. By using a coordinated initiative to engage across these programs and legislative mandates, the Administration can create a more catalytic, scalable whole-of-government approach to workforce training.

Collaborating on metrics can also help identify which programs are most effective at meeting the core metrics of workforce training—increased income and job placements—which often are not met in workforce programs. This initiative could be measured across programs and agencies by (1) the successful hiring of workers into quality green jobs, (2) the reduction of employer recruitment and training costs for green jobs, and (3) demonstrable decreases in identified skills gaps—as opposed to a diversity of measures without clear comparability that correspond to the myriad agencies and congressional committees that oversee current workforce investments. Better transferable data measured against comparable metrics can empower agencies and Congress to direct continued funds toward what works to ensure workforce programs are effective.

The DOL’s TAACCCT program provides a model of how the United States has successfully invested in workforce development to respond to labor market shocks in the past. Building on TAACCCT’s legacy and its lessons learned, we propose focusing investment in workforce training to address identified skills gaps in partnership with industry, engaging employers from day one, rather than primarily targeting investment based on participant eligibility. When investing in bridging critical skills gaps in the labor market, strategy and programs must be designed to work with the most marginalized communities (including rural, tribal, and Justice40 communities) to ensure equitable access and participation. 

Increased interagency collaboration is required to meet the labor market demands of the energy transition, both in terms of domestic production in the United States and the greening of international supply chains from Mexico to South Africa. Our proposed youth workforce global strategy, the Energy Security Workforce Training Initiative outlined below provides a timely opportunity for the Administration to make progress on its economic development, workforce and climate goals. 

Plan of Action

We propose a new Energy Security Workforce Training Initiative to coordinate youth workforce development training investments across the federal government, focused on critical and nearshored supply chains that will power energy security. ESWT will be charged with coordinating U.S. government workforce strategies to build the pipeline for young people to the jobs powering the energy transition. ESWT will rework existing education and training institutions to build critical skills and to transform how young people are oriented to, prepared for, and connected to jobs powering the energy transition. ESWT will play a critical role in cross-sector and intergovernmental learning to invest in what works and to ensure federal workforce investments in collaboration with industry address identified skills gaps in the labor market for the energy transition and resilient supply chains. Research and industry confirmation would inform investments by the Department of Energy (DOE), Department of Education (ED), Department of Commerce (DOC), and Department of Labor (DOL) toward building identified critical skills through scalable means with marginalized communities in mind. A key facet of ESWT will be to normalize and align the metrics by which federal, state, and local partners measure program effectiveness to allow for better comparability and long-term potential for scaling the most evidence-driven programs.

The ESWT should be coordinated by the National Economic Council(NEC) and DOC, particularly the Economic Development Administration. Once established, ESWT should also involve an international component focused on workforce investments to build resilience in nearshore supply chains on which U.S. manufacturing and energy security rely. Mexico should serve as an initial pilot of this global initiative because of its intertwined relationship with U.S. supply chains for products like EV batteries. Piloting a novel international workforce training program through private sector collaboration and U.S. Agency for International Development (USAID), DOL, and U.S. International Development Finance Corporation (DFC) investments could help bolster resilience for domestic jobs and manufacturing. Based on these results, ESWT could expand into other geographies of critical supply chains, such as Chile and Brazil. To launch ESWT, the Biden Administration should pursue the following steps.

Recommendation 1. The NEC should name an ESWT Initiative Coordinator in conjunction with a DOC or DOL lead who will spearhead coordination between different agency workforce training activities.

With limited growth in government funding over the coming years, a key challenge will be more effectively coordinating existing programs and funds in service of training young people for demonstrated skills gaps in the marketplace. As these new programs are implemented through existing legislation, a central entity in charge of coordinating implementation, learning, and investments can best ensure that funds are directed equitably and effectively. Additionally, this initial declaration can lay the groundwork to build capacity within the federal government to conduct market analyses and consult with industries to better inform program design and grant giving across the country. The DOC and the Economic Development Administration seem best positioned to lead this effort with an existing track record through the Good Jobs Challenge and capacity to engage fully with industry to build trust that curricula and training are conducted by people that employers verify as experts. However, the DOL could also take a co-lead role due to authorities established under the Workforce Innovation and Opportunity Act (WIOA). In selecting lead agencies for ESWT, these criteria should be followed:

  1. Access to emerging business intelligence regarding industry-critical skills—DOC, DOE
  2. Combined international and domestic remit—DOE/DOL, DOC (ITA)
  3. Remit that allows department to focus investment on demonstrated skills gaps, indicated by higher wages and churn—DOC
  4. Permitted to convene advisory committees from the private sector under the Federal Advisory Committee Act—DOC

Recommendation 2. The DOC and NEC, working with partner agencies, should collaborate to identify and analyze skills gaps and establish private-sector feedback councils to consult on real-time industry needs.

As a first step, DOC should commission or conduct research to identify quantitative and qualitative skills gaps related to the energy transition in critical supply chains both domestically and in key international markets — energy efficiency in advanced manufacturing, electric vehicle production, steel, batteries, rare earth minerals, construction, infrastructure and clean energy. DOC should budget for 20 skills gap assessments for critical occupational groups (high volume of jobs and uncertainty related to required, relevant skills) in the above-mentioned sectors. Each skills gap assessment should cost roughly $100,000, bringing the total investment to $2 million over a six-to-twelve-month period.  Each skills gap assessment will determine the critical and scarce skills in a labor market for a given occupation and the degree to which existing education and training providers meet the demand for skills.

This research is central to forming effective programs to ensure investments align with industry skills needs and to lower direct costs on education providers, who often lack direct expertise in this form of analysis. Commissioning these studies can help build a robust ecosystem of labor market skills gap analysts and build capacity within the federal government to conduct these studies. By completing analysis in advance of competitive grant processes, federal grants can be better directed to training based on high-need industry skill sets to ensure participating students have market-driven employment opportunities on completion. The initial research phase would occur over a six-month timeline, including staffing and procurement. The ESWT coordinator would work with DOC, ED, and DOL to procure curricula, enrollment, and foreign labor market data. Partner agencies in this effort should also include the Departments of Education, Labor, and Energy. The research would draw upon existing research on the topic conducted by Jobs for the Future, IYF, the Project on Workforce at Harvard, and LinkedIn’s Economic Graph.

Recommendation 3. Host the Energy Security Workforce Development White House Summit to galvanize public, private, and social sector partners to address identified skills gaps.

The ESWT coordinator would present the identified quantitative and qualitative skills gaps at an action-oriented White House Summit with industry, state and local government partners, education providers, and philanthropic institutions. The Summit could serve as a youth-led gathering focused on workforce and upskilling for critical new industries and galvanize a call to action across sectors and localities. Participants will be asked to prioritize among potential choices based on research findings, available funding mechanisms, and imperatives to transform education and training systems at scale and at pace with industrial transformation. Addressing the identified skills gaps will require partnering with and securing the buy-in of both educational institutions as well as industry groups to identify what skills unlock opportunities in given labor markets, develop demand-driven training, and expanded capacity of education and training providers in order to align interests as well as curricula so that key players have the incentives and capacity to continually update curricula—creating lasting change at scale. This summit would also serve as a call to action for private sector partnerships to invest in helping reskill workers and establish buy-in from the public and civil society actors. 

Recommendation 4. Establish standards and data sharing processes for linking existing training funds and programs with industry needs by convening state and local grantees, state agencies, and federal government partners.

ESWT should lay out a common series of metrics by which the federal government will assess workforce training programs to better equip efforts to scale successful programs with comparable evidence and empower policymakers to invest in what works. We recommend using the following metrics: 

  1. Successful hiring of workers into quality green jobs
  2. The reduction of employer recruitment and training costs for green jobs
  3. Demonstrable decreases in identified skills gaps

Metrics 2 and 3 will rely on ongoing industry consultations—as well as data from the Bureau of Labor Statistics. Because of the diffuse nature of existing skills gap analyses across federal grantees and workforce training programs, ESWT should serve as a convenor for learning between jurisdictions. Models for federal government data clearinghouses could be effective as well as direct sharing of evidence and results between education providers across a series of common metrics.

Recommendation 5. Ensure grants and investments in workforce training are tied to addressing specific identified skills gaps, not just by regional employment rates.

A key function of ESWT would be to determine feasible and impactful strategies to address skills gaps in critical supply chains, given the identified gaps, existing funding mechanisms, the buy-in of critical actors in key labor markets (both domestic and international), agency priorities, and the imperative to make transformative change at scale. The coordinator could help spur agencies to pursue flexible procurement and grant-making focused on outcomes and tied to clear skills gap criteria to ensure training demonstrably develops skills required by market needs for the energy transition and growing domestic supply chains. While the Good Jobs Challenge required skills gap analysis of grantees, advanced analyses by the ESWT Initiative could inform grant requirements to ensure federal funds are directed to high-need programs. As many of these fields are new, innovative funding mechanisms could be used to meet identified skills gaps and experiment with new training programs through tiered evidence models. Establishing criteria for successful workforce training programs could also serve as a market demand-pull signal that the federal government is willing and able to invest in certain types of training, crowding-in potential new players and private sector resources to create programs tailored for the skills industry needs.

Depending on the local context, the key players, and the nature of the strategy to bridge the skills gap for each supply chain, the coordinating department will determine what financing mechanism and issuing agency is most appropriate: compacts, grants, cooperative agreements, or contracts. For example, to develop skills related to worker safety in rare-earth mineral mines in South Africa or South America, the DOL could issue a grant under the Bureau of International Labor Affairs. To develop the data science skills critical for industrial and residential energy efficiency, the ED could issue a grants program to replicate Los Angeles Unified School District’s Common Core-aligned data science curriculum.

Recommendation 6. Congress should authorize flexible workforce training grants to disperse—based on identified industry needs—toward evidence-driven, scalable training models and funding for ESWT within the DOC to facilitate continued industry skills need assessments.

Congress should establish dedicated staff and infrastructure for ESWT to oversee workforce training investments and actively analyze industry needs to inform federal workforce investment strategies. Congress and the Administration should also explore how to incentivize public-private partnerships and requirements for energy, manufacturing, and supply chain companies to engage in curriculum development efforts or provide technical expertise to access tax credits included in the IRA or CHIPS.

Recommendation 7. ESWT could also incorporate an international perspective for nearshored supply chains critical to energy security and advanced manufacturing. 

To pilot this model, we recommend:

  1. Bilateral coordination of federal workforce and training investments across agencies like State, USAID, and DFC: Mexico could serve as an ideal pilot country due to its close ties with U.S. supply chains and growth in the manufacturing sector. This coordination effort should direct USAID and other government funding toward workforce training for industries critical to domestic supply chains for energy security and green jobs.
  2. Two-way learning between domestic and international workforce programs: As ESWT develops effective strategies to address the skills gap for the energy transition, the interagency initiative will identify opportunities for two-way learning. For example, as curricula for eclectic vehicle assembly is developed and piloted in Mexico with support from USAID, it could inform U.S.-based community colleges’ work with the DOL and DOE.
  3. If successful, expand to additional aligned countries including Brazil, India, and South Africa and nations throughout the Americas that source energy and manufacturing inputs for the green economy: ESWT could facilitate scalable public-private partnership vehicles for partner country governments, private corporations, philanthropy, and nongovernmental organizations to collaborate and fund country-dedicated programs to train their energy and climate workforce. This step could be done in conjunction with naming a Special Envoy at the State Department to coordinate diplomatic engagement with partner countries. The Envoy and Coordinator should have expertise and experience in North and South America economic relations and diplomacy, and labor markets economics. Congress could incorporate dedicated funds for ESWT into annual appropriations at State.


The transition from an economy fueled by human and animal labor to fossil fuels took roughly 200 years (1760–1960) and was associated with massive labor market disruptions as society and workers reacted to a retooled economy. Avoiding similar labor market disruptions as we seek to transition off fossil fuels over decades, not centuries, will require concentrated coordinated action. The Energy Security Workforce Training Initiative will overhaul education and training systems to develop the skills needed to reduce greenhouse gas emissions in the labor markets central to long-term U.S. energy security and ensure that supply chains are resilient to shocks. Such a coordinated investment in training will lower recruitment, selection, and training costs for firms while increasing productivity and move people into the middle class with the jobs fueling the energy transition. 

By focusing federal workforce funding on addressing the green skills gap, we will be able to address the human capital challenges implicit in scaling the infrastructure, manufacturing overhaul, and supply chain reconfiguration necessary to secure a just transition, both at home and abroad. By building in critical international supply chains both for manufacturing and energy security from day one, the ESWT Initiative incorporates two-way learning as a means to knit together strategic supply chains through bilateral investments in equitable workforce initiatives. 

Frequently Asked Questions (FAQs)
What can a coordinator/interagency collaboration model offer that existing approaches do not?

Existing investments in workforce development are fragmented and are not oriented toward building the workforce needed to a net-zero carbon world, with secure energy supplies and resilient supply chains. This collaboration model ensures that workforce investments are aligned towards the net-zero carbon by 2050 aim and are targeted to the domestic and international labor markets essential to ensuring that aim, energy security, and supply chain resilience.

Similarly, to the Feed the Future Coordinator, created in 2009 because of global food insecurity and recognizing after the L’Aquila Italy G8 Summit Joint Statement on Global Food Security towards a goal of mobilizing $20 million over three years towards global agricultural and development that we needed a greater focus on food security. 

This role would ensure that programs are aligned around common goal and measuring progress towards that goal. The NEC oversees the work of the coordinator. Ultimately, the Coordinator would work with Congress and the NEC to develop authorization language. 

How would the ESWT function with differing funding sources and agency stakeholders? Does Congress need to authorize this?

Instead of creating a new fund or program requiring congressional authorization, the ESWT strategy would align existing workforce investments across government with the Administration’s aim of net-zero greenhouse gas emissions by 2050.

What evidence is there that workforce training and education can meet the skills gap you identify? What is the risk of failure?

Skills gaps are persistent problems around the world as education and training systems struggle to keep up with changing demands for skills. Simply investing in training systems, without addressing the underlying causes of skills gaps, will not address skills gaps. Instead, investment must be tied to the development of market-demanded skills. In IYF’s experience, this requires understanding quantitative and qualitative skills gaps, developing an industry consensus around priority skills, and driving changes to curricula, teaching practices, and student services to orient and train young people for opportunities.

How does this approach align with current and past legislative priorities?

Our proposed unified approach to workforce development for the energy transition aligns with the priorities of the former Congress’s House Subcommittee on Higher Education and Workforce Investment, the US Strategy to Combat Climate Change through International Development; and the Congressional Action Plan for a Clean Energy Economy and a Healthy, Resilient, and Just America.

How does this approach align with USAID’s priorities?

Systemic workforce approaches that engage the public, private, and civil sectors spur catalytic investments and bring new partners to the table in line with USAID’s commitment to drive progress, not simply development programs. However, there has been little concentrated investment to build the necessary skills for the energy transition. A coordinated investment strategy to support systemic approaches to build the workforce also aligns with USAID’s localization agenda by:

  1. Building the capacity of local Technical Vocational Education and Training systems to develop the workforce that each country needs to meet its zero-emission commitments while continuing to grow its economy. 

  2. Developing the capacity of local organizations, whose mission will be to facilitate workforce development efforts between the public, private and civil sectors. 

  3. Incentivize industrial policy changes to include workforce considerations in the plan to decarbonize.

  4. Creating increased opportunities to generate and share evidence on successful workforce strategies and programs. To keep up with this rapid transformation of the economy, it will be essential to share information, lessons learned, and effective approaches across international, multilateral, and bilateral organizations and through public private partnerships. For example, the Inter-American Development Bank has identified the Just Transition as a strategic priority and is working with LinkedIn to identify critical skills. As Abby Finkenauer, the State Department’s Special Envoy for Global Youth Issues, has long championed, bringing domestic and international lessons together will be critical to make a more inclusive decarbonized economy possible.

Climate-Smart Cattle: US Research and Development Will Improve Animal Productivity, Address Greenhouse Gases, and Hasten Additional Market Solutions


Cattle in the United States release the greenhouse gas methane (known as “enteric methane”) from their digestive systems, which is equivalent to the amount of methane that leaks from fossil fuel infrastructure. Addressing enteric methane in cattle represents an opportunity to reduce the U.S. greenhouse gas footprint by 3% and simultaneously improve cattle productivity by ~6%. However, current solutions only address, at most, 10% of these emissions, and the U.S. has spent under $5m per year on R&D over the past five years to address this critical climate area. 

Pie chart showing how much of the current focus of methane reduction in cattle is focused on cows on feed over grazing cows.

Therefore, to establish long-term U.S. leadership and export competitiveness, we recommend regulatory simplification and an $82m per year U.S. Department of Agriculture research and innovation program. These common-sense recommendations would create a win for producers and a win for the environment by advancing solutions that easily drop into existing farm practices and convert avoided methane into increased milk and meat production.

Challenge & Opportunity

Cattle and other ruminants digest their food via anaerobic (oxygen-free) fermentation. This unique system allows them to digest roughage such as grasses and other forage and transform it into meat and milk. But it also generates methane. Cattle release on average 6% of the calories they eat as methane, a substantial loss in their potential meat and milk productivity. This methane is in addition to the methane emitted by their manure. 

An invisible and odorless gas, methane is a powerful greenhouse gas that is responsible for 0.5°C of the 1°C of modern global warming (based on the 2010-2019 average). One-third of U.S. anthropogenic methane emissions come from cattle and other ruminants. Solutions may be able to be developed that both disrupt enteric methane production while also increasing cattle productivity. That would help reduce global temperatures and provide benefits for both producers and consumers. Currently, there are a few tested and marketable solutions that use chemicals to disrupt methane-creating microbes in the cattle’s first stomach (the rumen). These are important solutions that need to be evaluated for regulatory approval. However, additional research and development must also be done, to help address the majority of emissions that don’t yet have available solutions, particularly from cattle grazing in pastures. Additional work is also needed to continue developing solutions that consistently lead to a productivity benefit. Focused scientific research could deepen our understanding of cattle metabolism, and advance new solutions for reducing enteric methane further.

Progress on this front also requires improved research tools to measure how much methane cattle emit and relate these methane emissions to their productivity and intake of feed and forage. Access to such research tools enables researchers and innovators to develop and evaluate new solutions. Methane emissions rates vary widely between cattle on the same farm of the same breed, as well as across breeds. Currently these tools are expensive and not widely available. For example, the primary tool available measures twenty cattle per day, costs ~$100,000, and can be found at only a handful of research institutions. That presents a practical problem of access not only for producers but also for non-specialist scientific innovators. Making those tools more accessible, for example via fee-for-service centers at leading U.S. Land Grant institutes, would make them more affordable for producers and researchers. That would help unlock the creativity of U.S. innovators, and provide evidence that their solutions have a positive climate impact and are feasible for producers and acceptable to consumers.

Even when new solutions are found and proven, innovators still face a 10-year FDA approval process. This is uncompetitive and restrictive compared to other countries. Since much faster approval is possible in Australia, Brazil, and Europe, innovators have an incentive to launch their products and build their businesses there rather than in the USA. And as climate-aware export markets develop, slow FDA approval will cost U.S. producers market share and market opportunity. We therefore recommend that the FDA be given authority and direction to evaluate new methane-reducing products for safety on an accelerated timeline, while maintaining critical human and animal safety standards. This would help the U.S. position itself as a global leader in a potential multi-billion dollar market while upholding its climate commitments.

Minimizing peak temperatures requires livestock enteric methane research today.

Plan of Action


Total Funds Needed: $50,000,000 per year 

Developing science-based, effective livestock enteric methane solutions depend on a detailed understanding of cattle microbiology as well as practical understanding of what makes solutions easy to adopt. These solutions have the potential to not only decrease enteric methane emissions but could unlock a new frontier of efficiency for the U.S. livestock sector, helping build a more resilient and productive food system. Increasing funding for basic and applied research could accelerate development of new methods, and rapidly build a portfolio of scalable potential solutions. Capacity funding will increase the near- and long-term throughput for solution development and shorten the idea to market timeline for these products. Competitive funding will drive innovation in sectors and geographies that have significant implementation barriers, such as those applicable to pasture operations, and can accelerate adoption of proven solutions. The Committee on Appropriations, has recognized the innovation potential increased public funds can make possible, and has encouraged USDA-NIFA to prioritize advancement of enteric fermentation solutions.  

We recommend competitive and capacity funding within USDA-NIFA, including AFRI, Hatch, Animal Health and Disease, and other programs be appropriated to:

Basic research in livestock methane microbiology to create a knowledge base that will support development of new win-win solutions and accelerate our understanding of host-microbiome interactions.

Applied livestock methane solutions research based on livestock methane biology knowledge. This work should prioritize solutions that reduce methane in new ways; that simultaneously increase the production of milk or meat; and that have the potential to be in a long-duration (e.g. once per year) product formulation compatible with grazing cattle. Such technology already exists for cattle nutrition and disease prevention.

Perform surveys and other social science research to understand barriers and opportunities to low-cost and low-complexity implementation for American producers and ranchers. This research will help guide the development of new solutions and tailor the design and deployment of solutions among the diversity of U.S. operations. Together, this will maximize the global market potential of U.S. innovation.   

We recommend Congress request of USDA a full-accounting and report of its current spending on enteric methane R&D across all its programs.

Cattle Enteric Methane ChallengesFunding & Policy Opportunity
U.S. risks losing global leadership on emissions, export markets, & productivity.Create knowledge, expertise, & research infrastructure for sustained leadership.
Current solutions don’t reduce all emissions and don’t consistently improve production.Fund basic & applied livestock methane research to create wins for producers and the environment.
Access to methane measurement equipment limits solution discovery and development.Create public fee-for-service testing facilities for livestock methane R&D.
Tools don’t exist for producers to affordably measure methane reductions.Fund development of low-cost cow methane measurement technology.
FDA approval for new solutions takes ten years, which is internationally noncompetitive.Support efforts to modernize the FDA, Food Drug and Cosmetic Act to facilitate rapid approval of climate-positive livestock. products
2/3 of enteric methane is from grazing cattle, which lack effective anti-methane solutions.Focus research and public-private partnerships on solutions that fit all cattle management practices.
Practices have upfront costs and producers may be slow to adopt new solutions.Include Enteric methane emissions as part of the Environmental Quality Incentives Program (EQIP).


Funds Needed: $15,000,000 per year

Access to methane test facilities, from the laboratory to the dairy barn, is a bottleneck. It limits how many innovative ideas for solutions can be tested. Only a small number of institutions worldwide have the tools needed to test methane, and outside access to those tools is limited. We recommend funding be authorized and appropriated for innovation-enabling research infrastructure to USDA-ARS through USDA Equipment Grants and USDA-AFRI. This funding would:

Authorize and establish a nationwide network of fee-for-access livestock methane research facilities. This equips the USDA-ARS laboratories with research measurement equipment and technical staff by partnering with U.S. land grant universities that already possess the necessary research cattle management expertise. Joint investment with them and partial support from research users will quickly make the U.S. an international leader in livestock methane research.

Develop a national center for pre-livestock testing and screening of potential products. This will serve as a user facility. Specialized cattle researchers shouldn’t be the only ones who can test new ideas for reducing livestock enteric methane. Accessible facilities can unlock innovation from the U.S.’ world-leading biology researchers. 

Livestock methane production is invisible: current livestock methane measurement equipment costs about $100,000 for a system that measures 20-30 cattle per day.


Funds needed: $15,000,000 per year

What is measured guides innovation and management, and what we measure easily and consistently, we improve. Producers measure milk production on every cow, every day, leading to a 300% productivity increase since 1950. But for all producers and most researchers, livestock methane production is invisible: current livestock methane measurement equipment costs about $100,000 for a system that measures 20-30 cattle per day. We recommend authorizing and appropriating $15 million per year to USDA-NIFA, Division of Animal Systems in order to:

Develop lower-cost measurement systems so every research barn can measure livestock methane. U.S. land grant universities have over ten thousand research cattle. Equipped with measurement systems, they could all provide livestock methane research data.

Develop farm-integrable measurement systems that make methane emissions and costs  visible to U.S. producers, enabling them to experiment and innovate. Methane is a loss for livestock production. If producers can see it, they’ll work to decrease methane and improve their bottom line.

A $15 million annual budget for this technology development will lead to rapid improvements. Part of this would fund interdisciplinary projects that bring engineers from across industry and livestock experts together. We recommend another part be framed as a grand challenge to achieve cost and performance targets connected to a government procurement market-shaping program.


Funds Needed: $2,000,000 per year

Current anti-methane feed additives are regulated as drugs, requiring a ten-year approval process. As European export markets increasingly regulate emissions, this may lead to a lack of competitiveness for U.S. products. To address this, Congress asked the FDA to review options to accelerate the approval of environmentally beneficial additives. One mechanism to shorten the regulatory timeframe of approval is to amend an existing approval pathway which exists for feed additives. Legislation has been introduced (Innovative Feed Enhancement and Economic Development Act of 2023) which would, in part, amend the Federal Food, Drug, and Cosmetic Act to include Zootechnical Animal Feed Substances as a category under the feed additive petition process. This could reduce the approval timeline for environmentally beneficial additives by 5-fold. 

We recommend Congress continue to support the modernization of the U.S. Food, Drug and Cosmetic Act, and authorize and appropriate an additional $2 million per year to the Food and Drug Administration, Center for Veterinary Medicine, for personnel resources and infrastructure to robustly evaluate new anti-methane solutions for safety and efficacy and make new solutions available to farmers.


Funds Needed: No Additional Funding

In a recent survey, fewer than 30% of U.S. producers indicated they would be willing to adopt an enteric methane solution if they had to bear the cost. Government or other funding assistance was the second most important factor influencing the use of potential solutions behind increased productivity. The Environmental Quality Incentives Program (EQIP) is the flagship program administered by USDA- Natural Resources Conservation Service and can provide financial assistance for the implementation of conservation practices, including practices that reduce greenhouse gasses. In order to promote the adoption of enteric methane mitigation solutions, we recommend USDA-NRCS:

Review conservation practice standards to include new enteric methane mitigation solutions when applicable and include mechanisms to incentivize established methods to reduce enteric methane (i.e. lipid supplementation). Encourage regular updating of practice standards to rapidly incorporate new solutions as they are approved for use, and train technical assistance providers on the implementation of enteric methane mitigation strategies.

Frequently Asked Questions
What would the climate impact be of developing anti-methane enteric solutions? How much might we reasonably expect anti-methane solutions to reduce enteric emissions?

Enteric methane is responsible for ~15% or 0.16℃ of current warming. Protein production from animal agriculture is expected to increase in the coming decades to meet increased capita and per capita consumption. Early research on methane mitigating feed additives have demonstrated enteric methane reductions up to 90% in animal trials. Technology nearing regulatory approval has demonstrated 20-30% reductions. However, these solutions aren’t yet applicable to grazing cattle. With increased research and deployment efforts, enteric methane mitigation can help meet future protein demand with fewer animals and reduce overall warming by more than 10%.

Why is reducing enteric emissions a priority through anti-methane solutions rather than just focusing on replacing cattle with plant-based milk and meat?
While consumer behavior and product availability may change over time, current projections indicate that livestock product demand and production will be substantial throughout the coming decades. Therefore, enteric methane mitigation remains a necessary and impactful strategy toward minimizing peak temperatures.
What anti-methane solutions to enteric emissions exist today? What stage are they at?

Today, no products are approved by the FDA to reduce enteric methane emissions. However, some nutritional approaches are effective, including feeding higher amounts of lipids in an animal’s diet, since lipids increase the calories available for the animal, but do not promote methane production. However, lipids can be expensive for producers and to ensure animal health, no more than a few percent of an animal’s diet can come from lipids.

Other products currently being investigated include chemicals and natural products like 3-NOP, seaweed, and even probiotics. While dietary modification for lipids and supplementation with feed additives show promise in feedlot and confined operation settings, none of the emerging solutions are applicable to grazing systems. Research areas of interest include developing breeding strategies for low methane producing animals, anti-methane vaccines, and novel delivery mechanisms for grazing animals.

How does this relate to manure emissions?

Methane emissions from manure are largely dependent on whether the manure is exposed to air (methane producing microbes are not productive in oxygen rich environments). Grazing animals for instance generate very little manure methane, because manure is deposited over large areas and is exposed to open air. In confined operations like large dairies, manure is often flushed with water or scraped into a holding pond before it is applied to fields as fertilizer. These liquid manure lagoons quickly become anaerobic (without oxygen) and are an ideal environment for methane producing microbes.

Some enteric methane mitigation compounds could in theory reduce manure lagoon emissions, however the compounds would have to survive the digestive tract of the animal. It is also possible that some compounds could decrease enteric emissions but increase manure emissions. While this has not been demonstrated, prudent experimentalists include this in research studies. Growing efforts to reduce the methane from large manure lagoons include covering the lagoon and capturing the renewable biogas for use as transportation fuel, or electricity production, or processing the manure to separate the solids from the liquids and composting the solids to reduce emissions.

Using Other Transactions at DOE to Accelerate the Clean Energy Transition


The Department of Energy (DOE) should leverage its congressionally granted other transaction authority to its full statutory extent to accelerate the demonstration and deployment of innovations critical to the clean energy transition. To do so, the Secretary of Energy should encourage DOE staff to consider using other transactions to advance the agency’s core missions. DOE’s Office of Acquisition Management should provide resources to educate program and contracting staff on the opportunity that other transactions present. Doing so would unlock a less used but important tool in demonstrating and accelerating critical technology developments at scale with industry.

Challenge and Opportunity

OTs are an underleveraged tool for accelerating energy technology.

Our global and national clean energy transition requires advancing novel technology innovations across transportation, electricity generation, industrial production, carbon capture and storage, and more. If we hope to hit our net-zero emissions benchmarks by 2030 and 2050, we must do a far better job commercializing innovations, mitigating the risk of market failures, and using public dollars to crowd in private investment behind projects. 

The Biden Administration and the Department of Energy, empowered by Congress through the Inflation Reduction Act (IRA) and the Bipartisan Infrastructure Law (BIL), have taken significant steps to meet these challenges. The Loan Programs Office, the Office of Clean Energy Demonstrations, the Office of Technology Transitions, and many more dedicated public servants are working hard towards the mission set forward by Congress and the administration. They are deploying a range of grants, procurement contracts, and tax credits to achieve their goals, and there are more tools at their disposal to accelerate a just, clean energy transition. The large sums of money appropriated under BIL and IRA require new ways of thinking about contracting and agreements.

Congress gives several federal agencies the authority to use flexible agreements known as other transactions (OTs). Importantly, OTs are defined by what they are not. They are not a government contract or grant, and thus not governed by the Federal Acquisitions Regulations (FAR). Historically, NASA and the DoD have been the most frequent users of other transaction authorities, including for projects like the Commercial Orbital Transportation System at NASA which developed the Falcon 9 space vehicle, and the Global Hawk program at DARPA.

In contrast, the Department of Energy has infrequently used OTs, and even when it has, the programs have achieved no notable outcomes in support of their agency mission. When the DOE has used OTs, the agency has interpreted their authority as constraining them to cost-sharing research agreements. This restricts the creativity of agency staff in executing OTs. All the law says is that an OT is not a grant or contract. By limiting itself to cost sharing research agreements, DOE is preemptively foreclosing all other kinds of novel partnerships. This is critical because some nascent climate-solution technologies may face a significant market failure or a set of misaligned incentives that a traditional research and development transaction (R&D) may not fix.

This interpretation has hampered DOE’s use of OTs, limited its ability to engage small businesses and nontraditional contractors, and prevented DOE from fully pursuing its agency mission and the administration’s climate goals.

Exploring further use of OTs would open up a range of possibilities for the agency to help address critical market failures, help U.S. firms bridge the well-documented valleys of death in technology development, and fulfill the benchmarks laid out in the DOE’s Pathways to Commercial Liftoff.
According to a GAO report from 2016, the DOE has only used OTs a handful of times since they had the authority updated in 2005, nearly two decades ago. Compare the DOE’s use of OTs to other agencies in the four-year period in the table below (the most recent for which there is open data).


From GAO-16-209

Almost every other agency uses OTs at a significantly higher rate, including agencies that have smaller overall budgets. While quantity of agreements is not the only metric to rely on, the magnitude of the discrepancy is significant. 

Other agencies have made significant changes since 2014, most notably the Department of Defense. A 2020 CSIS report found that DoD use of OTs for R&D increased by 712% since FY2015, including a 75% increase in FY2019. This represents billions of dollars in awards, much of which went to consortia, including for both prototyping and production transactions. While the DOE does not have the same budget or mission as DoD, the sea change in culture among DoD officials willing to use OTs over the past few years is instructive. While DoD did receive expanded authority in the FY2015 and 2016 NDAA, this alone did not account for the massive increase. A cultural shift drove program staff to look at OTs as ways to quickly prototype and deploy solutions that could advance their missions, and support from leadership enabled staff to successfully learn how and when to use OTs.

The Department of Transportation (DOT) only uses OTs for two agencies, the Federal Aviation Administration (FAA) and the Pipeline and Hazardous Materials Safety Administration (PHIMSA). Like DOE, the FAA is not restricted in what it can and can’t use OTs for. It is authorized to “carry out the functions of the Administrator and the Administration…on such terms and conditions as the Administrator may consider appropriate.” Unlike DOE, the FAA and DOT have used their authority for several dozen transactions a year, totaling $1.45 billion in awards between 2010 and 2014.


From the GAO chart (Table 1), it’s clear that ARPA-E also follows the DOE in deploying very few OTs in support of its mission. Despite being originally envisioned as a high-potential, high-impact funder for technology that is too early in the R&D process for private investors to support, the most recent data shows that ARPA-E does not use OTs flexibly to support high-potential, high-impact tech.

The same GAO report cited above stated that:

“DOE’s regulations—because they are based on DOD’s regulations—include requirements that limit DOE’s use of other transaction agreements…. Officials told us they plan to seek approval from the Office of Management and Budget to modify the agency’s other transaction regulations to better reflect DOE’s mission, consistent with its statutory authority. According to DOE officials, if the changes are approved, DOE may increase its use of other transaction agreements.” 

That report was published in 2016, but it is unclear that any changes were sought or approved, though they likely do not need to change any regulations at all to actually make use of their authority.1 The realm of the possible is quite large, and DOE has yet to fully explore the potential benefits to its mission that OTs provide. 

DOE can use OTs without any further authority to drive progress in critical technologies.

The good news is that DOE has the ability to use OTs without further guidance from Congress or formally changing any guidelines. Recognizing their full statutory authority would open up use cases for OTs that would help the DOE make meaningful progress towards its agency mission and the administration’s climate goals. 

For example, the DOE could use OTs in the following ways:

Given the exigencies of climate change and the need to rapidly decarbonize our society and economy, there are very real instances in which traditional research contracts or grants are not enough to move the needle or unlock a significant market opportunity for a technology. Forward contract acquisitions, pay for delivery contracts, or other forms of transactions that are nonstandard but critical to supporting development of technology are covered under this authority.

One promising area where it seems the DOE is currently using this approach is in supporting the hydrogen hubs initiative. Recently the DOE announced a $1 billion initiative for demand-side support mechanisms to mitigate the risk of market failures and accelerate the commercialization of clean hydrogen technologies. The Funding Opportunity Announcement (FOA) for the H2Hubs program notes that “other FOA launches or use of Other Transaction Authorities may also be used to solicit new technologies, capabilities, end-uses, or partners.” The DOE could use OTs more frequently as a tool to advance other critical commercial liftoff strategies or to maximize the impact of dollars appropriated to implementation of the BIL and IRA. Some areas that are ripe for creative uses of other transactions include:

This demand-pull would complement other recent actions taken to bolster critical minerals like the clean vehicle tax credit and the Loan Program Office’s loans to mineral processing facilities. Such a consortium could come from the existing critical materials institute or be formed by separate entities.

DOE could use other transactions to further support this nascent consortium and increase the demonstration and deployment of geothermal projects. The agency could also use other transactions to organize the sharing of critical subsurface data and resources through a single entity.

A carbon removal purchasing agreement for the DOE’s Regional Direct Air Capture Hubs could function much the same as the proposed hydrogen hubs initiative. It also could take the shape of a consortium of DAC vendors, nonprofits, scientists, and others managed by a single entity that can set standards for purchase agreements. This would cut the negotiation time among potential parties by a significant amount, allowing for cost saving and faster decarbonization.

DOE could organize an advance market commitment for long-duration energy storage capabilities on federal properties that meet certain storage hour and grid integration requirements. Such a commitment could include the DoD and the General Services Administration (GSA), which own and operate the large portfolio of federal properties, including bases and facilities in hard-to-reach locations that could benefit from more predictable and secure energy infrastructure. Early procurement of capability-meeting but expensive systems could help diversify the market and drive technology down the cost curve to reach the target of $650 per kW and 75% RTE for intra-day storage and $1,100 per kW 55 and 60% RTE for multiday storage.

To use OTs more frequently, the DOE needs to focus on culture and education.

As noted, the DOE does not need additional authorization or congressional legislation to use OTs more frequently. The agency received authority in its original charter in 1977, codified in 42 U.S. Code § 7256, which state:

“The Secretary is authorized to enter into and perform such contracts, leases, cooperative agreements, or other similar transactions with public agencies and private organizations and persons, and to make such payments (in lump sum or installments, and by way of advance or reimbursement) as he may deem to be necessary or appropriate to carry out functions now or hereafter vested in the Secretary.” [emphasis added]

This and other legislation gives DOE the authority to use OTs as the Secretary deems necessary. 

Later guidelines in implementation state that other officials at DOE who have been presidentially appointed and confirmed by the Senate are able to execute these transactions. The DOE’s Office of Acquisition Management, Office of General Counsel, and any other legal bodies involved should update any unnecessarily restrictive guidelines, or note that they will follow the original authority granted in the agency’s 1977 charter. 

While that would resolve any implementation questions about the ability to use OT at DOE, the agency ultimately needs strong leadership and buy-in from the Secretary in order to take full advantage. As many observers note regarding DoD’s expanding use of OTs, culture is what matters the most. The DOE should take the following actions to make sure the changing of these guidelines empowers DOE public servants to their full potential:

  1. The Secretary should make clear to DOE leadership and staff that increased use of OTs is not only permissible but actively encouraged.
  1. The Secretary should provide internal written guidance to DOE leadership and program-level staff on what criteria need to be met for her to sign off on an OT, if needed. These criteria should be driven by DOE mission needs, technology readiness, and other resources like the commercial liftoff reports.
  1. The Office of Acquisition Management should collaboratively educate relevant program staff, not just contracting staff, on the use of OTs, including by providing cross-agency learning opportunities from peers at DARPA, NASA, DoD, DHS, and DOT.
  1. DOE should provide an internal process for designing and drawing up an OT agreement for staff to get constructive feedback from multiple levels of experienced professionals.
  1. DOE should issue a yearly report on how many OTs they agree to and basic details of the agreements. After four years, GAO should evaluate DOE’s use of OTs and communicate any areas for improvement. Since OTs don’t meet normal contracting disclosure requirements, some form of public disclosure would be critical for accountability.

Mitigating risk

Finally, there are many ways to address potential risks involved with executing new OTs for clean energy solutions. While there are no legal contracting risks (as OTs are not guided by the FAR), DOE staff should consider ways to most judiciously and appropriately enter into agreements. For one resource, they can leverage the eight recent reports put together by four different offices of inspector generals on agencies’ usage of other transactions to understand best practices. Other important risk limiting activities include:

  1. DoD commonly uses consortiums to gather critical industry partners together around challenges in areas such as advanced manufacturing, mobility, enterprise healthcare innovations, and more.
  1. Education of relevant parties and modeling of agreements after successful DARPA and NASA OTs. These resources are in many cases publicly available online and provide ready-made templates (for example, the NIH also offers a 500-page training guide with example agreements).


The DOE should use the full authority granted to it by Congress in executing other transactions to advance the clean energy transition and develop secure energy infrastructure in line with their agency mission. DOE does not need additional authorization or legislation from Congress in order to do so. GAO reports have highlighted the limitations of DOE’s OT use and the discrepancy in usage between agencies. Making this change would bring the DOE in line with peer agencies and push the country towards more meaningful progress on net-zero goals.

Frequently Asked Questions
What are some examples of OTs?

The following examples are pulled from a GAO report but should not be regarded as the only model for potential agreements.

Examples of Past OTs at DOE
“In 2010, ARPA-E entered into an other transaction agreement with a commercial oil and energy company to research and develop new drilling technology to access geothermal energy. Specifically, according to agency documentation, the technology being tested was designed to drill into hard rock more quickly and efficiently using a hardware system to transmit high-powered lasers over long distances via fiber optic cables and integrating the laser power with a mechanical drill bit. According to ARPA-E documents, this technology could provide access to an estimated 100,000 or more megawatts of geothermal electrical power in the United States by 2050, which would help ARPA-E meet its mission to enhance the economic and energy security of the United States through the development of energy technologies.

According to ARPA-E officials, an other transaction agreement was used due to the company’s concerns about protecting its intellectual property rights, in case the company was purchased by a different company in the future. Specifically, one type of intellectual property protection known as “march-in rights” allows federal agencies to take control of a patent when certain conditions have not been met, such as when the entity has not made efforts to commercialize the invention within an agreed upon time frame.33 Under the terms of ARPA-E’s other transaction agreement, march-in rights were modified so that if the company itself was sold, it could choose to pay the government and retain the rights to the technology developed under the agreement. Additionally, according to DOE officials, ARPA-E included a United States competitive clause in the agreement that required any invention developed under the agreement to be substantially manufactured in the United States, provided products were also sold in the United States, unless the company showed that it was not commercially feasible to do so. This agreement lasted until fiscal year 2013, and ARPA-E obligated about $9 million to it.”

Examples at DoD
“In 2011, DOD entered into a 2-year other transaction agreement with a nontraditional contractor for the development of a new military sensor system. According to the agreement documentation, this military sensor system was intended to demonstrate DOD’s ability to quickly react to emerging critical needs through rapid prototyping and deployment of sensing capabilities. By using an other transaction agreement, DOD planned to use commercial technology, development techniques, and approaches to accelerate the sensor system development process. The agreement noted that commercial products change quickly, with major technology changes occurring in less than 2 years. In contrast, according to the agreement, under the typical DOD process, military sensor systems take 3 to 8 years to complete, and may not match evolving mission needs by the time the system is complete. According to an official, DOD obligated $8 million to this agreement.”

Are there any restrictions on the use of OTs?

Other interpretations of the statute have prevented DOE from leveraging OTs, and there seems to be confusion on what is allowed. For example, a commonly cited OTA explainer implies that DOE is statutorily limited to “RD&D projects. Cost sharing agreement required.”

But nowhere in the original statute does Congress require DOE to exclusively use cost sharing agreements, nor is this the case at other agencies where OTs are common practice.

However, the Energy Policy Act of 2005 did require the DOE to issue guidelines for the use of OTs 90 days after the passing of the law, and this is where it gets complicated. They did so, and according to a 2008 GAO report, DOE enacted guidelines which used a specific model called a technology investment agreement (TIA). These guidelines were modeled on the DoD’s then-current guidelines for OTs and TIAs, mandating cost sharing agreements “to the maximum extent practicable” between the federal government and nonfederal parties to an agreement.2 An Acquisition/Financial Assistance Letter issued by senior DOE procurement officials in 2021 defines this explicitly: “Other Transaction Agreement, as used in this AL/FAL, means Technology Investment Agreement as codified at 10 C.F.R., Part 603, pursuant to DOE’s Other Transaction Authority of 42 U.S.C. § 7256.” However, the DOE’s authority as codified in 42 U.S.C. § 7256 (a) and (g) does not define OTs as TIAs, the definition is just a guideline from DOE, and could be changed.

What are Technology Investment Agreements?

Technology Investment Agreements are used to reduce the barrier to commercial and nontraditional firms’ involvement with mission-critical research needs at DOE. They are particularly useful in that they do not require traditional government accounting systems, which can be burdensome for small or new firms to implement. But that does not mean they are the only instrument that should be used. The law says that TIAs for research projects should involve cost sharing to the “maximum extent practicable.” This does not mean that cost sharing must always occur. There could be many forms of transactions other than grants and contracts in which cost sharing is neither practicable nor feasible.

Furthermore, the DOE is empowered to use OTs for research, applied research, development, and demonstration projects. Development and demonstration projects would not fit neatly in the category of research projects covered by TIAs. So subjecting them to the same guidelines is an unduly restrictive guideline.

What are consortiums?

Consortia are basically single entities that manage a group of members (to include private firms, academics, nonprofits, and more) aligned around a specific challenge or topic. Government can execute other transactions with the consortium manager, who then organizes the members around an agreed scope. MITRE provides a longer explainer and list of consortia.

Coordinating the U.S. Government Approach to the Bioeconomy


The bioeconomy touches nearly every function of the U.S. government. The products of the bioeconomy compete in an international marketplace and include medicines, foods, fuels, materials, and novel solutions to broad challenges including climate and sustainability. The infrastructure, tools, and capabilities that drive the bioeconomy must be safeguarded to maintain U.S. leadership and to protect against misuse. The vast scale of these issues requires a cross-governmental approach that draws on input and engagement with industry, academia, nongovernmental organizations, and other stakeholders across the bioeconomy. 

To achieve a durable and strategic interagency approach to the bioeconomy, the Office of Science and Technology Policy (OSTP) should establish and Congress should fund a Bioeconomy Initiative Coordination Office (BICO) to coordinate strategic U.S. government investments in the bioeconomy; facilitate efficient oversight and commercialization of biotechnology products; safeguard biotechnology infrastructure, tools and capabilities; and serve as a focal point for government engagement with nongovernmental partners and experts. 

Challenge and Opportunity

Executive Order 14081, “Establishing a National Biomanufacturing and Biotechnology Initiative,” was released in September 2022. Since then, OSTP has worked to coordinate this Initiative and has made significant progress with the March 2023 release of “Bold Goals for Biotechnology and Biomanufacturing,” which describes how government agencies will support and benefit from investments in the bioeconomy; an implementation plan is forthcoming. EO 14081 also initiated interagency efforts to better measure and track the bioeconomy, prepare the regulatory system for future biotechnology products, and establish a Biosafety and Biosecurity Innovation Initiative. Although these efforts are laudable, we need a more strategic, longer-term, and outward-facing approach to ensure that the United States remains the world leader in biomanufacturing and biotechnology development. Expert reports over several years, including those from the National Academies, support the formation of strategic coordinating body within the U.S. government that focuses on the bioeconomy and more strategic planning for its investments in these areas.

The CHIPS and Science Act of 2022 provides a critical opportunity for improved interagency coordination. Division B, Title IV calls for the formation of a National Engineering Biology Research and Development Initiative coordinated by an interagency committee, co-chaired by OSTP, and supported by an Initiative Coordination Office (ICO) with a director and full-time staff. This bill stipulates that this coordination office should:

A recent bipartisan letter from Congressman Jake Auchincloss of Massachusetts confirms Congress’s intent that the ICO described in the legislation incorporate the Initiative as described in Executive Order 14081.

An ICO focused on the bioeconomy would be analogous to other congressionally mandated National Coordination Offices that drive effective interagency coordination at OSTP, including those for the U.S. Global Change Research Program (USGCRP), the National Nanotechnology Initiative (NNI), and the Networking and Information Technology Research and Development (NITRD) Program. These offices have several features in common, including:

Now is the time for OSTP to establish and for Congress to fund a durable and well-staffed Bioeconomy Initiative Coordination Office (BICO) that leads ongoing, strategic, interagency coordination across the government to support the bioeconomy. The BICO should not replace current interagency committees and processes. Instead, it should coordinate bioeconomy-related efforts that reach across multiple domains, ensure a durable and long-term approach to the bioeconomy, and serve as a focal point and doorway for U.S. government engagement with industry, academia, and other stakeholders. 

Plan of Action

OSTP should establish the BICO within the next year. Its focus should be on (1) biomanufacturing, including infrastructure and capacity, pre-competitive industry issues (e.g., standards), and workforce; and (2) development and commercialization of biotechnology products, tools, and capabilities, with a particular focus on those developed for nontherapeutic uses. The interagency committee that drives the BICO should be established under the National Science and Technology Council, should be co-chaired by OSTP and the Department of Commerce, and should include as participants every agency listed in EO 14081, including:

Congress should provide an appropriation of at least $4 million per year to ensure funding for at least six full-time employees (director, lead for strategic planning and assessment, lead for regulation, lead for safeguarding, outreach coordinator, and administrator), plus office expenses, events, outreach, and other costs. Absent a specific appropriation from Congress, the BICO should follow the funding model of other congressionally mandated coordination offices, including the USGCRP and the NITRD Coordination Office: each participating agency would contribute a small percentage of its total expenditures on biomanufacturing and biotechnologies to support the BICO.

The office should be tasked with:

Strategic Planning

To maintain U.S. leadership in the bioeconomy, the federal government has made significant investments in biomanufacturing and biotechnology development over many years, and EO 14081 provided an important step toward a more strategic approach to these investments. However, we need a more robust and ongoing structure that incorporates opportunities for assessment of the rapidly changing bioeconomy and iteration of planning activities. The BICO should coordinate a strategic approach that includes:

To generate an accurate National Bioeconomy Assessment and ensure that it captures updated, relevant information, the BICO should actively seek external stakeholder input and engagement that includes academia, industry, manufacturing institutes (such as BioMADE or NIIMBL), state and local governments, nongovernmental organizations, and others. In addition to informing federal investment in the bioeconomy, this ongoing assessment will be valuable for other activities within the BICO by providing insight into the types of novel products that regulators might expect to see and highlighting priority topics for outreach and engagement on safeguarding biotechnology tools and capabilities. If a Living Evidence approach is not feasible, then National Bioeconomy Assessments could be generated in a more traditional format, with publication of updated assessments at regular intervals (e.g., every three years, offset from the strategic planning publication cycle).

A “Single Door Approach” for the Biotechnology Regulatory System

For the bioeconomy to flourish, the biotechnology regulatory system must allow low-risk products to be developed and marketed quickly and efficiently. At the same time, regulatory oversight is essential to identify and limit risks to human health and the environment. The BICO should establish and support a “single door approach” for the biotechnology regulatory system to reduce ambiguities and uncertainties in the system and to better prepare the regulatory agencies for future products. (See FAQs for more information.)

An effective single door approach requires robust interagency coordination that includes OSTP and high-level decision makers from each of the primary regulatory agencies: Environmental Protection Agency (EPA), Food and Drug Administration (FDA), and U.S. Department of Agriculture (USDA). Future biotechnology products will include a wide range of applications in the environment, so governmental entities responsible for environmental protection should also be included in this interagency process, including U.S. Fish and Wildlife Service, the National Marine Fisheries Service, and the Council on Environmental Quality. These groups have rarely engaged on issues related to the use of genetically engineered organisms in the environment but should prepare for this type of decision-making. Representation in this interagency process should include lawyers from the Offices of the General Counsel of EPA, FDA, and USDA who can work together within a reasonable time frame (e.g., three months) to determine which agency should lead when novel products arise. To support this single door approach, the BICO should:

When possible and as experience is gained, the BICO should work with the agencies to distill generalizable principles or summaries of decisions to provide guidance to product developers and the broader bioeconomy on how different types of products are likely to be regulated. 

Safeguarding the Bioeconomy

As the bioeconomy grows, the United States must ensure that its investments are protected and that biotechnology tools and capabilities are not accidentally or intentionally misused. In addition to coordinating discussions among U.S. government agencies on these topics, a key role for the BICO will be to conduct outreach and engagement with the broader bioeconomy community. There are several areas where outreach, particularly to industry partners, will be critical to maintaining U.S. competitiveness and leadership in the bioeconomy. Many industry standards and practices are not well-established, and there are opportunities for the federal government to work with industry partners to protect U.S. assets and keep biomanufacturing and biotechnology development securely within the United States. The BICO, in collaboration with the National Security Council, should facilitate engagement on topics such as:

Safeguarding the bioeconomy also requires a process to better understand the potential for accidental or deliberate misuse of biotechnology tools, services, and capabilities to cause harm, and to support development of resources and best practices to reduce these risks. The BICO should develop an engagement strategy that includes opportunities for public discussion of risks related to misuse and strategies to reduce those risks; a publicly accessible portal for experts outside the government to raise concerns or suggest topics for further scrutiny; and a protected venue in which companies can securely share more sensitive information about business products, interactions, or practices. The BICO will maximize the benefit of this forum by conducting outreach and raising awareness of these opportunities, particularly by targeting industry partners. 

Currently, the U.S. government does not have a venue or forum for multi-stakeholder engagement on risks related to potential misuse of biotechnology tools and capabilities. As the bioeconomy grows, a wide range of tools and capabilities will be developed to make biology easier to engineer, including many enabled by artificial intelligence. Accidental or deliberate misuse of these rapidly expanding capabilities could pose risks that will be difficult to anticipate and mitigate. By establishing a process for ongoing and robust engagement to better understand and manage these risks, the BICO can help address these biosecurity needs.


By establishing the BICO as a focal point for coordination among the interagency community and outreach to the broader bioeconomy, OSTP can ensure a long-term and robust U.S. government commitment to biomanufacturing and biotechnology. This commitment includes a strategic approach to investments that can be tracked over time, improvements to the regulatory system that will enable safe and useful products to be more easily commercialized, and activities and engagement to better safeguard advances in the bioeconomy. With appropriate funding, the BICO will form the foundation for a true cross-governmental approach that will ensure U.S. leadership and competitiveness and will ultimately enable the bioeconomy to flourish.

Frequently Asked Questions
Why should the BICO be established at OSTP instead of another agency? Are there alternatives?

Because OSTP is part of the Executive Office of the President, there is a risk that establishing the BICO at OSTP will make it vulnerable to changes in funding or priorities, particularly during presidential transitions. However, there are several reasons for the BICO to be at OSTP. A critical factor is that the CHIPS and Science Act names OSTP as co-chair for the interagency engineering biology initiative that is described in the Act. Executive Order 14081 also names OSTP as a key point of coordination for U.S. government activities on the bioeconomy. Some aspects of the bioeconomy, particularly the regulation of biotechnology, have been coordinated by OSTP for decades. Furthermore, OSTP plays a key role in multiple science- and technology-rich initiatives that are supported by Coordination Offices, including the USGCRP, NITRD, and NNI.

If it is not feasible for OSTP to establish the BICO, coordination could be established by lead agencies that are committed to supporting the bioeconomy. A model for this type of coordination is the Wildland Fire Leadership Council, which is established by a Memorandum of Understanding among the Secretary of the Interior, Secretary of Agriculture, Secretary of Defense, and Secretary of Homeland Security. However, to capture the full scope of coordination that is needed for the bioeconomy, this approach may require negotiation of multiple MOUs among different sets of government agencies.

Why is a single door approach needed for the biotechnology regulatory system?

Currently, the U.S. government regulates biotechnology products based on the Coordinated Framework for the Regulation of Biotechnology, established in 1986 and most recently updated in 2017. Under this system, agencies regulate biotechnology products based on their product-based authorities (e.g., drugs are regulated by FDA; pesticides are regulated by EPA). However, there are gaps, ambiguities, and uncertainties in the regulatory system that will be compounded by the accelerating pace of biotechnology development, expanding range of applications, and potential novelty of new products. Often, developers of novel products struggle to determine which agency (FDA, EPA, or USDA) has primary responsibility for regulation of their product and can receive conflicting information from the agencies over the course of months or years. Several reports, including from the National Academies and from PCAST, have called for improved interagency coordination and a single door approach to the regulatory system that would enable product developers to contact a single entity within the U.S. government and receive an actionable answer about their product’s regulatory path. Importantly, this approach will not require changes to the underlying statutes that define regulatory authorities or to the regulations that define how these authorities are applied. Instead, it calls for efficient decision-making among the agencies to decide which agency will take the lead for novel products as they arise.

How would the portal for product developers be implemented for the single door approach?

To use the single door approach, product developers would submit basic information about their products for the regulatory agencies to consider. At its simplest, this portal could be a submission system similar to that used by the federal government when requesting information from the public through (though product developer submissions would not be released publicly). A more secure system could be modeled on the Case Management System used for companies to share documents with the Committee on Foreign Investment in the U.S.

What else could the BICO do to improve the biotechnology regulatory system?

A more robust interagency process could also drive efforts to better harmonize regulatory approaches across agencies. For example, in 2017 the National Academies recommended ways the agencies could streamline oversight of familiar and low-risk products while focusing resources on products that are novel or require more complex risk assessments. The BICO should facilitate coordination on these topics, including progress agencies have made since 2017, lessons learned, and opportunities for improvements. The BICO should also conduct horizon scanning activities (e.g., as part of its National Bioeconomy Assessment or in public meetings focused on specific product types) so that regulators can best anticipate novel products and prepare for future decision-making. Expert groups, including PCAST, have also identified a need for training of regulators and opportunities for engagement between regulators and the broader bioeconomy; the BICO will be well-positioned to coordinate these activities.

How would the BICO fit into policy development for DNA synthesis screening?

DNA synthesis is one type of biotechnology for which the risks of misuse are well described, frameworks for reducing risk are already being developed and applied (including the 2010 HHS Screening Framework Guidance and efforts toward international harmonization), and best practices among responsible companies are established. An interagency process to update the Screening Framework Guidance is nearing completion; this process would have benefited from additional opportunities for engagement between the U.S. government and the DNA synthesis industry. The BICO should provide a forum for this type of engagement in support of future policy development.

Training for Safety and Success: Research & National Minimum Training Standards for Law Enforcement


Law enforcement is a highly visible profession where, without effective training, safety is at risk for both law enforcement officers and community members. Officers regularly respond to calls for service with uncertain risk factors and must balance the work with proactive activities to improve community well-being. Nationally, mandated training hours for new law enforcement officers are consistently less than those required for cosmetology licensure, with training quality and requirements varying significantly by state. Nearly three-quarters of states allow officers to work in a law enforcement function before completing the basic academy. Public trust and safety are placed in the hands of law enforcement officers, even if they lack the training, skills, and knowledge to be successful. Policing practices are regularly shaped by failures shown in national media, yet the shift in practices is rarely institutionalized in basic training practices.

To make communities safer and law enforcement officers more successful, the Biden-Harris Administration should fund research on the effectiveness of law enforcement training and create a national minimum standard for entry-level academy training to further support the Safer American Plan. The 2022 Executive Order on Advancing Effective, Accountable Policing and Criminal Justice Practices to Enhance Public Trust and Public Safety focuses on strengthening trust between communities and law enforcement officers, including training and equitable policing. The Department of Justice should oversee this research, and the Departments of Homeland Security, Labor, and Commerce can help create national standards and minimum training recommendations. Based on the findings and using pedagogical approaches for the most productive learning, minimum national training standards will be recommended by an interdisciplinary federal task force. Training can be used to compel change in law enforcement, improve community-police relations, and reduce liability while advancing community safety.

Challenge and Opportunity

Law enforcement actions have widespread implications due to the immense power and inherent risks associated with the position. The profession is plagued with complexity and unpredictability, further challenged by extensive discretionary capabilities and varied training requirements. Basic academy training is the foundational coursework for learning about laws and ethics, technical skills relating to actionable law enforcement functions, soft skill development, and honing critical thinking during stressful situations. However, more focus is placed on didactic portions with practical exercises than on cognitive, emotional, and social skills, which can be used to safely de-escalate situations. Even with these known training insufficiencies, academy training topics and hours are rarely updated. Training requirements and pedagogical approaches administered by peace officer standards and training or similar overseeing bodies generally require legislative updates to update curriculum standards, taking significant time and resources to enact change.

Back in 2015, President Obama highlighted the need for training and education in the 21st Century Taskforce on Policing, citing that law enforcement officers (LEOs) are required to be highly skilled in many operational areas to meet the wide variety of challenges and increasing expectations. The Biden-Harris Administration has vowed to advance effective, accountable policing through the Safer America Plan, noting that change at the local and state level requires congressional action. The Safer American Plan would provide funding for 100,000 additional LEOs, all of whom will require training to be effective in their role. Academy training requirements are not regularly collected or monitored at the federal level, and research is not routinely completed to show the efficacy of the training provided. The lack of data on law enforcement actions further complicates the training process, as the time spent during patrol is not regularly cataloged and reviewed to determine where officers spend most of their time. Data showing where officer time is spent can guide training decisions and adjust hours to provide skills for the most commonly utilized skill sets. 

There is no national training standard for LEOs: state requirements vary from 1345 hours in the basic academy in Connecticut to 0 hours in Hawaii. The basic academy provides future LEOs foundational knowledge and skills in law, defensive tactics, report writing, first aid, communication, and other critical skills. The average length of basic training is 833 hours, with an average of 73 hours dedicated to firearm skills and 18 hours to de-escalation techniques. While firearm familiarization and skills are of utmost importance due to the fatal consequences of not understanding the weaponry and one’s ability, the discharge of a firearm occurs significantly less than de-escalation and other communication techniques. When not used regularly, skills become perishable, and the lack of regular training on topics like firearms and traffic stops can reduce an LEO’s efficiency, response time, and safety. The 2022 Executive Order on Advancing Effective, Accountable Policing mandates training federal LEOs with clear guidance on use-of-force standards and implicit bias, but these basic tenets of policing requirements are not extended to state and local law enforcement.

Thirty-seven states allow LEOs to work before they have completed a basic training academy. The time LEOs can work before receiving basic training ranges from 3 months in West Virginia to 24 months in Mississippi. There are obvious dangers to LEOs and the public by providing a uniform and firearm to an untrained person to interact with the community in a position of power. Figure 1 shows the ranges of when the basic academy is required of new LEOs.

Figure 1

With the basic academy averaging 833 hours, or about 21 weeks, it may seem like a sufficient timeframe to train new law enforcement officers. However, it commonly takes at least six months to master a new skill, with the academy requiring many new skills to be developed simultaneously. The minimum basic academy hour requirement in California is 664 hours, though the training is commonly over 1000 hours. By contrast, earning a cosmetology license in California has more extensive hour requirements than the basic police academy, with cosmetology and barber training requiring 1000 hours for state licensure. While injuries can occur in cosmetology, the profession is inherently safer for the practitioner and the client. 

FBI Director Wray noted a 60% increase in murders of law enforcement officers in 2021, explicitly noting that violence against law enforcement officers does not receive as much attention as it should. Of the 245 LEOs who died in the line of duty in 2022, 74 were feloniously killed, up from 48 in 2019. In 2022, 1194 people were killed by LEOs, with 101 people being unarmed. Black people are disproportionately killed by LEOs, at nearly triple the population rate. The statistics of community members killed do not differentiate between legally justified uses of force and illegal actions, so a true picture of potential training concerns versus ethical violations cannot be determined. 

Recognizing the insufficiencies of current LEO training raises opportunities for data-driven improvements. Research is needed to determine the efficacy of the basic academy training in each state, with comparisons made to provide an overall recommendation for minimum national standards. Innovation should be encouraged when developing future training standards, as the basic academy training has not embraced technology or newer learning techniques that may aid in practical decision-making and skill mastery.

Plan of Action

Training can be used to implement vital reforms in law enforcement, potentially saving lives. A multipronged, transparent approach is needed to determine the efficacy of current training before introducing innovation and minimum training standards. Multiple agencies will need to collaborate to complete the evaluation and create recommendations to incorporate inclusive views through multifaceted lenses and coordinate future actions. Transparency of the research and its goals, including making findings available on public-facing websites, is needed for accountability and to foster trust in the process of improving law enforcement. Additional detail of the proposed agencies and their roles is below.

Department of Justice (DOJ)The DOJ is responsible for protecting civil rights, upholding the law, and keeping our country safe. The DOJ houses the Office of Justice Programs and Community-Oriented Policing Services, which will be instrumental in this project.

The DOJ should be the principal agency, as the Office of Justice Programs has a structure for creating, reviewing, and awarding grants. The DOJ can also spearhead the evaluation efforts either internally or through grant proposals for the components of the project and the overall assessment.
Department of Homeland Security (DHS)The DHS focuses on crime prevention and safety at our borders, including monitoring security threats and strengthening preparedness.

The DHS oversees Federal Law Enforcement Training Centers (FLETC). FLETC trains federal law enforcement personnel to assist with improving safety across the nation. FLETC can assist in the review of current state training practices and provide recommendations for national training minimums. While federal and local law enforcement focuses vary, safety, ethics, and communication are top priorities in both training communities.
Department of Labor (DOL)The DOL is the primary agency for labor and workforce concerns. The DOL should provide input on national training standards and programs.
Department of Commerce (DOC)The DOC oversees the National Institute of Standards and Technology (NIST). NIST works to advance science through the creation of standards to enhance innovation and promote inclusivity.

NIST should be the principal agency to create the nationally recommended standards for LEO training through its multidisciplinary process with input from DOJ, DHS, and DOL. The standard should also go through a standards-developing organization (SDO) to build consensus and due process.

Recommendation 1. Fund research for current LEO training and efficacy

Before overhauling training, data is needed to provide a baseline of training in each state, including its perceived efficacy by stakeholders. The DOJ should create and administer competitive grants to evaluate current training in every state/territory and complete surveys, interviews, and focus groups with stakeholders to determine the impact of training. Use-of-force incidents, accidents, LEO decertification, and other aspects of potential training deficiency should be examined for additional insight into effectiveness. 

Research should also be conducted on fatal and accidental duty-related incidents to determine the human and other contributing factors. Data and trends gained from the research should be incorporated into minimum training standards to reduce future errors. Competitive grants can be provided to evaluate potential root causes of duty-related fatal and accidental deaths.

A key component of the research phase will be bringing the researchers together to discuss findings, regional and national trends, and recommendations. Creating a formal networking  process will allow for best practices to be shared across all states/territories participating and made available to all LEO training commissions. 

Recommendation 2. Spark innovation from adult learning experts and practitioners for LEO training

Through a competitive grant process, the DOJ’s Office of Justice Programs can advertise funding opportunities and outline the application process. Grants focusing on practitioners and adult learning experts in collaboration, potentially through practitioner-higher education partnerships, can assist in bringing the necessary experience from the field and adult learning. Curriculum designers should consider immersive or simulation training experiences and the use of technology in training. In addition, they should consider redesigning the rigid paramilitary format to encourage LEOs to utilize critical thinking skills, improve adaptability, and hone communication skills. Using can also provide additional insights from the community. 

Recommendation 3. Create national minimum standards for LEO basic academy training

Using the recommendations from the state law enforcement training researchers, the fatality factor researchers, practitioner and adult learner experts, FLETC, and DOL, a compilation of recommendations from NIST, DOJ, DHS, DOC, and DOL of national minimal standards should be completed. Requirements for academy instructors will also need to be established, including training program requirements and regular reviews of their performance and impact. NIST will use the information gathered, including contemporary training topics and a focus on adult learning techniques, and create a draft standard. The research teams and the public will have an opportunity to comment on the draft standards, then NIST will adjudicate the comments before sending the standards to an SDO for additional feedback for a quality, peer review. 

The DOJ’s Office of Justice Programs will offer grants to all interested state LEO training bodies to adhere to the national minimum standard, with funding for planning, Implementation, and evaluation of the project. Grants should require a three-year timeline for implementation to ensure trainees receive training before their first day on the streets and the basic academy meets the minimum national requirements.

Recommendation 4. Evaluate curricula changes with environmental changes

Grant funding for the planning and implementation should extend an additional two years for the evaluation component. Evaluators chosen during the grant process can review how well training adheres to the national standards across all academies in the state, LEO feelings of preparedness upon graduation and quarterly after that for up to two years, and supervisor/administrator feedback on LEO performance after the academy. Deidentified records of unjustified use-of-force, decertification, and criminal actions can be reviewed for additional insight into the effectiveness of the basic academy training.

An overall program evaluation will be needed, including reviewing the state evaluations and the overall administration of the project. The grant can be open to one organization or multiple organizations with the selection and funding provided by DOJ’s Office of Justice Programs. Competitive grant funding for up to $5 million should be awarded for the six-to-eight-year evaluation.

Budget Proposal

A budget of $125 million is proposed to evaluate current LEO training, develop minimum requirements, and evaluate the implementation. The primary research of determining current LEO basic academy training and efficacy requires $500,000 for one researcher/research group per state/territory, totaling $28 million.

For the adult learning and practitioner component, competitive grants for up to 10 collaborations should receive up to $300,000 each, totaling $3 million. FLETC and DOL can be funded for their participation in the minimum standard creation at $1 million each, totaling $2 million. 

Each state LEO training commission should be eligible to receive up to $2 million each to plan, implement, and evaluate the minimum training standards. If all states/territories participate, the funding will total $112 million.

An evaluation of the entire program will be conducted for $5 million for six to eight years of expected evaluative work. The final report will be provided to the DOJ to determine if performance metrics were met. 


The national LEO training standard is meant to be the floor of training for states and does not remove the oversight of state peace officer training commissions. Every LEO should go through a basic academy and field training before serving the community to ensure they can be safe and effective in their roles. Developing innovating training techniques can help increase skills and understanding of vital topics while refining critical thinking skills in high-stress situations. Minimum training standards can improve safety for the public and first responders, reduce ethical and criminal violations by LEOs, and assist in repairing community-police relationships.

Frequently Asked Questions
Does the federal government have legal oversight of law enforcement training?

No. The 10th Amendment restricts the federal government from mandating standards, but federal grant funding can be restricted from states that do not meet the minimum training mandates. Precedence was made with DOJ’s Community Oriented Policing Services grants, which restrict federal funding if the agency’s use-of-force policy does not adhere to federal, state, and local laws.

Why shouldn’t states update their requirements independently?

States can update their training requirements at their will. States may be incentivized with federal grant funding, rather than waiting for unfunded and underresourced local attempts. Change involving many or all states can create pressure to conform to minimum requirements where there is currently little pressure with no financial incentives offered.

Are there any current federal efforts to initiate changes to state law enforcement training?

In December 2022, the House passed S.4003 Law Enforcement De-Escalation Training Act of 2022. The bill provides $34 million to the Department of Justice to fund scenario-based training for de-escalation and use-of-force for individuals experiencing a mental, suicidal, or behavioral crisis.

Stemming from the deaths of two unarmed Black men, HR 1280 and HR 1347 requested additional training and standards to reduce excessive force by LEOs. HR 1280 passed the House, and HR 1347 was introduced to the House with no actions since 2021.

How does LEO training in the United States compare to training internationally?

LEO training in the United States is among the lowest in the world, with France training LEOs for 10 months or 1600 hours, Scotland’s basic training lasting for 92 weeks or 3680 hours, India for 2.5 years or 5400 hours, and Finland for three years or 6240 hours, with an additional year of field training.

What about continuing education or professional development for LEOs?

Most states require continuing education or professional development. Hawaii has no LEO training requirements, and New Jersey law states agencies may provide in-service training without hourly requirements. Once minimum standards for basic training are implemented, national minimum mandatory annual continuing education or professional education can be developed.

How will the effectiveness of training be measured?

The first recommendation requests funding to assess and determine the current efficacy of law enforcement training in every state. The multistage research would include interviews, surveys, and focus groups with stakeholders to determine training perceptions and impact, while a comparison is made using data from use-of-force incidents, officer decertification, accidents, fatal incidents, and other areas of potential training deficiency.

Protecting Consumers by Reforming Food Labeling Regulations


The Biden-Harris Administration has consistently prioritized consumer protectioninvigorating rural communities and natural technologies that address climate change. These three priorities are embodied in this proposal and present an opportunity for a bipartisan win-win. Agriculture directly connects rural Americans with urban ones and is central to practical climate solutions. But as biotechnology advances, consumers face a myriad of new ingredients and labels to parse through at the supermarket. These labels, including ‘organic’ and ‘non-GMO,’ can often be confusing. There are competing views about the proper regulatory framework that will provide the highest nutrition to the most citizens at the lowest possible cost while respecting the environment. Comprehensive food labeling regulation reform can help consumers avoid deceptive marketing and allow farmers and grocers to compete fairly. In addition, it can be a tool to leverage the marketplace to implement climate-friendly solutions.

There are two possible approaches to implementing this reform: The best alternative would be to pass legislation that expands the BE labeling program, enhancing the labeling authority of USDA, strengthening Truth-in-Advertising laws, and providing a legal framework to address misleading claims across Federal agencies. Alternatively, the Federal Trade Commission (FTC) is already empowered to enforce existing Truth-in-Advertising laws. It can use this authority to reinforce the USDA’s existing labeling programs to ensure that consumer information aligns with scientific evidence. 

Challenge and Opportunity

In the past 50 years, the idea of “health foods” has gone mainstream. Despite the lack of hard scientific evidence, the term has morphed from denoting foods that help individuals avoid diet-related diseases to marketing foods that claim to help every American live healthier. This change in the market has also generated healthy profit margins for certain grocery retailers.1 But the distinction is more than marketing—most physicians now agree that there is a strong relationship between diet and disease based on scientific evidence. For example, scientific communities agree that specific ingredients like saturated fats can affect health. To ensure consumers can make informed choices about these ingredients, their presence is explicitly listed on the FDA’s nutrition labels.

Unfortunately, the zealous proponents of health foods have gone beyond advocacy of ingredients the medical establishment deems “healthy.” Foods whose heritage can be traced to intentional genetic modification in a modern laboratory are ominously labeled as “genetically modified organisms” (GMOs). Although this label has taken on a negative connotation, it’s simply a descriptor and, by itself, cannot convey whether or not a product is “healthy.” Such labeling is like singling out children born using modern in vitro fertilization and treating them differently than children conceived “naturally”! Conflating the nutritional composition of food with its genetic heritage allows marketers to extract a premium for foods labeled “non-GMO” while failing to acknowledge the actual health benefits of some GMOs.

In 2016, Congress established the National Bioengineered Food Disclosure Standard (NBFDS), a US federal law that mandates “BE” labeling for bioengineered foods. These foods contain genetic material not accessible via breeding, added using in vitro recombinant DNA techniques. This law empowers USDA to specify whether ingredients should be labeled BE depending on their supply chains and to define analytical tests that establish whether labeling is necessary. These analytical tests allow the agency to define bioengineered products precisely. While GMO and BE foods may overlap, the two labels are inconsistent and have different criteria specified by different organizations. 

Science has weighed in on GMO/BE foods, and numerous studies have shown no health risks associated with the consumption of GMO/BE foods.2 Indeed, bioengineering improves the nutritional content of some foods. For example, low linoleic acid canola oil has less trans-fat, a dietary component associated with increased rates of heart disease. In such cases, the nutritional differences are reflected on food labels following FDA guidelines. In addition, bioengineering can reduce the number of agricultural chemicals needed to prevent spoilage, eliminating potentially toxic residues and food waste. But marketers of “health(y) foods” have spent millions to support “non-GMO” labels that are unrelated to health while continuing to sow irrational fears to help maintain their margins.

To make matters worse, marketers have added to the confusion by labeling certain foods with another vague descriptor, “organic”. Organic farming is a cultivation practice that avoids synthetic pesticides and artificial fertilizers. It is how the crops are grown, not what. But even the USDA’s National Organic Program (65 FR 80547. 12/21/2000)3 conflates the two, specifying that even animals fed with GMO feed cannot be labeled USDA Organic! From a scientific perspective, it is inaccurate to consider any GMO an “ingredient” because the genes themselves are present in minuscule amounts and can be fully digested. The changes are in the code, not the composition. They are made up of natural building blocks, as are the proteins produced.

Further, because farm animals digest food to these components, any “pass-through” of GMO characteristics would require extraordinary proof. While it is impossible to prove a negative, there is no evidence of adverse consumer reactions (even among those with severe food allergies) to GMOs themselves. For this reason, USDA’s BE designation expressly excludes animals fed with bioengineered foods (NBFDS, Sec 293(a)(2)(A)]. The current regulatory regime around bioengineered foods, organic farming, and GMOs is inconsistent and requires reform. Consumers deserve objective and relevant information about the foods they consume, but current sources of information can be inaccurate or incomplete.. As consumers have become more health- and origin-conscious, corporations have seized on this awareness to promote their products. Unfortunately, health(y) food marketers often use scientifically tenuous and potentially deceptive labels. Corporations fund academic researchers and non-governmental organizations to conduct independent research to legitimize these marketing messages, often as philanthropic, tax-advantaged donations.

While such funding is not necessarily nefarious, it can confuse consumers and undermine more trusted and objective sources of nutrition information – federal agencies. The Government’s responsibility is to provide accurate ratings that support fact-based competition. Free and fair competition in the marketplace has long been the objective of Federal regulations. While corporations should be allowed to differentiate their goods in the eye of the consumer, they shouldn’t be allowed to instill irrational fear of health hazards lacking robust scientific support. This is not unique to the agricultural industry – in fact, it is the core of the regulatory framework for pharmaceuticals.

Corporations currently exploit the hodgepodge rating system, but it can be improved through Government regulation. As shown in the figure, surveys show that U. S. consumers trust Government ratings more than any other source except for “experts” and find such ratings to be more understandable, particularly in contrast to those expressed by experts.

Figure 1

Data from Rupprecht, CDD, et al., “Trust me? Consumer trust in expert information on food product labels”, Food and Chemical Toxicology 137 (2020) 111170,

There is an opportunity for regulatory improvement in the food labeling space, both legislatively and through executive action. Because USDA labeling covers agricultural food sources (including Bio-Engineered and Organic labels), adding a non-Bio Engineered label would further enable consumers to make an informed choice. The dissonance between BE and USDA Organic labels should also be resolved by removing the prohibition on using BE/GMO sources as a condition of Organic labeling. However, this is an issue that must be corrected legislatively.

Furthermore, because of the significant market advantages gained through advertising unsubstantiated health claims, market players have taken to the courts, where dozens of lawsuits have been filed against USDA, attempting to force the Department’s labels to support spurious health claims due to ambiguities in the legal definitions of both “organic” and “bioengineered”. Affirming that USDA is empowered by statute to determine specific criteria for its own labels when legislative language is ambiguous will help negate any claims to the contrary. 

Plan of Action

Food labeling is central to the flow of accurate and unbiased information from farm to table. Currently, two primary agencies are responsible for food labeling, USDA and FDA (under HHS), and one agency is responsible for truth in advertising, FTC (under Commerce). These responsibilities are split: USDA covers farm products, FDA covers nutrition, and FTC prosecutes false advertising. The recommended actions below will improve coordination among these agencies, produce a more uniform response to labeling issues, and increase consumer confidence in and knowledge of the food they purchase.

Because food labels are often relied upon during a purchase decision in the grocery aisle, the Bioengineered Food Labeling Standard established in 20164 and mandated in 20225 should be strengthened. Specifically:

Congress should pass legislation removing redundancy in USDA’s Organic and BE labeling requirements.Simple, mutually exclusive legal definitions will lead to more explicit decisions by the judiciary.
USDA’s Agricultural Marketing Service should certify a non-BE label through independent laboratory analysis to supplement its BE labeling program.Accountability to a laboratory analytical standard for content, rather than a judgment call by a non-profit NGO, will provide clarity.
The Secretary of Commerce should direct FTC to prosecute false advertising for improperly labeled Organic or non-GMO consumer goodsImpartial & objective treatment of consumer-facing advertising allows consumers to choose based on their needs.

Congress should pass legislation removing redundancy in USDA’s Organic and BE labeling requirements. 

Although this may be a more long-term solution, the current regulatory regime is confusing and conflates agricultural methods with content. Congress should take up this issue in future Farm Bills and appropriations cycles and develop clear, mutually exclusive legal definitions. This will create more transparent labels for consumers and lead to more explicit decisions by the judiciary in marketing lawsuits. 

USDA’s Agricultural Marketing Service should certify a non-Bioengineered label. 

AMS currently oversees the assignment of BE labels. Through independent laboratory analysis, the agency should also offer a service to firms to certify a non-BE label, using the NBFLS criteria. USDA already has analytical laboratories and staff conducting spot inspections of meat producers. These capabilities could be leveraged to confirm a non-BE label. In addition, producers who wish to label their goods as “non-BE” would be willing to pay an evaluation fee comparable to fees paid to non-governmental certification agencies, so the budgetary impact should be minimal. Alternatively, because the NBFLS establishes methods that can be performed in certified testing facilities, USDA’s resources could be deployed to spot-check the claims. Further, because non-BE labeling would not be mandatory, producers can choose to remain silent on the content of their goods if their bioengineered content is unknown.

Any ingredients with known health benefits should appear on the FDA nutrition label, and any marketer that uses either Organic or non-GMO labeling without adhering to USDA’s authorities should be prosecuted for false advertising.

For budgetary purposes, USDA’s Animal and Plant Health Inspection Service (APHIS) and its Food Safety and Inspection Service (FSIS) are allocated approximately $1.7B and $1B, respectively. Additional staffing needs would likely be minimal because spot inspections of manufacturing facilities are already part of their routine.

The Federal Trade Commission (FTC) should increase enforcement of ‘Truth-in-Advertising’ regulations to prosecute improperly labeled Organic or non-GMO foods. 

Another angle agencies could take to support a more coordinated approach to consumer protections is through prosecution of improperly labeled Organic or non-GMO foods. While USDA would maintain the responsibility of conducting spot inspections, the FTC would be responsible for enforcing any transgressions through False Advertising Laws.6 

There is already precedent for this type of enforcement. Between 2003 and 2010, FTC successfully removed spurious health claims made by POM Wonderful, a marketer of pomegranate juice and related products, despite a vigorous appeal mounted by the company. While this example rejected false advertising based on specific health claims, it could also be extended to false advertising based on general health claims.


This proposal presents a more coordinated framework for food labeling regulations and would have wide-ranging effects. Among the stakeholders are farmers (both large and small), national grocery chains, food processing companies, agricultural biotechnology companies (particularly those that use laboratory-derived technologies that do not result in a “Bio-Engineered” label), and alternative protein companies that create consumer goods using processes developed in laboratories (e.g., Impossible Foods). In addition, various organizations, such as the Biotechnology Innovation Organization (BIO), have filed amicus briefs in lawsuits that target USDA labeling. There is significant interest in improving the current system.

In addition to providing the protection that consumers deserve, this proposal has health and climate impacts. Nutrition and health are tightly linked, and consumers know for themselves what foods are likely to aggravate their health outcomes. Accurate labeling empowers consumers to decide for themselves about their individual needs, to the extent that consumers believe that non-BE foods are more nutritious. Constraining both seed and method to organic, non-GMO can have a demonstrable negative impact on the climate mitigation capabilities of agricultural practices.

As suggested above, language suggesting that using seeds descended from laboratory methods of genetic modification anywhere in the chain precludes organic production methods should be eliminated. This can be more accurately communicated using two different labeling permutations, “organic & BE” and “organic & non-BE.”

Frequently Asked Questions
Doesn’t the current non-GMO labeling provide the same information?

No. The Non-GMO Project (the NGO responsible for certifying the labels) has extensive, published criteria that suggest that there is a precise definition of a GMO. But, unfortunately, there isn’t one: It’s a gray area whose definition is scientifically imprecise, to the extent that it is defined differently in the US than in the EU (for example). In particular, the Project’s definition is so broad that any food determined (by the Project) to be “unnatural”, including processes and products traced to the use of a genetically modified organism, can be denied a label. In contrast, the USDA’s BE Label is scientifically precise and focused on an analytical criterion that can be objectively determined in the laboratory.

What is an example where foods currently labeled non-GMO would be labeled BE?

Probably none. It’s hard to tell because, as mentioned above, The Non-GMO Project’s labeling criteria are subjective. According to their criteria, determining a new GMO is intrusive and requires surveillance of its entire development path. In contrast, determining a BE label requires inspection (much like the USDA’s meat grades), albeit in a laboratory setting.

What is an example where foods not currently labeled as non-GMO would be labeled non-BE?

Because The Non-GMO Project label includes processes and derivatives, foods such as the plant-based Impossible Burger could be labeled non-BE, even though the process involves a GMO, disqualifying it from their labeling. (A GMO is used to create the meat flavor of the protein, which is purified before blending.)

Will The Non-GMO Project have a role?

Of course! Because they already monitor new GMOs, this non-profit can help guide USDA inspectors to foods that should be labeled as BE but are not. In addition, they can guide analytical procedures that can be used to ascertain whether a given food product is, in fact, BE.

What does food labeling have to do with climate change?

Agriculture is a globally significant enterprise that can both capture and release greenhouse gases responsible for global warming. Under the current scheme, improving the efficiency of agricultural practices involving GMO processes is discouraged because of the stigma. Innovations such as PivotBio’s enhanced nitrogen fixation organism (a GMO that reduces the amount of fertilizer needed) may be avoided by farmers because of a fully-justified fear of being labeled.

Health Care Coverage for the Incarcerated Population to Reduce Opioid-Related Relapse, Overdose, and Recidivism Rates


Untreated substance use disorders (SUDs) are common among those who pass through the criminal justice system. At both the state and federal levels, re-entry into communities is a critical time period for these individuals. Preventing opioid relapse and potential overdose post-release can prevent recidivism, and improve an individual’s life after time in jail. Medication-assisted treatment (MAT) for opioid use disorders (OUDs) can help some sustain recovery. However, there are many barriers that interfere with the distribution of medication: cost, accessibility, and distribution are difficult to overcome, along with a lack of professionals trained to prescribe medication for OUDs.

To address this facet of the growing opioid crisis, the United States Department of Justice (DOJ) and the Centers for Medicare & Medicaid Services (CMS) should facilitate the accessibility for medications for OUDs (MOUDs) and train professionals to prescribe MOUDs. Additionally, incarcerated individuals with an OUD should have intensive case management that continues through reintegration into society. Finally, Medicare coverage should be available in order to continue treatment and support successful reentry into their community. Together, these will help reduce risks of recidivism, opioid-related relapse, and overdoses during reintegration back into their community.

Challenge and Opportunity

Approximately 65% of the United States prison population has a substance use disorder. An estimated 17% of those detained in state and federal prisons who meet the criteria for substance use disorder have an opioid use disorder specifically. Repeated drug usage causes a person to grow physiologically reliant on the drug, requiring more to have the desired effect, known as increasing tolerance. Individuals with an OUD lose their tolerance to the drug while incarcerated, which sets them at a greater risk of overdose mortality upon release. The risk of mortality from a lethal overdose is more than 12 times greater than that of another person within two weeks of being released from jail or prison. A meta-analysis determined that MOUDs during incarceration increased post-release treatment involvement and reduced opioid use post-release. Similarly, a randomized control trial at a Baltimore pre-release prison setting, showed that those who began methadone therapy and counseling while in prison were more likely to continue treatment post-release. They also had reduced rates of opioid use re-offending over the course of six months compared to those who received counseling only.

Methadone, buprenorphine, and naltrexone are MOUDs that have been authorized by the Food and Drug Administration for the treatment of OUDs. Research on the utilization of MOUD has demonstrated to be an effective treatment, specifically with methadone and buprenorphine. However, the distribution amount of MOUDs in the criminal justice system settings is low: only 3.6% of incarcerated individuals with OUD across the United States were prescribed and administered buprenorphine. According to the Pew Charitable Trusts and Substance Abuse and Mental Health Services Administration (SAMHSA), just 14 states administered at least one MOUD, 39 states provided naltrexone in jail or prison settings, and only one state (Rhode Island) provided all three MOUDs. Increasing the percentage of MOUD administration in carceral settings and after release across the United States is critical in order to reduce opioid overdose deaths. 

Rhode Island’s Approach to Opioid Use Disorder Treatment

The Rhode Island Department of Corrections (RIDC) is the first correctional system to launch an extensive program to screen individuals for an OUD upon entry, offer all three MOUDs to eligible incarcerated individuals, and continue with treatment post-release. The RIDC MAT program provides incarcerated individuals with access to MOUDs, and counseling during incarceration. RIDC MAT also provides linkage to care after release through a partnered non-profit organization, Community Organization for Drug Abuse Control (CODAC) Behavioral Healthcare. Together, RIDC and CODAC have established a successful pipeline for the continuation of MAT post-incarceration. Prior to an individual’s release date, CODAC develops a re-entry strategy with the assistance of case management and care providers. As a result, Rhode Island’s statewide overdose fatalities decreased by 12% in the first year of this program’s adoption, while post-incarceration overdose deaths decreased by 61%. A decrease in mortality rates related to opioid overdose post incarceration allows approximately $7,300 more in personal income per individual’s extended years of life. Other states have turned to Rhode Island’s MAT program to learn from and advocate for incarcerated individuals in order to treat OUDs during and after incarceration, and help reduce recidivism. 

Challenges for Implementation

Despite these strong results, challenges remain. 

Opioid use treatment and services are covered by health insurances under the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008. However, incarcerated individual healthcare coverage is entirely operated by the state, which contributes to the above mentioned disparities in drug therapeutic access and counseling–but only while incarcerated. As individuals transition back into society, if they do not have health insurance to pay for their MOUDs or other rehabilitation treatments, they lose treatment, and experience an increased likelihood of relapse. 

The Medicaid Inmate Exclusion Policy under the Social Security Act prevents and prohibits Medicaid coverage while incarcerated, making it difficult for formerly incarcerated individuals to acquire healthcare upon release, and thus access MOUDs. The majority of these individuals qualify for Medicaid upon release since they are low-income and fall below the federal poverty line. In 2018, Congress provided waiver opportunities for CMS to connect individuals who were recently released from jail/prison to healthcare across the states, but not federally. 

Medicaid Section 1115 Waivers

To combat this gap, states are waiving the Medicaid Inmate Exclusion Policy to provide Medicaid coverage for incarcerated individuals upon release by filing Section 1115 waivers. A section 1115 waiver is a provision within the Social Security Act that grants the Secretary of Health and Human Services the authority to waive specific requirements within the Medicaid program. Section 1115 waivers offer states the flexibility to design and implement innovative approaches to enhance access to healthcare. To obtain approval, states must submit proposals outlining their proposed changes and demonstrate that the waiver will not increase federal government expenditures over the waiver period. Once approved, the waiver permits the states to operate the Medicaid program with modified, exempted, or alternative requirements. For instance, Section 1115 waivers from New Hampshire and Utah were approved, enabling the expansion of healthcare coverage to incarcerated individuals. Under the waiver, incarcerated individuals are granted full Medicaid coverage for care coordination and provider services, which commences approximately one month prior to their release. 

Plan of Action

The Biden Administration has urged states to submit Section 1115 waivers to propose options for expanding coverage in order to reduce health disparities, remove barriers to MOUDs treatment access, and find long-term solutions to OUDs issues. It is imperative that the federal government prioritize reducing relapse, and opioid overdose mortality rates during incarceration and post-release in order to reduce recidivism. The DOJ, CMS, and SAMHSA should collaborate to develop a pipeline that expands training across professionals, have MOUDs more accessible to correctional facilities, and have healthcare coverage post-release.

Recommendation 1. Compare and contrast the Section 1115 waivers submitted by states to encourage and detail advantages to the remaining states. 

A root of the issue is the failure to provide pre-release healthcare coverage to incarcerated individuals in order for them to continue having coverage post-release. Hence, increasing the access to healthcare post-release by states applying for Section 1115 waivers to propose measures and assist incarcerated individuals in obtaining healthcare coverage is important. Currently 35 states have filed approved Section 1115 waivers. Collecting data on these states would provide insight into how these waivers reduce recidivism and overdose rates. The Agency for Healthcare Research and Quality (AHRQ) should issue an open call for evidence synthesis to delve into the impacts of Section 1115 waivers. By doing so, AHRQ would aim to conduct a comprehensive analysis of the impacts and outcomes from the implementation of Section 1115 waivers. This initiative would contribute to evidence-based decision-making and further enhance the understanding of the implication of Section 1115 waivers on healthcare. Examples of data collection that could be obtained to assess the success of Medicaid resources are: 

  1. Overdose mortality rates between those who have Medicaid and those who do not 
  2. Post-release drug-related opioid reoffending
  3. Economic impact such as quality-adjusted life years gained. 

Once the data has been gathered, it is essential that the dataset is made publicly accessible to researchers. The dataset can be published on the CMS data website, enabling widespread access and utilization for researchers. This accessibility will allow researchers to examine the significance of reducing overdose-related fatalities after incarceration and assess how the expansion of Section 1115 waivers could contribute to achieve this reduction. 

Recommendation 2. Increase opioid treatment program accessibility during and after incarceration.

Rhode Island’s MAT program has shown to be effective in reducing opioid overdose deaths. A replica of the Rhode Island program has improved OUD treatment to reduce opioid related relapses and death in a correctional facility in Massachusetts. In order to provide intensive case management when individuals come into contact with the criminal justice system and adequately rehabilitate them, correctional facilities should use a method similar to that used by Rhode Island’s Department of Corrections MAT program. Since correctional facilities and licensed professionals must be accredited by the DEA and SAMHSA to provide MOUDs, individuals will have the opportunity to have access to MOUDs at Opioid treatment programs (OTPs) during and after incarceration who are certified. Thus, the DOJ and SAMHSA should collaborate with CODAC and similar organizations to increase OTP accessibility across correctional facilities during and after incarceration. These organizations can assist with creating a re-entry treatment plan during incarceration and continue after release. Incarcerated individuals will have access to MOUDs at OTPs as well as counseling. This aims to increase accessibility to MOUDs, licensed therapists, and medical doctors.

Recommendation 3. Intensive case management during incarceration should continue when reintegrating back into the community. 

The DOJ, CMS and OTPs should further collaborate to establish a pipeline that aids individuals to combat OUDs. Currently, upon release, formerly incarcerated individuals’ MOUD treatment is terminated and they do not have access to treatment unless they are referred to a rehabilitation center or seen by a licensed professional. The first two weeks after release are crucial because there is a higher risk of relapsing. Thus, it is essential for correctional facilities to assist incarcerated individuals to apply for Medicaid within a few months of release to access  MOUDs and therapy. Medicaid would cover MOUD costs and counseling services at OTPs or similar organizations. MOUD treatment should be administered during prison in order to commence proper rehabilitation, whether that is at a correctional facility or an OTP. Subsequently, continuing their pharmacological treatment in parallel with counseling post-release reduces relapse, withdrawal symptoms, and overdose deaths. This aims to expand access while in a correctional facility and continue treatment post-release to reduce opioid mortality rates.


Opioid relapses and overdoses following imprisonment have escalated significantly, accelerating the chance of overdose mortality. Incarcerated individuals with an OUD should get comprehensive case management while incarcerated that continues as they reintegrate into their communities. However, the Social Security Act prevents incarcerated individuals from receiving Medicaid coverage while incarcerated. Implementing these measures will decrease overdose mortality rates, risk of relapse, and reduce recidivism.

Frequently Asked Questions
What is the economic benefit of this proposal?

In Massachusetts, researchers were able to assess an estimated cost and benefits of administering MOUDs during incarceration, using the Researching Effective Strategies to Prevent Opioid Death (RESPOND) simulation model. The availability of all three MOUDs during incarceration showed that it was cost effective at approximately $7252 per quality-adjusted life year gained and reduced 1.8% of opioid related overdose deaths.

How will this proposal be funded?

The U.S Department of Health and Human Services (HHS) has provided science and community-based approaches to combat the opioid epidemic crisis. In the past years, the HHS has allocated $2 billion in grants to help reduce opioid mortality and relapse rates across the United States. Researchers and community-based organizations can apply for grant money from HHS for data collection on how Section 1115 waivers have improved reducing recidivism and overdose rates.

The DOJ has approximately allocated $340 million in grant award funding money to battle the opioid crisis. $7.2 million dollars have been used to treat individuals with a substance use disorder and assist with support during incarceration and reentry services.

Why should this be a federal concern rather than state level?

The United States is in the middle of an emerging life-threatening opioid epidemic crisis that is affecting over 33,000 deaths per year from prescription and synthetic opioids. The opioid epidemic crisis is highly prevalent among the criminal justice population. This impacts individuals across the country, not just in specific states. The federal government should encourage individual states to apply for federal funding that is available in order to combat the opioid epidemic crisis.

How do correctional facilities and partnered organizations become an accredited and certified OTP?

The use of MOUDs in OTPs in the United States is regulated by the 42 Code of Federal Regulations (CRF) 8. This regulation established a system for accrediting and certifying OTPs in order to grant the ability to dispense and administer FDA approved MOUDs. More information on the process of accrediting and certifying OTPs can be found in SAMHSA website.

What are the limitations for this proposal?

Given the rigorous nature of the accreditation process, obtaining accreditation for OTPs can be an intricate process, which involves several steps and requirements, including: thorough assessments of program infrastructure, staff qualification and training, and compliance with regulatory standards. These factors collectively contribute to the length of the accreditation process, potentially deterring some facilities from pursuing OTP status. Another aspect to consider is the decision-making process of states regarding the application for Section 1115 waivers. One significant consideration revolves around funding and financial considerations. States often conduct an extensive evaluation to assess the potential financial implications and cost-sharing arrangements associated with the Section 1115 waiver before finalizing their decision to apply. Despite these challenges, it is crucial to acknowledge that implementing OTP accreditation and Section 1115 waiver approvals play a crucial role in reducing relapse rates post-incarceration, while also creating a more comprehensive and effective healthcare system that saves lives by addressing the opioid crisis and minimizing recidivism.

Next-Generation Fire and Vegetation Modeling for a Hot and Dry Future


Wildfires are burning in ways that surprise even seasoned firefighters. Our current models cannot predict this extreme fire behavior—nor can they reproduce recent catastrophic wildfires, making them likely to fail at predicting future wildfires or determining when it is safe to light prescribed fires. 

To better prepare the fire management community to operate in a new climate, Congress should establish and fund five regional centers of excellence (CoE) to develop, maintain, and operate next-generation fire and vegetation models to support wildland fire planning and management. Developing five regional CoEs (Southeast, Southwest, California, Pacific Northwest, Northern/Central Rockies) will ensure that researchers pursue a range of approaches that will ultimately lead to better models for predicting future wildfire behavior, improving our ability to safeguard human lives, communities, and ecosystems.

Challenge and Opportunity

In the decade ending in 2021, total federal wildfire suppression expenditures surpassed $23 billion, which is a fraction of the total costs of damages from wildfire over that period. For example, the 2018 wildfires in California are estimated to have amounted to $148.5 billion in economic costs for the state. The costs of suppressing fire, and the societal and natural resources costs of extreme wildfire, will continue to increase with increasing temperatures. 

Fewer than 2% of ignitions become large wildfires, but it is this 2% that cause most of the damage because they are burning under extreme conditions. The area of forests burned by wildfire annually in the western United States has been increasing exponentially since 1984. While the number of ignitions remains relatively constant from year to year, climate change is drying fuels and making forests more flammable. As a result, no matter how much money we spend on wildfire suppression, we will not be able to stop increasingly extreme wildfires. Thus, we need to better understand where the risks lie on our landscapes and work proactively to reduce them. 

When vegetation—especially dead vegetation—is subjected to high temperatures, any moisture absorbed during the winter months quickly evaporates. As a result, increasingly hot summers are making our forests more flammable. Live vegetation moisture content does not react as quickly as dead vegetation, but sharp increases in air temperature when conditions are dry can make live plants more flammable as well. While this relationship between temperature and ecosystem flammability has remained consistent over time, until the past decade we had not reached a level of warming that dried ecosystems sufficiently to allow for consistent extreme fire behavior. This is in part because large dead fuels, such as dead trees and logs, did not dry sufficiently to become flammable for the majority of the fire season until recently. 

Our current operational models for simulating wildfire and vegetation are incapable of reproducing the extreme fire behavior and rapid ecosystem change that we are now experiencing. Forest growth-and-yield models, such as the Forest Vegetation Simulator, used by managers have served them well for decades. However, because they are built using statistical relationships between past tree growth and climate, they are incapable of capturing the effects of changing climate, especially extreme events, on tree growth and mortality. Similarly, our operational fire models, such as FARSITE, that are used for both management planning and simulating fire spread to plan fire suppression activities are not designed to deal with the substantial ecosystem changes that are occurring from climate change. These fire models have served us well in the past, but increasing temperature and a drying atmosphere are causing conditions that far exceed the data used to build these models. 

For example, our current operational fire models do not account for large dead trees and logs and how they contribute to fire spread or for the way fire behaves in the wildland–urban interface. Yet wildfires are increasingly burning through communities, and the number of dead trees and logs is increasing because of drought- and insect-induced tree mortality and is increasingly available to burn because of high temperatures. The 2020 Creek Fire in the Sierra Nevada, California, burned through an area of extensive tree mortality from prolonged drought and insect outbreaks. The operational fire spread model ELMFIRE, which is used to predict fire spread of active wildfires, was unable to predict the mass fire behavior created by the massive number of dead trees.

Managing wildfire risk both prior to and during wildfires requires advanced models that are able to account for changing climatic conditions. We need new wildfire models that account for the increasing fuel dryness that facilitates extreme fire behavior, and we need new vegetation models that account for the effects of extreme drought and temperature on vegetation mortality. The research and development necessary to prepare us for our increasingly flammable world requires both fundamental and applied research, neither of which is sufficient on its own. 

Further, we need to ensure that we commit to maintaining these models as the climate continues to change so that we do not create another tool that fails to serve us well within a decade or two. As the climate continues to change, these next-generation fire and vegetation models will be challenged with novel conditions that require continuous efforts to ensure they are capable of capturing the dynamics of the system. In addition, we must ensure that the mechanistic understanding of the system that develops is applied to supporting fire and vegetation management decision-making. This will require ongoing experimentation and observations of actual wildfire behavior, along with extensive data collection to characterize how quickly the flammability of the system changes as a function of vegetation type and weather conditions. 

Developing these next-generation models is necessary for both fire suppression and management planning. Incident command teams rely on fire spread models to help plan suppression efforts for active wildfires, and thus having better predictions of fire spread is essential for effective operations and firefighter safety. Likewise, planning forest treatments that are effective for reducing the risk of high-severity wildfire under extreme weather conditions requires better vegetation and fire models that can capture the influence of changing climate on the probability that high-severity wildfire occurs. 

Plan of Action

Developing and future-proofing next-generation fire and vegetation models will require new and sustained investment. Further, we must accept that these advanced models will require a level of expertise to operate that we cannot expect from a land manager trained in natural resource management, requiring that we fund expert model users to support management planning and suppression efforts. 

As with all research and development, there are many possible pathways. Regional differences in weather, vegetation, and management history will alter climate effects on vegetation growth, mortality, and flammability. Similar to the Manhattan Project approach of simultaneously pursuing two different ignition systems when there was more than one potential viable alternative, we lack the necessary understanding to pick a “winning” model at this point. 

To account for regional differences in vegetation and the research momentum that is developing in different nascent modeling approaches, an effective and robust federal investment would entail the following actions. 

Recommendation 1. Congress should establish and fund five centers of excellence housed at academic institutions in the Southeast, Southwest, California, Pacific Northwest, and Northern/Central Rockies to develop and maintain next-generation fire and vegetation models that are capable of modeling extreme fire behavior and can be operationalized to support planning for wildfire and vegetation management and to support wildfire suppression. 

Establishing five centers with this geographic distribution will allow for investigation into the forest types where the majority of wildfire area occurs and will capture the range of climatic conditions under which wildfires are occurring. It will also take advantage of past and ongoing regional research efforts that will form the information foundation for each center. While these centers should have largely independent research programs, it will be necessary to coordinate some large-scale experimentation and to ensure that research findings and advances are shared rapidly. To achieve these objectives, one center should be selected to act as the coordinating center for the network. 

Recommendation 2. Congress should require institutional partnerships between the host institutions and federal research institutions (e.g., U.S. Forest Service Research and Development, Department of Energy National Labs, U.S. Geological Survey, etc.). 

We are currently in an all-hands-on-deck situation in the fire and fuels research community, and we need to operate in a collaborative and regionally coordinated manner. Requiring partnerships between the academic centers of excellence and federal research facilities within each region will ensure that effort is not duplicated and a wider range of expertise. For example, efforts are under way at federal research facilities that could be integrated within the regional fire centers. The integration will ensure collaboration between academic and federal partners and allow for the overall research effort to draw on the strengths of these different types of institutions. 

Recommendation 3. Congress should mandate and fund the centers to operate these next-generation models and support wildfire and vegetation management planning and operations. 

To date, we have relied on fire and vegetation models developed by the research community to use data collected by fire and forest managers and packaged so that natural resource professionals can operate the models. Both of these constraints have contributed to the limitations of our current suite of models. We can no longer afford the limitations imposed by expectations on the research community to develop models that a natural resource professional can run on a desktop computer. Accounting for a range of factors, such as how changing climatic conditions will directly change the amount of fuel on the landscape and also for how short-term changes in weather will interact with longer-term changes in climate and influence fuel moisture, requires a more sophisticated approach to simulating the system than is necessarily accessible to a non-expert user. Expecting a natural resource professional to use an advanced coupled atmosphere-biosphere fire model would be like teaching someone how to balance their checkbook and then expecting them to calculate exactly how much they need to save every week for retirement. Further, important feedback to model improvement will come from repeated application by expert model users. To deploy next-generation fire and vegetation models in a manner that will effectively support fire and natural resource management decision-making, each center will employ experts who will work collaboratively with managers in response to their requests to run simulations for pre-fire management and suppression operations planning.

Recommendation 4. Congress should mandate the creation of strategic plans to support implementation and coordination across centers. 

Each center will develop a five-year strategic plan to guide its research and development efforts. Following strategic plan development, representatives from the five centers will convene to determine necessary coordinated experimentation and implementation plans to facilitate coordinated efforts. The coordinating center will hold biannual leadership meetings to ensure data and information flow and identify additional opportunities for collaboration among individual centers. 


Establishing five centers of excellence to develop, maintain, and operate next-generation models will cost approximately $26 million per year, which is less than 1% of the 2021 federal wildfire suppression expenditure. This level of funding would provide $5 million per year per center (plus an additional $1 million per year for the coordinating center). The annual budgets would fund staff scientist and research assistant positions, provide support for the experiments necessary to develop and parameterize new models, provide computing resources for computationally sophisticated models, and fund staff analysts to run the models in support of managers. Initially, the majority of the annual appropriation would be focused on model development, transitioning to maintaining and operating the models to support land management as the technology matures. 

The centers could be supported through National Science Foundation (NSF) funding. NSF could provide financial support for five university host institutions (one in each region) selected through a competitive bidding process. In turn, these university host institutions can manage the required federal partnerships. Selection of university host institutions could be based in part on demonstrated capacity to manage successful partnerships with federal institutions. 

It is imperative that we invest in new models that will support more effective mitigation to reduce wildfire severity, otherwise spending on suppression will continue to balloon despite improved fire intelligence.

Frequently Asked Questions
Are there universities with demonstrated capacity to perform the kind of work required to make this centers of excellence program successful?

Yes. Just a few examples include the colocation of the University of Georgia with fire researchers in the U.S. Forest Service (USFS) Southern Research Station; the University of New Mexico’s existing relationships with Los Alamos National Lab, Sandia National Lab, and the U.S. Geological Survey; and the University of Washington’s long-standing relationship with the USFS Pacific Northwest Fire and Environmental Applications research group.

Why might NSF be the right agency to fund the proposed centers?

NSF is in wildland fire research and, jointly with the National Institute of Standards and Technology, already funds research on fire in the wildland–urban interface. While much of the research needed to develop next-generation fire and vegetation models is basic, all wildland fire research is inherently applicable. NSF hosted a five-day Wildfire and the Biosphere Innovation Lab, and the findings included the assertion that “support for applied research will be most effective by aiming at both short- and long-term applications and solutions,” acknowledging that the application of research findings is an important part of the research enterprise.

Large investments in hazardous fuels management are being made now. Will models developed through this research have an impact in the near term?

Yes. These centers will bring together and build from ongoing efforts. There are already efforts under way to develop optimal treatment strategies that account for changing climatic conditions using advanced forest landscape models. This approach, with some refinement and validation, will be useful for informing treatment placement within the next two years.

Why do we need five centers of excellence? Wouldn’t it be more efficient to have one center that tracks and evaluates regional modeling efforts and creates best practices for management application?

This is functionally the system we have now. The Fire Research Management and Exchange System (FRAMES) provides a clearinghouse of models developed for fire and vegetation modeling to inform management. FRAMES may be a good interface to help increase manager awareness of the models the five centers will develop, but it is not a mechanism for facilitating the research and development needed to tackle the wildfire problem. We need five centers because there are already a number of efforts under way to develop new fire and vegetation models. None of the models will be perfect because they all take different approaches and there are tradeoffs inherent in any given approach. With simultaneous investment, we will be able to capitalize on the aspects of each model that best simulate a part of the fire spread or vegetation growth process and then develop a system that incorporates the best of each model. Competition within the U.S. scientific enterprise has helped our country achieve high global standing. Funding five centers will shift that competition away from researchers spending much of their time competing for funding and focus it on competing with their best ideas in a way that prepares us for managing wildfire in the future.

Save Lives by Making Smoke Tracking a Core Part of Wildland Fire Management


Toxic smoke from wildland fire spreads far beyond fire-prone areas, killing many times more people than the flames themselves and disrupting the lives of tens of millions of people nationwide. Data infrastructure critical for identifying and minimizing these smoke-related hazards is largely absent from our wildland fire management toolbox. 

Congress and executive branch agencies can and should act to better leverage existing smoke data in the context of wildland fire management and to fill crucial data infrastructure gaps. Such actions will enable smoke management to become a core part of wildland fire management strategy, thereby saving lives.

Challenge and Opportunity

The 2023 National Cohesive Wildland Fire Management Strategy Addendum describes a vision for the future: “To safely and effectively extinguish fire, when needed; use fire where allowable; manage our natural resources; and collectively, learn to live with wildland fire.” Significant research conducted since the publication of the original Strategy in 2014 indicates that wildfire smoke impacts people across the United States, causing thousands of deaths and billions of dollars of economic losses annually. 

Smoke impacts exceed their corresponding flame impacts and span far greater areas coast to coast. However, wildfire strategy and funding largely focus on flames and their impacts. Smoke mitigation and management should be a high priority for federal agencies considering the 1:1 ratio of economic impacts and 1:30 ratio of fire to smoke deaths.

Some smoke data is already collected, but these datasets can be made more actionable for health considerations and better integrated with other fire-impact data to mitigate risks and save more lives.

Smoke tracking

Several federal programs exist to track wildfire smoke nationwide, but there are gaps in their utility as actionable intelligence for health. For example, the recent “smoke wave” on the East Coast highlighted some of the difficulties with public warning systems. 

Existing wildfire-smoke monitoring and forecast programs include:

The EPA also publishes retrospective smoke emissions totals in the National Emissions Inventory (NEI), but these lack specificity on the downwind locations impacted by the smoke that would be needed to be used for health considerations.

Existing data are excellent, but scientists using the data combine them in non-standardized ways, making interoperability of results difficult. New nationwide authoritative smoke-data tools need to be created—likely by linking existing data and existing methods—and integrated into core wildland fire strategy to save lives.

Smoke health impacts

There is no single, authoritative accounting of wildfire smoke impacts on human health for the public or policymakers to use. Four key gaps in smoke and health infrastructure may explain why such an accounting doesn’t yet exist. 

  1. The U.S. lacks a standardized method for quantifying the health impacts of wildfire smoke, especially mortality, despite recent research progress in this area
  2. The lack of a national smoke concentration dataset hinders national studies of smoke-health impacts because different studies take different approaches
  3. Access to mortality data through the National Vital Statistics System (NVSS), managed by the National Center for Health Statistics (NCHS), is slow and difficult for the scientists who seek to use mortality data in epidemiological studies of wildfire smoke. 
  4. Gaps remain in understanding the relative harm of wildfire smoke, which can contain aerosolized hazardous compounds from burned infrastructure, compared to the general air pollution (e.g., from cars and factories) that is often used as analog in health research. 

Addressing these gaps together will enable official wildfire-smoke-attributable death tolls to be publicized and used by decision-makers.

Integration of wildfire smoke into wildland fire management strategy

Interagency collaborations currently set wildland fire management strategy. Three key groups with a mission to facilitate interagency collaboration are the National Interagency Fire Center (NIFC), the National Wildfire Coordinating Group (NWCG), and the Wildland Fire Leadership Council (WFLC). NIFC maintains datasets on wildfire impacts, including basic summary statistics like acres burned, but smoke data are not included in these datasets. Furthermore, while NWCG does have 1 of its 17 committees dedicated to smoke, and has collaborations that include NOAA (who oversees smoke tracking in the Hazard Mapping System), none of the major wildfire collaborations include agencies with expertise in measuring the impacts of smoke, such as the EPA or Centers for Disease Control (CDC). Finally, WFLC has added calls for furthering community smoke-readiness in the recent 2023 National Cohesive Wildland Fire Management Strategy Addendum, but greater emphasis on smoke is still needed. Better integration of smoke data, smoke-health data, and smoke-expert agencies will enable better consideration of smoke as part of national wildland fire management strategy.

Plan of Action

To make smoke management a core and actionable part of wildland fire management strategy, thereby saving lives, several interrelated actions should be taken.

To enhance decision tools individuals and jurisdictions can use to protect public health, Congress should take action to:

  1. Issue smoke wave alerts nationwide. Fund the National Weather Service (NWS) to develop and issue smoke wave alerts to communities via the Wireless Emergency Alerts (WEA) system, which is designed for extreme weather alerting. The NWS currently distributes smoke messages defined by state agencies through lower-level alert pathways, but should use the WEA system to increase how many people receive the alerts. Furthermore, a national program, rather than current state-level decisions, would ensure continuity nationwide so all communities have timely warning of potentially deadly smoke disasters. Alerts should follow best practices for alerting to concisely deliver information to a maximum audience, while avoiding alert fatigue.
  2. Create a nationwide smoke concentration dataset. Fund NOAA and/or EPA to create a data inventory of ground-level smoke PM2.5 concentrations by integrating air-monitor data and satellite data, using existing methods as needed. The proposed data stream would provide standardized estimates of smoke concentrations nationwide, and would be a critical precursor for estimating smoke mortality as well as the extent to which smoke is contributing to poor air quality in communities. This action would be enhanced by data from recommendation 4 (below).
  3. Create a smoke mortality dataset. Fund the CDC and/or EPA to create a nationwide data inventory of excess morbidity and mortality attributed  to smoke from wildland fires. An additional enhancement would be to track the smoke health impacts contributed by each source wildfire. Findings should be disseminated in NIFC wildfire impact summaries. This action would be enhanced by data from recommendations 4-5 and research from recommendations 6-8 (below).

The decision-making tools in recommendations 1-3 can be created today based on existing data streams. They should be further enhanced as follows in recommendations 4-10:

To better track locations and concentrations of wildfire smoke, Congress should take action to: 

  1. Install more air-quality sensors. Fund the EPA, which currently monitors ground-level air pollutants and co-oversees the Fire and Smoke Map with the USFS, to establish smoke-monitoring stations in each census tract across the U.S and in other locations as needed to provide all communities with real-time data on wildfire-smoke exposure. 
  2. Create a smoke impact dashboard. The current EPA Fire and Smoke Map shows near-real-time data from regulatory-grade air monitors, commercial-grade air sensors, and satellite data of smoke plumes. An upgraded dashboard would combine that map with data from recommendations 1-3 to give current and historic information about ground-level air quality, the fraction of pollutants due to wildfire smoke, and the expected health impacts. It would also include short-term forecast data, which would be greatly improved with additional modeling capability to incorporate fire behavior and complex terrain.

To better track health impacts of wildfire smoke, Congress should take action to:

  1. Improve researcher access to mortality data. Specifically, direct the CDC to increase epidemiologist access to the National Vital Statistics System. This data system contains the best mortality data for the U.S., so enhancing access will enhance the scientific community’s ability to study the health impacts of wildfire smoke (recommendations 6-8).
  2. Establish wildfire-health research centers. Specifically, fund the National Institutes of Health (NIH) to establish flagship wildfire-smoke health-research centers to research the health effects of wildfire smoke. Results-dissemination pathways should include through the NIFC to reach a broad wildfire policy audience.
  3. Enhanced health-impact-analysis tools. Direct EPA to evaluate the available epidemiological literature to adopt standardized wildfire-specific concentration-response functions for use in estimating health impacts in their BenMAP-CE tool. Non-wildfire functions are currently used even in the research literature, despite potentially underestimating the health impacts of wildfire smoke

To enhance wildland fire strategy by including smoke impacts, Congress should take action to:

  1. Hire interagency staff. Specifically, fund EPA and CDC to place staff at the main NIFC office and join the NIFC collaboration. This will facilitate collaboration between smoke-expert agencies with agencies focused on other aspects of wildfire.

Support landscape management research. Specifically, direct the USFS, CDC, and EPA to continue researching the public health impacts of different landscape management strategies (e.g., prescribed burns of different frequencies compared to full suppression). Significant existing research, including from the EPA, has investigated these links but still more is needed to better inform policy. Needed research will continue to link different landscape management strategies to probable smoke outputs in different regions, and link the smoke outputs to health impacts. Understanding the whole chain of linkages is crucial to landscape management decisions at the core of a resilient wildland fire management strategy.

Diagram with arrows showing data flow from top to bottom, between the proposed infrastructure, with each shape representing one recommendation. Data flows from the data inputs (top boxes) to actionable tools for decision-making (circles), and finally on to pathways for integrating smoke into wildland fire management strategy (bottom boxes). The three blue shapes are recommendations that can be implemented immediately.

Cost estimates

This proposal is estimated to have a first-year cost of approximately $273 million, and future annual cost of $38 million once equipment is purchased. The total cost of the first year represents less than 4% of current annual wildfire spending (subsequent years would be 0.5% of annual spending), and it would lay the foundation to potentially save thousands of lives each year. Assumptions behind this estimate can be found in the FAQ.

RecommendationCompletion DateAgencies Responsible
1. National smoke alertingASAPNWS
2. Smoke concentration datasetASAPEPA/NOAA
3. Smoke mortality datasetASAPEPA/CDC/NIFC
4. More air-quality sensors5 yearsEPA
5. Smoke impact dashboardASAPNOAA
6. Improved access to mortality data1 year to start, then ongoingCDC
7. Wildfire-health research centers2 years to start; 5-year grantsNIH
8. Enhanced health-impact-analysis tools1 yearEPA
9. Interagency staffingOngoingEPA/CDC/NIFC
10. Landscape-management researchOngoingUSFS/CDC/EPA


In the U.S., more and more people are being exposed to wildfire smoke—27 times more people are experiencing extreme smoke days than a decade ago. The suggested programs are needed to improve the national technical ability to increase smoke-related safety, thereby saving lives and reducing smoke-related public health costs.

Frequently Asked Questions
How long will it take to implement the proposal described in this memo?

Recommendations 1-3 can be completed within approximately 6-12 months because they rely on existing technology. Recommendation 4 requires building physical infrastructure, so it should take 6 months to initiate and several years to complete. Recommendation 5 requires building digital infrastructure from existing tools, so it can be initiated immediately but relies on data from recommendations 2-3 to finalize. Recommendation 6 will require one year of personnel time to complete program review necessary for making changes, then will require ongoing support. Recommendation 7 establishes research centers, which will take 2 years to solicit and select proposals, then 5 years of funding after. Recommendation 8 requires a literature review and can be completed in 1 year. Recommendations 9-10 are ongoing projects that can start within the first year but then will require ongoing support to succeed.

How many people die each year due to wildfire smoke?

The latest estimates indicate that thousands of people die across the United States each year due to wildfire smoke. However, there is no consistent ongoing tracking of smoke-attributable deaths and no centralized authoritative tallies.

For how long after a wildfire does smoke cause deaths?

Many deaths occur during the wildfire itself—wildfire smoke contains small particles (less than 2.5 microns, called PM2.5) that immediately increase the risk of stroke and heart attack. Additional deaths can occur after the fire, due to longer-term complications, much in the same way that smoking increases mortality.

Where are people dying due to wildfire smoke?

Wildfires and wildfire smoke occur across the country, so deaths attributable to these causes do too. Recent research indicates that there are high numbers of deaths attributable to wildfire smoke on the West Coast, but also in Texas and New York, due to long-distance transportation of smoke and the high populations in those states.

How were the cost estimates for this proposal calculated?

One-time costs for recommendations 2, 3, and 8 were estimated in terms of person-years of effort and are additive with their annual costs in the first year. Recommendations 2-3 require a large team to create the initial datasets and then smaller teams to maintain, while recommendation 8 requires only an initial literature review and no maintenance. One person-year is estimated at $150,000 per year, including fringe benefits.

One-time costs for recommendation 4 were calculated in terms of air-quality monitor costs, with one commercial grade sensor ($400) for each of the 84,414 census tracts in the U.S., one sensor comparable to regulatory grade (estimated at $40,000) for each of the 5% most smoke-impacted census tracts, and 15% overhead costs for siting and installation.

Annual costs for recommendations 1-3, 5-6, and 9-10 were estimated in terms of person-years of effort because salary is the main consumable for these projects. One person-year is estimated at $150,000 per year, including fringe benefits.

Annual costs for recommendation 4 were estimated by assuming that 10% of sensors would need replacement per year. These funds can be passed on to jurisdictions, following current maintenance practice of air-quality monitors.

Annual costs for recommendation 7 is for four NIH Research Core Centers (P30 grant type) at their maximum amount of $2.5 million, each, per year.