The Grain Inspector's Cash Reserve Went Negative. Then It Cut Staff.
Summary
Federal law requires the Federal Grain Inspection Service to hold three to six months of operating cash from the fees it charges to grade and weigh U.S. grain exports. In fiscal 2023 that reserve went negative — $0.50 million in the red, per a Congressional Research Service compilation of USDA's own accounts. FGIS's own fix, stated in a Federal Register notice: detail more than 10% of its roughly 450-person staff, freeze hiring, and cut overtime.
The account that isn't supposed to run dry
The Congressional Research Service's June 2025 review of the Grain Standards Act compiled five years of the Federal Grain Inspection Service's own user-fee accounting and found the fund covering FGIS-conducted export inspections missed its statutory reserve minimum in four of the five years — and, in fiscal 2023, went negative outright. The requirement itself isn't ambiguous: 7 U.S.C. § 79 directs to set fees "adequate to maintain a reasonable reserve" of three to six months of operating expenses, reviewed annually. states it plainly: the inspection account "was not within the statutory limits for FY2021-FY2024."
View data as table
| FY2020 operating reserve | $10.01M | 3.4 months of cost |
|---|---|---|
| FY2021 operating reserve | $7.07M | 2.2 months — below the 3-month floor |
| FY2022 operating reserve | $3.04M | 1.0 month — below the 3-month floor |
| FY2023 operating reserve | −$0.50M | −0.2 months — the account itself went negative |
| FY2024 operating reserve | $3.26M | 1.1 months — still below the 3-month floor |
| Statutory requirement | 3–6 months | 7 U.S.C. § 79; every year shown fell short except FY2020 |
The pattern is visible without the negative number: in FY2020 and FY2023, what FGIS spent running the inspection program (obligations) outran what it collected in fees (revenue). By FY2023 that gap had been compounding for years, and the reserve cushion built up earlier in the decade — $10.01 million in FY2020, equal to 3.4 months of cost — had been drawn down to nothing and then through it: −$0.50 million, −0.2 months, in FY2023. FGIS's own December 2024 Federal Register final rule states the agency "operated at a net loss for five consecutive years," even after charging the maximum fee increase its regulations allowed — capped at 5% a year — on top of four earlier years of fee decreases and a stretch of the highest inflation in four decades.
How FGIS closed the gap
FY2024 shows a reserve technically back above zero, at $3.26 million — but that recovery came almost entirely from cutting costs, not from charging exporters more. FY2024 revenue, $29.45 million, was barely different from FY2020's $30.26 million. What changed was obligations: $25.69 million in FY2024, the lowest of the five years in 's table, down from $31.75 million just one year earlier. FGIS's own account of how it got there, stated in the same Federal Register notice: it "detailed over 10 percent of its staff, froze hiring and awards, reduced overtime, and stopped travel unless mission critical."
View data as table
| Permanent employees, FY2023 | 379 | CRS R48577, p. 8 |
|---|---|---|
| Temporary employees, FY2023 | 54 | CRS R48577, p. 8 |
| Intermittent employees, FY2023 | 15 | CRS R48577, p. 8 |
| Total FGIS headcount, FY2023 | 448 | sum of the three categories above |
| Share detailed off inspection duties | >10% | FGIS's own figure, Federal Register, Dec. 27, 2024 — plus a hiring and awards freeze, reduced overtime, and travel restricted to mission-critical only |
FGIS's entire workforce — headquartered in Washington, D.C., with most staff at the National Grain Center in Kansas City and six field offices from Toledo to Portland — numbered 379 permanent employees, 54 temporary, and 15 intermittent in FY2023: 448 people doing mandatory inspection and weighing work at 29 export facilities nationwide, or supervising the state and private agencies that do. "Detailed over 10 percent" means, at that scale, somewhere north of 45 of them were pulled off their normal duties. The agency did not say for how long, or fully restored.
The takeaway
- The reserve isn't a rounding error — it's the law. 7 U.S.C. § 79 requires 3 to 6 months of operating cash. FGIS's inspection fund has been below that floor in four of the last five fiscal years on record, and negative in one of them.
- The FY2024 "fix" was mostly a cut, not new revenue. Revenue barely moved between FY2020 and FY2024; obligations fell 19% from their FY2023 peak, achieved in part by detailing staff, freezing hiring, and cutting overtime and travel.
- A fee-funded inspection service is only as stable as the volume it fees. notes FGIS's user-fee revenue depends on the tonnage of grain inspected each year, which ranged from 268.7 million to 349.2 million metric tons between FY2015 and FY2024 — a swing FGIS's own regulations can only partially smooth out, since fee increases are capped at 5% a year.
The reserve and revenue/obligation figures cover FGIS's fund for FGIS-conducted export inspections only — the larger of its two user-fee accounts. A second, smaller fund covering FGIS's supervision of delegated and designated state and private inspection agencies shows a similar pattern of missed statutory minimums in FY2020–FY2023 per the same table, but is not charted here. The FY2023 headcount and the "detailed over 10 percent" figure come from different points in time (FY2023 and a cost-cutting step described in a notice covering FY2025 rates, published December 2024) and are presented separately rather than combined into a single number.
Sources
- Congressional Research Service, U.S. Grain Standards Act: Overview and Issues for Possible Reauthorization (R48577, June 23, 2025) — the source for the five-year FGIS user-fee account table (revenue, obligations, net earnings/losses, operating reserve, and months of operating cost equivalent, FY2020–FY2024), the FY2023 headcount (379 permanent, 15 intermittent, 54 temporary employees), and the statutory reserve requirement and compliance history. congress.gov
- , Agricultural Marketing Service, Fees for Official Inspection and Weighing Services Under the United States Grain Standards Act (final rule, Federal Register, Dec. 27, 2024, Doc. 2024-30603) — the source for FGIS's own statement that it "detailed over 10 percent of its staff, froze hiring and awards, reduced overtime, and stopped travel unless mission critical," and that it "operated at a net loss for five consecutive years." federalregister.gov
- , Agricultural Marketing Service, 2025/2026 Rates for Grain Inspection and Weighing Services Under the United States Grain Standards Act (Federal Register notice, Aug. 19, 2025, Doc. 2025-15768) — confirms FGIS was still working to "rebuild the user fee reserve" into the 2025/2026 rate cycle and details the tonnage-fee formula (FY2024 national program administrative costs of $6,906,002 divided by a 115,262,834-metric-ton five-year rolling average). federalregister.gov
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Every export cargo of U.S. wheat, corn, or soybeans that leaves the country by grade gets there because a federal or federally supervised inspector graded and weighed it. The service is mandatory under the U.S. Grain Standards Act, and it isn't paid for by taxpayers — it's paid for by the exporters who use it, through hourly and per-ton fees that, by statute, are supposed to keep three to six months of operating cash sitting in reserve. In fiscal 2023, that reserve broke below zero.