Letter
Dear Undersecretary Hoskins,
On behalf of the National Association of State Departments of Agriculture (NASDA), I would like to express our appreciation for USDA’s continued partnership in advancing the National Milk Testing Strategy (NMTS). State departments of agriculture remain committed to safeguarding against foreign animal disease and maintaining the highest standards of food safety.
As the NMTS program has matured, many states have successfully reached Stage 4, or “Unaffected,” status, meaning there is a strong and consistent sample of data and no known detections of H5 Highly Pathogenic Avian Influenza (HPAI) in the states’ dairy herds. According to the USDA’s NMTS website, of the 46 states currently enrolled in the NMTS and performing active surveillance, as of the date of this letter, 34 states are classified as unaffected, and another 8 states are classified as provisionally unaffected.
In USDA’s original guidance on the NMTS, the agency indicated that testing frequencies would decline in states that achieve Stage 4 status. While some states have reduced their testing frequency, others have maintained their current testing levels without clear guidance from USDA. Continuing to test at the same frequency as affected states places an unnecessary burden on our members, both financially and operationally. This ongoing testing obligation is particularly concerning given the growing need to allocate staff resources toward other high-priority animal health risks, such as New World screwworm, that may require rapid and coordinated responses. While cooperative-agreement funding for NMTS testing has been helpful, those agreements are expiring; pending extensions or new awards, states are concerned about the program’s continuity.
We respectfully urge USDA to reduce NMTS testing frequencies for states that have reached Stage 4 status and have demonstrated limited risk of an HPAI outbreak in their dairy herd. We also ask that USDA provides clear guidance on the future of cooperative agreement funding for NMTS testing. These changes would uphold the integrity of the program, while ensuring that both federal and state resources are efficiently and strategically deployed.
Sincerely,
Ted McKinney
