Programs Submission Response: NAP

ISSUE:
In XX State there were 2015 NAP policies sold with the Direct Marketing Price option.  The office is being told that 2015 producers are not subject to direct market prices because their premiums were based on average market prices, even though they chose the direct market option.  How can we offer the direct market pricing (and organic pricing), if it’s not available?  Now we have 2016 contracts, again with the option of direct market pricing.  I really don’t know what to tell my producers.  Telling them it’s been in WDC since January and they are working on it just doesn’t seem to work anymore.

FACTS:
The office received this response from their STO:  “Please know our recommendation was made in January and was for those crops that had application closing dates that had not yet passed (our recommendation had to be made not later than 60 days before the application closing date for the crop.  So, please understand that the January 2015 recommendation was not for all NAP crops.  But it is my hope that we get an answer soon and that the answer gives us further guidance on how best to proceed for 2016.”

SOLUTION:
The CO believes that based on the training, the memo we received on September 18th and the handbook that:

  1. Producers should be entitled to 2015 direct market pricing as they had the option at enrollment, regardless of what the premium calculated out to.  If the premium calculated at average market price, it’s not under the producers control.
  2. The 2015 information was submitted to WDC well after the deadline outlined in 1-NAP, para. 207B.  Again, out of the producer’s control.
  3. And the memo on issuing manual payments clearly states that another payment will be issued to those producers who chose direct market pricing.

NATIONAL OFFICE RESPONSE:
The following is the latest on the recommendations of organic and direct market pricing from the XX State FSA Committee.

The State committee did send a timely recommendation of direct and organic prices for some crops.  Upon receipt, a representative of the National office visited with the State office in XX briefly to discuss the data sent with the recommendation.  The National office then performed extensive research and analysis of the crops and recommendations in order to arrive at an informed decision. 

On November 20, 2015, DAFP advised the XX State FSA Office of its decision on the 2015 recommended crops.  The crops were approved.  Prices were established.  A notice is forthcoming from the State office to XX county FSA offices advising them to apply the price to 2015 applications for coverage.

While we regret the length of time it took to analyze the recommendation, we believe the policy instituted by DAFP regarding establishment of direct and organic pricing (soon to be issued) will speed NCT crop approval of prices.

Thank you for your concerns.  However, XX counties should soon be receiving notice of 2015 direct and organic price approvals soon.