Programs Submission Response: Eligibility Forms

ISSUE:
Currently producer have two certifications that they need to certify to on two different forms. These producer certifications could be combined on to one form for submission to the County Office.

FACTS:
Currently producers are required to certify annually on form CCC-860 as to whether or not the qualify as a socially disadvantaged, Limited resource, or beginning farmer for program benefits according to 1-CM paragraph 950.

Producers are also required to submit a CCC-941 to certify their adjusted gross income for each year they are seeking program benefits.

SOLUTIONS:
These two form the CCC-941 and CCC-860 could be combined on to one form and require only one signature to certify both the Adjusted Gross Income as well as certify whether or not you qualify as a Socially disadvantaged, Limited Resource,  or beginning farmer or rancher. This would be less of a burden on the County Office Staff as well on the producer who already have enough to sign for while visiting the County Office. Not to mention, it would be one less form to file.

NATIONAL CHAIR COMMENTS:
The CCC-941 needs to be kept simple and meet IRS requirements, so adding information to the form may be challenging. However if it is possible then consolidating forms and reducing paperwork is always beneficial.

NATIONAL OFFICE RESPONSE:
Thank you for your message.  I understand the suggestion and the reasons for it. 

PECD staff looked hard at ways of minimizing the burden on producers and on FSA when we designed the CCC-860 to replace the FSA-217. We appreciate your national chair’s comments below about the need to keep forms simple.  We could not agree more.

FSA’s goal (seemingly met) was that the CCC-860 could be used for all the farm program applications (meaning we did not need different forms of CCC-860) based on program participation. We even tried to make our form usable for farm loan programs (agency wide if you will) – however, it seems we only mirrored farm loans’ definition of beginning farmer or rancher and the CCC-860 is still not usable by farm loan programs (farm loans program call).

I am sure that you are aware that the CCC-860 is not “required,” whereas the CCC-941 is (down to like the fourth level of embedded interest). The CCC-860 is the for the enrolling or applying participant who is seeking recognition as either an SDA, LR, or BF (for instance, as a SDA, LR, or BF joint operation, legal entity, or individual) and the CCC-941 is required for that same participant (and if the participant is a legal entity or joint operation, a CCC-941 is also required from each of the participant’s members (something that is not true of the CCC-860) down to the fourth level of ownership.

Two areas of different law cause need for a CCC-860 and CCC-941. They each accomplish different things. Additionally, a CCC-860 for a participant certifying as an SDA would not be required each and every year – where a CCC-860 for a participant seeking recognition as an LR would be required each year. The CCC-941s are referred to IRS (each year)… and the CCC-941 contains language regarding disclosure to IRS. 

Based on all these different things that each form is required for and from and what each accomplishes and how often each are required, I think it unlikely that we will be able to combine these forms into one. Further, I believe our CCC-941 universe is much larger than our CCC-860 universe. Lastly, completely different objectives are being accomplished with each form.

We appreciate the inquiry. By copy of this reply I have shared the suggestion and inquiry with PECD staff. In the event that either or both these forms are reopened for amendment, we will keep this suggestion in mind.