LIP software does not have an option to factor for share, and any livestock owned by multiple participants much be manually divided. Manually separating the inventory and losses in a manner equitable to each owner is rarely possible, particularly in the instance of 50/50 shares, and uneven number in inventory or uneven number of losses. LIP software should have an entry for share to reduce chance of erroneous payments, and to improve efficiency in data-loading producers’ applications.
1-LDAP (Rev. 1) Amend. 1, Par. 73 A specifies that when a participant has a percentage share interest in a livestock operation, the information for each participant shall be listed on separate CCC-852’s based on each participant’s share in the livestock operation. The example in the same paragraph uses an operation with 100 head, 50-50 ownership shares, and a loss of 10 adult beef cows. In that particular example, dividing the inventory and mortality into two separate applications is quite simple, and would be relatively fair to each producer; however in a situation where a 50-50 ownership operation had a total of 27 head and 3 losses, for example, one participant would have 13 in inventory while the other had 14, and one participant would claim 2 losses and the other would claim only 1.
The process of data-loading a LIP application correctly would be far more efficient if the total inventory and total number of losses could be loaded, and a share factor also entered into the software to be applied to the payment. A comparable example would be NAP application for payment. We enter total acres, total production, etc., and also a share.
For the Livestock Indemnity Program, it is unclear what date is to be loaded in Part B-Notice of Loss of the CCC-852. Our STO has advised that it is the date that the adverse weather event occurred, per confirmation from National Office. STO states that National Office agrees that subparagraph 76A item 6 needs to be rewritten in the 1-LDAP Handbook.
The Notice of Loss for LIP only captures one date, as opposed to the NAP Notice of Loss, which captures when the adverse weather occurred, and, as a separate entry, when the loss was apparent.
The form and software should be revised to allow for two date entries. In some cases, the loss may not immediately be apparent. This will ensure that COC’s are reviewing weather data for the correct dates (when the weather conditions actually occurred), while also ensuring that requirements are met for reporting losses within 30 days of when they are apparent.
NATIONAL OFFICE RESPONSE:
Thank you for forwarding the suggestions. I agree with both issues raised.
Issue 1 will require a change to software so I will need to make the software folks aware of this. This may take some time.
With respect to issue 2, I am currently working on an amendment to 1-LDAP (Rev. 1). I will see if I can get the notice of loss updated to clarify the date in the amendment.