Congressional Agricultural Hearings — October 28, 2019

FSA County Office Employees are facing challenging times.  You are administering more programs from various software platforms than ever before.  You face these challenges head on each day with fewer employees than we have ever had.  NASCOE understands you are struggling to meet the daily demands of providing an ever-increasing array of programs while maintaining the same quality of service your customers expect and deserve.

Your NASCOE team has worked diligently with the FSA Administration to increase staffing in field offices.  We supported the development of a work measurement tool to support our case for additional staffing, however the administration continues to withhold the full results of the workload model.  Members of Congress have also requested on multiple occasions and been denied this information from the Department.

NASCOE continues to work with concerned members of Congress to provide additional funding for FSA salaries and expenses.  Congress has responded and provided their support.  They are concerned about the American Farmers who depend on you to deliver the farm programs passed by Congress to help keep rural America strong.  Due to these concerns, both Houses of Congress have recently held hearings on the 2018 Farm Bill Implementation.  They have asked the tough questions regarding FSA county offices being properly staffed so employees have the ability to administer these farm programs.

On September 19, 2019, Under Secretary Bill Northey testified at a joint House hearing of the General Farm Commodities and Risk Management Subcommittee and Livestock and Foreign Agriculture Subcommittee to Review the Implementation of Federal Farm and Disaster Programs. You can view the hearing by clicking on the following link.

The hearing is 3 hours long so you may want to skip ahead to the following points indicated below to hear the items that best reflect the issues that NASCOE has been working closely with members of the House on:

1:06 – Congressman Peterson – Staffing concerns and part time offices

1:12 – Congressman Conway – 2018 Farm Bill implementation

1:15 – Congressman Peterson – Employment application process

On October 17th, Deputy Secretary Censky provided testimony and answered questions at a hearing held by the Senate Agriculture, Nutrition and Forestry Committee on implementation of the 2018 Farm Bill.  Below is a link to the page where you can watch this hearing.

Implementing the 2018 Farm Bill | The United States Senate Committee On Agriculture, Nutrition & Forestry

You may want to skip to the following times which highlight the committees concerns about the status of FSA staffing:

0:36 – Senator Hoeven – FSA office staffing

1:21 – Senator Hyde Smith – Asks questions concerning the current law prohibiting the closure of any FSA county office without prior congressional approval, and prohibiting the relocation of any staff that results in an office with two or fewer employees

FSA programs are discussed at various points throughout both hearings.  Please take time to look at the clips from the hearings to see how NASCOE and Congress are working together to address these concerns with USDA.  We believe you will find that Congress is very aware of the lack of hiring going on in FSA across the nation.  You will also see how much Congress appreciates the work that our members do for American agriculture in county offices across this nation each day.

NASCOE Program Submission Response: CARS

ISSUE:

When adding acreage information when in the bulk copy setting, you have the ability to select a field number that has the acreage already reported on it.

FACTS:

Being able to select a field that has already been information on it causes an error message to appear after you have tried to add the bulk copy, but will only tell you one field at a time that has already been completed(if you have multiple fields that have already been completed in the review screen, it will only show one field at a time that needs to be changed). This causes more time being taken to remove the field that already has information on it.

SOLUTION:

I think it would be very beneficial to have an error message that states all the fields that have the crop information already on them and see if you want to continue or cancel the submission.

WDC Response: 

I will add this to the list of IT enhancements for consideration.

NASCOE Program Submission Response: CARS & FSA-578s

ISSUE:

It would be extremely helpful to the county office if we could have a section on the 578 that lists the Producer’s share of the acres.  For example, John Doe has 2 farms, Farm 1 @ 100 acres and it is 100% his.  Farm 2 @ 250 acres, but it is on a 50/50 share.  This year, John Doe plants all of his acres to corn.  On the 578 it lists 350 acres of corn.  But John’s share is 225 acres. 

FACTS:

I’m not sure if there are any facts other than CARS does not generate a report or 578 that lists the producer’s share of the acres he/she farms.  But MFP and other programs are calculating the producer’s share of the acres. 

SOLUTION:

Update CARS to have a report of the producer’s share of the acres by crop he/she farms and list the producer’s share of the acres by crop on the FSA-578. 

WDC Response:

I believe this can be accomplish using the EDW producer crop detail report.  This is not a canned report so the user will need to export the data and query information for the specific producer.

NASCOE Program Submission Response: Continuous Acreage Certification

ISSUE:

To obtain the FSA-578C Continuous Certification form in CARS, an acreage report must be certified before the form can be printed.

FACTS:

According to 2-CP par 35, continuous acreage certification was developed to streamline the acreage reporting process and reduce producer visits to the County Office as well as reduce network congestion.  A lot of times, acreage reports are taken over the phone and printed for when the producer stops by to sign.  In order to get the 578C continuous coverage form that goes with the acreage report, some County Offices are certifying the acreage report, printing the form, then removing the certification dates after the form has been obtained.  In doing this, incorrect dates could potentially be entered back into the system.  A blank form can also be obtained from the FSA forms site but County Office staff must input all pertinent information when all of this information is already located in CARS. 

In doing this, it is only an attempt to provide the best customer service to our producers.

SOLUTION:

Remove the mandatory certification date in CARS in order to obtain the FSA-578C.  The producer is not signing up for continuous certification until they mark “Yes” in the boxes on the 578C and sign.

WDC Response: 

Policy requires at least one field of the crop, type, and intended use to be certified.  Because of this CARS requires the certification in order to obtain the FSA-578C.  I will work with policy to see if this functionality can be changed to not tie the printing of the FSA-578C to the continuous signature date.

NASCOE Program Submission: Common Programs / Farm Records / Recons / Transfers

ISSUE:

CARS-after removing a producer either as other tenant or owner in farm records, the producer still remains on the acreage report when the crop rolls over.

FACTS:

If a PT or farmer is not paying attention during the certification process the wrong producer gets the share if the crop rolls over.

SOLUTION:

When an edit in farm records removes the producer and you hit refresh farm data in CARS it should automatically delete any fields that the removed producer gets a share of.  Just like it does when a field edit is done.

WDC RESPONSE:

Current software requires 100 percent shares to be loaded.  I will add this to the list of IT enhancements for discussion and consideration.

NASCOE Program Submission Response: Acreage Reporting in CARS

ISSUE:

I absolutely love the auto populated initials on the 578, but I had an incident this morning where my producer spilled his Dr. Pepper on the farm folder after it was signed. I went in to the software to print a new 578 to resign the one that took place of the destroyed copy. When I went to print without revising, it put my initials down as a revision.

FACTS:

All revisions have to be documented in the COC minutes according to 2-CP. When initials are placed on a 578 as a revision, it will make it look like an erroneous revision.

SOLUTION:

Adjust the CARS software to read if a field was truly revised or if it is just a reprint.

WDC Response:

I will add this item to the list of IT enhancements for discussion and consideration.

NASCOE Program Submission: Common Programs / Farm Records / Recons / Transfers

ISSUE:

2-CP requires a hard map with crops certified to accompany the 578. 2-CP, Paragraph 340 allows you to use Cars maps when Citrix is down. We are finding Citrix down more often than not and printing delays are great running from remote servers. We would like to use cars maps more often, but often you cannot see the field numbers due to the zoom level. With the 578 being the heart of most of our programs, we need our acreage reporting tools to be as user friendly as possible.

FACTS:

We are having to use a combination of MIDAS, maps that you cannot read the field number on or the citrix software with workarounds to certify farms. It is creating huge time delays in certifying farms. If a COR was to review the map, it would be difficult to pass a COR review of marking every field with required information.

SOLUTION:

Have CARS Maps being able to change the zoom level of maps, so that labels fit inside of fields. Perhaps rotate the page orientation, so there is also more printing area. The other solution would be to run the required fixes on Citrix, so we can get legible maps printed out of Citrix.

WDC Response: 

This is a very valid concern and I will be include this suggestion on our IT Investment List for discussion and consideration.  Your feedback is very much appreciated.   Thank you and have a great day!

NASCOE Program Response: Common Programs / Farm Records / Transfers

ISSUE:

FSA-578 & FSA-578C is retained when OP/OW/OT is removed from farm

FACTS:

When a producer is removed from farm the interest they had via the FSA-578 and the  FSA-578C is retained  and will roll to next year..  

SOLUTION:

When producer is removed from farm, all 578/578C interest is also removed.

(NOTE: The system used to terminate ALL FSA-578C’s when a OP or OT was removed. COF’s could run the terminated FSA-578C to catch these and make the appropriate changes to the FSA-578 and FSA-578C.)

WDC Response:

When producer is removed, the continuous certification is terminated, however the crop will remain certified as CARS currently require shares to equal 100 percent.  In such cases, if counties are experiencing issue where the continuous election is not being terminated please submit it through the CARS issues SharePoint site for review.

NASCOE Programs Response: Payment Limitation interfacing with CARS Data

Issue:

Business File software currently is unable / unwilling to read producer shares from CARS software.

Facts:

Other applications (i.e. farmers.gov for MFP) are able to read the shares, and so should Business File. Typos could be reduced on the 902, reducing problems with IPIA.

Solution:

Program the software for Business File to read producer shares from CARS.

D.C. / KCMO Response:

Thank you for the proposal. We are always open to ideas for making the processes work better for COF’s to administer FSA’s programs including determining a producer’s payment limitation and payment eligibility. The following is my perspective on the issue.

Currently, the CCC-902 is the form used for collecting information about a farming operation’s land contribution and begins by automatically retrieving the basic farm interests from FRS for all tracts of land associated with the producer who is completing the farm operating plan. FRS is current, and up-to-date, with a producer’s farm interests as reported to FSA and any subsequent changes in a producer’s farm interest are reported to FSA and immediately recorded in FRS.

A producer, who becomes a program applicant, is further required to report detailed information on a Farm Operating Plan relative to the lease agreement (cash, share or AUM), number of acres associated with a lease, whether the producer had interest in the land in the prior year and the names of the producers who the land is leased to or from. This data collection is required on the CCC-902 to ensure an accurate determination for applying substantive change rules, and identifying the significant contributions for determining eligibility with actively engaged in farming and cash rent tenant provisions.

Unfortunately, it is not possible to rely on a producer’s acreage report to collect all the necessary information for a producer’s farming interests to make the determinations mentioned above. As you can imagine, it would be unconventional to rely on the acreage report when it is filed later in the program year or may not be filed at all in some situations. Furthermore, the acreage report does not collect the lease information necessary to populate a CCC-902 used to make the required payment limitation and payment eligibility determinations.

At the current time, FRS is best source for collecting all of a producer’s farming interests and then populating the lease information for each tract in Business File when the producer becomes a program applicant.