Programs Submission Response: ARC/PLC Payment Reports

ARC/PLC Non Payment Reduction Report

This report can be very lengthy and consist of several pages due to listing all known errors. Many of these pages are often the result of “Less than 10 acre Bases”, which are not errors that need corrected.  While per 1-ARCPLC, paragraph 235, we do need to know these farms to ensure the SDA flag has been properly loaded if applicable, this is not necessarily a potential fixable error in all cases.

The report needs the ability to eliminate certain errors, specifically “Farm does not meet minimum requirement of more than 10 total base acres for all crops”. This would greatly reduce the number of resulting pages making the report more manageable and more applicable.

Thank you for providing a suggestion regarding the Nonpayment Report. The problem with “eliminating” certain nonpayment reasons is that the Nonpayment Report obtains its information from the Direct Attribution process where the reductions occur and there isn’t a way to determine if the nonpayment is something the county office can correct or if it’s always going to be a reduction. The Nonpayment Report is provided to identify where reductions have occurred to the producer’s payment and for the county office to verify that the system was updated correctly at the time of payment, and if not, then they take corrective action to resolve the reason listed on the Nonpayment Report. 

An example of the problem is as follows: Producer A and producer B both don’t meet the 10 base acre provision. Producer A should have had the SDA value updated in the Subsidiary Eligibility system prior to the payment process, but the county office forgot to update the system timely. After the payment process both producers are listed on the Nonpayment Report as not meeting the 10 base acre provision. The county office should be reviewing the SDA and Limited Resource values for both producers to ensure they are updated correctly. If the Nonpayment Report no longer displayed the producers for not meeting the 10 base acre provision then the county office has no way of knowing that the SDA value for producer A should be updated and as a result producer A won’t receive the ARC/PLC payment.

As I stated above, the Nonpayment Report can’t pick and choose what reductions to display because it has no way of knowing what reductions are permanent or what changes could be made in the system to resolve the reduction reason. A suggestion might be for the county office to print the Nonpayment Report and after verifying the reductions listed, then the next time they can compare the verified Nonpayment Report to the new Nonpayment Report to identify any new producers or reductions since the last time the report was accessed.


Programs Submission Response: ARC/PLC Prepayment Report

There is a need for an ARCPLC Prepayment Report for 2015 and future years.

It is understood that ARCPLC does not have a guaranteed payment each year. However, it would be very beneficial to have access to some type of report prior to payment time that shows eligibility flags for a person/entity that would prohibit a payment being made timely. This would also reduce the number of producers who would show up on a nonpayment report.

Provide counties with access to a report that shows producer/entity with a share that is missing an eligibility flag prior to payments being announced and issued.

WDC Specialist stated that requirements have been completed and a report is scheduled to be available for the FY 2016 payment run. Unfortunately, the resources could not be allocated in time for the FY 2015 payment run.


2016 NASCOE Convention Q&A Session with Management

Management Panel: Val Dolcini, ADM, Chris Beyerhelm, Associate ADM, Greg Diephouse, DAFO, Darren Ash, FSA CIO, Radha Sekar, CFO, Thomas Mulhern, Director, HRD, Brad Pfaff, DAFP, Mark Rucker, DAM, Glen Schafer, BTO, Doug Nash, OCIO-CIO, Clinton Swett, Deputy OCIO

Q: What is the timeline for the new MPS and is that the only kind of printer that will be sent to the county offices?

A: Clinton Swett: There was problem with the original provider contract. There will be a MPS 2, and that contract should be awarded August 24, 2016, but any printers ordered will not come in until March 2017. There are many components in the process and it will take time to get that all in place.  Service Centers will be able to order the new printers. If you have a MPS 1 printer, you can keep until the end of 2017. If you don’t have any new printers, you will be able to get one after February 2017.  CTS provides the service and it will be up to Darren Ash to order, but the MPS saves about 40% of the cost of using a regular printer. FSA printed over 10 million pages and the department used only 13 million pages.


Q: What would it take to get sick leave eligible to donate?

A: Tom Mulhern: It would take an act of Congress


Q: It has been 28 years since Program Technicians have had an increase to a grade 7, when will it happen again?

A: Greg Diephouse: They are looking at program descriptions line by line to determine the level the program technician is working at and the position descriptions will be revised and then it will be examined for reclassification. Tom Mulhern: It is difficult to get new grades, and if it can be supported, it will be considered. The work group is working on this now.


Q: Are the states still limited on how many COC meetings can be held?

A: Greg Diephouse: States are funded for 8-10 meetings, but they are allowed to meet monthly, but not all counties meet monthly.


Q: Why did you choose to work for FSA?

A: Darren Ash: He had been at NRC for about 9 years and was ready to take on a challenge and liked the FSA mission.


Q: For 2014, there was a sweep in ARC/PLC to remove approval dates; can the sweep date happen based on the enrollment date rather than approving them individually?

A: Brad Pfaff: There is a difference between the allotment and the apportionment. When the sweep happened, it was due to the sequestration rate. Rahda Sakar: When the contracts were accepted we had not received funding; there was a sweep to make sure they were approved when funding was available. The sweep for this year should happen in September.


Q: The current GPS units will be going offline and that will create a problem with accuracy when using these units. When will TRIMBLE be released?

A: Darren Ash: He wants to go back and get additional data before committing to a timeline.


Q: Temporary employees hired after 1989 cannot buy back their time. Will this be changed?

A: Tom Mulhern: This has been addressed and some legislation would have to be changed in order for that to happen. Val Dolcini said they would work with OPM to address this situation and see what they can do.


Q: Windows 10 is to be installed soon and training will be needed to understand this system. What kind of training will be provided?

A: Doug Nash: Windows 10 will happen over the next couple of years as new equipment is installed. They will work on the training as the equipment is upgraded. They will communicate with FSA on training.


Q: When an update is done with a new producer, new farm, and  you go back to the business file you need to refresh that information but it takes out all the information on all their farms and it is necessary to re-load all that data.

A: Brad Pfaff: We will help get that fixed. Darren Ash: They will get the fix.


Q: What process do you use when a COC imposes a decision and what do you do to override the determination?

A: Brad Pfaff: He described the process of appeals and how it is done from the county level to the state level to the Washington DC level. They look at procedure and compare that to the appeal and if it possible to provide relief, then they do. If something is a violation, then DAFP looks at the situation surrounding the problem.


Q: Are there any plans to use retired employees?

A: Tom Mulhern: There is an act for hiring retired annuitant. It is a half time employment opportunity, but only about 1% would be able to be rehired. More information will be coming out on this issue. The notice has been issued on this subject. Val Dolcini: The mentor program using retired employees is something they are looking at in the succession planning process. Greg Diephouse: Work with the state office regarding managing this tool.


Q: CRP rental rates can be reviewed every two years. Why can’t we review the rental rates annually so they move with the current prices more reflectively?

A: Brad Pfaff: It does cost FSA to do the survey used for the rental rates. There are conversations on doing the survey annually and he will take that back to Washington.


Q: Are there discussions regarding allowing NRCS to edit our CLU layer?

A: Brad Pfaff: Yes those discussions are happening to have NRCS edit the CLU and SCIMS. Darren Ash: They are looking at the impact it could have allowing other agencies to have that type of access.  The goal is to have agencies be able to share information since we have common customers, but they are looking for an appropriate way to administer this.


Q: Could proration be done with BCAP funds because there is not enough money for this program?

A: Brad Pfaff: There has been a lot of interest in this program. There is $15 million available annually and this creates a challenge to administer this program. It is very limited what is available in this program. He wants to hear suggestions and comments to make the program better. The factor question can be considered to determine if this would be feasible.


Q: The furniture refresh project expired, but some offices did not get new furniture. Will they get some in the future?

A: Mark Rucker: If funds become available, they will continue this project. Chris Beyerhelm: With the new discipline about spending money, there will not be money left over at the end of the year to use in the furniture refresh. It needs to be worked into the budget so it happens all year and not rely on a surplus at the end of the year for such projects.


Q: There is some confusion regarding staffing ceilings. Can you clarify this?

A: Greg Diephouse: Two years ago we were 400-500 under ceiling and now we are at non-fed ceiling of 7228, so just over one hundred vacancies. Only 6 positions are left to work on.


Q: When will we be able to get credit in the county where the work is done?

A: Chris Beyerhelm: They are looking at this enhancement and they are planning a prototype in about 6 months.


Q: AGI’s have been sent to IRS and information came back and said it has been updated, but it has not been updated in the system, so it has to be re-sent and this takes a lot of time. Can this process be changed?

A: Brad Pfaff: They are working on trying to get answers from IRS on this issue and he would like to see it happen that the COF could put in a determination after a set amount of time. This is something they are working on. Val Dolcini suggested that this topic be discussed at the SED conference.


Q: Can the COC’s or STC’s look at the projected ARC rates and how this is determined? The projections are not good for some counties and this should not be happening.  This is really a problem with irrigated and non-irrigated land; they have to use the same benchmark for irrigated and the dryland producers would not receive a payment.

A: Brad Pfaff: They will look at the rates and they will have more discussion with Extension about releasing projected rates. If 25% of the crop is irrigated in a county, NASS usually breaks out the differences in irrigated and non-irrigated land, but in some states this is not happening.

They use NASS data and then to RMA and then to NASS district and then to the state committee when determining some yields. SED’s can submit documentation to justify a change, but STC’s do not have authority to adjust yields. Val Dolcini: This will probably be a 2018 farm bill issue, it will not be changed in the current bill.


Q: FSA employees are strongly concerned about NRCS having access to CLU and business partner applications. Can county committee members have access to new web 4.2 WebTA to approve time sheets?

A: Tom Mulhern: It will have to be discussed, from a technology perspective, it can be done, but the policy would have to be clarified.


Q: In the past, there was a person in USDA service centers to update LincPass. In many cases now, these centers are long distances away. Can a person in the service center do this?

A: Mark Rucker: At this time, the answer is no. An activation station would be required and most of this is a resource question. The only thing that can be done is a PIN reset on regular stations. You need a special station to do certifications.


Q: Temps are to be released on 9-30-16. Is there a way to keep them longer?

A: Greg Diephouse: They had a commitment to try and keep the temps until September 30 of this year. The farm bill money is mostly spent and there may be some money left for the next fiscal year, but there would not be much. Until more appropriations are secured, this would not be possible.

Chris Beyerhelm: If we want to have temps, we would have to give up something else. Val Dolcini: Many temps have become permanent employees, but it is a resources issue at this time. It looks like there will be a continuing resolution and it will have to be determined if there will be money for temps. We are 20% down on FTE’s from a few years ago, so we use temps more strategically to help where needed. States should not plan on temps at this point.


Q: Since grazing is required for emergency programs, can grazing rights be identified in CARS?

A: Brad Pfaff: Yes, this can be done, but he wants more information on the policy implications.


Q: There are offices in IL that are empty and rent is still being paid. Why?

A: Greg Diephouse: There is a law in effect that will not allow closing such an office. The legal language would have to be changed in order for that to happen.


Q: Thanked them for the employee satisfaction survey. Could there be a comment box to explain answers? 

A: Chris Beyerhelm: He agrees that we should be able to clarify answers. They will continue to try to have that added. In the meantime, employees can send comments to the staff that are present.


Q: When will the COC approval authority be restored in 2-CRP?

A: Brad Pfaff: There should be information released in the near future regarding this issue. This was an issue that Brad wanted to work on right away. A notice should be out in the next few weeks restoring this authority.


Q: Is it law that the IRS must verify AGI’s and can this be restored back to the county offices?

A: Brad Pfaff: This came out as a result of the improper payment act. This is a requirement that the IRS check the AGI’s.


Q: Facility loans for movable equipment and trucks are causing some banks to complain that they cannot match the interest.

A: Brad Pfaff: There will be training the week of August 8 regarding the new policy. Trucks under loan must be box trucks for cold or dry storage. We are not providing loans for semi’s. There is tremendous interest in helping growers to move their product to market, mostly fresh food and vegetable. This will provide a means to move the product. This is something the COC is involved in and they will review these applications. He believes this will help some regional problems in moving products. The producer always has the opportunity to obtain conventional lending.


Q: There is concern about the 3 year useable life for a truck and that this could result in producers coming in more regularly.

A: Brad Pfaff: There will be more training on this program. Val Dolcini: Please let management know if there are more complaints from bankers.


Q: Safe acres are limited; there are many applications but the acres are very limited. Is there any anticipation to increase SAFE acres?

A: Val Dolcini: There is a lot of interest in SAFE acres but those acres are under the conservation cap of 24 million acres and they are bumping up against that ceiling. They will be releasing information regarding the acres that could be available. They hope to have a more definitive answer by fall.


Q: ACRSI: Some agents were telling producers that they did not have to come to FSA at all if they certified with their agent. FSA certified the crop report and when it was submitted to insurance, the system messed up the crop reports in FSA. FSA certifies in hundredths and insurance certifies in tenths and this creates problems. Agents only care about the insured crops and this creates problems with non-insured crops.

A: Val Dolcini: ACRSI is an initiative in the current farm bill and they have been working on making this work between the agencies. The approach taken in the initiative, by starting with 30 counties and now up to 95% of reportable crops, seemed to be a good way to approach this situation. They utilized people from across the country to provide input. It is very important that the message is the same with the agencies involved. 95% of farmers come to FSA and then it is sent digitally to RMA at this time.  Precision Ag industry will be involved and must abide by the standards created for this program.


Q: AO-1660 requires language proficiency, why are we doing this?

A: Greg Diephouse: This will be addressed in the future


Q: Why are we not getting comp time given at time and a half for working with the producers?

A: Greg Diephouse: This is a state by state decision and they want to provide adequate compensation for work done.


Q: What is the significance of having death notices for people who died many years ago?

A: Val Dolcini: Congress mandated that we work with social security to track deceased producers and that is why these are coming up. Periodically, mass mailings are sent to deceased producers and this is an attempt to clean up the files.


Q: There is concern about the state DNR agencies changing their rules when working with conservation programs, burning, mowing, etc.

A: Val Dolcini: They work with land grant agencies in the states and NRCS is the technical agency and other agencies are partnered in this effort. They will look at this in the future.


Q: There is concern about NRCS doing FSA work on the CLU and business partner. There is also a problem with closing offices with no real data and justification based on workload rather than lack of staff.

A: Greg Diephouse: There are instances that producers may have to drive further for agency service, but there are cases where the office is in an isolated area, but at this time they cannot close offices. There are cases where the offices should be closed, but at this time that cannot be done.

Chris Beyerhelm: Using the criteria that Congress mandated was not based on workload but staffing and that should not have been the criteria, so this will be looked at in the future.


Q: On farms with less than 10 base acres, could those payments be made to beginning farmers?

A: Brad Pfaff: This is something that will be discussed. There is a beginning farmer initiative and this will be looked into. Brent Orr: This would take congressional action to change that statute.


Q: With regard to BTO, in many cases FSA is the point of contact, what are the future plans and the timeline for such.

A: Val Dolcini: This has been very successful and they want to expand this program further. There is a plan to expand this program so that all county offices can enjoy the benefits.


Q: Currently the county is in shared management and the CED retired, so now an adjoining CED must cover. Will CED’s be compensated for doing more?

A: Greg Diephouse: They will try and get to this issue.


Q: Fall reporting of winter wheat can be a problem to be done timely. Is there any way to do this regionally and not charge a late filed fee?

A: Brad Pfaff: They have worked with RMA on reporting dates. They have waived fees in the past, but that is not in effect at this time. The regionalization of reporting is something he would like to discuss.


Q: Why isn’t the DD getting input from the PT’s for CED reviews and likewise, the CED giving input on DD reviews and likewise upward?

A: Greg Diephouse: SED input comes to him throughout the year. He feels additional input is helpful, especially for the COC. At this time there is no formal process for this.


Programs Submission Response: ARC/PLC

eARCPLC – producer software error.  Producer’s farms are in random order in software (not numerical).  eDCP software was numerical.

Problem reported by a COC member who e-files contracts for 70 farms.  He reported farms are in no particular order (numerical or alphabetical by owner).  This is cumbersome for him to search and enroll.  County Office reported this problem during the 2014/2015 signup.  Producer reported the problem is still not resolved for his 2016 enrollment.

Update the software to show farms in numerical order similar to how eDCP operated.

The problem has been solved.

Programs Submission Response: ARC/PLC

Calculating HIP and Notifying Producers, National Notice ARCPLC-25 notified county offices that the Historical Irrigated Percentage was potentially incorrect or missing completely if the farm is not currently constituted the same as it was during the 4 year period of 2009 and 2012. There would also be missing data if a 2013 or 2014 reconstitution had been completed. County offices were instructed to research and find missing P&CP acreages for the farms listed on the Missing HIP Report that were reconstituted in 2013 and/or 2014 where HIP was not calculated. Once researched, the COF will load the manually calculated HIP into FRS for 2014 and into MIDAS for 2015 for each applicable crop. Once completed the COF is instructed to issue new Base and Yield reports to all producers on the farm.

For some county offices this includes multiple crops and producers on several hundred farms. This is adding a tremendous workload on these counties, especially if they have triggered for FY-2014 payments on either the irrigated guarantee or the non-irrigated guarantee. Preparing the new base and yield notifications for several hundred producers will be challenging.

Once the missing data is researched and the manually calculated HIP is loaded in FRS or MIDAS, run a batch process to produce base and yield notifications like we did during the initial phase of ARCPLC implementation.

I am excited about this suggestion and think that it would be beneficial for several of the programs.

They are making a change in MIDAS to add the HIP% to the 476, this will allow the COF to reprint the 476 after the HIP is updated and prevent them from typing the letter.   It’s scheduled to go out concurrently with Release 2.10 which is currently targeted for mid- to Late-March delivery to production.

I think this addresses the concern going forward.


Programs Submission Response: ARC/PLC

Correction to a CCC 861 or CCC 862 after the contract period is not allowed.

A CCC 861 was timely filed and timely approved for 2014. The contract had shares transposed between 2 producers resulting in the producers receiving the wrong payments. One of the producers contacted the office regarding the error when he received his payment. A request has to be submitted to the State Office for misaction/misinformation and then forward to DAFP for approval. The current process to make a correction is time consuming. There is no guarantee that this will be approved. Under the current process the producer may be penalized for being forth right about the error. (For example, if a farmer and landlord were on the contract with 60/40 shares and we entered 40/60, under the current correction process, if approved, each producer would get 40% of the payment. Had the producers not said anything, they could keep the whole payment.) Producers may appeal if misaction/misinformation is not approved which will cost the producer and the government time and money.

Can COC or SED be allowed to determine that there was no intentional misrepresentation by any of the producers and, provided there was a timely submitted CCC-861 or CCC-862, allow the producers to sign a corrected CCC-861 or CCC-862 after the contract period and have payments recomputed?

Producers are expected to review the forms prior to signing them, but with the combined 2014 & 2015 enrollment period many producers were reviewing a significant number of contracts. There may be an above average amount of honest mistakes and allowing an expedited relief process might be beneficial. 

Filing a contract after the end of the contract period (after the end of the enrollment period for 2014 and 2015) is not allowed. Any contract filed after the end of the appropriate period is subsequently not eligible for consideration to be approved. Once it is known that the contract is not correct, only DAFP has authority to act on the contract. 

Misaction and/or misinformation cannot be used as a request for relief in this case as the producer had a reason to know that the shares on the contract were not correct. The reason the producer had a reason to know is because the contract was signed with incorrect shares. The only relief that may be considered in these types of situations is programmatic relief as described in paragraph 252 of 1-ARCPLC.


Programs Submission Response: ARC/PLC

ARC-CO physical vs. admin county provisions are limited to 2014 & 2015.

If we have a payment system that can calculate a 14 and 15 payment based on physical location—why would producers be forced to change their administrative county to receive this payment for 16 and further years? Previously those producers have chosen an administrative office based on their residences and trade areas. Now we are forcing them to choose between administrative offices that provide convenience or that provide more relevant coverage benefits.  

Can the option to request benefits be based on physical county versus admin county be available each year of the program?

There are other programs that have eligibility based on physical county without changing the admin county (CREP is an example). Additionally, this would likely only affect a small number of farms.

Administrative county waivers are for 2014 and 2015 only. Because the regulation was crafted using administrative county as the source of revenue loss at the beginning of the farm bill, DAFP pursued the physically located waiver for 2014 and 2015 but could not change from the administrative county position. Base reallocation, yield updates, and election decisions were made with the knowledge that revenue losses were based on an administrative county.


Programs Submission Response: ARC/PLC Reports

ARCPLC reports show only farm numbers but not producer information.

Researching ARCPLC can be time consuming since offices often need to manually identify which producers are associated with the farms on various ARCPLC reports. CARS reports were recently updated to list both the farm number and the operator. While some individual farm contracts may have OW or OTs with shares, having the OP listed in ARCPLC reports also would greatly speed up the research in most cases.

List the OP name along with the farm number in ARCPLC reports.

This enhancement is on our list for ARC/PLC. I am not sure of a timeframe due to more pressing issues but we do hope to make this change on most reports. As an interim solution I would recommend using the ARCPLC reports with the MIDAS farm record reports made available in notice CM-774.  With a little cutting and pasting in Excel users can take the list from ARC/PLC and match it to the current producer data stored in MIDAS to get the names of all the OW, OP, and OTs as needed. I do realize this will leave a few gaps for prior years but should be a huge time savings compared to looking them all up one by one.

Programs Submission Response: ARC/PLC

Annual ARCPLC enrollment is scheduled to begin on December 1 of each year.  However many states have a November 15th deadline for small grains or hay.  Having enrollment begin on December 1 means that we just miss being able to enroll the producers who are coming into the office in November.  This means that the producer is likely to wait until the July reporting timeframe to complete his enrollment, which is a much busier time of year for us.

July is just a crazy time for us.  We used to spread the work between June and July, but with hay now being in November, we don’t see any June activity.   We’ve been looking for a way to spread out the workload in July already.  In my office we had just under 1000 farms on the July acreage reporting register last year, and that was with no DCP or ARCPLC.  This year we had a temp helping us with signup and acreage reporting and we still had over 1000 farms on the register and went into August with acreage reporting.

Allow ARCPLC enrollment to begin in October or November.  It would be easier to fit ARCPLC in November for those who had hay and ease up the work in July.  If allowing earlier signup would be something that could be considered then I think it would be greatly appreciated.

WDC is willing to look into moving the beginning enrollment date for ARCPLC up from December to maybe November.  This will allow producers who are making appointments in November to begin enrollment and to allow County Offices to manage workload.  Unfortunately, there is not enough time to enact these changes for the 2016 year.  However, they will endeavor to allow earlier enrollment in subsequent years.

Programs Submission Response: ARC/PLC

There are surprising holes in NASS data-counties that have production and have always had yield info but don’t for 2014 (3 of the top 10 counties for acres planted fall into this category), we have a county with a grain yield of 175 and a silage yield of 15. And overall, there is concern that the benchmarks were established using NASS data and we hear the annual yields will use a different formula.

Yield issues are still coming up. We have counties that are next door and similar everything. Their revenues are $138 apart. One count is capping at $70 the other is $67 short of a payment.

Producers and COF would like:

  • The final yield data. The yields are still not published as we were told they would be.
  • The information that support the yield. (Show your work on the math. How did we get to this final number?)
  • The reference to where this formula comes from. We are told the formula is not appealable. Where is the formula available? When I looked before I didn’t find it in the Federal Register or 1-ARCPLC.
  • What options were STC given to adjust benchmark and annual yields? A big issue in our counties is the benchmark yields. Were these adjusted for disasters?
  • STC was given a chance to look at yields around the 19th of October. What “rights” were they given?

NASS district yield be used over the RMA yield in priority order.

The National Programs Chair inquired with WDC to see if they knew why there was less NASS data for 2014 then there had been previous years. WDC didn’t know for sure but hazarded that it might be due to not enough producer’s returning the surveys. FSA must use NASS data whenever it is available. Only when NASS data is unavailable can DAFP use any other data. WDC has clarified that they established a method for determining the best data available to use assigning the yield (whenever NASS data is unavailable) as RMA data then NASS district. If NASS district yields were assigned, then STC’s were asked to review them to ensure they were reasonable for the county. In order to be consistent this method was used in all states and counties.

We probably need to start educating our producers on how important providing accurate data to USDA is. I’ve heard stories of producers who under-inflate their information to NASS because they “don’t want the government to know what they’re doing”. Conversely, I’ve heard of producer over-inflating their data to RMA to try and boost their APH’s. Even the COC’s are just making the best estimates they can when they set county average yields and aren’t typically using any hard data (beside maybe their own production). The fact of the matter is that you can point to any of the yield data and find a flaw in it. I’m not defending the DAFP ranking, but I can see their reasoning. NASS data is based on statistical methods. RMA data is based on actual reported production. NASS District is regional. COC data is estimated at best or guesswork at worst. None of it is perfect, but there isn’t perfect data out there for them to use.

Finally, you asked about the state office review of the 2014 yields that appeared off. I don’t know what percentage of the submissions that DAFP may have altered, but I do know that some states submitted changes that were not accepted. I think primarily it’s because they were questioning NASS yields and ,as I mentioned before, the regs require NASS data to be used when it’s available. They may have reconsidered some RMA or NASS data yields that STO’s were concerned about, but my guess is they would have had to provide some hard data to justify a change.