Programs Submission Response: Updating 902 Land Contributions

Updating the 902 Land Contributions when a producer needs to revise his/her Farm Operating Plan

It is very time consuming to select each:   *Farm Number *Tract Number *Owner Name * Farmland or Cropland *whether or not they farmed it last year Yes/No *Acres

It would be much more efficient to be able to have an option to “select all” above each column so we could uncheck the ones not needed.

We agree the option to select “All Tracts” would be beneficial when recording leases. I will add this suggestion to the list of enhancements that we would like to complete but it may be a while before we can implement the change due to resource and budget constraints. 

However, the option to “select all” for the Type of Acres, Land Interest the same as last year question and Name, we intentionally default the type of acres and land interest question to empty to force a selection and if there are multiple producers with relationship to the tract, the producers with the lease to or lease from must be selected. These fields should be reviewed and entered independently for each tract to ensure the information selected is accurate. In addition, for the Name, it is very possible different tracts have different customers related to the tract so the ability to “select all” cannot be used.

Programs Submission Response: Subsidiary Reports Enhancements

Subsidiary Business File Reports

There are several reports that need to be developed to assist County Offices in order to know what is within the Business File for a producer, or a specific “group” to target what is needed or may be incomplete. This can aid in preparation for sign up and preparing for payment cycles.

Provide County Offices with the following reports:

  • Producers in Business File without “Determined” status
  • Producers in Business File with “Determined” status with “Last Update” listed
  • Active Estates in Business File
  • Non Family Joint Operations

A project is currently underway to provide a data warehouse with the ability to create reports from the business file system. When the functionality is provided, users should have the ability to filter information for:

  • Producers with a specific farm operating plan status
  • Estates with an active farm operating plan
  • Joint Operations that do not include all family members.

I do not have a timeline when the report will be available. 

In the meantime:

  • I already provide a report monthly for producers with a farm operating plan that does not have a “Determined” Status
  • I provide a yearly report for Estates older than 2 years with active farm operating plans that have received payments. This year’s report was provided in December 2016 for State and County Offices to review according to notice PL-273
  • I provided a report of joint operations that do not include all family members for county offices in November 2016 according to the training and 5-PL handbook amendment Jim Baxa provided for determining actively engaged in farming and foreign person for joint operations.

County Eligibility Reports in Subsidiary

We can run reports for AGIs filed and not processed, but the report basically stops there. The capability to add information and more sorting field possibilities are needed in order to better track AGIs filed and not processed by the IRS.

It would be easier for us to track and monitor producer AGI forms if “date filed by the producer” was added as a field to be printed in the report. This would allow the possibility of being able to sort by date when the report is downloaded in spreadsheet format. This would allow us to better monitor those approaching the 180 day deadline.

The County Eligibility Report currently available in the Subsidiary system is not designed to include additional fields based on the criteria selected to run the report. The report will display customers that have been updated with a “Filed CCC-941” producer certification and the IRS determination has not been received. The “Date filed by producer” cannot be added to the report. 

A project is currently underway to provide a data warehouse with the ability to create reports from the Subsidiary/Eligibility file system. When the functionality is provided, users should have the ability to filter information for customers that have been updated with a producer certification and an IRS determination has not been received with additional information provided on the report.

I do not have a timeline when the report will be available.

In the meantime, I am providing a report approximately every 6 weeks for all producers with a “Filed CCC-941” and an IRS determination has not been received and am including the “Date filed by producer” on the report.

Programs Submission Response: CCC-527

Use of active form CCC-527 (03-24-09) is found in 3-PL, paragraphs 3, 4, and 132. However, instruction for completion of form CCC-527 is not found in any active FSA Handbooks. 

Instruction is not found in active handbooks.

Amend current PL Handbook with instruction and procedure for completion and use of form. 

The occasion and necessity for the faxing of subsidiary information and payment eligibility documentation between offices greatly diminished with the implementation of the web based subsidiary system and the availability of e-mail (Outlook). The CCC-527 is now essentially used only as a tool by offices to make adjustments to the available payment limitation amounts for multi-county producers.

The instructions for form CCC-527 were provided in handbook 2-PL. When 3-PL was originally published, the instructions were not included. A forthcoming amendment to 3-PL (Rev. 2) will include the Instructions.


Programs Submission Response: National Spot Check Survey

National Spot Check Survey

The list of program changes order each time a survey is completed by the user. This makes it very difficult to keep track of which surveys have been completed, especially when a large portion of them are simple “N/A”.

There should be a way to check all programs to which non applicable will be the answer. Preferably on the main menu program survey list, then the user must only enter the surveys that data actually exists for. The list of available surveys should also remain in the same order each time the main menu is accessed so that the user can just move down the list and enter data as necessary without having to keep a separate list of their own to remember which surveys have been completed.

It is agreed that changing order of surveys would be terribly frustrating. We are currently working with NASS to update the National Spot Check Surveys for 2017. We will discuss your recommendations with them to determine feasibility for the 2017 year or if the updates need to be delayed until 2018. 


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: Subsidiary Software Enhancement

Subsidiary eligibility YEAR selection

When entering records into the Eligibility section of the Subsidiary web site, the only way you know which year you are in is to scroll up to the top of the page, select a particular year and click GO. There are several sections on this page and it’s easy to lose track of which program year you are working in when you have multiple years that require entries. 

Would it be possible to use a floating year designation so the applicable year shows on the side of the screen as you scroll up and down through the sections?

Or to “freeze” the customer block portion of the record at the top so that the year and customer information stays visible as you scroll through other entries?

We will take the recommendation under consideration and discuss with our development team the ability to display the customer information as the user scrolls through the screen or clicks on specific determinations in the Eligibility web based system. Due to budget and resources, I do not have a time frame when the request will be completed.

Programs Submission Response: Subsidiary and AGI Validation

NASCOE has received several submissions concerning PL-271 and the AGI process in general. We have been sharing these concerns with WDC through various channels. One particular concern revolved around a February 26th deadline to begin enforcing that IRS determinations or SED determinations be received within 120 days of the producer’s certification. While discussions continue, WDC has issued the following response:

Notice PL-271 provided information on AGI compliance and the upcoming start of a 120-day time clock for overpayments due to AGI. This time clock was expected to begin February 26, 2016. The impacts of the 120 day time clock are still under discussion at the national office and as a result, the effective date will be delayed. Additional information will be forthcoming.

3-PL (Rev 2) Amendment 3 was issued on 10/6/2016 containing several updates to Subsidiary policy and software. Highlights include:

1) Par 25C has been updated to state that if the AD-1026 is mailed, the Subsidiary Record should be updated with the post mark date.

2) Par 26J contains new timeframes for State and County offices to ensure that producers are updated with an IRS or SED determination. Starting December 2, 2016, the window for obtaining an IRS or SED determination after certification will be reduced from 700 to 180 days. If the producer previously received payments for that program year, the producer’s payment will automatically be displayed on the Pending Overpayment Report after 180 days.

3) Par 26J also contains new procedure for situations where the IRS does not update the IRS determination after 3 attempts to mail the CCC-941 and IRS-3210 to the IRS. County offices will confirm that the producer is not on the Mismatch Report and submit documentation to STO showing that 3 attempts were made to send the producer’s AGI certification to the IRS and that all steps have been taken to ensure the CCC-941 has been properly completed and submitted. If the producer received an IRS or SED determination of compliance in the three preceding years, the CCC-941 flags will be updated as “Mismatch Verified.”

4) Par 41C has been updated to clarify that for businesses with an EIN, the SED Farmer or Rancher flag shall only be updated if the majority interest of all members have certified compliance as an SED farmer or rancher.

Additional guidance will be provided on changes to the AGI validation process for producers not updated by the IRS after being submitted 3 times. The AGI Validation Guide will be updated shortly as well.

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: COC Voter Eligibility

COC elections and voter eligibility is becoming an increasingly more area of focus for FSA. Eligibility and elections are important to how FSA operates.

Currently, when producers are added into BP, the COF user must also access COC Elections software to update their voting eligibility and LAA flags. Essentially this means doing the process twice.

Likewise, when a producer now longer is eligible to vote or deceased, elections software must be access separately from BP to remove voting eligibility flags.

Incorporate an Elections tab into BP with the required fields of LAA and voter eligibility flags. This should flow (behind the scenes) into COC Elections software, removing the requirement for a 2 software process to properly add customers.

Once a date of death is confirmed in MIDAS it would also remove the eligible flag in BP and flow over to the COC Elections software.

Incorporating the COC Election software into MIDAS has been suggested previously.  While WDC has indicated the removal of the COC Election Software entirely is unlikely in the near future, perhaps some of the fields could be automated/synced with MIDAS.

This is on our list of future enhancements and will be prioritized along with all of the other enhancement requests.


Programs Submission Response: Business File Enhancement

Each time a new business plan (CCC-902) is filed the County Office is required to notify the participants of the payment limitation determination (determination letters) according to 5-PL, Par. 371, 4-PL Par. 245, and 1-PL Par. 468.

Manually typing each of these letters are tedious and timely. Many COR review findings have resulted due to minimal errors.

Automate the letters from the web based subsidiary files. Information from the Business File can populate the “canned” required letter, thus saving County Office’s hours of time.

WDC will take the recommendation under consideration to automate the notification letters in the business file system. This suggestion is one of many enhancements they would like to complete (including automating the CCC-903 for Payment Limitation Determinations). Due to budget constraints and resources it may be a while before the enhancements can implemented.