Programs Submission Response: Common Payment Reports

ISSUE:
The nonpayment report (found in Common Payment Reports) only lists one reason at a time for the nonpayment at a time. Once that reason is fixed it takes a day for the report to populate any other reasons that are affecting the payment from being issued.

FACTS:
There are several instances when a producer is missing several forms or has multiple issues which are preventing the payment from being issued. As a result, when the producer submits the form as stated on the nonpayment report then the next day the next reason will populate on the report which can cause multiple trips for the producer and a potential delay in payments.

SOLUTIONS:
Can the report be updated to list all reasons at the same time?

NATIONAL CHAIR RESPONSE:
Due to the way payments are processed, the current version of the Nonpayment Report is unable to provide all reasons for nonpayment at one time. This has to due mainly with the Direct Attribution processing. 

WDC did inform us that they are currently working on a report that will show all bad eligibility values, similar to a Prepayment Report, that would be available year round. This enhanced version could possibly be available next year.

 

Programs Submission Response: AGI

ISSUE:
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:

NATIONAL OFFICE 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.

 

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.

Programs Submission Response: Eligibility

ISSUE
When revising a business file, changes to farms come over from farm records which is wonderful but when you click to update those changes you then have to reload every farm.  If a producer has 30 farms with several tracts and different shares you can see how much loading this is just to now add one or maybe two new farms to his operation.

SOLUTIONS
The current software does remove farms that have been dropped; would it be possible to have it also add the picked up farms to a producer’s list of farms and then those farms can be edited for shares and such?  This could be done in a minute versus 10 to 15 minutes to reload the current information that was just taken out.  With all the system problems we have had these updates get almost to the end and then give us an error message or shut down and then it has to be started all over again.  This can be a frustrating process.

AREA/CHAIR COMMENTS
I agree that it is frustrating to feel like you are reloading something that should be or was already there only to get timed out.  This can be a prolific issue in counties that have smaller average farm sizes and where producers tend to pick up and drop farms every year.

NATIONAL OFFICE RESPONSE
The Business File Web-Based System is designed to update the Land Data from Farm Records when a Farm Operating Plan is revised with a:

  • “Land Only Change”
  • “Other Change” and click the “Refresh from Farm Records” link

If there are currently farms and/or Tracts associated with the producer (as an Operator, Owner or Other Tenant) and one of the above actions is performed and:

  • the producer has been removed as the Operator, Owner or Other Tenant in MIDAS/FRS, the farm and tract along with any leases recorded will be deleted when the user updates the Farm Operating Plan.
  • the farmland or cropland on any of the associated farms or tract has been updated in MIDAS/FRS, the farm and tract will be updated with the change to the farmland or cropland and leases will be deleted when the user updates the Farm Operating Plan.  This is to ensure leases are recorded correctly with the latest information provided from MIDAS/FRS.
  • a lease from or lease to was recorded with another producer that is no longer associated with the Farm or Tract, the farm and tract are not deleted when the user updates the Farm Operating Plan.  However, the lease must be revised or deleted by the user.
  • the producer is added to a farm and/or tract, the farm and tract is added to the farm operating plan

In addition, recently the Business File software was updated to provide the farmland and cropland in 100ths to be in sync with MIDAS/FRS.  We are not requiring all farm operating plans to be updated with this change. However, if a Farm Operating Plan is revised with a “Land Only Change” or “Other Change” and clicking “Refresh from Farm Records” link, if the farmland and/or cropland is changed due to the 100ths, the farm and tract will be updated with the change and leases will be deleted.  This is to ensure leases are recorded correctly using the farmland and cropland in 100ths.

Also, the business file system should not time out on a farm operating plan as long as the user does not step away for an extended period of time.  If the user is concerned that they will have many leases to update or record and may need to step away, the best approach would be to revise the farm operating plan with the “Other Changes” option, navigate to the Land Contributions and click the refresh from farm records link.  This approach will create an “Initiated” Farm Operating plan that the user can update over a more extended period of time.  Once the user has completed updating the leases, they will need to review the farm operating plan and enter the producer signature and COC determination dates on file for the producer.