Programs Submission Response: NAP Reports in CVS Format

ISSUE:
Both CARS and ARC/PLC reports have the option to download reports into Excel. It would be extremely helpful for the NAP program to also have this capability.

 FACTS:
New NAP reports have been added (thank you !) to assist in the management of the program, but having the reports in Excel format would be extremely helpful as different crop types have different deadlines and work items.

 SOLUTIONS:
Implement the ability for NAP reports to be exported to Excel like other programs already have capability to do.

NATIONAL OFFICE RESPONSE:
The National Office is aware of the need for the reports in CVS format and is working to have this done for all NAP reports.  The limited contractors and funding has been the most recent hold up. 

2017 NASCOE Negotiation Items

ITEM 1: LOAN APPROVAL AUTHORITY

Issue:  Currently, 1-FLP, Par. 25 outlines that SED’s, in conjunction with FLC, should identify areas of their State that could justify and benefit from CED having loan approval and servicing authority.

The office or area where CED would be designated by SED to obtain loan making and servicing approval authority must meet both of the following conditions.

– Direct and/or guaranteed caseload in the office or area is high, complex, or geographically challenging and FLM, SFLO, or FLP team servicing the office or area needs additional help.

– CED has sufficient time for additional responsibilities required to obtain and maintain loan making and servicing authority without negatively impacting CED’s current farm program obligations.

The announcement of the new Microloan-FSFL program is an exciting opportunity to reach a new customer base with a streamlined loan product, but an already heavy workload of FLP loans may be an obstacle in this implementation.

NASCOE Position: Many Farm Loan teams already have a broad portfolio of direct and guaranteed loans, including microloans. Their workload in some locations is at a level that already equates to delayed processing of FSFL applications.  This impacts our ability to deliver Microloan-FSFLs, which by nature are intended to be streamlined, easily accessible, and quickly processed.

A good number of CED’s have either educational background or work history that includes finance, and equips them to be a candidate for Farm Loan approval authority.

When loan applicants present to FSA with a proposed project and are assigned to work with FLO/FLM to determine credit worthiness, we may see situations where customers could be redirected to the FLP Microloan program, instead of the FSFL.

A change in policy that would allow for CED’s to have a limited Loan Approval Authority specific to FSFLs up to $50,000 or $100,000, this would allow for a much more streamlined implementation of the FSFL Program, specifically the recently announced Microloan-FSFL.

A suggestion is for CED’s be required to complete Phase 1 of the FLOT program as currently prescribed in 6-PM, Part. 13, but then complete Phase 2 in a modified format to include meeting the state-established credit quality standards on a prescribed number of independently prepared files, which consist only of FSFLs up to $50,000/$100,000, or comparable direct microloans.

This delegation of authority would apply to loan approval only for FSFLs. It would accomplish a significantly improved delivery of service for FSFL applications, particularly in counties without a full-time FLP presence.

DAFLP Response: According to 1-FSFL Handbook, the COC or STC is the approval official for FSFL loans, and FLP loan approval officials only provides a recommendation.  FSFL loans are not mentioned in the loan delegation section of FLP Handbook (1-FLP), only Exhibit 15 for FBP, which describes how to document the recommendation.  Our FLP handbooks only cover FLP functions and program policies and procedures. We believe changes for approval of FSFL Microloans be a Price Support/DAFP, rather than DAFLP, decision.

DAFO Response: This would be a sea-change in CED duties requiring major discussions with DAFO, HRD, and FLP. Likewise, any such changes in the duties of the CED would require the assent of respective county committees to determine if the CED would be able to assume added duties.

DAFP Response: We appreciate the suggestion submitted requesting a change to FSFL policy where CED’s can be trained to have limited loan approval authority for FSFL’s up to $50,000 or $100,000.

The National Price Support Division and Farm Loan staff will work together to develop a modified “no cost” loan approval authority training package.  At a later time, we will share more details about the loan approval authority training package and intended audience.

Agreement: As resources may permit, DAFLP and DAFP agreed to put together a pilot program to give CED’s authority to conduct financial analysis on Farm Stored Facility Loans under the County Committee approval limits. The COC would still have final approval up to $100,000.00 for all FSFL loans. NASCOE accepts the response.


ITEM 2: MAILING CONTRACTS TO OTHER COUNTIES

Issue: Mailing of original FSA-578 certifications and ARC/PLC contracts after they are faxed or emailed to the office when working in nationwide customer service. I took a certification for a county and emailed the signed 578 & map to the county, now I have to take the time to also make out an envelope, make a copy of the original and mail the original to the county office that I just emailed the paperwork to. What a waste of time and finances (46.5 cents for each certification I have to mail to different offices.) Plus why do I need a copy of the contract since I have the copy of the email that I sent?

NASCOE Position: According to procedure State and County Office Action State and County Offices that process nationwide customer service FSA-578’s must: • immediately FAX a copy of the signed FSA-578 and map to the producer’s administrative county • mail the original signed FSA-578 and map to the producer’s administrative county • maintain a copy of the signed FSA-578 and map. When taking a FSA-578 or ARC/PLC contract under Nationwide Customer Service we must immediately fax or email the administrative county a copy of the certification or contract and then we must mail the original to the administrative county and keep a copy.

To remove the redundancy of having a lot of paper work in both offices by eliminating the mailing of the FSA-578 and/or ARC/PLC contract when working in Nationwide Customer Service because it will already either faxed or emailed the information and the original can be kept on file in the office. The forms should be emailed or faxed and the original filed in the office that took the form. The emailed form could be stored in a sent folder with the County’s name on it, but the original would still be available if needed.

DAFP Response: DAFP is not opposed to only requiring the emailed or faxed copy of the document being sent to the administrative county of the farm, however, there are some concerns that must be addressed.

Generally, the policy for sending/receiving contracts and certifications is outdated when compared to the technology available.  While this technology is usually reliable, there are times when it fails.  Also, the scanned and emailed copy of a map or the faxed copy of a map is not of the best quality which would necessitate the mailing of at least the map from one county to the other.

Policy for the sending and receiving of certifications and contracts needs to be removed from each program’s policy handbook and included in handbook 1-CM.  DAFP will move towards developing a more user friendly format in handling producers that are using the Nationwide Customer Access function to enroll or certify farms.

Agreement: NASCOE accepts the response.


ITEM 3: AGLEARN TRAINING

Issue: Training on various topics is provided for through the AgLearn website and employees are to log on and take the required training when the training has been posted to AgLearn and before the deadline.

NASCOE Position: Notification of training requirements are ongoing throughout the year, some have several months to complete, some have a relatively short timeframe to complete the training. During heavy workload times, it is difficult to complete the trainings with the short turnaround timeframe.

Have all required training issued and posted to Ag Learn at the beginning of the FY and have the year to work on the required training, or at least be able to see all the training at once and when it is due to be completed and be able to manage the completion of it more efficiently.

HRD Response: HRD appreciates NASCOE’s idea in this area. However, the Ag Learn courses are typically created by a specific program area (civil rights or IT) or at the Department level.  As a result, HRD cannot load the courses prior to their availability from the appropriate area.  HRD will; however, make a note and load the course just as soon as it is available thus giving employees the maximum amount of notice to complete their training requirement and meet the established deadlines.

Agreement: NASCOE accepts the response. HRD will work with the AgLearn contractor to enhance the software to add an email notification feature for when courses have been added to an employee’s worklist and the possibility of a 30-day deadline notification reminder email.


ITEM 4: STAFFING/PERSONNEL

Issue: The SWA RSO pilot has become an approved organization and consists of employees in state offices throughout the southwest area. There have been several job opportunities within the RSO, but they only list state offices as potential duty locations.

NASCOE Position: By limiting duty stations to state offices, numerous highly-qualified candidates do not apply because they don’t want to move across the state. If a job can be carried out across state lines, it doesn’t make sense that the same job couldn’t be carried out remotely in a county office.

RSO positions, as well as many other NOF jobs that allow STO duty stations, should allow the selected employee to work out of a county office.

HRD Response: HRD will defer to DAFO on this issue for the RSO positions.  If DAFO wishes to pursue this option, HRD can certainly accommodate the “area of consideration” in the vacancy announcement process.   As a side note, there are some STO positions which are located in county offices.

As far as National Office positions, this would be left up to the selecting official’s discretion. However, once again, HRD could certainly accommodate the “area of consideration” in the vacancy announcement process.

DAFO Response: The previous SED RSO Council established a policy, which strongly encouraged the duty station of RSO employees in SWA STO’s; however, they also afforded some latitude to the Selecting Official (in consultation with RSO Manager) to duty station an employee in a County Office.  A compelling reason for doing so was required.  Only one such request has been approved.

DAFO has discussed this item with the Manager of the RSO, who feels that the RSO needs its employees co-located, not scattered.  Concentrations of employees provide for a number of benefits including training, cross-training, and enhanced privacy protection because of the nature of the work performed, all of which ultimately provide payback to the end-user/customer in form of available and informed personnel to respond rapidly and efficiently.

There is also the issue of space to accommodate both the newly hired RSO employee in small offices.

Agreement: This item will be considered in the future. They will discuss the possibility of doing remote positions with the RSO management.  NASCOE accepts the response.


ITEM 5: CRP CONTINUOUS CONTRACTS

Issue: 7 CFR 1410.22 states “For general signup and continuous signup contracts except grasslands, mid-contract management must be conducted to implement management activities, such as disking and prescribed burning according to an approved conservation plan, as part of the CRP contractual obligation on all contracts entered into under general signup and continuous signup, as specified in 7 CFR 1410.30”.

NASCOE Position: Continuous CRP offers are made and approved based upon a determined resource need on the offered land. By requiring that the cover established on this resource concern be disturbed by a mid-contract management activity, it defeats the purpose of establishing a practice to correct a resource need

To maintain the intent of the Continuous CRP program, which is to address a resource concern and incorporate the appropriate practice to correct the resource concern, an update to the regulations needs to be made. Not all CRP contracts need to have mid-contract management practices which will disturb the established cover.

DAFP Response: The requirement for at least 1 management activity during the contract period for all practices, except CP87 and CP88, is to ensure the approved cover, applicable plant diversity and wildlife benefits are maintained, while ensuring the resource concern(s) continues to be addressed.  Management activities are site specific, developed in coordination with the appropriate technical agency with the experience necessary to ensure the resource concern(s) are not jeopardized during the approved management activity, and are included as part of the producers conservation plan of operations.  This is applicable to all practices, not just those enrolled under the continuous CRP signup provisions.  In addition, participants may receive cost-share for approved management activities to lessen the cost of such activities and further ensure the approved cover is in compliance with the practice standards and conservation plan of operations.   Over 30 years of experience with CRP cover establishment, maintenance, and management activities has shown that appropriate management activities performed at the appropriate time helps ensure the approved cover, plant diversity, and wildlife benefits are present and maintained throughout the contract period.  Such activities also assist participants in maintaining compliance with their contract requirements, which results in fewer contract violations for non-compliance, fewer contract terminations, and fewer required refunds of payments.  In addition, the required management activities ensure that tax payer funds are used in an efficient and effective manner for the benefits obtained, while treating all participants in a fair and equitable manner.

Though not specifically referenced in 2-CRP (Rev 5), Mid Contract Management is required by the CFR and Statute.

As you have referenced, 7 CFR 1410.22 states “For general signup and continuous signup contracts except grasslands, mid-contract management must be conducted to implement management activities, such as disking and prescribed burning according to an approved conservation plan, as part of the CRP contractual obligation on all contracts entered into under general signup and continuous signup, as specified in 7 CFR 1410.30”.

Further, Section 1232(a)(5) DUTIES OF OWNERS AND OPERATORS.

(a) IN GENERAL — Under the terms of a contract entered into under this subchapter, during the term of the contract, an owner or operator of a farm or ranch shall agree (5) to undertake management on the land as needed throughout the term of the contract to implement the conservation plan.

Agreement: Farm Bill discussions are going on currently and there could be some discretion used in the future to work with NRCS technical determinations. At this point, mid contract management could be modified but it must be followed.

NASCOE accepts this response.


ITEM 6: COC ELECTION BALLOTS

Issue: There are no clear instructions on the election ballot that a title is required if the voter is an entity.

NASCOE Position: Clear instructions should be added to the election ballot stating that a title for an entity is required.

Under Step 3, Sign on label to the right, it says “You must sign on the label next to Signature (By) or your ballot cannot be counted”, we could add an additional sentence that states, If you are an entity, trust, corporation, partnership, etc., you MUST include a title such as trustee, member, etc. or your ballot will not be counted. This sentence could even be in bold or red print.

DAFO Response: Below is what the label looks like now. The suggested addition could be added under the directions for Step 3.  The label has not changed for years, and there have been no issues so far.  However, it is doable. We will have to discuss this matter with MSD and the various contractors involved in the ballot process.

Agreement: NASCOE accepts the response. DAFO has agreed to insert a statement (note) in red to list example titles for persons to enter for signing authority. DAFO also agreed to update procedure to allow County Committee’s discretion to determine validity of individuals signing on behalf of an entity without entering a title on the ballot.


ITEM 7: COT OPENINGS AND PLACEMENTS

Issue: Currently COT’s are hired, trained and then apply for county office openings. During 2015 negotiations, NASCOE proposed hiring COT’s for the county office where the COT would be permanently placed and then training would take place.  NASCOE noted that this proposal would increase applications from individuals who wanted to be in that specific county which would lead to a stable county office into the future.  Management expressed openness to consider NASCOE’s suggested changes and NASCOE provided a white paper with concepts on how these changes might benefit county committees looking for stability and provide more opportunities for county office employees.

NASCOE Position:  Just like the FLOT position, NASCOE feels that a COT should be hired for the county office where the CED position is needed.  Further, this proposal is of high priority for our membership.  Management has not formally responded to NASCOE’s suggested changes to the COT program hiring process.  NASCOE requests that management respond in writing to the concepts to allow further discussion on this topic and search for solutions to NASCOE’s and management’s differences.  A PT would be able to apply for a specific CED position and be trained for that position, in other than for hard to fill positions

The COC would make the selection for the county and the state committee would actually hire the COTS.   The position would be advertised for a specific county, the application is done through USAJOBS, the STC selects COTS and would submit 3 names for county openings. (This item was also submitted in 2016)

HRD Response: The decision on how to select and train COTs as well as place them upon completion of the training program is an agency choice.   Obviously, there are pros and cons associated with the current at-large method as well as the specific location method which NASCOE supports.  There is certainly value in the at-large program as it allows states the ability to hire and train COTs before actual vacancies occur.  This way, when the vacancy does occur, there are individuals ready to be interviewed and selected for the CED position rather than just beginning the training process.  HRD will defer to DAFO for their determination on what is best for the States and County Offices on this issue.

DAFO Response: Not all FLOTs are hired for a specific office, as the past.   DAFO continues to believe that states cannot determine with complete accuracy where vacancies will be in the future.

Agreement: NASCOE accepts the response.


ITEM 8: ENHANCING MIDAS SOFTWARE

Issue:  Currently MIDAS users can search farm number, tract number, owner, operator etc.  Being able to search in Midas by CRP contract # would be useful for farms that have multiple contracts on the same tract number.  For instance, if a farm was reconstituted and the farm number changed, every CRP contract would have to be revised. Every field with CRP would have to be revised in Midas as well to add the suffix to the CRP contract #.  If you could search by contract, you could ensure that all the field numbers were updated correctly.

NASCOE Position: Modify the search options in MIDAS to include being able to search by CRP contract number and have all CLU’s associated with that shown in the search results. This will lead to fewer omissions on the CRP mismatched report.

DAFP Response: This suggestion is being added to our list of enhancements and will be implemented as soon as resources and budget can be allocated to the enhancement.

Agreement: NASCOE accepts the response.


ITEM 9: MODIFY THE CCC-576

Issue: The Issue is that when you enter multiple losses for a producer and the notice of loss application prints, it prints to a continuous run of pages. The first page of the CCC-576 Notice of Loss, has the producer’s name, crop year and state and county code listed.  However, the continued pages of the CCC-576 do not have any information listed regarding to name, crop, year, state and county code or page number.  If the pages get out of order or mixed with another producers notice of loss you cannot tell which page goes where.

NASCOE Position: Modify the CCC-576 to include the producer’s name, crop year, state code, county code and page number in the header to each page of the CCC-576 when it prints.

DAFP Response: This enhancement is being adopted and will be implemented in the near future.

Agreement: NASCOE accepts the response.


ITEM 10: USING CO SLOTS AND HIRING PROCEDURE TO FILL GS POSITIONS

Issue: Several states have routinely utilized CO ceiling slots to fill positions for the GS side. More and more often this is being done because it is usually less complicated and quicker than going through the GS hiring procedure.  Many times the intent is to convert the position to GS in a few months but there are several cases around the country where this has not been done or has not been done timely.

NASCOE Position: NASCOE understands that FSA is understaffed both on the CO and GS side and that SED’s have the ability to flex ceiling slot from CO to GS and vice versus. While this might be a tool that is available for states to consider it should not be a common occurrence and the slots should revert back to the original ceiling as soon as possible.

HRD Response: While this can be done, HRD would caution offices on doing this as a way to circumvent merit promotion hiring policies on the GS side. This hiring method should truly be used when we don’t have an FTE available for the position needing to be filled.

DAFO Response: The “flexing” of staff years from CO to GS and vice versa is a tool used by some SED’s to mitigate short-term staffing short falls and meet critical needs. It should be understood that positions are not flexed, rather it is the staff year (I.e., funding) that is flexed to fill a critical need.   It continues to be DAFO’s policy that the flexing of staff years is a short term situation and not a common occurrence.  It is DAFO’s policy that approved flexing does not carry beyond the fiscal year for which it is approved.  In recent years, many State’s individual employment levels have been below their State ceiling levels and the need for flexing has been minimal. 

Agreement: NASCOE accepts the response.


ITEM 11: INCLUDING THE NASCOE NEW HIRE PACKET PART OF EXHIBIT 6 IN 28-PM

Issue: NASCOE and management have agreed in previous negotiation meetings that State Offices shall make NASCOE membership informational brochures and application forms available to all new hires. This has been communicated to SED’s and AO’s through emails and memos from DAFO to the state offices.  However, with routine turnover in SED’s and DAFO, NASCOE has to make subsequent requests that State Offices be reminded of this agreement.

NASCOE Position: If the membership informational brochure, membership application and FSA-444 were added to the new hire checklist in exhibit 6 in 28-PM it would be made available to all new employees as previously agreed to by NASCOE and Management.

HRD Response:  While HRD recognizes NASCOE as an employee organization, we do not feel that putting informational material in our agency handbooks is appropriate.  Exhibit 22 of Handbook 22-PM, contains a copy of the Labor-Management Relations Agreement between USDA/FSA and NASCOE, and Section 3, Item 15 of this handbooks specifically states that solicitation of membership shall be conducted during non-duty hours of the employees involved.

Agreement: NASCOE accepts the response. HRD has agreed to add the FSA-444 to the checklist of required forms in the exhibit of 28-PM in a handbook update. HRD also agreed to insert a link to all employee associations for information in 28-PM.


ITEM 12: IT CYBERSECURITY

Issue: Our Country is in an ongoing battle of cyber threats and attacks. In fact, several thousand Federal employees have had their SS#’s stolen. After which, and over the past 18 months, Federal employees have been offered a free service of identity protection through CSID.

NASCOE Position: The threats on our identity are still very real and the need for cyber security has only increased. Would like to see all employees offered Identity protection during their employment years and possibly at a reduced cost for retirees.

HRD Response: The decision as to what type of credit monitoring and identity protection employees/retirees will receive as a result of the cyber incidents falls with the jurisdiction of OPM rather than HRD.

Agreement: NASCOE accepts the response.


ITEM 13: IT/WEBTA

Issue: WebTA 4.2 is not user friendly. The screens are hard to read/follow when loading time and attendance. The screens in the new WebTA system are very hard on the eyes when reading them, and program codes are not listed in order.

NASCOE Position: Several modifications would greatly increase the efficiency of recording our time and attendance. Those would include differentiating each line, grouping the activities alphabetically and locking the header so that the day is always visible when you scroll to the bottom of the entries.  In addition, it does not read very easy when the CED’s time and attendance is printed for the County Committee’s review and approval.

OBF Response: OBF concurs with this recommendation. OBF and HRD are working together to have a change implemented by the NFC to address this at a future date to be determined.

HRD Response: The WebTA 4.2 dashboard issue came up after implementation. NFC responded that the WebTA 4.2 system is 508 compliant and the current display is as designed.   NFC advised that any requested screen changes to the application would be an enhancement. On February 27, 2017, HRD submitted a follow-up inquiry to OHRM to determine whether USDA has any plans to requisition the enhancements and if so, what specifically, and when might they be available in WebTA 4.2.  HRD will continue to follow-up on this issue.

Agreement: The request has been made to list activities alphabetically. There has been assurance from Kronos to simplify WebTa.  To ensure the headquarters team is notified of the problems.  They are working on setting up a SharePoint site for state offices to input problems and issues.  They are aware that there are attempts to address issues and this has bypassed headquarters and this is not a good situation.  Everyone is facing the same problems.  There are people from the field involved in testing.  NASCOE accepts the response.  A list will be compiled and submitted through STO.  A NASCOE POC (Dennis Ray) will have access to the SharePoint site to submit issues.


Items from 2016 NASCOE Negotiations (Resubmitted)

ITEM 2: SHARED MANAGEMENT PROCEDURE

Issue:  “Before STC approval of the establishment of a permanent shared management operation, the SED will consult the NASCOE state affiliate.”  At present, many STO’s are not following this procedure.

NASCOE Position: NASCOE recommends that SED’s be reminded of applicable handbook procedures in 27-PM, paragraph 52C. SED’s are to consult in pre-decisional format before the establishment of a shared management operation.

HRD Response:  We agree that the policy requires the consultation and defer to DAFO on any reminders to or reinforcement of the policy with the States.  We do stand ready to assist if any clarifications or changes to the handbook need to be issued.

DAFO Response:  States routinely send in requests for approval of shared management proposal.  DAFO always ascertains if consultation has taken place.  If this is not happening, we should be informed.

Negotiation agreement: NASCOE would like an official response from the state association attached to the decisions regarding shared management to ensure the NASCOE state affiliate is involved. DAFO will review this issue to come up with a solution to show a written NASCOE position accompanying the State request for permanent shared management.  A response will be sent back to NASCOE within 30 days.  This is to ensure the states are following current policy.  NASCOE will provide feedback in the consultation.  Written documentation of the consultation with the state association included in the submission to DAFO for permanent shared management. An email will be sufficient for a response.  HRD can draft policy for DAFO review to be submitted to NASCOE.

DAFO Response: Shared management is and has been a reality for many years. Given budgetary and   legislative restrictions, we see no realistic alternatives in the near future.  DAFO approves all shared management requests and ensures that NASCOE affiliates have been contacted and that all requisite COC and STC approvals have been obtained. 

HRD Response: HRD will defer to DAFO on this issue; however, if the decision is made to incorporate this into the handbook, HRD can certainly update Handbook 27-PM, Paragraph 52C accordingly.

Agreement: Management will agree to consulting the associations during the proposed establishment of a permanent shared management situation and having COC involvement.   There will be an amendment to 27 PM to include such reference.  NASCOE accepts this response.


ITEM 4: TEMPORARY SHARED MANAGEMENT-LENGTH OF TIME

Issue:  Provisions in 27-PM paragraph 53C “temporary shared management operations shall not exceed 120 calendar days.”  At present, many STO’s are not following this procedure.

NASCOE Position:  NASCOE recommends that SED’s be reminded of applicable handbook procedures. Procedures shall be followed in instances where shared management operations exceed 120 days by SED’s meeting with COC’s to “work out a permanent solution.  Any exceptions to the 120 calendar day limitation shall be approved in advance by DAFO.”

HRD Response:  We concur with the statement of the policy and defer to DAFO on any reminders to or reinforcement of the policy with the States.  We do stand ready to assist if any clarifications or changes to the handbook need to be issued.

DAFO Response:  All extensions are approved by DAFO after it is determined how long the shared management operation will continue and what plans the State has to end it.  As was have reiterated many time, budgetary and current Congressional restrictions prevent us from taking necessary steps to ease the situation of so many shared management office.

Agreement: DAFO agreed to have temporary defined as 6 months and the review will have attached COC minutes showing the consultation with the state affiliate of NASCOE was done.

DAFO Response: Given the many variables is each situation, it is often difficult to determine prospectively when it might be feasible to discontinue a share management operation. DAFO always asks the state what their future plans are.

HRD Response: The 120 days has already been changed to 6 months in Handbook 27-PM. As soon as Revision 2 is released, this will be visible to all employees.

Agreement: Management agreed to have COC’s involved in shared management extensions. DAFO agreed to have temporary defined as 6 months and the review will have attached COC minutes showing the consultation with the state affiliate of NASCOE was done.

NASCOE accepts this response.

Programs Submission Response: NAP Notice of Loss

ISSUE:
The NAP Notice of Loss should provide a total of the “Disaster Affected Planted Acres”. 

FACTS:
At payment time, the notice of loss is matched to the producer print to verify acreage. Employee must manually total the notice of loss to accomplish this task.

SOLUTIONS:
The form does a great job of providing the FSN, unit number and acreage. In order for it to be easily matched to the producer print, add a line for TOTAL of DISASTER AFFECTED PLANTED ACRES.

NATIONAL OFFICE RESPONSE:
We have discussed this issue at the national level. We contend that Item 8D could potentially have the same acreage affected numerous times for difference disaster events. We realize that this item is not currently being totaled since that could result in the disaster affected acres exceeding the reported acres. Form CCC-576 is a multiple program form and is not necessarily being used strictly for NAP. As a division and team, we will propose to review this form under the next Farm Bill or if budget would allow for modifications during this current Farm Bill. If the form is revised it would have to meet the criteria of all other programs currently utilizing the information contained on the form as well as comply with the Information Collection Package as authorized by OMB under the Paperwork Reduction Act.

 

Programs Submission Response: NAP Correspondence

ISSUE:
NAP correspondence is sent through automated email systems directly to producers. The following is an example:

“Thank you for signing up for 2016 NAP Coverage with the USDA Farm Service Agency. Attached is your 2016 Summary of Coverage, including applicable service fees, estimated premiums, and estimated remaining balances due. For more information about your NAP coverage, please contact your administrative county office.”

FACTS:
Many producers are highly receptive to this prompt, effective means of communication; however they may read the message and call the COF, and we aren’t up-to-speed on exactly what message they are reading that they say we have just sent to their email account.

COF employees currently don’t have the text of the email message or the same Summary of Coverage report that the producer is seeing in the email readily available through the NAP Application Software.

SOLUTIONS:
It would be helpful and beneficial to program NAP correspondence so that a copy is sent to the respective County Office (at least the CED), so that the County Office is aware of the exact communication at the same time the producer receives it.

NATIONAL OFFICE RESPONSE:
We have worked hard to become more transparent in our mailings and e-mail to producers participating in our NAP program. Since our national mailings come from a centralized location in Kansas City, it has been difficult for offices to identify what letters have been sent to producers. Luckily we now have a way to track the letters and e-mails that are sent to individuals that participate in the NAP program. National training was delivered to State Offices in June about the availability of these enhancements. The National Office will work to provide these options in the 3-NAP handbook in a future amendment. As they are available now, I will walk you through the availability for each enhanced option. Should you have any questions about the delivery of these enhancements, please feel free to contact me.

When you access the main NAP menu an option appears for the Notification Center, as listed below:

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By Selecting on this Notification Center “Reports” tab, county offices can now access what e-mails and physical letters are sent to the producers in each county. An example:

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County offices have the option to run a report that will provide all letters sent by physical mail or by e-mail for each producer in their county. They have the options to see the dates that each of these pieces of information have been sent to producers. For example:

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The great thing about this report is it gives the exact dates that each letter was either physically mailed to the producer or e-mailed, if the producer chooses to receive e-mail. Producers receive both a physical copy and an e-mailed copy if they select to receive e-mail.

Another example but with the same idea is the Continuous Coverage Mailing Report. This report identifies each year, based on the year selected, which producers received a Continuous Coverage mailing and the date that those letters were sent to the producer. For Example:

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Once County Offices identify which producers received each of these letters, they can identify which letters were sent to the producer and select that producer to see the individual information that was sent out of the producer. That selection is made by doing a “Search by Producer” as listed below: 

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After that selection of the producer is made in the SCIMS Search, the following options are available for each individual producer. For Example: 

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By viewing the listed information, County Offices can access exactly what the producer received, in both the e-mail or the physically mailed document.

I hope this helps in your delivery back to the county offices. We will continue to work to provide the offices with all the information that is sent to producers concerning the NAP program.

 

Programs Submission Response: NAP

ISSUE:
In XX State there were 2015 NAP policies sold with the Direct Marketing Price option.  The office is being told that 2015 producers are not subject to direct market prices because their premiums were based on average market prices, even though they chose the direct market option.  How can we offer the direct market pricing (and organic pricing), if it’s not available?  Now we have 2016 contracts, again with the option of direct market pricing.  I really don’t know what to tell my producers.  Telling them it’s been in WDC since January and they are working on it just doesn’t seem to work anymore.

FACTS:
The office received this response from their STO:  “Please know our recommendation was made in January and was for those crops that had application closing dates that had not yet passed (our recommendation had to be made not later than 60 days before the application closing date for the crop.  So, please understand that the January 2015 recommendation was not for all NAP crops.  But it is my hope that we get an answer soon and that the answer gives us further guidance on how best to proceed for 2016.”

SOLUTION:
The CO believes that based on the training, the memo we received on September 18th and the handbook that:

  1. Producers should be entitled to 2015 direct market pricing as they had the option at enrollment, regardless of what the premium calculated out to.  If the premium calculated at average market price, it’s not under the producers control.
  2. The 2015 information was submitted to WDC well after the deadline outlined in 1-NAP, para. 207B.  Again, out of the producer’s control.
  3. And the memo on issuing manual payments clearly states that another payment will be issued to those producers who chose direct market pricing.

NATIONAL OFFICE RESPONSE:
The following is the latest on the recommendations of organic and direct market pricing from the XX State FSA Committee.

The State committee did send a timely recommendation of direct and organic prices for some crops.  Upon receipt, a representative of the National office visited with the State office in XX briefly to discuss the data sent with the recommendation.  The National office then performed extensive research and analysis of the crops and recommendations in order to arrive at an informed decision. 

On November 20, 2015, DAFP advised the XX State FSA Office of its decision on the 2015 recommended crops.  The crops were approved.  Prices were established.  A notice is forthcoming from the State office to XX county FSA offices advising them to apply the price to 2015 applications for coverage.

While we regret the length of time it took to analyze the recommendation, we believe the policy instituted by DAFP regarding establishment of direct and organic pricing (soon to be issued) will speed NCT crop approval of prices.

Thank you for your concerns.  However, XX counties should soon be receiving notice of 2015 direct and organic price approvals soon.