Question and Answer Session at 59th NASCOE Convention

A printable version of this post is available on the Forms and Downloads page, or at the following link:  Sioux Falls WDC Q&A

2018 National Convention
Sioux Falls, SD
August 2, 2018

Bill Northey, Under Secretary
Richard Fordyce, Administrator
Steve Peterson, Acting Associate Administrator
Brad Karmen, Acting Deputy Director Farm Programs
Terri Meighan, FPAC Business Center
Peggy Browne, Director of Field Operations
Linda Treese, Deputy Director Field Operations
Steve Stark, PECD
Darren Ash, OCIO FPAC
Ameer Ali, FPAC Contractor
Rebecca Dudley, FPAC Contractor

1.  Background: We know some STO’s have been proactive in sharing workload data with COF’s.  Other STO’s have been far less forthcoming. NASCOE is concerned about consistency and transparency in sharing of data.

Q:  Can you tell us when this data will be available down to the field level?

A:  Mr. Fordyce responded stated that moving to the workload model is a new way to distribute staff.  It is a tool for SED’s, AO’s and EO’s to determine where staffing should be placed.  The ability to distribute the information is left up to each STO.  There is nothing secret or hidden about the data.  The staffing model looks at metrics such as contracts and farm loan products and then time coded to those activities runs through a formula to determine where the staffing should go.  Once those are established the optimal office to place those positions.  OPO 2.0 is coming with improvements.  It is up the SED discretion on how they want to share that information. This tool is going to continue to evolve and improve.

2. Q: With the low number of staff we have on board for 2018 can you explain how the FY18 ceilings were established since there should have been funds left over from the last year when not hiring?

A:  Linda Treese responded that going from 17 into 18 the funding that was provided for 18 was less staffing and funding for FSA.  Yes, we saved money by not putting people on and it would not have been smart to hire and change the staffing levels this late in the season not knowing what the 2019 levels will be. There were ways that we utilized the extra money and put it back out to the field.

3. Q: There are numerous CED’s at retirement age. Is it possible to bring on COT’s above the ceiling anticipating these retirements?

A:  Mr. Fordyce responded that the agency recognizes that we have several CED’s about to retire. He stated that there are a lot of folks ready to retire and we have hopes to tackle this issue and respond by placing some COT’s across the country. We are hoping to get very inventive to start planning for attrition. 

A:  Linda Treese responded stating that we use to have the non-ceiling number of FLOT’s and COT’s and not lose out on ceiling numbers.  We did that for several years based on a lack of funding.  There have been discussions to utilize this again. Until the budget is known for 19 it might be hard to put that out now.

A:  Peggy Browne stated that it is key to succession planning.  Those discussions will be happening, and we are on board to find a solution.

4. There is a lot of printers and equipment that is not working in the field?

A:  Darren Ash responded that OCIO is aware of the issues. There is a workgroup established for a long-term solution to these problems. There is a work around that should help with some of those issues therefore offices should contact their IT person.

5. We have new ARCPLC regulations for Seed cotton if a producer had grass on it from 08-12 will it always be unassigned, or will they allow you to go back and claim?

A: Brad Karmen stated that seed cotton only looks at 12 however the next farm bill may address this issue.

6. Recently I was shown the staffing model for my office. I have a farm in my county that has 20 plus tenants on a farm.  When I am doing acreage reports and other contracts I am touching that form several times. Can you tell me how acreage reports are being counted?

A: Acreage reports are looked by field type. 

7. Has the issue of a physical county verses the admin county has been addressed for ARCPLC? I can service other counties for several other programs but not ARCPLC.

A: Fordyce responded we are making adjustments in the workload model for situations like this.  Therefore, it is important that there is state control because they are aware of these situations. That is where there is flexibility for exceptions.

A: Steve Peterson responded stating that they do know that is a discussion on the   Farm Bill. It should address the issue to allow farmers to be serviced in the office of their choice without forcing them.

8. With the extension of the DEC 7 sign up date for the cotton seed program will this affect the current roll over date?

A: Brad Karmen, the grand plan was to get everything done before rolling over.  The decision was made last week by the Sec. to extend and now that will be effect farm records. They are working to get a fix in the system to be able to take and application regardless of which year

9. What is the time frame for the PT excellence program? Is it being considered as an alternate to the COT program?

A:  Linda Treese stated we will be starting FY19 it is more of a leadership program with mentoring and virtual.  It will not be set up as a replacement for the COT training. It is a leadership and skills training.

10. Seed cotton election ends Dec 7 farms that is for generic and non-generic farms will have to come in twice is there any way we can help them, so they won’t have to come in twice?

A:  Brad Karmen, I do not have an answer today but will get back with us with an answer. The December 7th deadline only pertains to cotton seed.

11. Workload data is up to the discretion of the SED to share the information. Can we get your support to share that data with the field by the SED’s? This is causing a great deal of consternation among employees because they don’t see the number and get worried.

A:  Peggy Browne workload model is a tool. We are a proponent of transparency. The bottom line with that tool is that when we get request from your state for different situations.  The state management needs to be impowered to make these decisions.  Of the waivers we have been asked to grant we have approved approximately 90% of them.

12. Budget concerns drive staffing. How does this work with the other workload model?

A:  Fordyce the staffing model is one thing the optimal office is a separate thing. The staffing model is  distributive and  predictive.  What the right number of staff FSA needs to do their job.  There is also a part that is based on funding. Equally distributes them based on funding

A:  Northey in general we will see that we don’t have enough people to get the workload done manage the money we have by filling the deepest holes we have.  What is the size of the optimal office. There is no one optimal size.  Each office and county are different.

A:  Ameer Ali for what is good for county A may not be good for county B. One office may have the resources, but the other office may not. As our model evolves we may progress depending on the Farm Bill.

13. CRP once a cost has been paid the application continues to show up on the ULO report which causes the county office to enter zero data to clear it off the ULO report. Is there an option to resolve the ULO issues? The rental rates are a problem and discrepancies are showing across county lines.  Is there any initiative to resolve this issue?

A: Karmen stated we are working on the ULO issues  bringing in teams from the field and we are expecting to have a fix.  Rental rates use the NASS data. Previously people thought  our rates were too high. The SEC wanted us to use the NASS data. The producers are reporting data to NASS so that may be were the discrepancies. Resolving all our ULO’s is very important to our auditors.  98% of the last report was resolved but the auditor wants us to resolve 100%.

A:  Northey CRP is tough to balance the line to have a rate that is competitive and take land out of production verses lowering the rate and keeping it in production. There is some land in some counties where it is justified to spend a higher rental rate than the rental rates because of the type of land.  Congress is looking as NASS as the driver in the next farm bill.  If you increase acres the only way to control that is by lower rental rates.

A:  Fordyce stated that the timing of the ULO issue is more about fiscal year and trying to get the audit cleaned up.  We have asked for departments to be more considerate of the timing of the request to the field on cleaning up the ULO.  The rental rates in the mid-west we had some rates that were competing with cash rents. When the Federal government is paying the highest rate in the county that is not a position that we need to be in. Out bidding young farmers is not a way for FSA to help beginning farmers. NASS data is bad because we have low participation by the farmers and we should promote to our farmers for them to complete the surveys.

14. MPP – The program was a retroactive program going back to January and producers who had sold their dairy before the sign up are not allowed to sign up because they are commercially producing milk at the time of sign.

A:  Brad Karmen stated we will have discussions and get a good answer back.  When the language was written it was not intended for a retroactive sign up.

15. Workload and optimal performance tool- I have been told that offices that earn comp or credit time its make that office look less efficient than those offices that chose not to work late and earn comp or credit time?

A:  When you earn comp and credit time does not show until you use comp or credit time.  Unfortunately, at the mercy of the data.  Working on the issue to resolve.

16. The shortage of staffing is causing county office burnout and people to retire. What is management doing to encourage people to utilize things such as EAP?

A:  Fordyce the assets of this organization is people and if we are going to continue we must figure out ways to encourage our staff.  Encouragement, support we want to do more than that.  We are going to have to get innovative and think out of the box to invest in our assets.

A:  Northey- especially when we were not hiring positions has caused such a burden.  We would love to have ideas from the field of what we can do to show the field that we appreciate them. We know there are some that field under appreciated.  There are some of there pieces that we are working on some processing agreements to make our office more efficient and improving service.  What do we need to do that will give encouragement to the field?

17. Suggestion for FPAC NRCS is good with technical and we are good with paperwork is there any way that NRCS can do the field work for FSA for CRP?

A:  Fordyce stated that all possibilities must be explored.

A: Northey that is a question I don’t have the answer to but those are the type of things that we are looking at.

18. Thank you for trusting us with MFP but when this rolls out we won’t be able to measure all the bins since we don’t have a field reporter can we use RMA data?

A:  Northey the premise is we are going to make it as simple as possible and keep the shoe boxes out of the office.  RMA records will not be able to be populated by tract, but it still should be easy to use acres and other data for the program. It needs to be done by self- certification without doing field visits.  We have an issue with hogs and how they will certify. Utilize the COC with the local knowledge to make some of those determinations on the self-certifications.

A:  Browne stated we are very aware of the workload this program will bring and we will be reaching out to STO’s to determine the number of temps that will be needed.

19. We have a county office that was approved for a position that required a waiver. You said 90 percent have been approved where are we with the other 10 percent?

A:  Browne stated for the justification we need very specific data provided. Depending on the justification will determine whether it will be approved. We are going to continue to work super hard to make sure that comp and credit time is not used against us.

20. MSP installations what is the plan for the new installations where there is no plan to put one there before the Lexmark is pulled out?

A:  Ash stated we know we have old Lexmark systems out there and we must get off them.   We have ordered several and we recognize the issue and we will address the problem.

21. If the national office looks at the workload for efficiencies why do we have to load so many components in ARS?

A: Rebecca Dudley stated the way I understand is FSA request funding based on activities and ARS is built around activities.

A: Trina Brake we are looking at alternatives to make things better

22. We have multi county and centralized work these will only show up if the county keeps track of this. We need a generic code in the system for work completed for other offices?

A: Rebecca Dudley that is one of the points of conversation we are discussing right now.

23. What is the ceiling how does it work, what does it mean to DC and what should it mean to the CO?

A:  Fordyce the ceiling is when the time coded and metric generated are ran through the model and it generates a number which is the number we need to conduct our business.  Staffing ceiling which is based on funding. The model can do both of those.  The number needed and the number available based on budget.

A:  Treese it split CO and GS there is a flex between ceilings

24. Is there any consideration in revamping the county office training programs?

A:  Fordyce that is a really good question. We find ourselves in a position where we have several vacancies.  I am very well aware of PT” s that are long employees of the agency and the PT in charge becomes the defacto CED.  The PT in Charge is doing pretty much the same work as a CED. What can we do from program policy stand point to allow for these PT’s to become CED’s? There should be able to have a shorter path to becoming a CED. We need to be innovative to get these PT’s into CED’s.

25. Do you have any idea what kind of language will or will not be in the Farm Bill?

A:  Northey not a forecast but a constant conversation about how to be more efficient.  Are we in the right places and right counties?  The plan taken to congress to close offices needs to be bullet proof and not be of convenience.   We need to justify to Congress that this will provide better service.

26. Recently procedure came out regarding 2-CP that if an office made an error we could not fix those errors causing producers to have to come back into the office instead of us making those corrections?

A:  Karmen stated we will have to look into this a little bit more.

27. Are we going to have any training on or is the only training AgLearn?

A:  Ash sated the only type of training that will be giving will be within the program as they are rolled out.

28. If going forward and the staffing model is our only gauge for hiring is there a way in WebTa to document things better rather than having such broad categories?

A:  Brake stated yes, we are looking into developing more categories.

29. Linc Pass card get wiped out during the sign up and had to get passwords every day to sign and they had to wait for the new cards? Can we look at the one finger reset?

A:  Ash although Linc Pass is not part of our responsibility it is part of the business center and will pass the comments on to the people that are running that portion.

30. Has the experience levels of employees being taken into consideration when looking at staffing models?

A:  Ameer stated that the short answer is no State view and county view on the site. They have not been able to establish tenure of employee’s, but this is where the local management team would have input on.  

31. A CED is told that because they are fully staffed they will go help other counties is that a State decision or coming from the top? This could cause the workload tool to become a point of contention between offices.

A:  Browne- We need to think outside the box and we need to do whatever we can to help these folks however these are state leadership decisions.  We might get asked to do things we haven’t done in the past.

32. WebTa coding is absolutely necessary to document where work is getting done. Is there any way we can get WebTa codes in our handbooks by program?

A:  Treese stated there is a handbook for WebTa but that is a very good question. Good idea for us to do in the future. Regarding, the competition ideally in time there will be more availability of information down to the SED’s and DD’s.

A:  Fordyce stated that the staffing model was accelerated so that we could staffing out to the field.  Ideally it would have been nice to have it perfected before we rolled it out.  The staffing model is going to be pretty close of where it should be because we are using a three-year average.  The establishment of ceilings will go down to metric and time.

A:  Meighan stated it will take the WebTa coding issues back because they are having these conversations now.  This is where the business center can help.

33. November 15th for warm season grasses date is too early for certification is there any way we can change?

A:  Fordyce agrees and understands there is a lot of issues with changing that date however we are working on that and they will get back with us.

2018 Negotiation Responses from Washington, DC.

ITEM 1 –  Staffing/Personnel

NASCOE_LogoOne of the tools available to handle peak workload and also to recruit new employees to FSA is the volunteer and intern programs. These individuals would either help out when workload requires more people than are staffed at location or they may want to see how the agency operates and what they can provide as a future employer. The problem is that volunteers and interns are unable to access programs such as CARS or Farm Records because they do not have the right to permissions. Volunteers and interns are not given the same access as FTEs even if requested on a FSA-13A.

NASCOE’s Position:
Volunteers or interns are required to go through the same background checks, take the same security training, and obtain a LincPass card the same as full time employees, yet they are denied access to vital programs. This exhibits their ability to be of assistance in the COF or to gain hands on experience and observe the applications in which they could do potential work as an employee. This leaves a bad impression when they can’t get access. This is a decision that was made at the national level regarding roles and access according to the Access Management staff.

As long as the volunteer or intern completes all required training, such as the annual security training or application training such as is required for MIDAS Access they should have the same permissions as a full time employee.

FSA’s Response:
OCIO: The Access Management staff is the messenger not the decider. It was a business decision (i.e., Farm Programs) to disallow volunteer access. This is actually something that is tracked. These are the ones OCIO has researched so far: and we are wrapping up final analysis on all remaining Farm Program systems for Farm Program’s review.

HRD: FSA HRD supports the system access deemed necessary by the hosting office for their volunteers and interns. In order to effectively provide a fulfilling and enriching experience with the agency, volunteers and interns should be able to learn and understand systems used to achieve mission results.

Volunteers and interns are required to go through a background investigation process to receive a favorable approval to work notification that is required prior to any temporary or permanent assignment. FSA HRD defers to EPD concerning additional details concerning the levels of approved background investigations for different sensitivity levels for volunteers, interns, and full-time employees.

After a favorable determination is received by HRD, we instruct the hosting office to fill out the FSA-13A to obtain computer access which is approved or denied by OCIO. The decision of system access for any individual position belongs to the first line supervisor and the direction of the hosting office. There is no regulation within the Pathways Program that encourages offices to withhold system access to interns. Volunteers do have regulations on the duties they may perform per USDA’s Departmental Regulation 4231-001 that do not speak directly to why system access may or may not be provided but may go into the decision making of the host office:

  • Under 7 U.S.C. 2272, volunteer services performed by those not employed by USDA will meet the following criteria:
    • Services will be performed without compensation; and
    •  Volunteers will not be used to displace any employee of the Department of Agriculture including the local, county, and State committees established under 16 U.S.C 590h(b).
  • Volunteers providing services under 7 U.S.C. 2272 are not Federal employees for any purpose except for the purposes identified under:
    • 5 U.S.C. 81, relating to compensation and injury; and
    • 28 U.S.C. 2672 – 2680, relating to tort claims.
  • Volunteer service, in general, may not displace any USDA employee nor may it be used to perform any work which is inherently a government function as defined by Office of Management and Budget (OMB) Circular A-76, Performance of Commercial Activities.

DAFP: ITSD is reviewing all systems to determine if security is in place to allow volunteer access. DAFP is going to provide access as soon as the final analysis is complete on all of the systems.

NASCOE Response: What is the timeline for the final analysis to occur? To take this a step further temps need to have access to SCIMS in order to help us more for the short time they are working in the office.

Response: There is a website that can be shared through Kara. DAPF will respond on this issue as well. The overall goal is to give Temps access to our systems.

DAFP: Once KC completes their review of all our processes the accesses for interns and volunteers will be approved. Temporaries should have access to all systems. Midas is a separate system. AD-2017 is still required for SCIMs access even though it is read only. Within the month the final review of all the systems should be completed and request should start being approved.

DAFO: The request for access was originally being denied because the request was not clear as to the security they have been through. By the end of the month the final review of all requests should be done and access may be granted. Once they pass through security they will be approved. Temporaries are allowed accesses. They should not be disapproved.

ITEM 2 – Staffing/Personnel

Where is the National Mentoring Program at? It is my understanding that there was not enough interest in the program at the time and thus it did not move forward.

Across the country, new CEDs are not being supported after the completion of COT training, or upon being hired as a CED after a Hard to Fill position or a PT who was Acting in Charge was selected for the position.

NASCOE’s Position:
The National Mentoring Program has, in the past, been a successful program. Those who have participated feel that it was a very beneficial to their jobs and provided them with an invaluable resource. NASCOE supports the National Mentoring Program and recommends that it be re-advertised. In addition, NASCOE recommends participation in the program be a required element for all new employees.

In an effort to ensure the programs continued success, NASCOE would gladly offer assistance to the National office in identifying trainers as well as providing additional resources as needed.

Please see attached Exhibit 1 in support of the National Mentoring Program.

FSA’s Response:
HRD: On March 2, 2018, FSA/LEDB (Learning and Employee Development Branch) was informed that the Virtual University (VU) team is being defunded at the end of March 2018, as well as 19 positions affiliated with VU, including the Departmental Mentoring Manager. USDA agencies may continue their own mentoring programs; however, it is unclear whether or for how long FSA will be able to continue to use the Mentoring Portal, which matches up mentors/mentees, or matches up a mentor and mentee that have already pre-selected each other. FSA will continue the program using the portal as it is the only way FSA/USDA can manage and report the number of employees participating in the mentoring program. In the event the Mentoring Portal is no longer available, FSA is researching methods to do so independently of the system to continue the mentoring program.

FSA supports NASCOE’s request to re-advertise the National Mentoring Program with both GS and CO employees, to increase participation.

FSA greatly appreciates NASCOE’s offer of “assistance to the National office in identifying trainers/mentors as well as providing additional resources as needed” and would be glad to explore this kind of collaboration with NASCOE.

Concerning adding a performance element for mentoring, FSA can add an element or standard without Departmental permission. HRD recommends adding a standard instead of an element, under Execution of Duties. FSA can bolster mentoring accomplishments through activities like scheduling monthly check-ins/training/tips, and providing suggestions for mentoring activities such as brown bag lunches for mentees and mentors.

NASCOE Response: The intent was not to add another element to the performance plan. This is more of an onboarding element. What would be the method of pairing up the mentor with the mentee without the portal.

HRD is not sure of the answer to the question. HRD will provide an update after they have discussions about this item. HRD has raised the issue at the CHCO level and hopefully they will come up with a constructive response. In the absence of a constructive response HRD will reach out to NASCOE for assistance but will keep NASCOE updated.

ITEM 3 – Benefits

USDA does not currently cooperate with the TSA Pre-check travel program.

Participating in the USDA TSA pre-check program should be analyzed for viability. It is possible that USDA and TSA could cooperate on a blanket scale and save both time and money for FSA employees when traveling. It would seem that since USDA has already processed background checks that they may already have all of the elements of information needed to qualify for TSA pre-check.

NASCOE’s Position:
Currently if a USDA employee wanted to opt to be a TSA Pre Check traveler, they would have to submit an online application and then make an appointment to visit an enrollment center in order to process the request and pay the $85 fee.
USDA employees are required to be finger printed and a background check ran as a prerequisite to their employment. Once the screenings are complete, the employee’s credentials are then placed on a LincPass card which is provided to the employee in order to access government buildings and operating systems.

Having these credentials already in place, it makes sense that a partnership would be beneficial to both USDA and TSA alike. USDA employees would be given the added benefit of qualifying for the program using their LincPass credentials allowing USDA to realize time savings while employees are traveling on official duty and saving them the $85 application fee. TSA would be able to realize cost savings by utilizing the background check information and fingerprints already provided by USDA.

In November 2014, TSA and the DOD announced a partnership to expand TSA Pre-Check expedited screening benefits to more than 2.6 million U.S. Armed Forces service members. The service members opt in thru MilConnect (DOD employees website), and use their ID Number when booking their flights. Through negotiations USDA could implement a similar process utilizing existing systems and the employees LincPass cards that would fulfill TSA requirements.
It is very encouraging that TSA has successfully formed a partnership with another government agency. NASCOE would like to request USDA/FSA leadership to pursue partnership negotiations with TSA to save time, money along with adding an additional benefit to its employees.

FSA’s Response:
FMD is in support of forming a partnership with TSA to provide Agency employees expedited screening with the TSA Pre-Check program. This initiative needs to be supported and lead by the Travel Area of the Department OCFO. FMD Travel Section will discuss this effort with the Department OFCO to determine if feasible for USDA/FSA employees.

NASCOE Response:
What is the process and the timeline? Have you initiated contact with the other agency to start the process?

Currently TSA has a different vender than OPM and therefore the finger prints are not transferable. EPD will reach out to TSA to see if they can generate a conversation about sharing fingerprints and developing a process to collaborate on gaining USDA employees Pre-check credentials. Follow-up will be forthcoming.

ITEM 4 – Directives

File Maintenance and Disposition Manual (32 AS Transfer Guide) is not amended when changes are made to the manual. This results in employees not being able to properly update the manual when a hard copy manual is used in the COF. There is no way to know what part of the manual was updated, therefore, an entire new manual will need to be printed if hard copy is required.

NASCOE’s Position:
The File Maintenance and Disposition Manual (32-AS Transfer Guide) is not amended when changes are made to the manual. If a County Office uses a hard copy of the manual, the employee is not able to properly update it because there is no way to know what part of the manual was updated. Therefore, an entire new manual must be printed if a hard copy is required.

Handbook 1-AS, Par. 3A (last bullet) states the MSD Records Staff is responsible for “amending periodically the agency’s File Maintenance and Disposition Manual to ensure that filing codes and retention and disposition authority instructions are current and accurate.” NASCOE would like to recommend that the File Maintenance and Disposition Manual (32-AS Transfer Guide) be updated according to handbook 1-AS to include amendments in the same manner as any other handbook.

FSA’s Response:
The File Maintenance and Disposition Manual is a file plan. Because of the fluidity of records and the many changes that will continue to be required, this manual will not be considered as a handbook or directive.

FSA, however, has agreed to post changes to the file plan as an amendment. This amendment will contain each page on which there were changes/corrections since the last manual was updated on the Records Management SharePoint site. This will be added so that when a paper copy of the File Maintenance and Disposition Manual has been printed, only the amendment will need to be printed to replace the pages in the printed file.

NASCOE Response:
Accepts response as submitted with a projected deadline.

August 1 is the proposed date for this to begin. With the transition to Business Center some other things need to be in place first however that is the projected date.

ITEM 5 – Leave policy

FSA’s current procedure when interviewing for any USDA agency, restricts county office employees from using administrative leave when interviewing for an out of state vacancy. This leads to inconsistencies and inequality between national office and field level employees.

Par 161 G 17-PM as follows;

161 *–G Interviews
FSA/RMA National Office employees may be granted administrative leave if the interview is for another USDA job.

Permanent full-time or part-time employees may be granted administrative leave if the interview is within FFAS in the same State as their regularly assigned duty station. If the interview is outside of FFAS or out-of-State, the employee must use their own annual leave to cover the time absent from work.
Notes: Permanent employees may be granted a maximum of 4 hours administrative leave.

For permanent part-time employees, the administrative leave must correspond with their tour of duty.–* 5-29-08 17-PM (Rev. 2) Amend. 5 Page 7-3

NASCOE’s Position:
Every permanent, full-time FSA employee should be eligible for a maximum of 4 hours administrative leave to apply for another USDA positions, regardless of geography or agency. This would bring consistency and equality to the process and also potentially increase hiring pools. Allowing existing employees who have been selected to interview for USDA job openings to receive some administrative leave could promote applications and help staff critical and hard to fill positions.

FSA’s Response:
HRD: This policy is one which will be reviewed with the evolution of Farm Production and Conservation.

NASCOE Response:
Where do they see the evolution of FPAC going and where does HRD stand on this issue.

HRD will have to merge their policy with FPAC. We are in the process of working with design of the two working groups. The unique county challenges will be brought to that process. The first look will be an August -September look. HRD will take this to the Business Center through FPAC sometime in August -September and again later in 2019.

ITEM 6 – Staffing and Personnel

Staffing in offices is a continuing to become problematic issue. Not only does understaffing affect the service to producers, it also affects employee’s performance and morale as well. NASCOE notes there were 6 items in regards to staffing / personnel submitted as negotiation items by membership. We have combined these into one item to reduce redundancy.

NASCOE’s Position:
NASCOE believes that staffing is a problematic issue, at the same time we recognize the situation the Agency is in right now with the budget and a hiring freeze. In an effort to come to a solution that will alleviate some of the hardship being placed on our workforce, NASCOE proposes the following:

  • Develop an accurate and comprehensive workload and staffing tool:
    Through critical hire requests and the removal of the hiring freeze, staff offices based on actual workload needs. Consider all administrative, program, and applications not counted in the current workload systems. Many Administrative functions, County Committee functions, other miscellaneous required duties and use or lose annual leave could equal a considerable portion of 1 FTE.
  • The county level workload and staffing data should be available for CED’s to evenly distribute workload among employees.
  • Shared Management Training:
    Through the shared management task force, develop a training (face to face preferred) for CED’s who are currently in shared management to utilize.
  • Utilizing OneUSDA:
    Collaborate with sister agencies (NRCS, SWCD) to develop a policy of mutual assistance to the greatest extent practical when staffing situation occurs.

FSA Response:
HRD: HRD is supportive of the above ideas. HRD would defer to DAFO who leads on these issues at this time.

DAFO: County level analytics are available to State Offices. The staffing model will only be used as a tool in developing State ceiling levels.

NASCOE Response: Needs to go to the county level so that managers have that tool to staff their offices and manage their programs. Supervisors are having to deny request of employees who wish to participate in programs such as the fellows because they do not have the tools to manage their staffing. New manages do not have the tools to manage their staff since they don’t have the history or understand the workload of the programs. Not having the workload tools keeps managers from allowing their staff to volunteer to assist other states. We recognize the reports are accessible through OBE however a report with the hours would be most helpful. NASCOE wants transparency to the field.

Workload and Staffing Tool: DAFO is not sure where that is going to end up. FPAC eluded to the fact that the best resources are needed to staff offices accurately. OBF can address the staffing model questions. FPAC’s Optimal Office model came after the FSA staffing model. The report lays out the programs, the metrics, hours spent, and leave records. The optimal office workload tool looks at the same information as MCA but takes out the anomalies.

To attempt to provide county offices with workload data, DAFO requests that NASCOE to provide to them what data elements are needed from the old County Office Workload Measurement System report 14. Those would be items that would helpful for county offices to manage staff and workload.

There is also a 66 page report that should have been shared by STO’s with all county offices. It might have been helpful for COF’s to help manage staffing and workload. DAFO will discuss with the STO offices about sharing that info down to the county office level.

Shared management training: The task force was stopped until we had SED’s on board and the creation of FPAC it has been slowed down however the intent to start the task force back up and continue the process. DAFO agrees to continue with the Shared Management task force. In 60 days DAFP will come up with a timeline for the task force.

Revision of 27-PM revision 2: It is in final review. The changes that were agreed to last year are included in the revision

Utilizing ONE USDA: The local FAC is the vehicle to make those decisions. FSA will entertain asking the National FAC about setting some policy that can be pushed down to the local FAC. Policy would be voluntary practices and suggestions that may be used by service center personnel to assist each other in servicing the customer. The FPAC Optimal Office concept may bleed into this and help resolve some of these issues.

ITEM 7 – Benefits

Consistent official benefits/retirement counseling/training are not being provided by State Offices.

Handbook 35-PM Par. 3 C, State AO Responsibilities states that State AO’s shall:

  • provide benefits guidance to all employees
  • counsel all employees in matters about benefits and retirement
  • assist CED’s in providing guidance for newly hired employees for eligible benefits

NASCOE’s Position:
According to 35-PM Amend 2 Par 17 A & C:

A: Agency Responsibilities

The Thrift Savings Plan Open Elections Act of 2004 (Pub. L. 108-469) requires OPM to develop and implement a retirement financial literacy and education strategy for employees as part of the retirement training offered by OPM under 5 U.S.C. 8350. The implementation of the strategy must:

• educate employees on the need for retirement savings and investment
• provide information on how to:
• plan for retirement
• calculate the retirement investment needed to meet their retirement goals

The programs must target employees at a minimum of 3 career points:
• New employee
• Mid-career
• Pre-retirement

The financial education strategy is designed to:

  • provide employees with a framework for analysis and decision-making so that they can achieve their retirement goals
  • leverage the existing resources of agency benefits officers to broaden their focus in helping employees plan for retirement
  • set forth a model of financial education to improve the financial literacy of employees
  • create a system that allows employees to learn how to plan for retirement and to calculate what their retirement investment should be for the goals the employees have established.–*

B: Retirement Workshops

State Offices shall conduct retirement workshops at least every 2 years on a district, multi-district, or State level for all employees that are age 50 or older.

State Offices may:
• invite outside speakers to participate in the workshop; include a Social
Security representative, if possible
• use available audiovisual aids to explain retirement programs.

If State or County Office employees require retirement training, contact the State Administrative officer.

Currently there is a wide array of options being offered by states, from not providing any assistance to others providing an adequate face to face training for the employees in differing stages of their careers. Obviously the benefits/retirement options are the same across the country and likewise all employees need the same opportunity to understand and be educated on their benefits towards their retirement. Along with the differences among States we are sure that there are differing reasons, ranging from budget to training resources.

NASCOE is requesting to work with leadership to establish a standard and the budgetary requirements and resources so that all employees are afforded an equal opportunity to education and exercising their employee benefits. NASCOE believes the agencies greatest resource is its employees and know that an investment into their future will be, and has been, reciprocated in the agencies mission.

FSA’s Response:
HRD: On July 13, 2017, HRD provided, to the State Offices, through DAFO, two PowerPoint presentations which could be used for retirement training. One of these presentations was for CSRS employees and the other was for FERS employees. In accordance with Handbook 35-PM, paragraph 3B, HRD will continue to lead the efforts of developing training materials for State Offices to use in conducting benefit sessions for employees across the agency.

As an additional comment, Aglearn also contains a wealth of information on benefits/retirement-related issues which employees may use to supplement the information received from their State Office.

NASCOE Response:
How many STO’s have provided the training? Has it been monitored? The PowerPoints are not fulfilling their obligation. Open dialogue to address the disparity. Accountability?

Response: There is not any tracking outside of AgLearn. There are going to be some initiatives coming out of OPM to assist our new employees in understanding the benefits of TSP. As part of the new FPAC organization design there is an initiative to review the training that has been conducted and design the type of trainings we want our employees to have. In terms of the retirement training, we will be looking at retirement training but at this point we are not sure how we will conduct that. The training models that currently exist are being reviewed to see if it meets our needs. HRD is in support of providing personnel at the NASCOE convention to provide training. FSA will also commit to providing some form of retirement training during the SEA rally and possibly other Area Rallies. FSA will conduct a review of what trainings state offices are providing and will make sure they are consistent.

ITEM 8 – Staffing/Personnel

We have many excellent employees that work in our County Offices that would like to apply for the COT program/CED positions, but they are tied to the community that they live in. They are unwilling or unable to commit to a training program and being placed “somewhere” within the state.

Current practice has our STC interviewing and selecting COTs. They train for 6 months to a year and then interview for various open CED positions. The positions that are open at the start of the training program are not necessarily the ones that are open at the end of the program, either due to permanent shared management or possibly a permanent hire. The end result is that people end up in locations that they don’t really want to be at, maybe even 5 to 6 hours from home. This practice puts an extra strain on the family members or causes employees to choose between what’s best for their career or what’s best for their family.

NASCOE’s Position:
NASCOE recommends incorporating a Leadership Program for PTs that allows the Agency to identify future leadership candidates and that changes be made in the COT hiring process to reflect the same opportunities that are afforded in FLOT hiring. Doing such will allow added upward mobility opportunity for the incredibly talented cadre of qualified employees that have leadership potential within FSA.

A recent Federal Employee Viewpoint Survey for FSA asked employees “how satisfied are you with opportunities to get a better job in your organization?” Results showed that less than a third of employees offered a positive response. County committees are hiring COT’s that stay in a county office for 2 years and move to another county office that they find more attractive. Many of these county committee’s endure a revolving door of CED’s leading to low morale and lack of direction/continuity for the county office staff.

Management has stated that the COT program is working adequately to fill the need for CED’s and that PT’s can apply for this opportunity and compete. NASCOE sees county offices going too long without a CED and when a COT is hired, county offices must struggle to deliver programs until the COT slot is released to use somewhere else. In addition, many PT’s have expressed they would like to apply for a COT position however can’t because of current situations and the uncertainty of where they may be placed. The door for hiring CED’s-in-training for the county office where stationed has already been opened through Hard-to-Fill provisions in paragraph 458 of 27-PM.
The following recommendations will address the intent of this item and make it even more successful for employees and county committees:

Recommendation #1
NASCOE believes FSA is missing an opportunity to develop leadership/management skills in our Program Technician workforce. Why not create a program that identifies PT’s with management potential and provides a career ladder opportunity to feed the FLOT and COT program rather than waiting until a PT applies and “hope” management skills are present?

NASCOE proposes a two year Aspiring Leadership program be developed that PT’s could apply to participate in that would train and give opportunities to enhance management skills. Through an application process, selected PT’s would take part in leadership development programs taught by FSA as well as other outside organizations. FSA would also have a mentoring element to this program that would assist in oversight of the training. Participants passing this two year program would help FSA identify a cadre of qualified PTs that have COT/FLOT potential. Many universities have similar programs that train potential leaders in agricultural practices through comparable methods and have document great success.

Recommendation #2
NASCOE proposes that the hiring system for COT’s be enhanced to be comparable to the FLM/FLOT system where COT’s can be hired in the county where they will be stationed with an end goal that it will be a long term career decision. This would also provide an opportunity for PT’s to apply for a COT position with the insight of knowing where they will be stationed, avoiding the potential situation of having to uproot their family. This hiring process would not only benefit PT’s in the advertising county, but those in surrounding counties as well as. In recognizing that county committees might be more inclined to hire PT’s that they know rather than the most qualified candidates; certain safeguards would need to be put in place to assure the most qualified and suitable candidates are hired.

NASCOE suggests the following steps to avoid “preselection”:

  1. Smith County advertises both within and outside of FSA for CED’s and COT’s that would ultimately be the CED in Smith County.
  2. All applicants apply through USAjobs.
  3. A panel, similar to the one that does COT interviews currently (AO, FLC, CED, DD, etc.), conducts interviews and submits qualified candidates to the STC.
  4. The STC determines the top 3-5 candidates to submit to the COC for interview.
  5. The COC, with the counsel of the DD, selects a COT that will begin training for the CED position in Smith County.
  6. As training progresses the selected COT will increase the amount of time spent in Smith County as he/she takes the opportunity to put into practice skills that have been developed over the course of training. The COT would progress by conducting staff meetings and COC meetings while working under the direction of a mentor who would be the temporary shared management CED.

Why is a policy of hiring FLOT’s to specific counties acceptable on the GS side and not acceptable for COT’s on the CO side? Why are some FLOT’s being hired with the expectation of being placed in a “region” of the state when COT’s do not receive this same opportunity? NASCOE sees Program Technicians leaving their position for FLOT positions when the same career ladder flexibility is not made available for COT position.

In Summary,  NASCOE recommends incorporating a Leadership Program for PTs that allows the Agency to identify future leadership candidates and that changes be made in the COT hiring to reflect the same opportunities that are afforded in FLOT hiring. Doing such will allow added upward mobility opportunity for the incredibly talented cadre of qualified employees that have leadership potential within FSA

FSA’s Response:
HRD: The decision on how to hire and train COTs as well as how to place them upon completion of the training program is an agency choice. There are considerations associated with the current hiring, training, and placement process just as there are considerations with the proposed hiring, training, and placement process. HRD defers to DAFO for their determination on what is best for the State and County Offices on this issue.

DAFO: Not all FLOT positions have a permanent duty location cited in the announcement. We understand the NASCOE position on this issue, but it is very difficult to determine which CED position would be available at the beginning of COT training, and, in fact, openings cannot be predicted with any certainty at all.

NASCOE Response:
Not all COT’S will be hired using this method so is management agreeing with our method.

DAFO’s position has not really changed. There is a process for the hard to fill program and for local PT’s to be able to apply. FLOT’s are under the authority of the SED and can be moved at any time, therefore they are not hired for set areas. DAFO will visit with HR and will revisit this item to see if there are more options for us to open doors for our PT’s.

ITEM 9 – Staffing/Personnel

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.

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.

NASCOE’s Position:
NASCOE presented this item last year (item 4, 2017) and accepted the response. In the final response it was stated that this item would be considered in the future and discussed with RSO management the possibility of doing remote positions. NASCOE feels that in order to achieve the goals of maximum efficiency and effectiveness the ability to pursue the best and the brightest for these positions should not be limited by the physical location of the duty station. The evolution of FPAC gives us the opportunity to mimic successful private business models for our employees. NASCOE would like to know if this discussion has happened if not how soon can it happen.

FSA’s Response:
HRD: HRD defers to DAFO for a response on whether conversations have occurred with the SWA-RSO Leadership team on this issue.

DAFO: The discussion has occurred and RSO leadership maintains that the organization best functions and fulfills its purpose when its employees are co-located and not scattered. Concentrations of employees provide for many benefits including 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.
Appropriate, available space in county offices remains a concern as well. The (10) SWA States have committed to make space available in any of the respective STOs where RSO employees are hired and duty-stationed. A similar commitment is not in place for duty stationing newly hired RSO employees in any of the (458) Service Centers across the SWA or outside of the SWA.

NASCOE Response: Through FPAC we are trying to create a model that allows our producers to apply through different portals. We should be to allow our own personnel models to follow the same model. The current RSO is spread out all over the SWA.

Resolution: The RSO is going to merge into the FPAC Business Center.

ITEM 10 – CRP 848 Review

CRP 848 Review Process has been very grueling. I am the Conservation Technician in our county which has heavy CRP participation in both regular CRP and the SAFE program. The spreadsheet provided for review was overwhelming and a very short deadline was given to complete the process. There was no option for a “register” or any extension that would be granted. The timeframe given was unrealistic and caused a lot of added stress on the county office employees.

We were given a spreadsheet listing CRP 848’s with expired expiration dates to review during the third week of December and given until January 11th to complete the review. In my case I had 719 848’s to review. This process is not a quick and easy process. The majority of the 848’s were set up to expire during the first year of the time span for the two mid contract management practices and are valid 848’s. When software was moved from the SYS36 we had to reissue new referrals for each contract with little guidance. As with most things we deal with, the way they want us to handle setting up these 848’s and the rules to the program have changed numerous times making it impossible to make the revisions it would take to keep them off these lists that they are coming out with now. It is my understanding that now that we have cleaned up this report it does not keep them from appearing on a future report to look at again. Apparently if an 848 has no activity on it for over 12 months, that 848 will reappear on the report to look at to see if it is still valid. We have a hard enough time keeping our heads above water without having to go back over the same issues only to tell them it is still valid.

NASCOE Position:
Now that an initial review of outstanding FSA-848’s has been completed and the county office has identified which 848’s are valid, that information should be carried forward. It should not be necessary to routinely conduct such a time-consuming review of these FSA-848’s which could knowingly continue to appear on the report. Further, automated MCM tracking should be developed to assist county offices and ensure uniformity.

FSA’s Response:
DAFP: FSA is working on several items to try to identify cost share issues prior to their placement on the ULO report. CEPD agrees that County Offices should only have to look at a specific FSA-848 once during a fiscal year. Additional guidance will be issued to State and County Offices providing more flexibility on creating FSA-848’s when the CRP contract is approved.

NASCOE Response:
What solutions and items are PECD working on?

CEPD stated that ULO’s has been a topic of discussion. A letter just went out today to the STO’s from FMD that described the next round of reviews. The items on the list not yet expiring will be taken care of by the NO. The field will be responsible for the items on the report that have expired will need to be reviewed. CEPD would be open to any suggestions on how to handle 848’s and cost share tracking/automation in the future. CEPD recommends that when a practice is completed that it be marked final in the system to clear that item off the list as complete. PECD will check with EDW to see what parts moved to that to see what reports can now be generated to assist us with tracking our practices.

ITEM: 11  Supervisory Standards

National Notice PM-2993 contained several changes that are of concern to NASCOE. These include New Supervisory Standards for Managing Employee Performance contained in Exhibit 1, Standards in Exhibit 3: Customer Service, Outreach Education and Engagement and paragraph 3H Employee Performance and PIP.

NASCOE is concerned with the suspension of language in DR 4040-430, Section 9.g.(3)(a) pertaining to the minimum 60 day PIP. The requirement to hold the employee in “unacceptable” performance status for the entire appraisal period, despite an employee’s successful completion of the terms of the PIP, is not a fair and objective directive to allow managers to properly assess performance. Suspension of the 60 day minimum for a PIP, does not allow an employee a fair pathway to correct and meet their performance goals.

Exhibit 3, Page 2 Under Element 815: NASCOE believes that the standard requiring supervisors and managers to ensure receipts for service are issued when required with no more than 1 exception is not realistic or attainable. Additionally, the standard requiring non-supervisory employees to issue receipts for service for customer interactions with no more than 2 exceptions is not realistic or attainable. Furthermore, this standard directly conflicts with guidance provided in Par. 4A of this notice that states “exceptions should be stated within a range…..exceptions should not be stated as an absolute.”

Exhibit 1, Pages 1 and 2 list the 11 the required standards for meeting fully successful and the requirements for exceeding fully successful. Although FSA policy encourages the use of only 5 to 7 standards, PM-2993 requires 11. NASCOE doesn’t want to marginalize performance process but believes the 11 standards are excessive.

NASCOE’s Position:
NASCOE believes a minimum 60 day performance improvement period (PIP) should be used to allow supervisors/managers to fairly access the employees progress in complying with terms of the PIP (Par. 3H);

NASCOE does not agree that an employee should continue to be rated “unacceptable” for the entire rating period if the employee has successfully met the goals and terms of his/her PIP (Par. 3H);

NASCOE believes there are too many standards in Exhibit 1 for meeting fully successful and they should be reduced to FSA’s recommended number.

NASCOE has concerns with the use of absolutes in standards. It is particularly concerning to see absolutes used in Exhibit 3, Pages 2 and 3 under Element 815. Attainable ranges should be used for all standards and measures (Par. 4A).

FSA’s Response:
HRD: The Department (OHRM) mandated the changes regarding the length of the PIP as well as if the duration of the PIP exceeds October 30th, the “unacceptable” rating for the employee will remain the employee’s rating of record for that year.
It is FSA’s policy to encourage the use of only 5 to 7 standards for each element; however, the Department may provide supplemental guidance which will cause these numbers to be exceeded.

Since the above items were mandated by the Department, they were incorporated into FSA Notices and cannot be changed by HRD. However, these issues can be escalated for formal discussion with USDA.

HRD defers to the Outreach Staff regarding the language in the standards required under Element 815, Customer Service WITH Outreach Education and Engagement Outreach Education and Engagement Standards. If the Outreach Staff elects to changes this language, HRD will accommodate this in the next notice.

DAFO Outreach Response:
Outreach will remove absolutes from the exceptions listed in Exhibit 3 pages 1 and 2 and provide changes in the next HRD performance guidance that is issued. Outreach has proposed the removal of absolutes with NRCS and RD regarding the number of exceptions cited in employee performance plans for issuing receipts and will advise of changes also in the next notice.

NASCOE Response:
When will this take effect? We ask that pages 3 and 4 be looked as well. NASCOE would like a formal discuss with USDA regarding the number of standards.

DAFO: A standard can be changed mid-year before a final is issued. DAFO will start the correction now to remove the absolutes from items 1-4 and send forward for review. A notice will be issued and midyears should not be done until then. An email will be sent to STO’s to make them aware of the changes coming.

HRD: They will start the discussions with FPAC regarding the standards. Dennis and Brandon will be updated on the progress.

ITEM 12 – Category: RCO Compliance Reviews

The FSA/RMA reimbursable agreement on RCO compliance reviews performed by FSA only includes mileage and no compensation for supplies and actual time spent performing the RCO compliance reviews. A well thought out reimbursable agreement that includes dollars for time spend performing the reviews would allow FSA the ability to hire good steady field assistants who could perform the RCO compliance reviews, stay on board longer, work multiple counties and obtain specialized knowledge and experience. This would allow USDA to utilize teamwork and expand opportunities for FSA to use its network of offices and staff to help RMA ensure insurance compliance. The end result will be a public that is confident in the vital insurance program that USDA administers.

FSA and RMA are required to “work together to improve program compliance and integrity of the Federal Crop Insurance Program”. NASCOE believes FSA should continue the current arrangement with RMA, however, through planning associated with the new FPAC mission area, re-negotiate the following:

  • Funding available from RMA for time (hours worked) spent by field assistants and other office staff performing RCO compliance checks.
  • Expand the number of RCO compliance reviews to ensure program integrity
  • Supply each USDA service center with one GPS unit for all agencies present to use
  • Supply each USDA service center with one digital camera for all agencies present to use
  • Arrange for the use of USDA fleet to be available for all agencies present to perform any USDA official duties
  • Hire field assistants that will work multiple counties performing RCO compliance reviews as well as other USDA compliance reviews (CRP, Farm Program, NRCS etc.)

FSA’s Response:
DAFP: The previous Memorandum of Agreement (MOA) only include mileage incurred when completing RMA growing season inspections. We have reached out to RMA to execute a subsequent MOA for these inspections and will broach additional expenses incurred in these compliance efforts when we negotiate.
NASCOE Response: When is the agreement done?
Resolution: The MOU will have to be reviewed to see when it is up for renewal. They do not have expiration dates.

ITEM 13:  1-INFO (Rev. 3)

1-INFO (Rev. 3), Amend. 1 was issued 10/24/17. The issuance date of 1-INFO (Rev. 2) was 4/9/85. A lot has changed in communications technology since 1985 and it’s understandable that a revision was certainly needed. However, as much as the methods of communication have evolved, communication at the local level with our customers has not changed; our customers expect to be informed with information specific to their locality and circumstances. One concern with Revision 3 is the content of Paragraph 94C. This new directive requires field offices to consult and receive clearance from the OEA Director and/or the PAB Chief through field PAS, share drafted text of the news release information at least 2 weeks in advance of the proposed announcement for all local issuances of news releases about local programs, issues, and concerns.

CED’s are grade 11 and grade 12 employees that should be held accountable for communication content and success at the local level. This has always been the expectation and responsibility of CED’s and accountability should not be diminished. The fact that communications technology and equipment has changed does not mean that CED roles and duties for direct customer service and outreach have changed. It is simply not feasible or efficient to require such bureaucracy and delays to affect information delivery to our customers at the local level. If there are noted communication deficiencies, this should be addressed by adequate and proper training or, in cases of disregard for procedure, CED’s should be held accountable for performance.

NASCOE’s Position:
Par. 94C should not require consultation, clearance, or 2 week advance submission to the OEA Director and/or PAB Chief through field PAS for field offices to issue news releases about local programs, issues, and concerns. It is reasonable to require CED’s to be accountable for all content released in local issuances and to require local consultation and review of all local releases prior to issuance.

FSA’s Response:
OEA: OEA understand the concerns. The clearance of news releases and other public-facing communications tools is imperative to ensure a consistent FSA, FPAC and OneUSDA message. We, at the national level, are required to have clearance, and the states and counties are held to the same standards. It is extremely important that we ensure that programs and policies have final approval from FPAC and the Department prior to external announcement– especially as we embark on a new farm bill. To date, with the 1-INFO policy in place, we have received few, if any, complaints from the communications coordinators. OEA staff understands the necessity for their responses to the requests for review and approval of locally issued materials to be as timely as possible without getting out ahead of the Administration. OEA staff works closely with states and counties to clear narrative that may be required to meet specific needs outside of strategic department and national office messaging.

Due to time constraints, DAFO agreed to facilitate a teleconference between NASCOE and appropriate staff at a later date.

Items from 2017 for follow up


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.

(Reference #1)
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.

NASCOE: The COC has the authority for FSFL, but the question is to allow CED’s to have the ability to make the financial analysis. The option is available to designate CED’s to get loan authority for FLP in states now, but if this could be an option for FSFL. You must be delegated loan approval authority at this time to do financial analysis. There are two things: loan approval authority to compete with FLM on a level playing field and do not take authority away from COC. This would allow the microloan program to become more viable. COC would have final approval authority.

Management Response:
This will be deferred to FL and they want to make this a larger issue than just FSFL. They did agree with the recommendation and FL agreed also and were ready to start the process. Currently CED’s can receive loan authority if the SED consents with the need. There are no real extra costs associated with this type of request at this time. NASCOE wants the loan approval authority to do the financial analysis for FSFL loans up to $100,000 with the final approval under the COC authority.

Final Agreement:
The DAFLP agreed to put together a pilot program to give CED’s loan approval authority for the purpose of doing financial analysis for FSFL to include micro loans. The COC would still have final approval up to $100,000.00 for all FSFL loans.

Final Agreement from 2017 Negotiations:
“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. “

NASCOE Response: What is the status?

DAFP: Nothing has been done at this point but will be added to the radar to be done.

DALP: Has been discussing this for FP and will be getting together in the next few months to put a plan together. The will reviewing the FLOT training to determine what portions of the training that will be utilized. The will have to decide whether this will be expanded to the Micro loan program. Finding trainers for the program will be a challenge. Meeting with FP in the next 3-4 weeks to put together a more formalized approach for the training.

ITEM 12 – Including the NASCOE New Hire Packet Part of Exhibit 6 in 28-PM

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.

27-PM and 28-PM are in process of revision, they have no problem adding the form FSA-444 to the checklist. They could provide links or information to employee associations in the informational packet. This would be especially helpful if the packets were done electronically. NASCOE accepts this response.

HRD: Handbook 28-PM is in the process of being re-written, and this item will be addressed in the handbook revision.

NASCOE Response: What is the status of this handbook?

28-PM revision will start after 27-PM is released. 27-PM is in the final review process.

Items to Follow-up from 2016

The following items were addressed during the 2017 negotiation session. Both items were addressed and agreed upon pending the release of 27-PM revision. Please provide the status of the 27-PM revised handbook.

Handbook 27-PM has a complete revision which is in the final review stage. We would anticipate this handbook being issued by this summer.


“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.

Management will agree to having the associations also be part of the shared management situation and having COC involvement. There will be an amendment to 27 PM to include such reference. NASCOE accepts this response.

HRD: Handbook 27-PM has a complete revision which is in the final review stage. We would anticipate this handbook being issued by this summer.



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.

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.

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.

Accepts this response.

HRD: Handbook 27-PM has a complete revision which is in the final review stage. We would anticipate this handbook being issued by this summer.

Items to Follow-up from 2015


Management has an aspiring leadership program for Grade 9 employees but no such program for CO-7 employees. We have many Program Technicians that have leadership potential and need a vehicle to develop leadership skills making them more attractive to promotion opportunities.

NASCOE position:
NASCOE supports an aspiring leadership program for CO program technicians that will provide an opportunity to develop leadership skills and open the door for more opportunities in our agency. NASCOE proposes a national task force to develop an aspiring leadership program that might encompass one or two years of leadership development for program technicians.

Regarding an Aspiring Leaders Program for PTs, LEDB welcomes a work group with representation from NASCOE, which would explore what the program would look like, from a nonmonetary perspective. Please provide LEDB with NASCOE contacts consisting of members interested in following through with this idea.

NASCOE will provide names of 6-8 employees to work on this group (CED’s and PT’s, one PT from each area and balance CED’s) within 30 days.

This was agreed to and NASCOE was informed that a contractor had been hired a couple of years ago. Barbara Boyd informed NASCOE that the contractor was not meeting expectations and would have to be replaced. NASCOE would like a status update on the item agreed upon in 2015.

The first phase of the PT Leadership program was completed in FY 2015-2016. In FY 2017, there was no funding available to hire contractors to complete this training program. In FY 2018, HRD hired DAI Solutions to carry out the final curriculum for Phase 2 of the PT Leadership program, which includes a train-the-trainer aspect. This contract is currently in progress under the auspices of Theresa Martin and Linda Treese, DAFO. HRD has received positive feedback from both contractors and DAFO that the program planning is moving along as planned and is on time. The PT Leadership Program is scheduled to be completed and ready to implement, by September 30, 2018.

DAFO: Leadership Excellence for Program Technicians will be completed in September 2018, and ready to roll out in FY 2019. The course is a nine month process with 2 virtual and 3 live training sessions. The purpose of the course is to help PT’s prepare to advance their career paths or become a better leader in place. The course will be an application and selection process, similar to the Graduate School Aspiring Leader course.


Several items agreed to in the FSA/NASCOE Shared Management Agreement, Exhibit 8, in 27 PM are currently not being followed by some State Offices.

“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 requests that SED’s be reminded of applicable handbook procedure. SED’s are to consult in pre-decisional format before the establishment of a shared management operation.

In a permanent shared management operation, “one Program Technician (PT) position in the headquarters office and each full-time sub-office shall be graded one level higher than their normal grade up to a CO-8, if the PT is responsible for all the activities in the office when the CED is absent, and the CED is absent at least 40 percent of the time.” At present, many STO’s are not following this procedure.

NASCOE Position:
NASCOE requests that SED’s be reminded of applicable handbook procedure. STO’s and CED’s should follow procedure by grading applicable employees one level higher than their normal grade.

“For temporary shared management operations expected to last more than 30 days, upgrades for CED’s and lead PT’s shall be on the beginning of the first pay period following the effective date of the shared management operation. CED’s and lead PT’s in current temporary shared management operations where the arrangement has be effective for more than 30 days shall be immediately upgraded according to this agreement.” At present, many STO’s are not following this procedure.

NASCOE Position:
NASCOE requests that SED’s be reminded of applicable handbook procedure. STO’s and CED’s should follow procedure by grading applicable employees one level higher than their normal grade.

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

NASCOE Position:
NASCOE requests that SED’s be reminded of applicable handbook procedure. Procedure should be followed in instances where shared management operations exceed 120 days by SED’s meeting with COC’s to “work out a permanent solution”.

The challenge of shared management for CED’s and PT’s is often overwhelming. CED’s are required to handle a double workload and with the CED out of the office, responsibility falls on PT’s to handle management issues for which they have not been trained or compensated. To date, little or no resources are available to assist CED’s and PT’s operating in a shared management working environment.

NASCOE Position:
NASCOE requests that a national task force be assembled to develop resources and tools for CED’s and PT’s geared specifically for shared management. Information gathered by the task force should include input from round table discussions between employees to share ideas and problem solving. NASCOE requests that by May 30th, a shared management task-force be appointed and subsequent framework be developed to guide the task-force. Improving shared management is also expected to increase positive feedback on future Employee Viewpoint Surveys (EVS).

DAFO will remind States of the requirements in the handbook related to establishment of temporary or permanent shared management operations. Note: DAFO always asks if the State consultation with the NASCOE affiliate has occurred when notified of a shared management proposal.

Please note that upgrades are not always appropriate but DAFO agrees that when they are appropriate then they should be implemented. CED’s must meet the provision for the higher classification, and an upgrade for a lead PT is appropriate only IF they are delegated to perform the CED’s duties during the CED’s absence when the CED is absence at least 40% of the time. If the CEDs retain control and handle much of their duties remotely (work assignments, program or payments approvals, leave approvals, etc.), then the requirements for a lead PT position is not met. That determination on the delegation of the duties is made locally; the national policy and procedures provide the option when warranted.

If the policies and procedures are not being followed please provide the specifics so that DAFO can address it with the applicable SEDs.

DAFO does not believe a taskforce is required to develop resources and tools for CEDs and PTs for shared management but we do agree that a tool kit to provide State Offices and applicable CEDs and PTs with shared management best practices could be helpful to all involved. DAFO will solicit best practices and develop a method to provide access to this information.

Management agrees to encourage states to work with NASCOE to do some more education with state presidents on consulting for shared management proposals and management will do more education on using these positions.

Grade 8 positions: Management agrees with NASCOE on this issue Will include language of lead PT’s in check sheet for these combinations

Temporary Shared Management: NASCOE will inform management of any unofficial shared management situations.

Workload problems with shared management: Management will put together a virtual workgroup. Management will work with NASCOE on development of this group.

HRD will continue to work with DAFO to support any needs they may have with this request.

Shared management training: The task force was stopped until we had SED’s on board and the creation of FPAC it has been slowed down however the intent to start the task force back up and continue the process. DAFO agrees to continue with the Shared Management task force. In 60 days DAFP will come up with a timeline for the task force.

NASCOE News Flash: Meetings with FSA Management July 8-11, 2018

Dennis Ray, NASCOE PresidentNASCOE Vice President Brandon Wilson and I traveled to Washington, DC July 8-11, 2018 to meet with management. The purpose of the trip was to complete a holdover negotiation item from our April meeting, consult on several items that had been submitted by members during the negotiation process and to get an update on the workload tool and staffing model. We had three full days of meetings and want to thank Administrator Fordyce and his leadership team for their open doors and the willingness to meet and discuss items of concern. I will not have enough space in this article to fully discuss every topic we worked on during the trip. I will however, try to highlight as much as we can.

We were able to meet with Administrator Fordyce on a couple of occasions. The first meeting was with DAFO staff members, Acting Associate Administrator Peterson and contractors who were working on the staffing model and workload tool. This meeting was designed to give NASCOE leadership a deeper look into the Staffing Model, Optimally Productive Office (OPO) Model and the workload analytics which are used to fuel both models. We were also shown how the SED’s can use the various resources contained in the tool to analyze their state as they and their leadership teams determine where staffing in most needed. NASCOE membership will have an opportunity during the general session on Thursday of the National Convention to see a presentation provided by DAFO on the Staffing Model and Optimally Productive Office.

The second meeting with Administrator Fordyce and his team focused more on the concerns that NASCOE has heard from membership. These concerns include the lack of workload/staffing information shared by some states, an update on hiring and staffing, clarification on backfilling internal hires and the upcoming farm bill. When asked about the Staffing Model and OPO being available for all employees to see, Mr. Fordyce explained there are future enhancement planned and until that is completed, the SED’s have been asked to not share the tool itself. However, it should be noted that SED’s are not restricted in discussing and sharing FY18 ceilings and the workload analytics with all employees. State associations are encouraged to work with their SED about the availability of the data.

While we were in town, the Administrator and his senior staff were meeting in preparation of the next release of hiring, which will include backfilling vacancies created by an internal hire. We also discussed the money that was designated in the omnibus appropriation for hiring up to 200 FLOTS. That money was earmarked for FY18 and FY19 and any money not spent by the end of FY-19 will be forfeited by the agency. We also discussed the upcoming farm bill and comparisons between the house and senate versions.

There were many consultation items including revising data collection forms, revising and creating reports, requesting training and updating software. NASCOE met with several people representing several divisions on these consultation items. We also met with the Office of External Affairs to negotiate the remaining item from the 2018 negotiation session. These were productive meetings and we will try to give updates in future communications as these items progress to resolution.

I would like to close this update with some final comments about the 2018 National Convention coming up in Sioux Falls, SD. We have a tremendous agenda planned for you with attendance by Undersecretary Northey, Administrator Fordyce, Acting Associate Administrator Peterson, Acting DAFP Brad Karmen, Acting DAFO Linda Treese, FPAC CIO Darren Ash, FPAC Business Center Chief of Staff Terri Meighan and DAFO nominee Peggy Browne. I know that the time until the convention is short, so I hope you have already made your plans. The South Dakota Association has worked tirelessly to make this an experience not to miss. Hope to see you there.

Respectfully submitted,
Dennis Ray
NASCOE President

Link to Printable Version

NASCOE News Flash: Hiring Plan and Workload Tool Presentation

Dennis Ray, NASCOE PresidentIf you have been following our NASCOE updates, you know that the hiring plan for FSA to bring on over 1,039 FTE’s was approved a few weeks ago. Recently, 400 of the 1,039 were allocated to the states and most, if not all, will have been advertised by the time you read this update. An additional 400 are scheduled to be hired in August and the balance in September and October. These hires are in addition to the 150 approved in February and the 175 temporaries that were allocated to states. It is important to note that the 1,039 FTE’s include positions at all levels of FSA, not just the county level. NASCOE welcomes and supports the hiring of permanent employees.

State Executive Directors were recently given their state ceiling numbers for FY-18. National ceiling numbers are driven by budget and allocations. NASCOE has been advocating for a workload tool ever since 126 offices were closed without any consideration to workload during the last round of office closures. For the past few years FSA has had a working group develop a workload tool and staffing model. NASCOE requested representation on that working group and NASCOE, along with the other employee associations, have been part of that process. While the tool developed by the working group will never be perfect, it is the closest method of determining workload that we have seen since we stopped doing work measurement.

The FY-18 staffing numbers are the first to be allocated using the new staffing tool. As mentioned earlier, the budget sets the number of employees we can have on board. The staffing tool is used to determine where those employees are needed. The workload tool counts metrics in 25 programs and the corresponding time recorded in Activity Recording System is used to calculate processing rates that can identify efficiencies or inefficiencies. These processing rates are then used to identify where staffing is needed. Even though the workload tool demonstrates a need for increased staffing, there was an overall reduction in fiscal year 2018 ceilings due to the amount of funding to FSA for salaries and expenses. The reduction in ceilings due to the decreased funding was distributed among the states according to analytics suggested by the staffing model.

Workload can fluctuate from year to year based on the programs that are enacted in the farm bill. Due to this fluctuation, we have seen some changes in the approved staffing levels for several states. Since there is an overall lower ceiling in FY-18 those changes have been amplified in some states. NASCOE has advocated and will continue to advocate that the workload data should be transparent and available to the county level so that FSA employees in the field can see how and why decisions are made.

NASCOE is aware that some states have taken a significant hit on staffing levels based on the changing workload data and the staffing model. We also know that due to the changing workload and staffing model other states staffing levels have increased. It is also our understanding that if unrestricted by budget the workload tool shows the need for more employees than what the budgeted FY-18 ceiling allows.

In August, at the National Convention, management will provide a demonstration of the workload tool and staffing model during a presentation to members at the general assembly. NASCOE hopes membership will take this opportunity to learn about the tool and the results it produces. As we move forward, NASCOE will keep telling our story to members of Congress and working with our legislative consultant to secure the highest level of appropriations that we can for County Offices.

Respectfully submitted,
Dennis Ray
NASCOE President