I may comment more later, or I may lose interest, but I am puzzled by one aspect of the report.
OIG says they couldn't audit because of problems with the system, specifically including this point:
"Specifically, we learned that joint ventures without permanent identification numbers were not recorded in FSA’s entity database,..."As they recognize in a footnote, FSA doesn't make payments to such joint ventures, payments are made to the members. That should mean the payments are automatically attributed to members. To me that says it doesn't constitute a weakness in the system and shouldn't be considered a problem in auditing.
FSA's response doesn't point this out.
If I follow correctly, Environmental Working Group has been "attributing" payments for some time now, using the same data as OIG refused to tackle.