Friday, July 20, 2007

Pity the Poor Bureaucrat

Assume for the moment that the payment limitation rules in the current House bill pass and become law. (See pages 15 on of the Managers amendment.) Why should we pity the bureaucrats who have to administer them?
  • First of all, I don't think there's many people in DC in FSA who were there for the last major change of payment limitation in 1985--in 22 years most people have moved on.
  • Second, the provisions of the bill are longer, and probably more complex, than the 1985 Act.
  • Third, farmers have gotten used to much higher levels of payments than they were in 1985. It took a couple years for some farmers to figure out how much money they were leaving on the table beginning in 1983-5. If you see that you're leaving $10,000, then it starts making sense to call friends and strangers, anyone who may know what's going on and have an insight into what you should do or have the leverage to affect the way the rules are written.
  • Fourth, we're in a more legalistic environment today than in 1985, both in terms of rulemaking and in the application of the rules to individual farmers.
  • Finally, 1985 was pre-Internet, which makes all the difference.
What will happen? On one side there's the problem of automating the rules (I start with that because it's closer to my heart--I always tried to steer clear of payment limitation). That's major--if FSA is to get payments made correctly based on the paperwork submitted, there will be some major changes to files and software.

On the other side, the rulemaking process will be under intense scrutiny from everyone--the Hill, the press, the farmers, and the interest groups suspicious that FSA will be too friendly to farmers. In the midst of this, the poor bureaucrat has to write regulations and directives, set up training sessions for field offices, provide good information to everyone. The likelihood is, based on 1985 experience, management will change its mind a few times, meaning that the poor bureaucrat will end up misinforming farmers, press, field offices and get everyone mad.

In 1985 there were fewer channels of communication that operated slower than today. Now we have the Internet, which has shown its ability to spread rumors and misinformation. So if everything runs merely twice as fast today, the poor bureaucrats in FSA have to be twice as good as their 1985 predecessors.

Pity, have pity.

No comments: