CCC-910 for Market Facilitation Program

FSA now has the form approved by OMB and up and operational on its website. (Or, actually on the farmers.gov website.)

Since I've started off nitpicking the program and it's a convenient subject to blog about, some more comments. (And there aren't many people left at FSA from my time there, which is a consideration--don't want to be unfair to friends, but unfair to strangers is another matter.)

I wonder why the producer's certification only notes that failure to certify production accurately will result in loss of benefits.  I'm too lazy to check, but didn't FSA used to note penalties for false certification--18 U.S.C. something or other? I also wonder why there's no language either tying the production to the producer's farm(s) or certifying that it is the total production from all farms in which the producer has an interest.  Don't know if there's an appendix to this contract.  Nor do I know the significance of the "adjusted production" column.

I'm a bit disappointed that FSA asks for a producer's fax number, but not her email address. 

I note with some bemusement that the nondiscrimination statement has been modified since my time--I've bolded the changes.

"In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident."

I note the farmers.gov website promises the ability to file electronically.  Maybe I've found another area to nitpick.