FSA Reorganization

I found two new notices from FSA interesting:

One was a reorganization into Safety Net and Program Delivery Divisions.  If I understand it correctly it splits program policy and automation into separate organizations.  The question of the best organization has been an issue ever since the original System/36 automation of county offices in the mid 1980's.  At different times and in different areas we've had policy and automation united in one person, or the responsibility in one section but with different people specializing in each, or in separate sections within the division.

When Jerry Sitter was division director in the mid 80's he split out a branch to handle automation under Mike McCann, with the policy in other branches.  In a way this followed the personnel--the policy types were mostly established DC specialists, people who'd come in from the field before the System 36 arrived.  The automation types were the early "SCOAPers", mostly program assistaants brought in under 2-year temporary appointments (which turned into permanent slots as time passed).  It also, IMHO, reflected an attitude among management that automation was a subject they didn't really understand or feel comfortable with, so it was best housed in its own shop.  There was a similar setup in the commodity loan area.

I always had my reservation with that setup--my argument was that a program specialist needed to know the whole span of operations.  Just as in the pre-automation days we'd work with MSD to get forms designed and printed, procedures written, cleared and distributed, regulations written  and published,  automation was just another area to learn and manage.  Looking back, I was reflecting my own belief in my abilities to do the whole scope of activities, and I was probably unrealistic.  But I still think there's a kernel of truth there--sometimes policy issues and automation issues become one and the same.

Which leads me to the second notice: on a workaround to handle multi-county producers, which seems to me to be an example.  Here the history of ASCS/FSA going back to New Deal days has been to work with producers on a county by county basis, unlike FmHA which tried to consider all of a producer's assets and liabilities when making a loan.  FSA has gradually been forced to move away from a county basis with need to enforce payment limitation.  My point is that a policy decision to apply rules on a producer basis, as with loans, and to allow producers one-stop shopping at one office, or at one web page, as with this notice, has big implications for automation, both in the design of the database and in the operation of the software.