GAO looked at how FSA is enforcing payment limitation rules. The summary conclusion seems to be "improving, but with a ways to go". I ran across this paragraph, which reminded me how Mike Campbell in the Sherman county FSA office in 1992/3 wanted us to make the process so simple it would put consultants out of business. We failed to do it, and so have the people now in FSA (and Congress, especially Congress):
Several FSA officials said that large farming operations receive assistance from consulting firms to help them comply with active personal management criteria. For example, a state office official said the documentation that consulting firms prepare for farming operations is consistently sufficient to support a determination of active personal management.
https://www.gao.gov/assets/720/710470.pdf
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