CFAP--A Tip of the Hat

I remember the pains of trying to implement new legislation on a rush basis.  I could tell, and have told, stories about the experience. 

One thing I never experienced was trying to implement new legislation while working from home during a pandemic.  A tip of my hat to those working in DC and the field who are trying to navigate that morass.  (Post inspired by Brent Orr's picture of the training room in the South Building from which they did online training of the field on CFAP.)

The Impact of Technology on FSA Communications

I posted previously on my discovery of the FDA Facebook group, which is a new means of communication across the organization.  Some further thoughts:

When I joined ASCS my impression was it was hierarchical organization.  Questions would come from the county through the district director to the state office to the area director to the applicable program specialist in the program division.  At least that was the theory. Over time I discovered the role of the county and state committees, which was contested.  In theory they were in charge of applying policy decisions to their counties and states.  (This is what they had been in the 1930's.) In reality it seemed to me that they often lacked the expertise and always lacked the day-to-day operational awareness really to fulfill that role.  As a result over the years their role had diminished, but smart county and state executive directors would manage their relationships with their committees.

The role of the district director was also evolving, as symbolized by the change in terminology from "farmer fieldman" to "district director".  My impression is that these positions were often quite political, with significant turnover when the political party in charge changed.  As a cynic my impression was the quality of the DD's varied, meaning they sometimes were obstacles and were bypassed by the more knowledgeable CED's.

When ASCS started installing System/36's in county offices, it put a lot of strain on the old systems.  First and foremost, nobody involved in the new technology had experience with it, so a simple question that a program assistant might take to a more senior person, or the CED, wouldn't receive an answer. The time required to move a question from county through state to DC (KCMO)and finding someone with an answer and then getting it back down the chain was simply too long.

Time and experience solved some of the problems as we all learned by trial and error. I suspect, but can't prove, that informal communication networks expanded.  People learned who in the state was more capable with the technology. 

FSA Now and Then

I signed up for Facebook years ago, but rather quickly decided I wouldn't make much use of it.

But, the other day I thought to search for FSA and found there's a big and active FSA group there.  I was approved to join, so I'm occasionally starting to review the posts (whatever the Facebook term is for it).

Apparently most (all?) FSA offices are operating behind locked doors, so producer contact is by phone and email.  Looks to be variation in the rules applied and the infrastructure being supplied.  (IMHO that's an old story, inevitable in the US but that's no consolation to those getting the short end of the stick.) 

Reading some of the comments of the toll being experienced by the staff reminded me of the field's experiences with the 1983 PIK program and then the pain of moving to the System/36.  This generation will have their own war stories with which to bore their young successors.

CFAP Parameters

From Sentator Hoeven's website:

"Direct Assistance for Farmers and Ranchers 

USDA will provide $16 billion in direct payments to farmers and ranchers including:

• $9.6 billion for the livestock industry
• $5.1 billion for cattle
• $2.9 billion for dairy
• $1.6 billion for hogs
• $3.9 billion for row crop producers
• $2.1 billion for specialty crops producers
• $500 million for others crops

Producers will receive a single payment determined using two calculations:

• Price losses that occurred January 1-April 15, 2020. Producers will be compensated for 85% of price loss during that period.
• Second part of the payment will be expected losses from April 15 through the next two quarters, and will cover 30% of expected losses.

The payment limit is $125,000 per commodity with an overall limit of $250,000 per individual or entity. Qualified commodities must have experienced a 5% price decrease between January and April. 

USDA is expediting the rule making process for the direct payment program and expects to begin sign-up for the new program in early May and to get payments out to producers by the end of May or early June. "

Sounds as if this part of the program will be FSA's hot potato.

What's in the Covid-19 Bill for FSA?

From Politico:

Special deal: The stimulus provides $9.5 billion in emergency aid for the agriculture industry and replenishes $14 billion in spending authority to the Agriculture Department’s Commodity Credit Corp., a Depression-era financial institution set up to stabilize the farm economy — the same USDA agency sending trade bailout payments to farmers. Producers ranging from dairy farmers and cattle ranchers to fresh fruit and vegetable growers are eligible.

How they got it: Livestock groups have been leaning on lawmakers for weeks to pony up funds for producers who have seen commodity prices plummet since January. Western senators including John Hoeven (R-N.D.), who chairs the Appropriations panel that oversees agricultural spending, made sure those provisions were part of the stimulus plan from the get-go. Then, top Democrats like Michigan Sen. Debbie Stabenow, ranking member on the Agriculture Committee, pushed to include language making specialty crop farmers — like Michigan’s tart cherry growers — eligible for the emergency aid.

Parable of the Forms

As an ex-bureaucrat I'm always interested in forms.  Here's the link to an academic paper entitled "The Parable of the Forms". The author is trying, I think, to address some issues of legal procedure by translating them into the language of a university bureaucracy.  I was struck by some parallels in USDA history.

Very briefly, when the New Deal created the farm programs in the 1930's it seems each field crop had its own program and, sometimes, its own bureaucracy.  In addition, there were siloed initiatives for conservation, housing, rural regeneration etc.

Over the years there were a number of reorganizations of these basic elements.  Also, over the years and underway when I came on board was a drive to generalize the crop programs.  When I started we had wheat and feed grains, upland cotton, ELS cotton, producer rice, and farm rice. Over time the programs were changed so by the time I retired we just had "program crops" and "ELS cotton", but then we'd added oilseeds, and a number of other categories.

The paper's author argues there's an ebb and flow to the forms issue, and to his legal issue: sometimes focused on the differences in situations and sometimes on the commonalities.  Perhaps there's a similar dynamic with programs.  Or perhaps I'm full of it.

How To Do Big IT Projects

FCW has a post on how to do big IT projects, referring back to a study of 5 years ago.    There are four keys listed, but I can boil it down to one:

• Get the right bigshot personally involved from start to finish and be sure she has skin in the game, as in will lose her job if the project fails.

Early on I was involved in a project to bring computers to county administrative actions (payroll and related services).  The big shot then was the deputy administrator, management (Felber) who brought people together from DASCO and DAM to do the project.

In the middle of my career I was involved with implementing the Payment-in-Kind program in 1983.  The big shot then was Seeley Lodwick, who was the Under Secretary (following service in a previous administration as exec assistant to the Administrator, ASCS)  He pulled together lawyers and program people and kept on us until it was off the ground.  

By contrast other projects failed because either they lacked bigshot involvement and/or the bigshots moved on with a change of administration.

The Obama administration did one thing right--put Biden in charge of the stimulus package implementation and one thing wrong--ineffective leadership in rollout of Obamacare.

Hemp Problems Again and FSA/NASS?

The Rural Blog has this post.

I wonder if NASS and FSA are now taking acreage reports for hemp. A claim of more than a half million acres licensed for hemp means it's one of the mid-major crops.

And has it been added to the NAP list of crops?

Renting Office Space from Members of Congress

I've a vague memory that back in the early 70's there was a flap about Agricultural Stabilization and Conservation Service county offices leasing office space from members of Congress.

Possibly it was an issue raised by Rep. Findlay of IL, who didn't much like anything that ASCS did, but I won't swear to that.

Anyhow, memory suggests that ASD (Administrative Services Division) issued notices to do a survey of how many instances of this we had and requiring the leases to end.  I don't remember that there was a statutory basis for the prohibition, just a policy one. 

I've done a quick look at the USDA manual on property and didn't find anything.  Apparently FSA has determined not to put their handbooks covering administration on the website so I haven't checked that.

Anyhow, I thought the issue of renting office space is a good parallel with the issue of renting hotel rooms from President Trump.

Farmers Working with FSA and NRCS

Agriculture.com talks about the traffic to FSA (and NRCS) offices, listing six trips required.  But I found these reported farmer interactions on the Agriculture.com talk forum interesting, with my comments in bold:

“There is a visit to the NRCS division to apply for cover crop cost share and then the one later to submit seed receipts for payment. [Can't mail them?}Plus, if you live in a county that doesn’t have an NRCS office, as I do, and you rent farms, you may get to make trips to several different counties to get all of them signed up,” the southern Iowa farmer posted. [NRCS hasn't enabled consolidation as in the last bit below?]
Hobbyfarmer adds, “Got a call literally 10 minutes ago from an FSA employee. He forgot to have me sign some MFP papers. They want me to have to drive 42 miles each way to finish it up, so they can pay me, maybe, sometime in next two weeks.” [Thought FSA had authorized electronic signatures a long time ago.  Maybe employees are still in the hard copy world?]

“Usually, I make two trips per year – one in late winter and another after planting. But with this MFP thing, there was an extra one in late fall and another one yesterday,”  [Wonder why he got away with two before, not the six above?}Rickgthf says.
Rickgthf adds, “I had all my business for the different counties consolidated to one office, so there’s no running around to different counties at all.” [Hmm--that should be great--wonder why NRCS hasn't done the same?]

AFIDA Reports and Foreign Ownership of Agricultural Land

I posted earlier this year on the issue of foreigners buying agricultural land.  At that time I found an obsolete link to FSA AFIDA reports (last updated in 2012).

The other day I saw a hysterical tweet on the same subject, with Tamar Haspel (a good writer on food issues) countering.

This morning for no reason I decided to Google AFIDA and found the active list of FSA AFIDA reports. The last report on this one is for 2016.

It starts with:

Foreign individuals and entities reported holding an interest in 28.3 million acres of U.S. agricultural land as of December 31, 2016. This is 2.2 percent of all privately held U.S. agricultural land and approximately 1 percent of all land in the United States (see fig. 1 for State-level detail).

A Thought for FSA Personnel

Chris Clayton of Progressive Farmer has tweeted asking USDA for answers on prevented planting.

I  expressed doubts as to whether leadership could make fast, good decisions.  That's not necessarily a criticism of Sec. Perdue and his team--I wouldn't have had great confidence in the capability of any of the leadership teams during my time at agriculture.  It seems to me the prevented planting issue has spun up very quickly, more quickly than I can remember situations in the past.  With MFP1 there was a longish lead up, during which the analysis people could get their acts together and the implementation people in DC and KC could get prepared.  MFP2 is different, although to the extent it covers 2019 production there won't be that much impact.  Where it's key is on the plant/no plant/change crop decision.(

Another factor is FSA doesn't have recent experience with prevented planting.  Back in my early days in the agency the disaster program included PP. Then, as FSA  was phased out of the disaster business in favor of crop insurance, we lost that institutional memory.  The inclusion of PP in crop insurance policies means the implementation process is going to be more complicated than it was in the old days.)

(Can't resist noting that the combination of Trump's trade war and flooding has undercut the idea that crop insurance could mean the end of ad hoc disaster programs.)

Bottom line: FSA personnel in DC trying to implement whatever decisions are made are having a bad few weeks.  FSA personnel in the field are in worse shape: face to face with farmers desperate for information to make their decisions and lacking the direction from DC.   

My sympathy for both groups, but particularly the field.

NPR and Furriners Buying Our Land

NPR had a piece on foreigners buying up agricultural land.  It's not clear where the correspondent's data comes from, but I'd suspect it's reports under the Agricultural Foreign Investment Disclosure Act..

I remember when the law was enacted in 1978.  That was when foreigners were rolling in dollars, partly because OPEC had successfully raised the price of oil, Nixon had taken us off the gold standard, and Japan was starting to sell cars (bought my first Toyota in that year) to us.  Those dollars were being used to buy land, causing concerns in the U.S.  That resulted in the act, requiring buyers to report their ownership to ASCS/FSA.

The regulations to implement the act were always questionable--basically it was a stand-alone requirement to report in its own little silo, with no interface to the rest of ASCS functions.  That meant there was no real enforcement, except the good will of the buyers and the conscientiousness of the county office.  But we had no way to ensure the buyers knew the requirement.. And we had no way to get data on sales by foreign buyers.

As a result, when someone looked at the AFIDA database in 2014, they found problems.  I'd have my doubts that it's been fixed since.

In the back of my mind I wanted to integrate AFIDA into the farm records system as we re-engineered it from the System/36 to the new platform.  But it never happened, never became important enough to devote the people to it, and I got fed up and retired.  I strongly suspect in the 20 years since no one involved in the redesign of FSA operations was conscious enough of AFIDA to include it in the redesign.  Such is the fate of silos; they don't have enough significance to attract attention.

I did a search on this blog to see if I'd written on AFIDA before.  I did a couple times in 2008, but using the FSA label.  One post did refer to FSA's AFIDA reports.  They're available here. But the web page hasn'te been updated for 5 years, a fact which supports my overall take on the subject.

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.

FSA Employees Turn Out To Be Essential?

USDA has decided to recall 9500 FSA employees beginning Jan 24 to provide services.  Chris Clayton reported this on twitter and here's an article.

Apparently all field offices will open (not clear on DC and KCMO) and will handle most, but not all, program activities, including MFP applications, the deadline for which has been extended. 

More on FSA and Shutdown

Politico has a piece more focused on farm loans than farm payments.

FSA Goes Back to Work?

Only in part.  Here's the Politico piece on Perdue's telling 2,500 employees to return on Jan 17, 18, and 22.

And here's the USDA press release.

And here's the list of offices which will open.  (My impression is that a smaller share of offices in the Northeast are being reopened than in the rest of the country.  They may have given preference to locations with heavy MFP activity?)

I wonder how they determined the employees to call back?  All CED's of offices they're reopening?  Might not be the best employees to have. 

I wonder what happens after Monday?

Will be interesting to see how this works out.

And here's a NASCOE explainer from yesterday.  (Thumbs up to NASCOE for the post.)

FSA Offices Closed; NRCS Offices Open

That's the word.  For NRCS here.

BTW, neither agency has updated its "farm bill" page to reflect the signing of the 2018 farm bill.

Farm Production and Conservation (FPAC) Business Center

Hadn't seen this before this public notice of redelegations of authority by the secretary of USDA.  Turns out I'm way way late to the game.

This is what is included in the 2019FY budget for the center.

This is the explanation of the center:

"The Farm Production and Conservation (FPAC) Business Center is a centralized operations office within the FPAC mission area and headed by the Chief Operating Officer (COO), who is also the Executive Vice President of the Commodity Credit Corporation (CCC). The FPAC Business Center is responsible for financial management, budgeting, human resources, information technology, acquisitions/procurement, customer experience, internal controls, risk management, strategic and annual planning, and other similar activities for the FPAC mission area and its component agencies, including the Farm Service Agency (FSA), the Natural Resources Conservation Service (NRCS), and the Risk Management Agency (RMA). The FPAC Business Center ensures that systems, policies, procedures, and practices are developed that provide a consistent enterprise-wide view to effectively and efficiently deliver programs to FPAC customers, including farmers, ranchers, and forest landowners."

It sounds very much like Sec. Glickman's proposal in the late 1990's, a proposal which was killed in Congress.

According to this article on the creation of FPAC from February Bob Stephenson is the head and the initiation of the center is Oct 1.

One of the complications in implementing this is the mixed legal status of NRCS--it's a federal agency working with the Soil and Water Conservations Districts which are established by state law and get funding from states and which have their own organization to lobby Congress.

Trump Administration Gets Bad Press, a Bit Unfairly

Our president would argue there's no news in my title. But while I'd argue the administration often deserves all the poor publicity it gets, articles in the press today are a bit unfair.

I'm referring to an article in the NYTimes on the progress of payments under Trump's "Market Facilitation Program" of providing payments to producers of commodities whose sale has been impacted by Trump's tariffs. The criticism is partly that FSA has been slow in getting payments out to farmers (and also that the payment rates aren't equitable.)

I'll make my point by citing a blog I follow: Life on a Colorado Farm.  (I recommend it for the great photos and the glimpses into the rhythms of farm life.)  The author reported today they'd just finished corn harvest.  Why is that important?  Corn growers can qualify for MFP payments only if and when they can provide production evidence, like warehouse receipts.  I don't know that they're going to apply for MFP payments (my guess is not), but today is the first day they could have a completed application. 

While it's true grain harvests are winding down, the USDA-NASS graphs show soybean harvests span about 2 months, from mid September when it begins to now, when it's 85-90 percent.  What that time frame could mean is that FSA offices receiving the applications are overwhelmed.