FSA and the Last Mile Problem

 Sec. Vilsack is announcing additional programs to aid producers impacted by the pandemic.

My impression of the various programs which have authorized spending in response to the pandemic and its effect is that several of them have had big problems in getting the money out the door.  Some of the programs have struggled to get the money out; others have perhaps been vulnerable to fraud.  

Those are impressions only.  Meanwhile I'm following the FSA employee group on Facebook. I likely suffer from the old-timer's presumption that the newcomers have it easier, but I try to resist that snap judgment.  On the one hand, I'm very impressed by the variety of programs, some directed to people FSA has long served, some directed to new groups, which the counties have had to deal with.  On the other hand I remember PIK in 1983 and particulary the disaster program in 1986 (IIRC) which hit in the midst of the System/36 automation. 

I hope someday somebody, GAO or Congress, does a high level review of the government's operations, their speed, efficiency, and weaknesses.  My expectation and hope is that FSA would do well in such a review, largely because of a long history in dealing with crash programs and, most importantly, the county offices deal directly with the people, a big contrast with most of the rest of government which has to try to operate through state and county government agencies, and/or NGOs.

Is Email Effective?

 It turns out a researcher at Illinois State University did a survey in 2019 of Illinois FSA personnel (CED's, DD's, etc.) which concluded:

The USDA Farm Service Agency replaced paper mailings with GovDelivery electronic communication in order to increase efficiency and reduce costs. This case study presents evidence from one state indicating a perception among local FSA officials that GovDelivery does not allow them to effectively serve their constituents. A gap in reliable rural Internet service and low usage of smartphones in place of rural broadband may contribute to the extremely low open rates for GovDelivery email notifications. Findings suggest that electronic-only communication does not allow the agency to effectively engage with farm owners, operators, and managers.

Boerngen, Maria A. “Efficiencyfectiveness of Paperless Communication from the USDA Farm Service Agency.” Journal of ASFMRA, 2019, pp. 27–32. JSTOR, www.jstor.org/stable/26872597. Accessed 13 July 2021.

FSA Employee Is Credited

Politico has a long piece on FSA loans to black farmers.  It's not full of praise, to say the least.  Not sure whether I'll come back to it, but it does end with this nice bit

What helped Cleaver was a woman in the FSA office who took the time to explain the processes.

“She was like an angel. I had been going through the loan officers and the HBCU [historically Black colleges and universities] that was here and they couldn't get anything done,” he said. “[She] held my hand and she told me everything step by step. She was patient, she was polite.”

I'm sorry Politico doesn't provide email addresses for its reporters so I could compliment Ximena Bustillo for including this.  I think in years of following reporting on FSA and race it's the first time I've seen a compliment published.

Representative Capacity and Data Sharing

 I saw this notice today. I was struck by this paragraph:

In late 2020 and early 2021, shared services were developed to make RepCap data available for use by Farmers.gov and other FSA systems through a Representative Authority for Producers (RAP) service. This means the RepCap data (which is loaded and stored in Business Partner) is now being shared with external FSA systems and in the future will be shared with other agencies. Therefore, it is critical that County Offices ensure that data is still valid and correctly loaded.

I don't remember seeing references to sharing data with farmers.gov or other agencies before.  I'm sure it's failing memory, but data sharing hasn't been very common.  

Rocky Road for Debt Relief for Disadvantaged Farmers

 Another judge, this time in Florida, has issued an injunction against FSA's implementing the debt relief program.  

I wonder if FSA employees are relieved that implementation is delayed, just from the point that their workload will be lighter in the fall and winter than now, and that DC will have more time to prepare regulations, instructions and training packages.

How Is CDC Like USDA/FSA?

 An article in the NY Times mag on CDC, critically assessing it and its role in the overall health care system.  One thing which stood out to me was this:

Around half of the agency’s domestic budget is funneled to the states, but only after passing through a bureaucratic thicket. There are nearly 200 separate line items in the C.D.C.’s budget. Neither the agency’s director nor any state official has the power to consolidate those line items or shift funds among them. “It ends up being extremely fragmented and beholden to different centers and advocacy groups,” says Tom Frieden, who led the C.D.C. during the Obama administration. That lack of flexibility makes it extremely difficult to adapt to the needs of individual states.

It reminds me of USDA/FSA.  Over the years the number of programs and crops covered has grown rapidly, The reason seems similar in both cases: there is a group/organization which feels strongly and has found a representative in Congress to push for coverage.  In the case of a disease/illness, it's patients and their families; in the case of agricultural products it's the growers. In both cases, they're tapping the federal treasury and have no countervailing opponents; it's not like the old days when big business was counterbalanced by big labor.

Our Modern Government at Work

 Just saw this FSA notice.  Its title: Updated Schedule for FAXing CCC-941’s to IRS.

The Farm Service Agency has to check with the IRS to see that program participants have an adjusted gross income (AGI) of less than set amounts.  Because of restrictions on releasing IRS data, FSA has to provide an authorization signed by the participant--the CCC-941 form.   FSA and IRS use fax to transmit and receive the form. 

I don't know enough to comment further, but I will.  It seems to me if IRS can accept 1040s electronically, they ought to be able to accept 941's electronically. Or it seems as if lawyers/Congress could work out a way to bypass the requirement entirely.  

Let's Forgive More FSA Loans

 Al Cross at the Rural Blog reports on a bill which would provide forgiveness of up to $250 K of FSA loans to farmers whose AGI is less than $300K.  They'd have to stay in farming for 2 years after receiving the forgiveness.  See here for text.

It, of course, is a response to the problems white farmers have with the forgiveness in the law.

FSA and American Rescue Plan Act Provisions

 Looks to be a couple provisions of the American Rescue Plan  which impact FSA:

• a provision for paying 120 percent of outstanding indebtedness for loans made or guaranteed by USDA to socially disadvantaged farmers or ranchers.  My guess is it might be easy to administer, assuming FSA records currently record a farmer's status as disadvantaged or not.  The problem will be with those with outstanding loans who aren't disadvantaged, and will yell at the counter clerk  program tech.  Need to have the numbers of the local offices of the Congressional representatives handy.
• the other provision provides $1 billion for things which seem to be outlined in the Sen. Booker and Sen. Warnock "Justice for Black Farmers" bill.  

There is provision for $47.5 million for expenses (which won't all be FSA, but some might be.

FSA Administrator Designate

  Zach Ducheneaux is from South Dakota and a Native American, the first for FSA. USDA announcement.

Gloria Montano Greene is nominated to be Deputy Undersecretary for Farm Production and Conservation.  She has been state executive director for Arizona in the Obama administration, while Ducheneaux isn't shown as having any FSA experience.

I wonder--the Trump Administration reorganized USDA--IIRC they moved NRCS and FSA into the same undersecretary's remit, where it had been FAS and FSA together?  Wonder if Vilsack will go back to the old organization or keep the new.  The establishment of the FPAC Business Center to serve admin functions of NRCS and FSA would argue for keeping the new, but I've no idea of how well that is working nor whether there could be any advantage politically to reorganizing.

Bureaucracy Extremes

Started reading "Midnight at Chernobyl" today.  It's been around the house for a while since we saw the TV series based on it,  but hadn't gotten to it until today.

Then I just got off the Facebook group for current and retired FSA employees (mostly field employees but some DC and retirees). I like to keep up with what's happening there. 

There's a big contrast between the rigid bureaucracy of the Soviet Union and the more free floating discussion of issues and techniques in the Facebook group. I wonder how much of that is American versus Russian and how much is technology enabling exchange of ideas. 

I think it was true in the old days of ASCS that there was pretty good sharing of ideas within a state, and perhaps some across state lines based on personal connections.  Back in the 90's we tried to develop the sharing by having "train the trainer" courses with county people mixed in with the state people.  Having the internet and Facebook now facilitates the exchange even more.  

Multiple Communication Channels--CFAP

 Back in the day I remember catching flak from state specialists when the various agricultural media outlets--magazines and radio--came out with program announcements and details before our procedures from DC had hit them. 

I suspect the problem has become even more complex.  An example:

My twitter feed is announcing a freeze of CFAP:

Biden just froze CFAP aid to farmers program. https://t.co/dOx5Lf6B62

— NYFarmer (@NYFarmer) January 28, 2021

The farmers.gov site has the notice:  

I'm sure the FSA directives system will take a while to catch up. 

A Third CFAP?

 Joe Glauber, former chief economist for USDA, tweets here:

The US farm sector just reported its 4th highest net farm income since 1970 (adjusting for inflation). So why more aid when there are millions out of work? 👇👇👇 https://t.co/HZuW99hyFy

— JoeGlauber--IFPRI (@JoeGlauber1) December 22, 2020

responding to this:

Congress should not give #farmers, who already have numerous safety net programs, more aid. @JoeGlauber1, @dwschanz, and Vince Smith argue congress should aid Americans facing #hunger instead in @thehill. #COVID19 https://t.co/1Ti3ogwWlp

— Philip H🌐xie (@phoxie58) December 22, 2020

Which in turn links to this AEI post.

Over at the Facebook group for FSA employees there was surprise and some consternation at the prospect of doing another round of payments. 

NASCOE has a summary here.

On Enforcing Payment Limitation

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

FSA Flip-Flops on Actively Engaged?

 Rural Blog has a post linking to a Progressive Farmer article on a change in payment limitation regulations published here. The article interprets it as a flip-flop, easing the requirements for payment limitation determinations.  I'm not sure that's right but  I'm 23+ years out of date on these technicalities, if not more, so I'll just quote the meat of the explanation:

After publication of the rule, stakeholders notified FSA of concerns regarding potential non-intended, adverse effects to farming operations comprised solely of family members. In streamlining the definitions for consistency, these revised definitions were inadvertently made applicable to farming operations solely owned by family members. This was not the intent of this rule change, and as revised, the definitions were more restrictive than they needed to be in order to provide intended consistency in the rule. Those more restrictive definitions were not intended to apply to farm operations comprised or owned solely of family members. Therefore, this document restores § 400.601 and the previous the definitions of “active personal management” and “significant contribution” in § 1400.3 that were applicable prior to publication of the final rule on August 24, 2020. The more restrictive definitions described in § 1400.601 apply only to farming operations comprised of non-family members that are subject to a limit in the number of farm managers seeking to qualify for actively engaged in farming based on a contribution of active personal management alone.

 There's a reference to a GAO study as well, which seems to be this.

Justice for Black Farmers Act--First Take

 Successful Farming has a piece discussing this bill, introduced by Sens. Booker, Warren, and Gillibrand. Warren's statement of support is here. The legislative language is here . (I'm not sure the bill has actually been introduced--the draft language doesn't have a number and I can't find it at Congress.gov.) Mother Jones has an article on it.

It includes several reforms and programs, most of which are focused on black farmers (defined as American-born).

The biggest ask is a program to give qualified applicants of up to 160 acres of farmland, representing from $400,000 to $800,000 in value (using Farm Bureau's average farmland value of $4,100) at no cost.

Other provisions seem to oust OGC from civil rights matters, to put additional layer(s) of authority and/or review over the existing civil rights structure and the FSA county committees, and call for an extensive research and statistical work by ERS and NASS. In addition to the provisions on black farmers there are changes relating to packers and stockyards, conservation, and local markets.

There's an "Oversight Board" focused on current and future USDA/FSA operations and an "Equity Commission" focused on historical and structural issues to do a report within 2 years, and a Civil Rights Ombudsman.

I'm still trying to understand everything in this.  Some things which struck me:

• while I don't see anything about the composition of the Oversight Board, the Equity Commission is specified in detail--black farmers, NGO members, and HBCU faculty.
• there's a discrepancy--the title is for "Black Farmers" but some of the language is "socially disadvantaged".
• Alcorn State's Policy Center is written into the bill.  It's headed by Eloris Spight, who seems to have moved from the HR side at NRC to policy before moving to the education world in 2014.

For now, that's what I have. 

Women Advance? Some Evidence

It's interesting to follow the posts on the FSA Facebook Group for a number of reasons.

Sometimes posters in the group ask for help on various issues, questions of policy, software, approaches to handling service during the pandemic. Sometimes it's just sharing news, funny stories, etc.

In the last week there was a work issue which seems to have been solved by some software developed by a county employee, which a number of people asked for.  Back in the day that sort of thing happened as well.  A couple difference from 30-40 years ago:

•  the existence of the Facebook group.  I don't think we had a formal sharing site before the SCOAP QandA's in the late 80's and Jeff Kerby's BBS around 1990 or so. There's more lateral communication these days as opposed to running things up and down the ladder of the hierarchy.
• the gender of the person creating the solution. In the old days the creators tended to be males (I'm thinking of doing programs for programmable calculators around 1980 and queries for the System/36.  I might be wrong on this--it might be I just noticed or remember the men more and/or the female creators were operating in a more informal environment.

I think both differences are good. 

CFAP II Coming, and Here

 From Progressive Farmer, a report from Trump's rally saying that CFAP II will be announced next week at $13 billion.

Just went to Facebook FSA employees group and found this was announced.  Don't know why the amount went up $1 billion in a day.

Loren Becker Is Happy

As I've said, I've been lurking in the FSA Facebook group, watching the exchanges of hints, encouragements, etc. as the field offices struggle through CFAP (along with their regular work, all working from home or with restricted access to the offices].

One facet of the implementation effort is the use of Excel worksheets.  Back in the day, Loren Becker worked in KCMO. He became very proficient in Lotus 1-2-3, the dominant spreadsheet software of the day, and strongly urged us to use Lotus to develop test data, modeling what the results of System/36 software programs should be.  FSA isn't doing exactly that, but Loren would be happy, maybe is happy but I don't know, to see the extensive use of spreadsheets.

Watching the Messy Process of Implementation in the Field

I'm enjoying watching the FSA field people administering the CFAP by logging into the FSA Facebook Group. 

I have to remember I'm lurking, and no longer have the knowledge nor authority to comment on anything.  Much of the discussions seem familiar from times gone by but what's more visible (probably not new but it wasn't visible before) is the networking among the program technicians as they're officially called today.  I wonder how many of the State and DC specialists are auditing this group?

NASCOE has had a system of "program" recommendations where they pass problems and suggestions from the field on to the DC specialists for possible resolution. It seems to take a while to make the circuit.  Some of the problems raised in the Facebook group are resolvable there--just a lateral flow of knowledge and tips.  Some of the problems may be tackled by people with special knowledge, particularly of the software. Since the group has maybe 1,000 members, and the field offices probably have 7K+ employees plus temps I wonder whether the lateral flow of info is reaching everyone it should.