United States 

Department of 

Agriculture

Federal Crop

Insurance

Corporation

FCIC-14060 (11-2023)

GOOD FARMING 

PRACTICE

DETERMINATION

STANDARDS 

HANDBOOK

2024 and Succeeding Crop Years
THIS PAGE IS INTENTIONALLY LEFT BLANK
November 2023 FCIC-14060 TP 1 

UNITED STATES DEPARTMENT OF AGRICULTURE

FARM PRODUCTION AND CONSERVATION

RISK MANAGEMENT AGENCY

TITLE: GOOD FARMING PRACTICE 

DETERMINATION STANDARDS HANDBOOK

NUMBER: FCIC – 14060

OPI: RISK MANAGEMENT SERVICES DIVISION

EFFECTIVE DATE: 2024 and Succeeding Crop Years ISSUE DATE: November 20, 2023

SUBJECT:

Provides the Standards and Procedures for 

Administering Good Farming Practice Decisions, 

Determinations, and Reconsiderations

APPROVED:

/s/ Delores Dean

Deputy Administrator for Insurance Services

REASON FOR ISSUANCE

This handbook contains the FCIC-issued standards and procedures that AIPs, and RMA use to administer and 

issue good farming practice decisions, determinations, and reconsiderations. This handbook replaces FCIC14060 Good Farming Practice Standards Handbook dated August 08, 2022. This handbook is effective for the 

2024 and succeeding crop years and is not retroactive to any 2023 or prior crop year determinations. 

However, exhibits 1 through 8 should be used for current or pending GFP decisions, determinations, or 

reconsiderations on or after the issue date of this handbook.

SUMMARY OF CHANGES

Listed below are significant changes for the 2024 FCIC-14060 Good Farming Practice Determination Standards 

Handbook. Highlighted text throughout the GFPH represents changes or additions, and three stars (***) 

identify removal of information.

Reference Description of Change

Throughout this 

handbook

For consistency, the term “producer” has been replaced for “policyholder”.

Reason for 

Issuance

Page TP1: Reason for Issuance language modified to include language from Filing 

Instructions

Control Chart Page TP3: Section removed to comply with new EHS requirements.

Filing Instructions Page TP3: Section removed, and language merged with Reason for Issuance section to 

comply with new EHS requirements.

Para. 1B(5) Page 2: Added Agriculture General Administrative Regulation for consistency with GSH.

Para. 1F Page 4: Mailing address updated.

Para. 1G(1) Page 5: Added “If not resolved” to match the language used in the GSH. 
November 2023 FCIC-14060 TP 2 

SUMMARY OF CHANGES (Continued)

Para. 2A Page 5: Added “(b) for failure to follow GFP decisions, provide the policyholder with a 

GFP decision letter describing how that decision was made, in accordance with 

Part 4;” to clarify that AIP GFP decision letters must include information on how 

the AIP determined that the policyholder failed to follow GFP.

Page 5: Previous item (b) was split into two tasks“(c) notify the RMA RO serving the 

location of the insured acreage in writing or electronically if the policyholder 

requests a GFP determination through the AIP” and “(d) upload the entire GFP 

decision file through the ROE Program Review Log as directed in Para. 23B – 

Requests for GFP determinations” to clarify that communications with RMA 

regarding requests for GFP determinations can be in writing or electronically.

Page 5: Added requirement “(e) the AIP will respond timely to any RMA requests for 

further information or clarification, in accordance with Part 4” To clarify that 

AIPs need to respond in a timely matter to RMA’s inquiries.

Page 5: Replaced language in (2) to clarify that failure to follow AIP responsibilities may 

result in a referral to RSD for further action.

Para. 2B Page 6: Added “(g) submit referrals upon discovering AIP GFP performance issues in 

accordance with Para. 41 (C)” to clarify that it is the RO responsibility to refer 

AIPs that do not follow procedures to RSD.

Para. 2C Page 6: Reworded (a) to clarify that RMSD will guide, assist, and coordinate with the 

ROs during the GFP review process. 

Page 6: Modified language of (b)(i) to explain RMSD will monitor referrals and provide 

status updates to the ROs.

Para. 11A Page 8: Modified language to clarify training requirements for RMA employees that 

make GFP determinations.

Para. 11B Page 8: Modified language to clarify that the certification requirements for employee 

making GFP determinations are the same for those that perform PPA Reviews. 

Para. 21A Page 9: Added language to clarify that the opinion of agricultural experts will not be 

accepted if there is a personal or financial interest in the insured crop.

Para. 21B Page 10: Updated mailing address to request approvals for agricultural experts.

Para. 22A(2)(b)(ii) Page 11: Modified language to clarify that if the written opinion of an agricultural expert 

is used, a statement disclosing that the expert has no familial, business, or 

other relationship(s) with the policyholder, AIP, agent, or loss adjuster is 

required.

Para. 23B(2) Page 13: Language removed to clarify that AIPs are required to make a GFP decision, in 

accordance with the BP.

Para. 31A Page 15: Added language to clarify that the AIP GFP decision Letter must describe how 

the policyholder failed to follow GFP, how its farming practices adversely 

impacted yields, and how the AIP determined those farming practices were 

not GFP.
November 2023 FCIC-14060 TP 3 

SUMMARY OF CHANGES (Continued)

Para. 31A(5)(b) Parge 16: Removed (b) to clarify that if there is a genuine dispute about the 

policyholder's farming practices, the AIP must research other sources of 

information to make a GFP determination.

Para. 31A(5)(c) Page 16: (c) moved to (b).

Para 31B(3) Page 17: Reworded to clarify that AIPs must specify each cultural practice that does not 

constitute GFP and provide a detailed description of each practice.

Para. 32A(1) Page 18: (a) reworded to clarify that it is the RO's duty to determine if the AIP decision is 

complete and within the scope of a GFP review.

Page 18: Added new (b) to clarify that it is the RO's duty to verify if there is any 

insurability issue pending and require clarification from the AIP if needed.

Page 18: Previous (b) item moved to (c).

Page 19: Added (d) to clarify that RMA will not consider any hypothetical situations.

Page 18: Added (e) to clarify that reports that are supported by substantiated evidence 

other than opposing accounts or narratives of the same issue.

Page 19: (c) moved to (f), and modified language to clarify that if the AIP decision letter 

is incomplete or unacceptable and the AIP fails to respond to RMA, the AIP will 

be referred to RSD, and the RO will issue a GFP determination using the 

documentation available.

Para. 41C Page 22: Changed the language from “Referrals for Systemic AIP Performance Issues” to 

“Referrals for AIP Performance Issues” to clarify that failure to follow FCICissued policies, standards, and procedures will be referred regardless of 

whether it is systemic or not.

Para. 52A Page 28: Mailing address to request a GFP reconsideration updated.

Para. 52B(b) Page 29: To be consistent with Para. 32A(e)(i), the number of calendar days allowed for 

the policyholder to submit any additional documentation for consideration 

was changed from 30 to 10.

Exhibit 1 Page 32: Added definition of the PPASH acronym.

Exhibit 2 Page 33: Added persons certified by the International Society of Arboriculture as 

Certified Arborists to the definition of agricultural expert to match language in 

Para. 21A. 

Page 33: Changed definition for AIP to be same as defined in the GSH.

Page 34: Changed the language to clarify that NRCS Conservation Practice Standards are 

considered good farming practices and do not impact federal crop insurance 

coverage.

Page 34: Added “standards” to match the language used by NRCS.

Page 34: Added definition for practice as defined in the GSH.

Exhibit 6B and 6C Pages 44 and 46: Replaced Dear Sir (or Madam) with Dear Policyholder or Legal 

Representative Name/Title. 

Page 49: Mailing address updated.

Exhibit 7A Page 51: Replaced Dear Sir (or Madam) with Dear Policyholder or Legal Representative 

Name/Title.

***

***
November 2023 FCIC-14060 TC 1

GOOD FARMING PRACTICE DETERMINATION STANDARDS HANDBOOK

TABLE OF CONTENTS

PART 1: GENERAL INFORMATION AND RESPONSIBILITIES..............................................................................1

1 General Information......................................................................................................................1

2 Responsibilities..............................................................................................................................5

3-10 Reserved........................................................................................................................................7

PART 2: TRAINING..........................................................................................................................................8

11 RMA Employee Training Requirements.........................................................................................8

12-20 (Reserved) .....................................................................................................................................8

PART 3: GENERAL REQUIREMENTS.................................................................................................................9

21 Agricultural Experts.......................................................................................................................9

22 General Basis for GFP Decisions..................................................................................................10

23 Requirements for an RMA GFP Determination ...........................................................................12

24 GFP Applicability .........................................................................................................................13

25 GFP and Cover Crops...................................................................................................................13

26-30 (Reserved) ...................................................................................................................................14

PART 4: GFP PROCESS ..................................................................................................................................15

31 AIP Duties....................................................................................................................................15

32 RO Duties ....................................................................................................................................18

33-40 (Reserved) ...................................................................................................................................20

PART 5: REFERRALS......................................................................................................................................21

41 Procedures for Written Referrals................................................................................................21

42-50 (Reserved) ...................................................................................................................................26

PART 6 DISPUTE RESOLUTION.......................................................................................................................27

51 Dispute Resolution ......................................................................................................................27

52 Reconsideration ..........................................................................................................................27

53 Filing Suit Against FCIC ................................................................................................................30

54-60 (Reserved) ...................................................................................................................................30

Exhibit 1 Acronyms and Abbreviations.................................................................................................31

Exhibit 2 Definitions .............................................................................................................................33

Exhibit 3 (Reserved)..............................................................................................................................36

Exhibit 4 File Organization and Storage................................................................................................37

Exhibit 5 Guidelines for Supporting File Records..................................................................................41

Exhibit 6 RO GFP Letter Templates.......................................................................................................43

Exhibit 7 RMSD Reconsideration Letter Template................................................................................51

Exhibit 8 GFP Decision Appeal Process.................................................................................................52
November 2023 FCIC-14060 1 

PART 1: GENERAL INFORMATION AND RESPONSIBILITIES 

1 General Information

A. Purpose and Objective

FCIC is established by the Federal Crop Insurance Act, 7 U.S.C. 1501, to promote the national 

welfare by improving the economic stability of agriculture through a sound system of crop 

insurance and providing the means for the research and experience helpful in devising and 

establishing insurance. RMA administers the crop and livestock insurance programs on behalf 

of FCIC.

This handbook provides the standards and procedures for each RMA RO and AIP for 

participation in GFP actions, including:

(1) training;

(2) AIP responsibility in GFP decisions;

(3) RMA GFP determinations and reconsiderations; 

(4) referral of identified program vulnerabilities and suspected cases of fraud, waste, and 

abuse; and

(5) dispute resolution.

This handbook remains in effect until superseded by reissuance of either the entire handbook 

or selected portions (through amendments, Manager’s Bulletins, or FADs). If amendments are 

issued for a handbook, the original handbook as amended shall constitute the handbook. A 

Manager’s Bulletin or FAD can supersede either the original handbook or subsequent 

amendments. 

B. Source of Authority

Federal programs enacted by Congress and the regulations and policies developed by RMA, 

USDA, and other Federal agencies provide the authority for program and administrative 

operations, and basis for RMA directives. Administration of the Federal crop insurance 

program is authorized by the following:

(1) Federal Crop Insurance Act (Act), Section 508(a)(3)(B)(i):

“A policyholder shall have the right to a review of a determination regarding good 

farming practices... in accordance with an informal administrative process to be 

established by [FCIC].”

(2) The Food Security Act of 1985, 16 U.S.C. 3801 et seq.

(3) Controlled Substance Act of 1970, 21 U.S.C. 801 et seq.

(4) Personal Responsibility and Work Opportunity Reconciliation Act of 1996, 42 U.S.C. 653a
November 2023 FCIC-14060 2 

1 General Information (Continued)

B. Source of Authority (Continued)

(5) Agriculture General Administrative Regulation, 7 CFR Part 400

(6) 2024 SRA, Section I. Definitions

“‘Inspection’ means verification: (4) that the reported practice is being carried out in 

accordance with good farming practices.” 

and 

Appendix IV, Section III (a) (3): 

“(a) The Company is responsible for (3) conducting an inspection.”

(7) FCIC Policy Provisions:

(a) Common Crop Insurance Policy Basic Provisions (24-BR), Sections 12 and 20.

(b) ARPI Basic Provisions (24-ARPI), Section 23.

(c) WFRP Pilot Policy (24-0076), Section 21.

(d) Rainfall Index Common Policy Basic Provisions (24-RI), Section 6 and 15.

(e) LRP Insurance Policy (24-LRP-Basic), Section 11.

(f) Other crop provisions as applicable.

C. Title VI of the Civil Rights Act of 1964

The USDA prohibits discrimination against its customers. Title VI of the Civil Rights Act of 1964 

provides that “No person in the United States shall, on the ground of race, color, or national 

origin, be excluded from participation in, be denied the benefits of, or be subjected to 

discrimination under any program or activity receiving Federal financial assistance.” Therefore, 

programs and activities that receive Federal financial assistance must operate in a nondiscriminatory manner. Also, a recipient of RMA funding may not retaliate against any person 

because he or she opposed an unlawful practice or policy, or made charges, testified, or 

participated in a complaint under Title VI.

It is the AIPs’ responsibility to ensure that standards, procedures, methods, and instructions, as 

authorized by FCIC in the sale and service of crop insurance contracts, are implemented in a 

manner compliant with Title VI. Information regarding Title VI of the Civil Rights Act of 1964 

and the program discrimination complaint process is available on the USDA public website at 

www.ascr.usda.gov. For more information on the RMA Non-Discrimination Statement see the 

DSSH.
November 2023 FCIC-14060 3 

1 General Information (Continued)

D. Order of Precedence

If there is a conflict between the procedure in this handbook and other documents issued by 

RMA, the following order of precedence will apply.

(1) The Federal Crop Insurance Act, as amended (7 U.S.C. 1501 et seq.) and any FAD 

interpreting the Act.

(2) The CAT Endorsement, as applicable, and any FAD interpreting the CAT Endorsement.

(3) Written Agreement, as applicable.

(4) The SP and other actuarial documents in the following order of precedence: 

(a) SP; and 

(b) Actuarial Map.

(5) The Commodity Exchange Price Provisions, as applicable.

(6) Crop endorsement/options/exclusions and any FAD interpreting the crop 

endorsement/options/exclusions if published in 7 CFR Part 457. Exception: For ARH 

policies, crop provisions will take precedence over the ARH Endorsement.

(7) CP and any FAD interpreting the CP.

(8) BP and any FAD interpreting the BP.

(9) Administrative Regulations at 7 CFR Part 400; any FAD interpreting the administrative 

regulations; or any FCIC interpretation at 7 CFR § 400, Subpart X — Interpretations of 

Statutory Provisions, Policy Provisions, and Procedures.

(10) PPSH (FCIC-25370) and any interpretation of these procedures.

(11) CIH (FCIC-18010) and other applicable underwriting guides for a specific commodity or 

plan of insurance and any interpretation of these procedures.

(12) GSH (FCIC-18190) and any interpretation of these procedures.

(13) LAM Standards Handbook (FCIC-25010) and any interpretation of these procedures.

(14) Crop LASH and any interpretation of these procedures.

(15) GFP Determination Standards Handbook (FCIC-14060). 

(16) Product Management and Insurance Services Informational Memorandums.
November 2023 FCIC-14060 4 

1 General Information (Continued)

E. Related Handbooks

The following table provides handbooks related to this handbook.

Handbook/Manual Purpose

CIH This handbook provides the official FCIC-approved underwriting 

standards for policies administered by AIPs for the General 

Administrative Regulations, Common Crop Insurance Policy Basic 

Provisions, and Area Risk Protection Regulations.

GSH This handbook provides the official FCIC-approved standards for policies 

administered by AIPs under the General Administrative Regulations, 

Common Crop Insurance Policy Regulations Basic Provisions, including 

the Catastrophic Risk Protection Endorsement; the Area Risk Protection 

Insurance Regulations Basic Provisions; the Stacked Income Protection 

Plan of Insurance; the Rainfall Index Plan; and the Whole-Farm Revenue 

Protection Pilot Policy.

LAM This handbook provides the official FCIC-approved general loss 

adjustment standards for all levels of insurance provided under FCIC 

unless a publication specifies that none or only specified parts of this 

handbook apply.

PPSH This handbook provides the official FCIC-approved standards 

requirements for adjusting losses related to prevented planting in a 

uniform and timely manner.

F. Procedural Issuance Authority

This handbook is written and maintained by: 

Office of Deputy Administrator for Insurance Services 

Risk Management Services Division 

USDA—Risk Management Agency 

USDA/RMA/Stop 0801/Room 2004-South 

Washington, D.C. 20250–0801
November 2023 FCIC-14060 5 

1 General Information (Continued)

G. Procedural Questions 

(1) Questions regarding procedures in this handbook are to be directed first to the AIP. If 

not resolved, then through appropriate channels within the AIP to RMA. 

(2) If a perceived error is identified, notify RMA in writing at the address contained in the 

preceding paragraph or by email at rma.rmsd@usda.gov. The notification must clearly 

identify the error and provide the proposed correction. 

If RMA determines the perceived error is not an actual error, RMA will make no 

changes. However, if RMA determines the identified error is an actual error and is 

significant, RMA will issue a correction in the existing crop year. Conversely, if RMA 

determines the identified error is an actual error and is not significant, the correction 

will be included in the subsequent issuance of the GFPH. 

H. RMA RO and Compliance Field Office Contact Information 

For the applicable RMA RO or Compliance Field Office and the associated contact information, 

refer to www.rma.usda.gov/en/RMALocal/Field-Offices/Regional-Offices or 

www.rma.usda.gov/en/RMALocal/Field-Offices/Regional-Compliance-Offices.

2 Responsibilities

A. AIP Responsibilities

(1) The AIP will:

(a) make an initial GFP decision in accordance with Para. 31 – AIP Duties; 

(b) for failure to follow GFP decisions, provide the policyholder with a GFP decision 

letter describing how that decision was made, in accordance with Para. 31; 

(c) notify the RMA RO serving the location of the insured acreage in writing or 

electronically if the policyholder requests a GFP determination through the AIP; 

(d) upload the entire GFP decision file through the ROE Program Review Log as 

directed in Para. 23B – Requests for GFP determinations; and

(e) the AIP will respond timely to any RMA requests for further information or 

clarification, in accordance with Part 4. 

(2) Any failure to follow AIP responsibilities listed above may result in referral under Para. 41C.

B. RO Responsibilities

(1) The RO will:

(a) screen GFP determination requests in accordance with Para. 23 – Requirements 

for an RMA Review, and accept or reject the request;
November 2023 FCIC-14060 6 

2 Responsibilities (Continued)

B. RO Responsibilities (Continued)

(b) send an acknowledgment or rejection letter to the AIP and policyholder (see 

Exhibit 6);

(c) make the GFP determination based on Para. 32 – RO Responsibilities;

(d) issue the GFP determination letter to the requestor, with a copy to the AIP, 

policyholder, and Regional Compliance Office, as appropriate;

(e) upload additions to the GFP file to the ROE Program Review Log within 30 days 

of issuing the GFP determination letter; and

(f) write referrals upon discovering fraud, waste, abuse, or other vulnerabilities in 

accordance with - Referrals of this handbook Para. 41D. 

(g) submit referrals upon discovering AIP GFP performance issues in accordance 

with Para. 41C. 

(2) RO Directors will:

(a) ensure all appropriate staff members are trained in accordance with Part 2 - 

Training; and 

(b) maintain training records for their staff in the ROE Program Review Log.

C. RMSD Responsibilities

(1) RMSD will:

(a) provide guidance, assistance, coordination, training, and monitoring of the ROs, 

and: 

(i) develop and maintain policy and handbook procedures for GFP 

determinations; 

(ii) develop training standards and procedures;

(iii) establish target deadlines and monitor the progress for timely 

completion of GFP determinations.

(b) provide a written process for referrals and:

(i) follow up, provide updates to the RO involved, and document outcome of 

referrals;

(ii) advance and coordinate recommended corrections for vulnerabilities 

identified in FCIC programs.
November 2023 FCIC-14060 7 

2 Responsibilities (Continued)

B. RMSD Responsibilities (Continued)

(c) process reconsideration requests of GFP determinations and coordinate with the 

DAIS for signature on reconsideration determinations.

3-10 Reserved
November 2023 FCIC-14060 8 

PART 2: TRAINING

11 RMA Employee Training Requirements

A. Training Curriculum

To obtain the proficiency required to make GFP determinations, RMA employees that make 

these determinations must undergo the training curriculum found in the PPASH, Part 2 – 

Training. 

B. GFP Certification

RMA employees responsible for making GFP determinations must obtain the same certification 

as those performing PPA reviews. RMA employees already certified to conduct PPA reviews are 

exempt from further GFP certification requirements. Ongoing maintenance of GFP certification 

is not required unless specifically required by RMSD or the RO Director.

RO Directors will: 

(1) assign a GFP mentor to the RMA employee to complete their first GFP determination;

(2) review completed GFP determinations and identify competencies for improvement for 

the employee; and

(3) ensure follow-up training initiatives are provided and completed for competencies 

identified for improvement on the part of an employee working with GFP 

determinations. 

12-20 (Reserved)
November 2023 FCIC-14060 9 

PART 3: GENERAL REQUIREMENTS

21 Agricultural Experts 

The opinions and published materials by agricultural experts are an integral part of determining 

whether a production method is a GFP.

A. Agricultural Experts Currently Approved by RMA 

Approved Agricultural Experts include personnel whose research or occupation is related to the 

specific crop, and practice, in the region for which such expertise is sought, have demonstrated 

expertise in the production practice in question, does not have a personal or financial interest 

in the insured or the crop, and are:

(1) employed by Cooperative Extension Service or USDA National Institute of Food and 

Agriculture (NIFA), formerly Cooperative State Research, Education, and Extension 

Service (CSREES);

(2) employed by the agricultural departments of universities;

(3) certified by the American Society of Agronomy (ASA) as Certified Crop Advisers and 

Certified Professional Agronomists, www.agronomy.org; 

(4) certified by the National Alliance of Independent Crop Consultants (NAICC) as Certified 

Professional Crop Consultants, www.naicc.org; 

(5) certified by the American Society for Horticultural Sciences as Certified Professional 

Horticulturists; 

(6) certified by the International Society of Arboriculture as Certified Arborists; or

(7) an employee certified by the Natural Resources Conservation Service (NRCS) to make 

determinations regarding good cover cropping practices.

For the organic industry, in addition to the experts listed above, approved Organic Agricultural 

Experts include persons employed by:

(a) the Appropriate Technology Transfer for Rural Areas National Sustainable 

Agriculture Information Service www.attra.ncat.org; 

(b) the Sustainable Agriculture Research and Education organization, www.sare.org; 

or

(c) USDA Accredited Certifying Agents (ACA), third party agents who certify 

operations under USDA organic standards. A list of ACAs is available on the AMS 

website, www.ams.usda.gov. 

NOTE: Both Organic Agricultural Experts and Agricultural Experts are 

referred to as “Agricultural Experts” in this Handbook for simplicity.
November 2023 FCIC-14060 10

21 Agricultural Experts (Continued) 

B. RMA Approval for Other Experts 

Persons certified through other programs may be recognized as agricultural experts by RMA if 

their research or occupation is related to the specific crop, and practice, in the region for which 

such expertise is sought and has demonstrated expertise in the production practice in question. 

To obtain approval for such persons, contact RMA’s Deputy Administrator for Insurance 

Services by email to rma.rmsd@usda.gov, or if email is not an option by mail at:

Office of Deputy Administrator for Insurance Services 

Risk Management Services Division

ATTN: RMA Approval for Agricultural Experts

USDA—Risk Management Agency 

USDA/RMA/Stop 0801/Room 2004-South 

1400 Independence Ave. SW

Washington, DC 20250Washington, D.C. 20250–0801

22 General Basis for GFP Decisions

The purpose of the GFP provisions is to ensure that a policyholder’s production methods do not 

adversely affect the quantity and/or quality of the production. Consider any practice that could affect 

the amount and quality of the crop, from ground preparation through harvest. In the case of 

perennials, consider practices from post-harvest of the previous crop year through harvest of the 

current crop year that could affect the amount and quality of the crop. Policyholders are responsible 

for establishing that the farming practice in question was a good farming practice.

All GFP evaluations, including decisions made by the AIP, determinations made by the RO, or 

reconsideration determinations made by RMSD, must consider the items in Para. 22A. 

A. Basis for GFP Decisions

Base GFP determinations on the following:

(1) Agronomic situation of the policyholder, including: 

(a) material facts about the production methods that were used or will be used to 

produce the crop;

(b) weather and climate factors;

(c) pest or disease risks; and

(d) other factors affecting the crop.
November 2023 FCIC-14060 11

22 General Basis for GFP Decisions (Continued)

A. Basis for GFP Decisions (Continued)

(2) Expert opinion;

You must use the opinion from at least one agricultural expert, who meets the 

standards in Para. 21- Agricultural Experts, regarding the production method(s) used by 

the policyholder to support the decision. The opinion must be in one of the following 

forms:

(a) published material; or

(b) a written opinion or recommendation which complies with the following:

(i) An agricultural expert who provides a written opinion or 

recommendation on farming practices should submit it on letterhead or 

include evidence of their certification, as appropriate.

(ii) A statement disclosing that the expert does not have any familial, 

business , business, or other relationship(s) with the policyholder, AIP, 

agent, or loss adjuster is required.

Note: If the agricultural expert is not qualified to render an objective, 

unbiased opinion of the production methods, crop, or areas at issue, the 

opinion cannot be considered in the GFP decision or determination.

(3) Additional expert opinions, if required.

The recommendation of at least one additional agricultural expert is required if:

(a) the expert providing an opinion has a business relationship with the 

policyholder, such as providing advice and/or sale of inputs to the policyholder’s 

operation, or is employed by a firm that provided such advice or inputs;

(b) the expert providing an opinion has a familial relationship with the policyholder, 

loss adjuster, or agent, or will benefit financially from the outcome of the 

opinion (other than disclosed amounts paid to provide a written opinion); or

(c) the written opinion is not supported by published material. 

(4) Review of the production method; 

(a) Determine whether the production method(s) used by the policyholder 

conforms with the requirements of the policy held. For example, does the 

production method:

(i) allow the insured crop to make normal progress toward maturity;

(ii) produce at least the yield used to determine the production guarantee or 

amount of insurance, including any adjustments for late planted acreage;
November 2023 FCIC-14060 12

22 General Basis for GFP Decisions (Continued)

A. Basis for GFP Decisions (Continued)

(iii) not reduce or adversely affect the yield; or

(iv) stand as a generally recognized good farming practice by agricultural 

experts or organic agricultural experts, depending on the practice, for the 

area.

Note: Any other objective supporting statements provided by a disinterested 

third-party may be considered and included to support any basis for GFP 

decisions. 

B. Determining if a Production Method May be Considered a GFP

The production method will not be considered a GFP if:

(1) the production method fails to meet the standards in Para. 22A(4); or

(2) there are no published materials supporting the recommendation, unless two or more 

agricultural experts specifically support the production method as meeting all the 

criteria in Para. 22A(4). 

23 Requirements for an RMA GFP Determination

A. What Does Not Qualify for GFP Determination

A GFP determination is used to determine whether a particular production practice meets the 

criteria set forth as a GFP. It is not to be used for situations that fall outside of the GFP authority 

and definition in the Basic Provisions. As such, RMA will not accept requests related to:

(1) the amount of production or value assessed to crop acreage for uninsured causes of loss 

due to a failure to follow GFP;

(2) the expansion of coverage to states, counties, crop, practices, types, or varieties where 

coverage is not available;

(3) establishing insurability;

(4) the denial of requests for written agreements;

(5) identifying or determining that an insured cause of loss was present; or

(6) any other decisions related to a claim determination including but not limited to:
November 2023 FCIC-14060 13

23 Requirements for an RMA GFP Determination (Continued)

A. What Does Not Qualify for GFP Determination (Continued)

(a) interpretations of policy and procedure;

(b) emerging crop disease issues;

(c) whether or not a production method was used;

(d) when the production method in question is not clearly defined; 

(e) whether or not a cause of loss impacted a production method; or

B. Requests for RMA GFP Determinations

(1) If the policyholder disagrees with the AIP’s GFP decision, the policyholder may request a 

GFP determination within 30 calendar days of receipt of the AIP’s decision. Once the 

RMA Regional Office is notified of a request for a GFP determination, the RO will log the 

GFP into the ROE Program Review Log. The AIP will then receive an email with a link to 

upload the complete request. It is the AIP’s responsibility to provide the complete 

request file to the ROE Program Review Log. A complete request must include: 

(a) the AIP GFP decision file, including both the complete underwriting file and the 

complete claim file, which will contain all material facts, written opinions, 

published material and supporting documentation provided by the policyholder, 

any recommendations and research conducted by the AIP, the AIP analysis of the 

policyholder’s actions compared to the recommended practices, and the AIP 

decision letter; and

(b) the policyholder’s written request, and any attachments provided with the 

request, if applicable.

***

24 GFP Applicability

GFP decisions, determinations, and reconsiderations apply to all the Shareholders on the acreage for 

which a decision is made. All Shareholders and AIPs that service a policy on the acreage must receive a 

copy of the final decision letter by certified mail or encrypted email.

25 GFP and Cover Crops

Cover Cropping – The voluntary practice of cover cropping shall be considered a good farming practice 

if the cover crop is terminated in accordance with the NRCS Cover Crop Guidelines. 

(1) Policyholders can obtain an exception to the NRCS Cover Crop Guidelines following the 

guidance and meeting the requirements found in Para. 21 and 22. 

(2) It is recommended that exceptions be provided to the AIP by the crop’s applicable 

acreage report date.
November 2023 FCIC-14060 14

26-30 (Reserved)
November 2023 FCIC-14060 15

PART 4: GFP PROCESS

31 AIP Duties

A. GFP Decision Process

The AIP makes an initial decision of whether the production methods used by a policyholder 

constitute GFP according to the terms of the policy and these procedures and determines 

whether the policyholder carried out generally recognized GFPs. These procedures apply to all 

GFP decisions, regardless of the origination of the review, i.e., RCO review requests, loss 

adjustment process, growing season inspection, etc., when the AIP or RMA has a reason to 

question whether GFP were followed by the policyholder. 

The AIP shall provide a precise description of the production methods employed by the 

policyholder that adversely impacted the yield from making normal progress towards maturity. 

The AIP is responsible for providing sufficient documentation that supports all failure to follow 

good farming practices determinations.

(1) To decide if GFP were followed, the AIP may ask policyholders to demonstrate they 

complied with the policy provisions and followed generally recognized GFP. The 

policyholder must provide the AIP with all the relevant facts relating to their agronomic 

situation, including but not limited to:

(a) receipts; 

(b) farm records;

(c) third party verification;

(d) Organic Plan, if applicable; and

(e) any other documentation to show the practice is or is not a recognized GFP, as 

requested. 

(2) The AIP may request the policyholder provide, as applicable, published material relating 

to the production method or a written opinion directly from an agricultural expert:

(a) that the production method used by the policyholder meets the standards 

contained in Para. 22A(4); or

(b) recommending the production methods that would meet the standards 

contained in Para. 22A(4). 

(3) The AIP should also document the condition in the field through adjuster reports, 

photographs (appropriately labeled with date, location, etc.), and other means, as 

applicable. The AIP may also consider including photographs from neighboring fields for

comparison.
November 2023 FCIC-14060 16

31 AIP Duties (Continued)

A. GFP Decision Process (Continued)

(4) Economic conditions are not a valid consideration for deciding if a production method is 

a GFP or if a policyholder is justified in not following GFP. Accordingly, the policyholder 

will not be exempt from following a recommended GFP because a policyholder does not

want to or cannot afford to incur the costs associated with following the 

recommendations of agricultural experts or published materials.

(5) The AIP must decide if:

(a) the production method is a GFP in accordance with Para. 22 – General Basis for 

GFP decisions; and

***

(b) When deciding there is a genuine dispute among agricultural experts or between 

the opinion of an agricultural expert and published materials, consider whether:

(i) there is longstanding general agreement among experts in an area that 

the practice is a GFP for the agronomic circumstances particular to the 

policyholder’s acreage, but a minority of experts disagree;

(ii) policyholders can prove that they or similarly situated policyholders have 

used the production method in the same manner over an extended 

period and produced levels consistent with at least the yield used to 

determine the production guarantee or amount of insurance;

(iii) the opposing opinion or published material is more general in 

applicability to the specific crop, area, or practice than the opinion or 

materials relied on by the policyholder;

(iv) the opposing opinion or published material is issued by an expert whose 

experience is less directly applicable to the specific practice, area, or crop 

than the opinion or materials relied on by the policyholder;

(v) the opposing opinion or published material is not supported by 

substantiated scientific or experiential data to a sufficiently equivalent 

degree as the opinion or materials relied on by the policyholder; or

(vi) other relevant factors would lead a reasonable person to conclude that 

one expert opinion or set of published materials is more applicable, 

credible, or reliable than the other.

(6) The AIP must include the following in a GFP decision file:

(a) documentation of agricultural expert opinion(s) and RMA procedures or other 

published material to support the AIP decision that the policyholder failed to 

follow GFP;
November 2023 FCIC-14060 17

31 AIP Duties (Continued)

A. GFP Decision Process (Continued)

(b) description of the production methods employed by the policyholder; and

(c) analysis of production methods employed by the policyholder compared to the 

recommendations of the experts or published material.

B. GFP Decision Letter

The GFP decision letter provided from the AIP to a policyholder must:

(1) be in writing, dated, and mailed via certified mail or overnight delivery;

NOTE: In situations where a policyholder refuses to sign for certified mail containing a 

GFP decision, the date an attempt was made by the postal service to obtain the 

signature is the date the policyholder received the decision.

(2) state that the letter is a GFP decision and include clearly identified issues in which the 

policyholder failed to follow GFP;

(3) Identify the specific cultural practice(s) the AIP determined did not constitute a GFP;

(4) state the facts relating to the production method;

(5) contain or reference RMA procedures, other published materials, any written opinions, 

or recommendations, or state the opinion or recommendation of at least one 

agricultural expert;

(6) state why the production method does or does not meet the requirements in Para. 22 – 

General Bases for GFP decisions; and

(7) inform the policyholder of their appeal rights under Section 20 of the BP:

(a) to mediate or arbitrate with the AIP any disagreement regarding the amount of 

assigned production or other claim determinations; and

(b) the necessary steps to request a GFP determination from RMA in writing, 

through the AIP to the RO, within 30 calendar days from the date the 

policyholder received the GFP decision. The written request must state the basis 

upon which the policyholder relies to show that:

(i) the determination was not proper and not made in accordance with the 

program regulations and procedure; or

(ii) all material facts were not properly considered in the AIP’s 

determination. 
November 2023 FCIC-14060 18

31 AIP Duties (Continued)

C. Routing Policyholder Requests for GFP Determination

When a request for a GFP determination is received from the policyholder, AIPs must:

(1) date stamp the request on the date it was received to verify timeliness;

(2) follow the procedures in Para. 23B – Requests for a GFP determination; and

(3) notify the RO within 5 business days of receipt of the request. Upon notification, upload 

the policyholder’s request, with all required AIP documentation through the ROE 

Program Review Log.

D. Uninsured Cause of Loss

If an AIP’s GFP decision finds the policyholder failed to follow GFP, only the AIP can assign 

production or value as uninsured causes of loss for such failure. 

According to the BP Section 20(d)(ii), if the policyholder disagrees with the AIP’s determination 

of the amount of assigned production or value, the dispute must be resolved through the 

arbitration or mediation process contained in the BP. A GFP determination from the RO will not 

address the amount of assigned production or value or any other claim determination.

32 RO Duties

A. GFP Determination Process

If the policyholder disagrees with the AIP decision, the policyholder (through the AIP) may make 

a written request that the RO serving the location of the insured acreage make a GFP 

determination. 

(1) Screening Requests for GFP determination

(a) Determine that the request is timely, complete, and within the scope of a GFP

review. A complete request must be in writing and comply with Para. 23B – 

Requests for RMA GFP determinations.

(b) Verify with the AIP the crop acreage is insurable and if there are any pending 

insurability issues. If insurability is questionable, require the AIP to provide 

clarification within 20 calendar days. If this results in a change to the AIP’s GFP 

decision, require the AIP to issue a new GFP or insurability decision letter within 

10 calendar days. The policyholder will be given an additional 30 calendar days 

to request a GFP determination after the GFP decision letter is reissued by the 

AIP.

(c) Ensure the AIP GFP decision letter to the policyholder contains required 

language in Para. 31B and Exhibit 4. If the AIP GFP decision letter is 

unacceptable, require the letter be corrected and reissued to the policyholder 

within 20 calendar days. The policyholder will be given an additional 30 calendar 

days to request a GFP determination after the letter is reissued by the AIP.
November 2023 FCIC-14060 19

32 RO Duties (Continued)

A. GFP Determination Process (Continued)

(d) FCIC will not consider any hypothetical situations, as those could be construed as 

a finding of fact by FCIC. 

(e) FCIC will not consider conflicting reports unless they are supported by 

substantiated evidence other than opposing accounts or narratives of the same 

issue.

(f) If there is no response from the AIP or the GFP decision letter still fails to meet 

the criteria in Para. 31B, the RO will refer the AIP in accordance with Part 5 (C)

and will issue a GFP determination.

(g) Do not make GFP determinations on requests outside the authority of GFP in 

accordance with Para. 23A – What Does not Qualify for Review.

(h) Send a letter by certified mail or encrypted email if available to the policyholder 

and AIP acknowledging receipt of the request within 10 business days. See 

Exhibit 6 for a sample acknowledgement template.

(i) Allow the policyholder 10 calendar days from receipt of the RO letter in 

which to submit any additional information to support their position. 

Reasonable extensions may be approved by the RO Director. 

(ii) If a request is incomplete, notify the AIP of what is missing and allow the 

AIP five calendar days to resubmit a complete request to the RO.

(iii) The RO may accept requests directly from the policyholder to preserve a 

timely request for a GFP determination. The RO will notify the AIP of the 

policyholder’s request and request the AIP send all required AIP 

documentation to the RO within five business days of the RO’s 

notification as required in Para. 23B. 

(2) GFP Determination Process

When the RO receives a request for GFP determination, the RO:

(a) may contact agricultural experts who provided written opinions or have 

prepared published materials to clarify their opinions.

(b) may seek other publications or opinions not cited by the AIP or policyholder

regarding the crop production methods used to confirm or refute the AIP or 

policyholder’s position. However, the AIP’s decision should be sufficiently 

supported by the AIP’s own documentation.

(c) will make a GFP determination of the issues identified by the AIP in accordance 

with Para. 22 based on:
November 2023 FCIC-14060 20

32 RO Duties (Continued)

A. GFP Determination Process (Continued)

(i) the information provided by the AIP and policyholder in the AIP decision 

file; and

(ii) other generally available published material identified by the RO which is 

pertinent to the case.

(d) will issue a written GFP determination letter and send it to the requesting party 

(with a copy to the policyholder, shareholders, or AIP, as appropriate) via 

encrypted email if available, certified mail or overnight delivery within 60 days of 

the date the complete file was received as required in Para. 32A(1)(e)(i) unless 

otherwise extended in writing.

(i) GFP determination letters issued by the RO will include a notice of the 

policyholder’s appeal rights and will state the policyholder cannot bring 

suit against the AIP for GFP determinations made by RMA.

(ii) A GFP determination letter issued by the RO that determines that GFP 

were followed is not considered adverse and will not include appeal 

rights.

B. GFP Determination Applicability

Any GFP determination issued by RMA is not retroactive and may not be used to reopen claims 

that were settled in prior crop years.

(1) Enter all GFP correspondence and information in the ROE Program Review Log.

(2) The RO will create and maintain records in accordance with Exhibits 4 and 5. 

C. Written Referrals

See Para. 41 – Procedures for Written Referrals for instances that require referrals.

33-40 (Reserved)
November 2023 FCIC-14060 21

PART 5: REFERRALS

41 Procedures for Written Referrals

A. Background 

In the normal course of performing RO duties and responsibilities related to the review of GFPs, 

situations arise that require referral to various functional units within RMA for additional 

follow-up. This part establishes the process and requirements for written referrals when 

program vulnerabilities are identified, an AIP systemically fails to follow FCIC-issued policy and 

procedures, and/or program fraud, waste and abuse is identified. These referrals should be 

made to the RMSD and RMSD will forward the referral to the appropriate division within RMA. 

Complaints received from outside sources of alleged fraud, waste, and abuse of the crop 

insurance program must be immediately documented and referred in writing to the 

appropriate division with a copy to RMSD.

B. Referrals of Program Vulnerabilities for Policy or Procedural Changes

ROs are in a unique position to review policies, standards, and procedures in actual farming 

situations. ROs can identify program vulnerabilities or the misunderstanding and 

misapplication of policies and/or procedures and suggest program improvements that protect 

program integrity and provide the appropriate risk protection to policyholders.

Referrals of program vulnerabilities for policy or procedural changes that arise from 

participation in GFP determinations are to be submitted to RMSD for consideration and 

coordination of cross-regional issues. If in agreement, RMSD will forward the referral to DAPM 

through DAIS.

To be effective, referrals must include, to the extent possible:

(1) Condition 

(a) describe the situation or problem; and

(b) include documents as exhibits only if necessary.

(2) Current criteria

Cite and reference the FCIC issued policy or procedure at issue, if applicable. 

(3) Effect of the condition

(a) state the negative program impact that is occurring due to the condition; and 

(b) state the consequence of not correcting the problem (i.e., loss of time, accuracy, 

monetary, etc.), quantified, if possible.
November 2023 FCIC-14060 22

41 Procedures for Written Referrals (Continued)

B. Referrals of Program Vulnerabilities for Policy or Procedural Changes (Continued)

(4) Recommendation 

State a suggested solution for the problem or improvement for the situation. Include 

specific language, if possible. 

(5) Analysis and assessment 

(a) Consider and describe the effect of the condition and the recommendation on 

any other programs, rates, coverage, regions, etc., to the extent possible.

(b) Consider and describe the effect of the recommendation on stake holders (e.g., 

increased field inspections for AIPs, workload changes for AIPs or RMA, benefits, 

etc.).

(6) Support for recommendation

(a) State whether the recommendation has been discussed with other ROs, AIPs, 

NCIS, and/or Product Management staff; and

(b) state any support or concerns raised regarding the recommendation.

C. Referrals for *** AIP Performance Issues

Referrals for systemic failure to follow FCIC-issued policies, standards, and procedures that 

arise out of the normal conduct of RO activities or operations which can be fully documented 

and do not require further review must be submitted in writing to RMSD for consideration and 

coordination of cross regional issues. If in agreement with the referral, RMSD will forward the 

referral to RSD through the DAIS.

(1) Systemic AIP performance issues include non-compliance with the SRA and Appendix IV, 

including but not limited to:

(a) failure to respond to specific agency directions;

(b) failure to correct identified discrepancies; and 

(c) failure to reconcile identified errors, etc.

(2) Written referrals must include:

(a) Party(ies) of the alleged wrongdoing: 

Include full name, address, phone number, AIP, agent, policy number, crops, 

etc., for all parties involved.
November 2023 FCIC-14060 23

41 Procedures for Written Referrals (Continued)

C. Referrals for *** Systemic AIP Performance Issues (Continued)

(b) Condition – the situation or problem itself:

(i) describe the discrepancy and who is alleged to be responsible; and

(ii) include documents relevant to the discrepancy as exhibits.

(c) Cause: 

The RO should state the underlying reasons why the condition occurred (e.g., 

lack of training, absence of quality controls, AIP reluctance to research cause of 

loss, etc.). 

(d) Criteria: 

(i) Provide the policy provision or procedure that establishes the standard.

(ii) Cite, quote, and exhibit FCIC-issued policies, procedures, SRA, etc., to 

clearly identify the standard to be applied or followed.

(e) Impact: 

(i) State the logical quantified result of correcting the discrepancy, or 

applying FCIC issued policies and procedures, i.e., bushels, tons, etc., of 

APH correction, amount of reduced indemnity, etc. 

(ii) State the consequences of not correcting the discrepancies or problem.

(f) AIP response:

(i) include the manner, date, etc., the AIP was made aware of the 

discrepancy; and 

(ii) detail the AIP reaction, reply, actions they are taking or plan to take, or 

disagreements.

D. Referrals for Suspected Cases of Fraud, Waste and Abuse

While conducting GFP determinations, instances of suspected fraud, waste, or abuse and 

suspected wrongdoing in the use of FCIC-issued policies, standards, and procedures may be 

identified and should be discussed initially with the appropriate RCO. All referrals originating 

out of this process must be in writing to RMSD for consideration and coordination of cross 

regional issues. If in agreement, RMSD will forward the referral to the DAC through the DAIS.
November 2023 FCIC-14060 24

41 Procedures for Written Referrals (Continued)

D. Referrals for Suspected Cases of Fraud, Waste and Abuse

(1) A referral must include:

(a) Copies of all relevant documentation such as acreage determinations, appraisals, 

verification of entity, documented interviews, telephone interview records, 

contact information, etc., that the RO has obtained or completed prior to 

referral;

(b) party(ies) of alleged wrongdoing; 

Include full name, address, phone number, AIP, agent, FSA county office, policy number, 

crops, etc., for all parties involved.

(c) Condition: 

(i) describe the discrepancy and who is alleged to be responsible; and

(ii) include documents including the discrepancy as exhibits.

(d) Cause: 

The RO must state the underlying reasons why the condition occurred (e.g., lack 

of training, absence of quality controls, AIP reluctance to research cause of loss, 

etc.). 

(e) Criteria: 

(i) Provide the policy provision or procedure that establishes the standard.

(ii) Cite, quote, and exhibit FCIC-issued policies, procedures, SRA, etc. to 

clearly identify the standard to be applied or followed.

(f) Impact: 

(i) State the logical quantified result of correcting the discrepancy, or 

applying FCIC issued policies and procedures, i.e., bushels, tons, etc. of 

APH correction, amount of reduced indemnity, etc.,

(ii) Describe impacts such as potential widespread misunderstanding or 

misapplication of procedure or claim administration.

(iii) Include the cost avoidance when RMA participation avoids or corrects a 

monetary discrepancy.

(g) Recommendation: 

The RO should state their recommendation to correct the problem, i.e., more 

specific training needed, AIP conduct further claim review, etc.
November 2023 FCIC-14060 25

41 Procedures for Written Referrals (Continued)

E. RMA Regional Compliance Office Responsibilities

(2) ROs will provide written updates to the referral when additional information becomes 

available.

(1) Cases referred by RMSD to Compliance must be recorded and tracked according to 

established procedures. RCOs will send an email to the referring RO and RMSD 

acknowledging their receipt of information within 30 calendar days of receipt and advise 

if the referral has been accepted for review.

(2) RCOs will provide written information and updates to the RO every 30 calendar days, or 

sooner when necessary, and when RCO action is complete. The RCO will provide valid 

information that could affect the GFP determination or other RO function as soon as it 

becomes available.

(3) DAC is responsible for referring appropriate cases to the OIG. The RCO will refer cases 

appearing to have reasonable cause for investigation to the appropriate OIG office. The 

RCO will notify the RO of any open OIG investigation(s) related to the referral to ensure 

that RMA administrative action does not interfere with the OIG case(s).

(4) Cases must be referred to the OIG if fraudulent activity is known, suspected, or alleged, 

including: 

(a) the submission of false claims or false or fraudulent statements by employees, 

policy holders, contractors, or others; and

(b) any violations of agricultural programs involving contractors, policy holders, 

employees, or others.

(5) OIG involvement:

(a) The OIG determines whether to accept the case for investigation based on 

consultation with the Department of Justice. Once a case is accepted by the OIG, 

all subsequent administrative actions pertaining to the case must be coordinated 

with the OIG.

(b) RCO Directors will inform the referring parties of any actions deemed necessary 

by the OIG and ensure administrative actions do not interfere with the OIG's 

investigation. 

(c) If the case is accepted for investigation, any indemnity due will be held until 

completion of the investigation or until released by OIG.

(d) If the OIG declines to investigate a matter referred to them, the OIG will advise 

Compliance to take any administrative actions determined to be appropriate.
November 2023 FCIC-14060 26

41 Procedures for Written Referrals (Continued)

F. Filing Requirements

In all cases where a referral results from a GFP determination, the referral must be referenced 

in the “Notes” section of the ROE Program Review Log. The notes should include the date 

forwarded to RMSD, the issue or vulnerability identified for referral, and the outcome of the 

referral when notified. The referral document itself must be attached to the referral note.

42-50 (Reserved)
November 2023 FCIC-14060 27

PART 6 DISPUTE RESOLUTION

51 Dispute Resolution

General Information – This paragraph provides the avenues to dispute unresolved issued between the 

AIP and RMA, or between policyholders and RMA, with respect to RMA’s determination or 

reconsiderations of a GFP. 

(1) For the AIP:

(a) If there are any disputed or unresolved issues between RMA and the AIP regarding a 

GFP determination during RMA’s review or participation in such determination, such 

disputes, or unresolved issues:

(i) will be elevated to the AIP’s National Claims Manager and to RMA’s RMSD. 

(ii) will not, without RMA concurrence, be discussed in the presence of the 

policyholder or anyone else outside of RMA or the AIP.

(b) If there is a dispute between RMA and the AIP, with respect to RMA’s determination of 

a GFP, the AIP will apply RMA’s written GFP determination or reconsideration according 

to RMA’s policy and procedures. The AIP retains the right to dispute RMA’s actions in 

accordance with administrative appeals procedures found in 7 C.F.R. § 400.169.

(2) For the policyholder:

If the policyholder does not agree with RMA’s GFP determination, the policyholder has a right 

to request a reconsideration (see Para. 52) within 30 calendar days from the receipt of the GFP 

determination letter. The policyholder may also file suit in United States District Court for the 

district in which their farm is located within one year of the date of the GFP determination 

letter or the reconsideration letter. (See Para. 53) 

(a) There is no option for mediation or appeal to NAD for GFP determinations or 

reconsiderations, in accordance with 7 C.F.R § 400.98.

(b) The policyholder is not required to request reconsideration of the GFP determination 

before filing suit against FCIC for GFP determinations, however, the policyholder must 

request a GFP determination from the RO before requesting reconsideration or filing 

suit. 

52 Reconsideration

A. General Information

If the policyholder does not agree with the RO’s GFP determination, the policyholder has a right 

to request a reconsideration of the RMA GFP determination within 30 calendar days of receipt 

of GFP determination letter, by providing the required information to RMA’s DAIS by sending an 

email to rma.rmsd@usda.gov, or by mail at:
November 2023 FCIC-14060 28

52 Reconsideration (Continued)

A. General Information (Continued)

Deputy Administrator for Insurance Services

USDA/RMA/Stop 0801/Room 2004-South 

ATTN: GFP RECONSIDERATION 

1400 Independence Avenue SW

Washington, D.C. 20250-0801

(1) The written request must state the basis upon which the policyholder relies to show 

that: 

(a) the determination was not proper and not made in accordance with the program 

regulations and procedure; or

(b) all material facts were not properly considered in such determination.

(2) First class mail to Washington, D.C. is often delayed for security measures. Participants 

are encouraged to send information by a delivery service (e.g., overnight or 2-day 

certified mail) that records pickup or postmark, and tracks and guarantees delivery.

B. Processing Requests for Reconsideration by RMSD

(1) RMSD will accept a request for reconsideration of a GFP determination if the request:

(a) complies with the requirements in 7 C.F.R. § 400.98;

(b) is in response to an RO GFP determination;

(c) is not related to the items described in Para. 23A – What Does Not Qualify for 

Review; and

(d) is received or postmarked within 30 calendar days of the policyholder’s receipt 

of the GFP determination letter, unless the policyholder can demonstrate an 

inability to timely request the reconsideration. 

(2) If the request does not meet the criteria in Para. 52B(1), RMSD will notify the 

policyholder and RO in writing that the request was not accepted, including the reason 

for non-acceptance, and will provide a copy of the letter to the AIP.

(3) If the request meets the criteria in Para. 52B(1), RMSD will:

(a) notify the AIP and RO of the request for reconsideration;
November 2023 FCIC-14060 29

52 Reconsideration (Continued)

B. Processing Requests for Reconsideration by RMSD (Continued) 

(b) provide a letter to the policyholder acknowledging receipt of the request for a 

reconsideration and allow 10 calendar days for the policyholder to submit any 

additional documentation for consideration, unless an extension is approved in 

writing by RMSD Director; 

(c) review the GFP case documents uploaded by the RO and if necessary, contact 

the RO, the policyholder or AIP for additional information or documentation; 

(d) render a written reconsideration determination of whether the GFP 

determination was properly made by the RO under the standards in Para. 22; 

(e) apply the reconsideration determination to all the crop acreage insured under 

Shareholder policies or companion policies (e.g., landlord/tenant operations, a 

policyholder with a policy as an individual entity and a separate policy for a 

partnership or corporation, etc.). RMA may issue one decision for multiple 

requests on the same acreage, crop, and production method in the same crop 

year or for policyholders who are grouped together because they are making the 

same request; 

(f) brief the RO on the reconsideration determination prior to sending it to the 

Deputy Administrator for Insurance Services for signature.

(4) Reconsideration determinations that uphold an RMA determination that GFP were not 

followed will include a notice of the policyholder’s right to bring suit against FCIC in 

United States District Court and will state the policyholder cannot bring suit against the 

AIP for GFP decisions or determinations made by the RO or DAIS respectively.

(5) RMSD will send the GFP reconsideration letter and exhibits to the policyholder in 

accordance with PII requirements as a PDF copy via encrypted email if available, or by 

certified mail or overnight delivery service. The RO and AIP will also receive an email 

PDF copy of the reconsideration letter (no exhibits).

(6) RMSD will scan, name, and upload the signed GFP reconsideration letter and new 

additional information generated or received during the review to the ROE Program 

Review Log.

C. Reconsideration Applicability

GFP reconsideration determinations issued by RMA are not retroactive and may not be used to 

reopen claims that were settled in prior crop years.
November 2023 FCIC-14060 30

53 Filing Suit Against FCIC

General Information – This paragraph provides the steps that policyholders should take to file suit 

against FCIC in United States district court when the policyholder does not agree with FCIC’s 

determination as issued in a GFP decision letter or reconsideration determination.

(1) If the policyholder does not agree with FCIC’s determination as issued in a GFP decision 

letter or reconsideration determination, they have a right to file suit against FCIC in 

United States district court for the district in which the insured acreage is located.

(2) Any reconsideration determination by RMA regarding GFP shall not be reversed or 

modified as a result of judicial review unless the reconsideration determination is found 

to be arbitrary or capricious.

54-60 (Reserved)
November 2023 FCIC-14060 31

Exhibit 1 Acronyms and Abbreviations

Approved Acronyms 

and Abbreviations Term 

AIP Approved Insurance Provider

AMS Agricultural Marketing Service

APH Actual Production History

ARD Acreage Reporting Date

ARH Actual Revenue History

ARPI Area Risk Protection Insurance

BP Basic Provisions

CES Cooperative Extension Service

CFR Code of Federal Regulations

CIH Crop Insurance Handbook

CP Crop Provisions

DAC Deputy Administrator for Compliance

DAIS Deputy Administrator for Insurance Services

DAPM Deputy Administrator for Product Management

ECIC Eligible Crop Insurance Contract

EHS External Handbook Standards

Exh. Exhibit

FAD Final Agency Determination

FCIC Federal Crop Insurance Corporation

FPAC Farm Production and Conservation

FSA Farm Service Agency

GFP Good Farming Practice

GIP Good Irrigation Practices 

GNP Good Nursery Practices

GSH General Standards Handbook

IS Insurance Services

LAM Loss Adjustment Manual

LASH Loss Adjustment Standard Handbook

LRP Livestock Risk Protection

MPCI Multiple Peril Crop Insurance

NAD National Appeals Division

NCIS National Crop Insurance Services

NIFA National Institute of Food and Agriculture

NOP National Organic Program

NRCS Natural Resources Conservation Service

OGC Office of General Counsel

OIG Office of Inspector General

Para. Paragraph

PASS Policy Acceptance Storage System

PDF Portable Document Format

PII Personal Identifiable Information

PIVR Plant Inventory Value Report

PPA Program Performance Assessment
November 2023 FCIC-14060 32

Exhibit 1 Acronyms and Abbreviations (Continued)

PPASH Program Performance Assessment Standards Handbook

PPSH Prevented Planting Standards Handbook

RCO Regional Compliance Office

RMA Risk Management Agency

RMSD Risk Management Services Division

RSD Reinsurance Services Division 

RO Regional Office

SP Special Provisions

SRA Standard Reinsurance Agreement

Subpara. Subparagraph

USDA United States Department of Agriculture

WFRP Whole- Farm Revenue Protection
November 2023 FCIC-14060 33

Exhibit 2 Definitions 

The following are definitions of terms related to good farming practices or are used in this handbook.

Agricultural Expert: Person(s) who are employed by the Cooperative Extension System or the agricultural 

departments of universities, or other persons approved by FCIC, whose research or occupation is related to 

the specific crop or practice for which such expertise is sought. Persons who have a personal or financial 

interest in the insured or the crop will not qualify as an agricultural expert. For example, contracting with a 

person for consulting would be considered to have a financial interest and a person who is a neighbor would 

be considered to have a personal interest. See also Organic Agricultural Experts.

Note: Agricultural experts currently approved by RMA include persons employed by the Cooperative 

Extension System, the agricultural departments of States and universities, an employee certified 

by the Natural Resources Conservation Service (NRCS) to make determinations regarding good 

cover cropping practices, and persons certified by the ASA as Certified Crop Advisers and 

Certified Professional Agronomists, persons certified by the NAICC as Certified Professional Crop 

Consultants, persons certified by the American Society for Horticultural Sciences as Certified 

Professional Horticulturists, and persons certified by the International Society of Arboriculture as 

Certified Arborists. Persons certified by other certification programs may be recognized as 

agricultural experts by RMA if their participant’s research or occupation is related to the specific 

crop or practice for which such expertise is sought.

Approved Insurance Provider (AIP): A legal entity, including the Company, which has entered into an SRA 

with FCIC for the applicable RY.

Certifying Agent (Organic): A private or governmental entity accredited by the USDA Secretary of Agriculture 

for the purpose of certifying a production, processing, or handling operation as organic.

Conventional Farming Practice: A system or process that is necessary to produce an agricultural commodity, 

excluding organic practices.

Generally Recognized: When agricultural experts or organic agricultural experts, as applicable, are aware of 

the production method or practice and there is no genuine dispute regarding whether the production method 

or practice allows the crop to make normal progress toward maturity and produce at least the yield used to 

determine the production guarantee or amount of insurance.

Good Farming Practices: The production methods utilized to produce the insured crop and allow it to make 

normal progress toward maturity and produce at least the yield used to determine the production guarantee 

or amount of insurance, including any adjustments for late planted acreage, which are those generally 

recognized by agricultural experts or organic agricultural experts, depending on the practice, for the area. The 

AIP may, or the policyholder may request the AIP to, contact FCIC to determine whether or not production 

methods will be considered to be “good farming practices.”
November 2023 FCIC-14060 34

Exhibit 2 Definitions (Continued)

Note: The use of NRCS Conservation Practice Standards will be recognized by agricultural experts for 

the area as considered good farming practices. Therefore, the appropriate use of NRCS 

Conservation Practice Standards will have no impact on Federal crop insurance coverage.

Good Nursery Practices: In lieu of the definition of “good farming practices” contained in section 1 of the 

Basic Provisions, the horticultural practices generally in use in the area for nursery plants to make normal 

progress toward the stage of growth at which marketing can occur and: (1) for conventional practices, 

generally recognized by agricultural experts for the area as compatible with the nursery plant production 

practices and weather conditions in the county; or (2) for organic practices, generally recognized by the 

organic agricultural industry for the area as compatible with the nursery plant production practices and 

weather conditions in the county or contained in the organic plan. The AIP may, or you may request the AIP 

to, contact FCIC to determine whether or not production methods will be considered to be “good nursery 

practices.”

NRCS Conservation Practice Standards: Practice standards recognized and published by Natural Resource and 

Conservation Services (NRCS) which contain technical information about the conservation of soil, water, air, 

and related plant and animal resources. Technical guides used in each field office are localized so that they 

apply specifically to the geographic area for which they are prepared. More information regarding these 

practices can be found at www.nrcs.usda.gov/wps/portal/nrcs/detailfull/national/technical/cp/ncps. 

Organic Agricultural Experts: Persons who are employed by the following organizations: Appropriate 

Technology Transfer for Rural Areas, Sustainable Agriculture Research and Education or the Cooperative 

Extension System, the agricultural departments of universities, or other persons approved by FCIC, whose 

research or occupation is related to the specific organic crop or practice for which such expertise is sought. 

Note: Pre-approval from FCIC is recommended before using organic experts that do not fall into the 

listed organizations.

Organic Crop: An agricultural commodity that is organically produced consistent with Para. 2103 of the 

Organic Foods Production Act of 1990 (7 U.S.C. 6502).

Organic Farming Practice: A system of plant production practices used to produce an organic crop that is 

approved by a certifying agent in accordance with 7 CFR part 205.

Organic Plan: A written plan, in accordance with the National Organic Program published in 7 CFR part 205, 

that describes the organic farming practices that you and a certifying agent agree upon annually or at such 

other times as prescribed by the certifying agent.

Personal Identifiable Information (PII): Any information, in any medium, that identifies a specific individual 

whether on paper or electronic.

Practice: Production methodologies used to produce the insured crop consisting of unique combinations of 

irrigated practice, cropping practice, organic practice, and interval as shown on the AD as insurable.

Sustainable Farming Practice: A system or process for producing an agricultural commodity, excluding 

organic farming practices, that is necessary to produce the crop and is generally recognized by agricultural 

experts for the area to conserve or enhance natural resources and environment. 
November 2023 FCIC-14060 35

Exhibit 2 Definitions (Continued)

Transitional Acreage: Acreage in transition to organic where organic farming practices are being followed; but 

the acreage that does not yet qualify as certified organic acreage.

Written Documentation: Any written information related to the case in hard copy or compatible electronic 

format, including facsimile.
November 2023 FCIC-14060 36

Exhibit 3 (Reserved)
November 2023 FCIC-14060 37

Exhibit 4 File Organization and Storage

A. The ROE Program Review Log

All GFP participation and associated case files will be stored in the ROE Program Review Log. 

This Database is the only approved electronic storage location for GFP files. ROs are no longer 

required to keep paper copies of files as official records, but may have them on hand for 

reference.

B. Organization and Contents

Each electronic GFP file must contain the complete GFP decision, and all documents related to 

the decision must be uploaded to the ROE Program Review Log.

(1) GFP Record (Notice Screen) in the ROE Program Review Log

(a) Upon receiving notice of a request for GFP determination, ROs must ensure all 

data fields in the ROE Program Review Log that are not already filled, are 

completed where applicable. 

(b) Summary Cost Information is entered under “Time and Expenses” for each 

period of time an employee spends working on a GFP determination. Cost 

savings is automatically calculated in the ROE Program Review Log based on the 

original Estimated Indemnity, Summary Total Cost, and the Final Indemnity.

(2) Activities

(a) ROs may add an Activity to a GFP record to document a task, fax, phone call, 

email, letter, or appointment. However, the majority of activities can easily be 

documented and uploaded into the Documents folder as described in Para. B(3) 

below.

(b) When communicating with an AIP for any reason about a GFP, annotate the 

activity in the ROE Program Review Log as an “activity” or in the “notes” section.

(c) Activities that are automatically annotated in the ROE Program Review Log, such 

as automated email activity, should not be deleted.

(3) Documents 

(a) ROs must use the Documents folder in the ROE Program Review Log to upload all 

documents related to the GFP as soon as available. The main document folder is 

accessible by both RMA and the AIP. The RO Documentation Folder is only 

accessible by RMA. All documentation, if not in an electronic format, must be 

scanned as individual PDF files with the exception of:
November 2023 FCIC-14060 38

Exhibit 4 File Organization and Storage (Continued)

B. Organization and Contents (Continued)

(i) Data that is too large to be scanned (such as periodicals);

(ii) Data not suitable for scanning (such as certain types of photographs); or

(iii) Data marked as duplicate data that is already on file.

(b) Most documents related to a GFP file will fit into one of the categories below. 

ROs should create the following folders inside the RO Documentation Folder, 

with the below names to hold documents that fall into each category:

AIP Records

Expert Opinion(s)

Policyholder Records

Underwriting File

Correspondence and Emails

Decision Letter and Exhibits

Interview or Telephone Records

 Photographs 

 Other 

 Reconsideration 

(4) Naming Convention

The Naming Convention for each “PDF” file will be:

(a) Exhibit name - Document Name.

Leave a space between segments. Invalid characters include: # % & * : < > ? / { | 

and }.

Example: EX A - Basic Provisions.pdf

(b) After the GFP determination letter is signed, it becomes the final signed version. 

The final signed version will be scanned prior to mailing and will use the same 

naming convention as follows:

Example: Farmer Farms Potatoes GFP Determination Letter 01-23-16.pdf
November 2023 FCIC-14060 39

Exhibit 4 File Organization and Storage (Continued)

B. Organization and Contents (Continued)

(c) All subsequent letters and exhibits are scanned and uploaded as they are 

delivered or revised. Any revised files must contain the letters “REV” prior to the 

new date (date of revision). 

Example: Farmer Farms Potatoes GFP Determination Letter REV 02-18-16.pdf

(5) ROs may use the following tools and forms, or similar forms to document field notes, 

telephone calls, or interviews. Any form used should be uploaded in the Documents tab 

in the appropriate named folder. ROs should use ROE to document field notes, 

telephone calls, as well as fill out the GFP checklist. Any form used outside ROE should 

be uploaded to the associated folder inside the RO Documentation Folder.

GFP Determination Requests - RO Evaluation Tool

Evaluate each GFP case based on independent circumstances. Always refer to the 

procedures in this Handbook. The request, whether from the AIP or the policyholder, 

should be routed to the RO through the AIP. Review the AIP decision and the request 

before making a determination.

If the AIP decision letter does not meet the requirements in Para. 31B, the RO must 

notify the AIP that the decision letter is unacceptable and require the letter be 

corrected and reissued to the policyholder within 20 calendar days.

If there is no response from the AIP or the GFP decision letter still fails to meet the 

criteria, the RO must make a GFP determination on the farming practice(s) in question, 

and, if necessary, seek additional information from other sources if available.

(6) ROE Program Review Log Appeal Logs

(a) Add a new appeal log in the GFP file whenever a policyholder requests 

Mediation, reconsideration, or files a lawsuit.

(b) Only one appeal type may be active at any one time. Therefore, it is important 

to update the dates and files immediately when several appeal types are elected 

and are held in abeyance until completion of another. Any new appeal shall be 

added. 

(7) Additional Information

(a) Duplicate Materials. The same (exact) information may be received from 

different sources. Use one set for the exhibit(s) and store all duplicated 

materials at the end of the file. This material should be separated with a label 

stating, “Duplicate Materials.” It is not necessary to scan duplicate materials.
November 2023 FCIC-14060 40

Exhibit 4 File Organization and Storage (Continued)

B. Organization and Contents (Continued)

(b) Electronic Format. If everything is received in electronic format (i.e., a CD is 

received and no other emails were generated, no phone calls were made, etc.), 

then the original file would only contain the CD. However, the data would need 

to be extracted from the CD, appropriately labeled following the examples for 

exhibits, pages, etc., converted to PDF and loaded into the ROE Program Review 

Log.

(c) File Retention. The file will be maintained in accordance with RMA’s Record 

Keeping Management System guidelines.
November 2023 FCIC-14060 41

Exhibit 5 Guidelines for Supporting File Records

A. Additional Supporting File Guidelines

In addition to GFP file guidelines contained in Exhibit 4, the RO must:

(1) Develop a record of phone conversations with the policyholder, AIP, or loss adjuster and 

any interviews for the file as they occur.

(a) Use the ROE Program Review Log to document interviews and telephone 

records.

(b) Include the time of day and date; the name, address, and contact information for 

the person you are talking to; the purpose of the call or conversation; and a 

written overview of the conversation. 

In some cases, you may want to document what the person is saying word for word. Do 

not hesitate to ask them to repeat something to ensure that you clearly 

understand what they are saying. 

(c) If the RO representative is asked to keep the person’s name and contact 

information confidential, do so. It is very important to comply with the person’s 

wishes. If the information provided is pertinent to the issue or supports an 

adverse finding, then, if possible, verify the validity of the information through 

other sources.

(2) Ensure that copies of all documents are clear, easy to read, and understandable. 

Include an objective narrative when appropriate to ensure a person unfamiliar with the 

issue can understand its purpose and how it pertains to the proper GFP determination. 

(3) Upload copies of all documents in the ROE Program Review Log.

B. Requesting Information from the AIP

(1) Any requests for AIP action, such as measuring insured acres and determining uninsured 

acres, obtaining documentation, researching a GFP issue, etc., must be in writing and 

submitted to the AIP as soon as possible. 

(a) E-mail may be used so long as it is treated in the same way as any other official 

form of communication; i.e., use the same level of thought and decorum as a 

Manager’s Bulletin or Informational Memorandum; do not use off-handed or 

inappropriate comments.

(b) Follow up telephone requests in writing.

(c) Set a reasonable date for completing the action and document when it is 

complete. 

(d) If not completed by the agreed upon date, immediately contact the AIP by 

telephone and follow up in writing with the AIP about the matter. This lack of 

response may also trigger the referral process.
November 2023 FCIC-14060 42

Exhibit 5 Guidelines for Supporting File Records (Continued)

B. Requesting Information from the AIP (Continued)

(e) The RO must document their actions and the AIP’s responses in the ROE Program 

Review Log.
November 2023 FCIC-14060 43

Exhibit 6 RO GFP Letter Templates

A. General Rules for Writing the Letter

Note: Letters and exhibits mailed to the policyholder must be packaged, marked, and 

processed according to PII requirements.

(1) Follow the format to the extent possible. Address each section as indicated in the 

example.

(2) Write using plain language guidelines.

(3) Write in a logical manner.

(4) Write to follow the exhibits in sequential order to the extent possible.

(5) Use spell check and grammar check.

(6) Watch for tone and personal bias. 

(a) State facts without asserting personal opinion.

(b) Refrain from stating personal opinions or observations assumed but not 

supported by facts.

(7) Use non-controversial terms.

(8) Double check all references and quotations.

(9) Make certain that you use the correct version (applicable crop year and plan of 

insurance) of the crop provisions, BP, CIH, Manager’s Bulletins, etc., used as exhibits.

(10) Update the header to reflect the policyholder’s name and crop year. 

(11) The template letter may not be in the exact font and margin size of the approved letter 

format used by RMA for correspondence. Please format accordingly in terms of 

letterhead, font, and margins.

(12) Include exhibits for any GFP determination.

(13) Include an Exhibit Index at the end of the letter.
November 2023 FCIC-14060 44

Exhibit 6 RO GFP Letter Templates (Continued)

B. RO Policyholder Acknowledgement Letter Template

The following templates are suggested formats for RO GFP determinations. ROs may adjust 

language as appropriate for each particular case.

(DATE)

(Policyholder or Legal Representative Name/Title)

(Address)

(Address)

Re: Good Farming Practice Determination for (Name of Insured)

(Crop Year), (Crop), (Policy #XXXX), (County, State)

Dear Policyholder or Legal Representative Name/Title: 

The XXX Regional Office (RO) received your (Date of Request) request for a Good Farming 

Practice (GFP) determination. According to your letter, you disagree with the GFP decision 

made by (Name of AIP) on (Date of AIP decision letter). 

Unless an extension is approved in writing, the (XXX RO) will begin the review on (Date 10 days 

from receipt of this letter). The 10-day delay allows you to provide additional documentation 

that you want to be considered in the review. If the (XXX RO) does not receive additional 

documentation from you by this date, it will use the information provided by (Name of AIP) and 

information you provided in your request.

You may send additional documentation by email (RO email address) or to the following 

address:

(Name)

RO Director

USDA, Risk Management Agency

(Name of Regional Office)

(Address)

If you prefer to send electronic documents, please make sure they are legible. We will provide a 

status of the review every forty-five (45) calendar days from (date the review begins). Once our 

review is complete, you will receive the RMA GFP determination letter by encrypted email or 

via overnight mail or certified mail.

United States

Department of

Agriculture

Farm Production 

and 

Conservation 

Risk

Management 

Agency

RO Address
November 2023 FCIC-14060 45

Exhibit 6 RO GFP Letter Templates (Continued)

B. RO Policyholder Acknowledgement Letter Template (Continued)

If you have any questions, please contact me at (Phone number).

Sincerely,

(Name)

Director

(Regional Office Name)
November 2023 FCIC-14060 46

Exhibit 6 RO GFP Letter Templates (Continued)

C RO GFP Determination Letter Template

 

(Date) 

VIA CERTIFIED MAIL/EMAIL – XXXX XXXX XXXX XXXX XXXX

(Policyholder or Legal Representative Name/Title)

Address)

(Address)

(Address)

RE: Good Farming Practices Determination for (Name of Policyholder) 

(Crop Year) (Crop) (Policy #XXXXXXX)

(County Name), (State Name)

Dear Policyholder or Legal Representative Name/Title: 

This Good Farming Practice (GFP) determination originates from your Approved Insurance 

Provider (AIP), ABC Insurance’s [DATE] GFP decision concerning the production methods you 

used for your 20XX Corn Crop. 

Based on our review of reference materials submitted by you and ABC Insurance, the Risk 

Management Agency (RMA), has determined that your weed control and fertilization practices 

were not GFPs. 

(Add a brief summary of the RO determination. Placing the determination at the top of the 

letter provides an immediate answer to the reader.). Example: 

Issues to be Determined

(State the issues that you must determine in the format below.). Example:

In accordance with the 2023 Good Farming Practice Determination Standards Handbook and 

the Common Crop Insurance Policy (Basic Provisions), RMA, on behalf of the Federal Crop 

Insurance Corporation (FCIC), is required to make a GFP determination. 

The issues that must be resolved in this case are:

1. Whether you applied adequate herbicide on your corn crop in a timely manner to 

control weeds which would allow your crop to make normal progress toward maturity 

and produce at least the yield used to determine the production guarantee.

United States

Department of

Agriculture

Farm Production 

and 

Conservation 

Risk

Management

Agency

RO Address
November 2023 FCIC-14060 47

Exhibit 6 RO GFP Letter Templates (Continued)

C. RO GFP Determination Letter Template (Continued)

2. Whether you applied adequate fertilizer on your corn which would allow your crop to 

make a normal progress toward maturity and produce at least the yield used to 

determine the production guarantee.

Background 

(These paragraphs summarize the events that led to the GFP determination. If any pertinent documents 

relate to the event or were created due to the event, cite the document as an exhibit using footnotes. List 

events in chronological order. Use the Analysis section to reference Expert Opinions and discussion about 

them. Summarize the opinions without quoting large chunks of the opinion.). Example:

On [DATE], Mr. Looker, the Loss Adjuster for ABC Insurance, issued an Adjuster Special Report which 

documents the conditions of the fields in [Name] County, [State]. 

On [DATE], you had a conversation with Mr. Looker at your farm in which it was requested fertilizer, seed, and 

herbicide receipts. This request was documented on an Adjuster’s Special Report. 

On [DATE] you prepaid for your purchase of fertilizer and herbicides from the Feed and Seed Store in 

[location]. ABC Insurance provided copies of these receipts, which showed [DATE] as the date of invoice. 

Analysis

(In this section, break out the issues separately and begin the RO analysis of each issue in this order: Basis 

for AIP’s decision; Appellant’s position; RMA reasoning and finding; Conclusion. Do not place these headings 

in the Analysis. Repeat the analysis for each issue.) Example: 

To complete this GFP determination, RMA carefully reviewed the ABC Insurance decision file and 

documentation provided by you. RMA also reviewed published documents as outlined below to determine if 

the practices you used would generally allow you to reach the production guarantee.

Issue 1: Whether you applied adequate herbicide on your corn crop in a timely manner to control weeds 

which would allow your crops to make a normal progress toward maturity and produce at least the yield 

used to determine the production guarantee.

To complete this GFP determination, RMA carefully reviewed the ABC Insurance GFP decision file and 

documentation provided by you. RMA also reviewed published documents as outlined below to determine if 

the practices you used would generally allow you to reach the production guarantee.

1

See Exhibit A

2

See Exhibit A

3

See Exhibit B
November 2023 FCIC-14060 48

Exhibit 6 RO GFP Letter Templates (Continued)

C. RO GFP Determination Letter Template (Continued)

In your request for a GFP determination, you assert that ABC Insurance’s decision that you failed to carry out 

GFPs is erroneous. Contrary to ABC Insurance’s contentions, you argue that the actual cause for your low 

yields was weather conditions (rain and wind), prior to and during the growing season, that delayed the 

effectiveness of your weed control and fertilizer practices. In support of your position, you cited expert Dr. 

Pro’s opinion, that the crops’ poor results were caused by circumstances beyond your control, namely, 

adverse weather conditions. However, RMA does not find any merit in your argument.

(Continue RMA Analysis for this issue...then conclude.). Example:

Because of the above-mentioned reasons, RMA has determined that your herbicide application practice failed 

to follow generally recognized GFP for the corn crop and is not an insurable cause of loss.

(Continue Analysis with Issue 2.)

Conclusion

(Summarize the RO findings and include the last two sentences below.). Example:

RMA finds that you failed to follow generally recognized good farming practices for your corn crop which is 

not an insurable cause of loss. This GFP determination does not determine whether an insured cause of loss 

was or was not present, or reconsider any other decision made for your policy. In addition, this determination 

applies to all insured shareholders, landlords, and tenants with an interest in the 20XX corn crop on all acreage 

for which this determination is made.

Appeal Rights

If you do not agree with FCIC’s GFP determination, you may:

(1) Request reconsideration of the RO GFP determination within 30 calendar days of receipt 

of written notice of the adverse decision by providing the required information to the 

RMA Deputy Administrator for Insurance Services at:

(a) Email rma.rmsd@usda.gov, or;

(b) By mail to:

4 Exhibit D

5 Exhibit H
November 2023 FCIC-14060 49

Exhibit 6 RO GFP Letter Templates (Continued)

C. RO GFP Determination Letter Template (Continued)

Deputy Administrator for Insurance Services

USDA/RMA/Stop 0801/Room 2004-South 

ATTN: GFP RECONSIDERATION 

1400 Independence Avenue SW

Washington, DC 20250-0801

The written request must state the basis upon which you rely to show that the determination was not proper 

and not made in accordance with the program regulations and procedure, or that all material facts were not 

properly considered in such determination.

First class mail to Washington, DC is often delayed for security measures. Participants are encouraged to send 

information by email or by a delivery service (e.g., overnight or 2-day certified mail) that records pickup or 

postmark, and records and guarantees delivery.

OR

(1) File suit in United States District Court for the district in which your farm is located in 

accordance with section 20 of the Basic Provisions within one year of the date of this 

letter, or the date of your reconsideration determination if you request reconsideration. 

You are not required to request reconsideration from FCIC before filing suit.

Arbitration or Mediation Rights:

If you do not agree with the amount your insurance company assessed for your failure to follow good farming 

practices, you may choose to arbitrate or mediate the dispute in accordance with section 20(d) of the Basic 

Provisions. You may not appeal such amount to FCIC.

If you have any questions about this GFP determination, you may contact (name of contact) at (contact’s 

telephone number).

Sincerely,

_______________________

Name

[RO] Regional Office Director

Risk Management Agency

Email 

cc: (Name of AIP Point of Contact) 

(AIP Address)

cc: (Policyholder’s Legal Representative)

(Address)

cc: Director, (Name of Compliance Office)
November 2023 FCIC-14060 50

Exhibit 6 RO GFP Letter Templates (Continued)

C. RO GFP Determination Letter Template (Continued)

The Exhibit Index and exhibits are attachments to the RO determination Letter and must be included at the 

end of the letter. (List exhibits in numeric order using the Exhibit Index. Make sure the exhibit list follows 

the exhibit order as they appear in footnotes. Send each referenced exhibit to the policyholder with the 

determination letter if not already provided.)

Example: 

Exhibits: 

A. Mr. Looker’s Adjuster’s Special Report, [DATE]

B. Feed and Seed Store Receipts, [DATE]

C. Photographs of neighboring fields, [DATE]

D. Policyholder’s Statement, [DATE]

E. Feed and Seed Store Work Statement, [DATE]

F. ABC Insurance GFP Decision, [DATE]

G. Policyholder’s Request for GFP Determination, [DATE]

H. Dr. Pro’s Expert Opinion, [DATE]

I. NOAA Data, [DATE]

J. Extension Reference Bulletin, [DATE]

K. AD-2007 FSA/RMA Compliance Referral, [DATE]

L. Ms. Expert’s Expert Opinion, [DATE]

M. [NAME] Coop Statement of Work, [DATE]
November 2023 FCIC-14060 51

Exhibit 7 RMSD Reconsideration Letter Template 

A. RMSD Reconsideration Letter Template Language

RMSD must use the same basic format as the RO GFP determination letter and follow all 

general rules for writing the letter in Exhibits 4 and 5, except:

(1) for the first page of the RMSD reconsideration letter, where RMSD will add in all caps 

and bold text if the RO’s GFP decision has been UPHELD or NOT. 

(2) the letter will be written in first person and contain the language in Exhibit 6B.

B. RMSD Reconsideration Letter Template

VIA OVERNIGHT MAIL/EMAIL

(Policyholder or Legal Representative Name/Title)

(Address)

(Address)

(Address)

RE: Good Farming Practices Reconsideration 

for (Name of Policyholder) 

(Crop Year) (Crop) ( Policy #XXXXXXX) 

(County Name), (State Name)

Dear Policyholder or Legal Representative Name/Title 

On behalf of the Federal Crop Insurance Corporation (FCIC), I have completed my reconsideration review of 

the [RO Name]’s good farming practice (GFP) determination for your [Crop Year] [Crop Name]. This 

reconsideration decision only applies to determinations of GFP and does not determine that an insured cause 

of loss was or was not present, nor does it reconsider any other decision made for your policy.

To complete this GFP reconsideration, I have carefully reviewed the [RO Name] RO determination file, related 

information you submitted, and documentation provided by your Approved Insurance Provider (AIP), [AIP 

Name]. After careful review, I (concur with the [RO name]) (concur in part with the [RO name])(disagree with 

the [RO name]) that GFP were not followed and the determination (IS UPHELD)(IS NOT UPHELD).

(For more examples, and sample template letters, see the GFP SharePoint Site.)
November 2023 FCIC-14060 52

Exhibit 8 GFP Decision Appeal Process

GFP Decision Appeal Process

(Basic Provisions, Section 20)

The AIP makes an initial decision

and determines if the Policyholder 

carried out generally recognized 

GFPs or not.

If the Policyholder disagrees with 

the AIP’s determination of the 

amount of loss in production or 

value. 

Request an RMA RO 

Determination of the GFP Decision

within 30 days of AIP Decision. 

File Judicial Review of RMA RO 

Determination or RMA DAIS 

Reconsideration within 1 year of 

the date of the latest RMA 

decision letter. 

Request RMA DAIS 

Reconsideration of the RO 

Determination within 30 days of 

receipt of RO Determination. 

Mediate or arbitrate the assigned 

production with the AIP within 1 

year from AIP Decision

Determination. 

If the Policyholder disagrees with 

the AIP’s GFP decision

determination. 

If the Policyholder does not agree with RMA RO’s GFP 

determination (Policyholder is not required to request 

Reconsideration prior to filing suit). 

Policyholder may elect one or both paths.