Enclosure Page 2

FCIC Interpretation of Procedure

Risk Management Agency Interpretation of Federal Crop Insurance Corporation Provisions:

Subject: Request dated March 8, 2021, to the Risk Management Agency (RMA) for an interpretation 

of the 2018 Whole-Farm Revenue Protection (WFRP) Pilot Policy regarding whether sections 15(j), 

(k), and (l) allows an Approved Insurance Provider (AIP) to cancel or terminate a policy.

The relevant policy provisions provided by the requestor are sections 15(j), (k), and (l):

15. Required Reports

(j) You must provide, sign, and certify all required reports and you are responsible for the 

accuracy of all information contained in those reports. You should verify the information 

on all reports prior to submitting them to us. If you submit information on any report that 

is different than what is determined to be correct and the information you originally 

submitted resulted in:

(1) A lower insured revenue than the corrected insured revenue, the insured revenue 

under this policy will remain consistent with the reported information and all revenue 

will be included as revenue to count; or

(2) A higher insured revenue than the correct insured revenue, the information contained 

in the Farm Operation Report will be revised to be consistent with the correct 

information and your insured revenue will be lowered to the corrected amount.

(k) If we discover you have incorrectly reported any information on your reports for any policy 

year, corrections may be made if authorized in section 41 but you may be required to 

provide documentation in subsequent policy years substantiating your reports for those 

policy years, including but not limited to, an acreage measurement service at your own 

expense. If the correction of any misreported information would affect an indemnity, or 

replant payment that was paid in a prior policy year, the claim will be adjusted and you 

will be required to pay any overpaid amounts.

(l) Errors in reporting may be corrected by us at any time we discover the incorrect 

information and unless corrections are authorized in section 41.

Interpretation Submitted by Requestor(s)

The first requester’s interpretation is that section 15(j), (k), and (l) allow an AIP to make revisions or 

adjustments to an insured’s coverage or indemnity in the event the AIP believes that the insured has 

submitted information that is inaccurate or incorrect on the required reports. However, the first 

requester does not interpret section 15(j), (k), or (l) to permit an AIP to cancel or terminate a policy. 

The first requester continues that there is nothing in section 15(j), (k), or (l) that would allow an AIP to 

cancel the policy if the AIP believes the information is incorrect, inaccurate, or if AIP is unable to 

reconcile the information provided with the Schedule F tax forms, Whole Farm History Report, 

Income and Expense Worksheets, or any other reports provided by the insured during the policy year. 

Rather, Section 15 permits adjustments in coverage only. There is an obligation to work with the 

insured to determine the appropriate coverage, not to simply cancel the policy.

The second requester interprets sections 15(j), (k), and (l) of the WFRP Policy to authorize an AIP to 

revise or adjust an insured’s coverage or indemnity in the event the insured has submitted information 
Enclosure Page 3

FCIC Interpretation of Procedure

that is inaccurate or incorrect on the required reports. If the AIP determines that there is a lack of 

verifiable records to support or accurately establish the allowable expenses and allowable revenue, 

sections 15(j), (k), and (l) do not prohibit the AIP from cancelling the coverage.

Federal Crop Insurance Corporation Determination

FCIC agrees with both requester’s interpretation that sections 15(j), (k), and (l) of the 2018 WFRP 

Pilot Policy allow the AIP to revise or adjust an insured’s coverage or indemnity. FCIC agrees with 

the first requester’s interpretation that sections 15(j), (k), and (l) do not permit an AIP to cancel or 

terminate a policy.

However, if the AIP requests additional information to verify what has been reported by the insured 

and that information results in the insured or the insured’s farm operation not meeting the 

requirements of eligibility per section 3 of the 2018 WFRP Pilot Policy, the AIP may cancel the 

insured’s WFRP policy.

In accordance with section 33(a)(1) of the WFRP Pilot Policy, this FCIC interpretation is generally 

applicable and binding in any mediation or arbitration. In accordance with section 33(a)(1), any 

appeal of this interpretation must be in accordance with 7 C.F.R. part 11.