ARPA LIST REVIEW STANDARDS

SUMMARY OF SCENARIOS

The scenarios used to generate the ARPA List are subject to change from year to year. As 

such, the narrative associated with the ARPA list shall be retrieved from HyDRA. Once the 

ARPA list is generated the narrative is located under the Docs icon in the upper right 

toolbar. 

REVIEW STANDARDS

For the agent scenarios, the primary focus of the review will be the production and acreage 

reports used to establish the guarantee. Absent collusion with a loss adjuster, an 

inappropriately high guarantee is the main mechanism by which the actions of the agent 

could result in excessive losses. For the loss adjuster scenarios, the claim determination 

will be the focal point of the review to make sure the claim was worked in accordance with 

procedure and accurately reflects the magnitude of the actual loss. The intent of the ARPA 

List review and monitoring program is to identify, correct and/or deter the activities and 

interpretations of agents and loss adjusters that may be contributing to the poor loss 

experience. In general, data mining can only determine whether a given claim is 

anomalous; it cannot establish whether the loss is legitimate or identify the specific factors 

that contributed to the anomalous indication. As previously noted, being on the ARPA List 

does not mean the agent or adjuster is engaged in wrongdoing. Rather, it is an indication 

that the loss experience is not consistent with peers and further review and monitoring are

warranted. 

I. Review and Monitoring

1. Agent Scenarios – Underwriting Review: For each eligible crop insurance 

contract (ECIC) associated with an agent on the AIP’s ARPA List, conduct an 

underwriting review of the acreage and production reports, along with the 

supporting documentation, used to establish the insurance guarantee for the crop 

insured for the reinsurance year that coincides with the year the ECIC appears on 

the ARPA List. For example, the 2021 ARPA List is distributed to AIPs in May 

2021 and includes a list of policies that had claims for the 2020 reinsurance year. 

The AIP is to conduct an underwriting review of the 2021 acreage and production 

reports, not a review of the reports for the 2020 reinsurance year. The 

requirements for the acreage and production reports are described in the Crop 

Insurance Handbook (CIH) FCIC 18010-1, Parts 12 and 13, respectively. The 

intent of the underwriting review is to ensure the accuracy of the information used 

to establish the guarantee in accordance with instructions provided in the CIH, 

and that procedures are applied appropriately. 
A. Acreage Report (CIH Part 12):

Review the information submitted on the acreage report (CIH Part 12, section 

1211). The acreage report should meet all filing requirements described in 

section 1202, with appropriate adjustments for failure to file an acceptable 

acreage report (section 1203) or for an inaccurate acreage report (section 

1204). Follow the guidance provided by sections 1212 through 1236 to 

validate the information submitted on the acreage report. Among the questions 

that the reviewer should be able to answer affirmatively for a valid, accurate 

acreage report: 

‒ Are all acres reported accurately as described in the CIH?

‒ Are land classifications correct?

‒ Were guarantee reductions based on planting dates assessed as 

required?

‒ Is the share for each unit reported correctly?

‒ Does the unit structure selected meet the unit structure requirements?

‒ Were the conditions allowing a revised acreage report met?

B. Production Report and APH Database (CIH Part 13 and Part 15, respectively): 

Review the information submitted on the production report (CIH Part 13, 

section 1308), following the review, verification and correction process 

specified in section 1309. The requirements for an acceptable production 

report are covered in section 1302 and production reporting requirements are 

described in section 1303. Assure the information is used appropriately to 

construct the Actual Production History (APH) databases following the 

procedures described in CIH Part 15. The intent of the review is to assess the 

production report and APH databases for yield accuracy, records 

acceptability, and unit structure used to establish the approved APH yields 

entered on the acreage report. 

Among the questions the reviewer will be able to answer affirmatively for 

valid, accurate production reports and APH databases are the following:

‒ Are the production records used to support the production certification 

acceptable?

‒ Do the production records submitted support the unit structure?

‒ Do the production records support the approved APH?

‒ Do APH databases contain the correct yields (actual, assigned, nonactual, etc.)?

‒ Were the rules for construction of APH databases applied correctly?

‒ Does the Approved APH Yield accurately reflect (1) the information 

from the production report and supporting documentation, and (2) the 

correct use of applicable procedures? 
2. Adjuster Scenarios -- Claim Review: For each ECIC on the ARPA List associated 

with a loss adjuster, conduct a review of the claim for the year shown on the 

report. For example, the 2021 ARPA List includes policies that had a 2020

reinsurance year claim. The claim review would be conducted of the reinsurance 

year 2020 policy. The intent of the claim review is to provide reasonable 

assurance that the claim was legitimate, worked according to applicable 

procedures, and the payment was correct.

A. Below are the types of questions the reviewer will be able to answer 

affirmatively following the claim review: 

‒ Did the adjuster include all information required by the Loss Adjustment 

Manual in the file?

‒ Was a timely notice of loss provided in accordance with policy 

provisions?

‒ Was the cause of loss for all units correct and confirmed by the adjuster?

‒ Was unit structure, practice, type, variety, rotation requirements, etc. all 

confirmed by the adjuster?

‒ Was production to count calculated correctly?

‒ If part of the claim, did the adjuster use the correct quality factors (test 

weight, moisture, damage, etc.)?

‒ Were applicable appraisal procedures used correctly per the applicable 

crop LASH?

‒ Did the adjuster make a visual inspection of the loss units?

‒ Were all acres in each unit/line accounted for?

B. For each claim, evaluate the loss adjuster’s determination and documentation 

for similar damage or in the adjuster’s notes on the Production Worksheet. 

C. For each claim, evaluate the adjuster’s determination that all production was 

accounted for, per the Loss Adjustment Manual Standards Handbook (FCIC25010-1), Parts 202(8)(d) and 901(5), as shown below:

“202(8)(d) – Inspect insured crops and establish all harvested, UH, and 

potential production for all units of each crop being inspected in 

accordance with Part 9. Determine (measure, if applicable) all farm-stored 

production from the loss units of the crop being inspected in accordance 

with Part 9.”

“901(5) – The adjuster must obtain and document an estimate of total 

production per acre for each undamaged or non-loss unit of the 

indemnified crop from the insured or the insured’s authorized 

representative and record as instructed in the crop LASH.”

D. For each claim, evaluate the process used to verify the cause of loss and 

determine whether good farming practices were carried out.
E. For each ECIC, review the production worksheet for loss units and estimated 

production for all non-loss units to determine if the amounts are reasonable. If 

the amounts are not reasonable, resolve yield and/or production-to-count 

discrepancies (inconsistencies, anomalies, etc.) that arise from the review of 

production from loss and non-loss units. 

3. Agent & Adjuster Scenarios – Underwriting and Claim Reviews: The ARPA List 

may contain ECICs associated with both an agent and a loss adjuster. In these 

situations, the AIP will conduct both an underwriting review per Part I.1 “Agent 

Scenarios – Underwriting Review” and a claim review per Part I.2 “Adjuster 

Scenarios – Claim Review”.

4. All Scenarios -- Quality Control Review: Any claim filed for an ECIC and the 

associated crop and county identified under any of the agent and/or adjuster 

scenarios for the crop year in which the ECIC appears on the ARPA List is a 

mandatory quality control review. Thus, for example, if a producer first files a 

prevented planting claim and later files a claim for loss of production following 

harvest for an ECIC on the AIP’s ARPA List, the AIP would be required to 

conduct two quality control reviews following its normal procedures for such a 

review.

A. For each claim, evaluate the loss adjuster’s determination and documentation 

for similar damage or in the adjuster’s notes on the Production Worksheet. If 

the loss adjuster determined that damage was similar, interview the loss 

adjuster(s) and ask him/her to identify the similar acreage in the area used for 

loss comparison for the claim units under review.

B. For each claim, evaluate the adjuster’s determination that all production was 

accounted for. If the adjuster determined that all production was accounted 

for, interview the adjuster, and ask him/her to describe how production was 

verified for loss units and he/she estimated production on non-loss units, per 

the Loss Adjustment Manual Standards Handbook, Parts 202(8)(d) and 

901(5). 

C. For each claim, interview the loss adjuster and evaluate the loss adjuster’s 

process to verify the cause of loss and whether proper planting and care of the 

crop was carried out as it pertains to fertilizer, herbicides, irrigation, etc. 

D. For each ECIC, review the production worksheet for loss units and estimated 

production for all non-loss units. Resolve yield and/or production-to-count 

discrepancies (inconsistencies, anomalies, etc.) that arise from the review of 

production from loss and non-loss units, e.g., production on loss unit well 

below county average while production on non-loss unit is well above county 

average. 
If underwriting or loss adjustment errors or concerns are identified through the monitoring 

and review activities described in Parts I.1-I.4 above, interviews of the agents, loss 

adjuster, and/or insured, as applicable, may be warranted to determine the cause of the error 

and resolve the concern.

II. Reporting of Results

1. For each ECIC subject to a review under any agent and/or adjuster scenario 

described above (Parts I.1 to I.4), the AIP shall:

A. Conduct an underwriting review, claim review, and/or quality control review 

as applicable.

B. Submit the appropriate P57 and P57A records through the Policy Acceptance 

and Storage System (PASS). A P57 record must be submitted for each review

utilizing the data mining review code.

2. For each agent and adjuster on the AIP’s ARPA List, the AIP shall: 

A. Prepare a written evaluation that summarizes the results of monitoring and 

review program. 

B. The written evaluation must include:

i. For the agent scenarios, a summary of the results of the acreage and 

production report reviews (Parts I.1. or I.3 above), along with the results 

of any quality control reviews conducted pursuant to Part I.4 above. 

ii. For the adjuster scenarios, a summary of the results of the claim reviews 

conducted for losses from the prior year (paragraphs I.2 or I.3 above), 

along with the results of any quality control review conducted pursuant to 

paragraph I.4 above. 

iii. Specific errors, omissions, deficiencies, etc. identified with respect to said 

agents and adjusters during the review and monitoring program.

iv. Any corrective actions taken by the AIP with respect to said agents and 

adjusters.

C. The written ARPA List evaluations should be submitted directly to RMA 

Compliance through the AIP HyDRA application maintained by the Center 

for Agribusiness Excellence (CAE). Send the documentation to the onsite 

RMA employee at CAE. To upload the documentation in HyDRA, utilize the

AIP User Manual located in the Doc Library icon on the AIP HyDRA 

homepage. Submit summary evaluations after all reviews have been

completed. The evaluations should no longer be submitted with the AIP’s 
annual Plan of Operations submission as discussed in the TPEP/TPER 

Guidance, Section II(3)(A). 

3. Provide appropriate notification to RMA Compliance for follow up on any issues 

relating to potential fraud, waste, or program abuse uncovered during the reviews, 

per section IV of SRA Appendix IV. 

4. AIPs should take action to collect improper payments and to resolve any 

questionable actions by a policyholder, agent, or adjuster.