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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 

for the 2018 policy year in the determination of whether section 9(g) of the 2018 Whole-Farm 

Revenue Protection (WFRP) Pilot Policy allows an Approved Insurance Provide (AIP) to cancel or 

terminate a policy if they believe the information provided by the insured is incorrect, not supported 

by verifiable records, or they cannot reconcile the information on the Schedule F forms with 

information on the Substitute Schedule F forms they requested.

The relevant policy provision provided by the requestor is section 9(g):

9. Coverage

(g) We will reduce your approved revenue and any indemnity or deny coverage at any time we 

become aware that the information used to determine your approved revenue is incorrect or 

is not supported by verifiable records. Your premium will be adjusted to reflect any revised 

approved revenue.

Interpretation Submitted by Requestor(s)

The first requester’s interpretation is that section 9(g) specifically allows the AIP to, “reduce approved 

revenue and any indemnity or deny coverage at any time we become aware that the information used 

to determine [the insured’s] approved revenue is incorrect or is not supported by verifiable records. 

[The insured’s] premium will be adjusted to reflect any revised approved revenue.” The first requester 

also interprets this section to not, however, state that the AIP has authority to cancel or terminate an 

insurance policy if the AIP believes that information provided by the insured is incorrect, not 

supported by verifiable records, or the AIP cannot reconcile the information on Schedule F forms with 

information on Substitute Schedule F forms it requested. It is also the first requester’s interpretation 

that section 9(g) only allows the AIP to reduce approved revenue or indemnity, or deny coverage for a 

claim for indemnity, but section 9(g) cannot be relied upon by the AIP to cancel or terminate a WFRP 

policy, as nowhere in this section does it refer to an AIP’s right to cancel coverage. The first requester 

believes this interpretation is consistent with Section 4, which enumerates the specific grounds on 

which the policy can be cancelled. It is a continuous policy and cannot be cancelled for any reason by 

the AIP.

The second requester interprets section 9(g) as it does not expressly provide for the cancellation of the 

policy, the section permits the company to reduce approved revenue, including reducing the approved 

revenue to zero (0), at any time the company discovers the information is incorrect or is not supported 

by verifiable records, including after coverage attaches or a notice of loss is filed. In addition, the 

second requester interprets section 9(g) to not prohibit the cancellation of a policy authorized by other 

sections of the WFRP Pilot Policy.

Federal Crop Insurance Corporation Determination

FCIC agrees with the first requester’s interpretation that section 9(g) of the 2018 WFRP Pilot Policy 

authorizes the AIP to reduce the insured’s approved revenue, at any time, when it is determined the 

information used to determine the insured’s approved revenue is incorrect or cannot be verified. FCIC 

also agrees with the second requester’s interpretation that the reduction in approved revenue can be to 

zero (0), including after coverage attaches or a notice of loss is submitted. Furthermore, FCIC agrees 

with the first requester’s interpretation that section 9(g) does not explicitly give an AIP the authority to 
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FCIC Interpretation of Procedure

cancel or terminate a WFRP policy. However, FCIC also agrees with the second requester’s 

interpretation that section 9(g) does not prohibit the cancellation of a WFRP policy when authorized 

by another section of the 2018 WFRP Pilot Policy; specifically, when 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.

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.