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 

for the 2018 Whole-Farm Revenue Protection (WFRP) Pilot Policy regarding whether section 3(a)(3) 

and (4) requires an insured to submit a Substitute Schedule F to the approved insurance provider when 

the insured filed a Schedule F, that covers 100 percent of their farm operation, with the Internal 

Revenue Service (IRS).

The relevant policy provisions provided by the requestor section 3(a)(3) and (4):

3. Qualifying Person Criteria and Insurance Eligibility

(a) To be considered a qualifying person, you must:

...

(3) File either a Schedule F tax form or other farm tax forms that can be converted to a 

Substitute Schedule F;

(4) The Schedule F, or Substitute Schedule F, must cover 100 percent of your farm 

operation.

Interpretation Submitted by Requestor(s)

The first requester’s interpretation of section 3(a) of the WFRP Policy is when the insured files a 

Schedule F tax form with the IRS that covers 100% of their farming operations, they should not be 

required to also submit a Substitute Schedule F to the Approved Insurance Provider (AIP) because the 

AIP should rely solely on the Schedule F tax forms that were filed with the IRS. It is also the first 

requester’s interpretation that, under section 3 of the Policy, it is improper and contrary to the Policy 

language for the AIP to request that the insured to fill out and submit a Substitute Schedule F after the 

insured actually filed Schedule F tax forms with the IRS for their farm operation and submitted the 

Schedule F forms with their application for the WFRP Policy, and accepted by the AIP. The first 

requester further believes that once the WFRP Policy has been issued to the insured and approved 

based upon the insured’s Schedule F forms filed with the IRS for the five-year history period, the AIP 

cannot use information provided on a Substitute Schedule F to later cancel the policy or adjust 

coverage levels. The first requester interprets this section to prohibit the AIP from considering any 

information from a Substitute Schedule F when the insured has filed Schedule F tax forms with the 

IRS that cover 100% of their farming operation in accordance with section 3(a)(3) & (4) of the WFRP 

Policy. Similarly, the first requester believes that it is contrary to Section 3(a) of the Policy for the 

AIP to use information on Substitute Schedule F tax form to retroactively cancel the insured’s policy 

after the policy was initially issued.

The second requester interprets that section 3(a) of the WFRP Policy sets forth the criteria that a 

person must meet to be considered a “Qualifying Person.” If a person meets the minimum criteria for 

a “Qualifying Person,” as defined in section 3(a), it simply means that the person is qualified to 

purchase a WFRP Policy. Being a “Qualified Person” does correlate to the amount of coverage or 

excuse an insured’s obligation to comply with all conditions of the WFRP Policy. Eligibility for 

coverage, the determination of allowable expenses and revenue, and the amount of coverage is 

established based on the insured meeting all of the applicable requirements of the WFRP Policy.
Enclosure Page 3

FCIC Interpretation of Procedure

Federal Crop Insurance Corporation Determination

FCIC disagrees with the first requester’s interpretation that section 3(a) of the 2018 WFRP Pilot 

Policy that when an insured files a Schedule F tax form with the IRS that covers 100% of their

farming operations, they should not be required to submit a Substitute Schedule F to the AIP. Section 

3 of the WFRP Pilot Policy sets forth eligibility requirements and it does not describe what documents 

may be requested by the AIP. FCIC does agree with the first requester that an AIP may not request a

Substitute Schedule F if a Schedule F is filed with the IRS. Sections 16(a)(1)(i), (ii), and (c)(1) states

under what conditions the insured is required to submit a Substitute Schedule F. Although, FCIC 

agrees the AIP cannot request a Substitute Schedule F under the conditions stated above, additional 

information requested by the AIP and provided by the insured could affect the insured’s eligibility for 

a WFRP policy under section 3 of the WFRP Pilot Policy. Failure to establish and maintain eligibility 

for the policy may lead to cancellation, denial, or adjustments to coverage per sections 15(i) or (j) of 

the policy.

FCIC agrees with the second requestor’s interpretation that section 3(a) of the 2018 WFRP Pilot 

Policy sets forth the minimum requirements the insured must meet to be considered a “Qualified 

Person” for purposes of WFRP coverage. FCIC disagrees with the second requester’s statement that

“[b]eing a ‘Qualified person’ does correlate to the amount of coverage or excuse an insured’s 

obligation ....” However, FCIC would agree if the statement read, “Being a ‘Qualified Person’ does 

not correlate to the amount of coverage or excuse an insured’s obligation to comply with all conditions 

of the 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.