Enclosure Page 2

FCIC Interpretation of Procedure

Risk Management Agency Interpretation of Federal Crop Insurance Corporation (FCIC) 

Provisions:

Subject: Request dated July 23, 2021, to the Risk Management Agency for an interpretation for the 

2018 policy year in the determination of whether section 15(l) of the 2018 Whole-Farm Revenue 

Protection (WFRP) Pilot Policy authorizes an Approved Insurance Provider (AIP) to correct errors in 

reporting at any time they discover an error.

The relevant policy provisions are:

15. Required Reports.

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

information unless corrections are authorized in section 41.

41. Correction of Errors.

(a) In addition to any other corrections allowed in your policy and subject to section 41(b), we 

may correct:

(1) Within 60 days after the sales closing date, any incorrect information on your 

application or provided by the sales closing date, including identification numbers 

for you and any person with a substantial beneficial interest in you, to ensure that the 

eligibility information is correct and consistent with information reported by you to 

any USDA agency;

(2) Within 30 days after the Revised Farm Operation Report, information reported to 

reconcile errors in the information with correct information that has been determined 

by any USDA agency;

(3) Within 30 days of any subsequent correction of data by FSA, erroneous information 

corrected as a result of verification of information; and

(4) At any time, any incorrect information if the incorrect information was caused by 

electronic transmission errors by us or errors made by any agency within USDA in 

transmitting the information provided by you for purposes of other USDA programs.

Interpretation Submitted by Requestor(s)

First Requestor’s Interpretation:

The first requestor’s interpretation is that Section 15(1) of the WFRP Policy allows the AIP to correct 

an error “unless [the correction at issue] [is] authorized in section 41.” Section 41(a) of the WFRP 

Policy outlines four (4) categories of errors that are authorized to be corrected by the AIP, and the 

timing of such corrections if they are to be made.

• Section 41(a)(1) allows the AIP to correct any incorrect information on the application or provided 

by the sales closing date within 60 days after the sales closing date to ensure that the eligibility 

information is correct and consistent with information reported by you to any USDA agency. 

• Section 41(a)(2) allows the AIP to reconcile errors with correct information that has been 

determined by any USDA agency within 30 days after the Revised Farm Operation Report.
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FCIC Interpretation of Procedure

• Section 41(a)(3) allows the AIP to correct within 30 days of any subsequent correction of data by 

FSA any information deemed erroneous as a result of verification of information.

• Section 41(a)(4) allows the AIP to correct information at any time if the incorrect information was 

caused by electronic transmission errors made by the USDA or any agency.

The first requestor continues their interpretation that based upon the plain language of Section 15(1), 

errors in reporting that do not fall within the aforementioned categories of authorized corrections can 

be corrected at any time upon discovery of the incorrect information. Conversely, if the error in 

reporting at issue falls within one of the four categories outlined in Section 41, Section 15(l) does not 

authorize correction. It can only be done pursuant to Section 41.

Second Requestor’s Interpretation:

The second requestor interprets that under section 15(l), the authority of an AIP to correct “incorrect 

information” is not restricted to only the information and deadlines identified in section 41(a)(1) – (4). 

To this end, the term “unless” as used in section 15(l) should not be read to mean “only if corrections 

are authorized by section 41.” An interpretation of section 15(l) that permits only those corrections 

described in section 41(a) effectively negates the purpose of the provision and the “at any time” 

language.

The second requestor also interprets section 15(l) to authorize the AIP to correct incorrect information 

“at any time” unless section 41(a) has imposed a temporal limitation on the correction of information 

in specific circumstances. Thus, if the Farm Service Agency (FSA) corrects data, the AIP must 

correct any incorrect information within 30 days of the FSA’s correction rather than at “any time.”

Furthermore, the second requestor interprets that if an AIP discovers that the producer reported 

incorrect information, other than the information specifically identified in section 41(a), the AIP must 

correct the information “at any time” so that is consistent with the applicable policy and procedure.

Federal Crop Insurance Corporation Determination

FCIC agrees with both requestors’ interpretations. Section 15(l) authorizes an AIP to correct errors in 

reporting of information at any time an error in reporting is discovered, except for those errors 

identified by Section 41 which may only be corrected according to the deadlines specified. 

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.