National Organic Standards Board

Certification, Accreditation, Compliance Subcommittee (CACS)

Climate-Induced Farming Risk and Crop Insurance

Discussion Document

February 6, 2024

Intro & Background:

As USDA has recognized Organic farming as climate-smart, the NOSB has worked to identify barriers to 

farmers' transition to organic and the further retention of existing organic producers. Through robust 

rounds of public comment, we have heard repeatedly that crop insurance is one program that has an 

outsized potential to help farmers mitigate the risk of both transitioning to organic and staying organic 

once they’ve been certified. 

The Director of the Product Administration & Standards Division of the USDA’s Risk Management 

Agency (RMA) gave a presentation on crop insurance at the Fall 2023 meeting in Providence, RI. Her 

presentation described the crop insurance landscape across the United States and how the agency 

works diligently to make better insurance products available to more producers. 

Progress: 

The CACS celebrates the progress RMA has made to improve access to crop insurance for organic 

producers. RMA has attempted to understand how organic farming works and to build better programs 

for organic farmers. Indeed, several CACS members remarked on how much progress has been made in 

the past ten years. Some of this progress includes:

 

1. RMA introduced a contract price addendum that allows transitioning and organic producers to 

submit their contracts in advance to obtain a higher price for crop coverage.

2. RMA has launched its 2024 handbook, with updated good farming practices (GFP) definitions – 

making it clear the use of NRCS Conservation Practice Standards will be considered GFP

3. RMA allows enterprise units by organic farming practice. 

4. RMA allows enterprise units for specialty and perennial crops 

5. The RMA Agent Finder Web Page connects farmers interested in the Whole Farm Revenue 

Program/Microfarm Program with agents experienced in writing those policies. 

6. Pasture, Forage, Rangeland (PRF) now has organic forage as an option allowing for more suitable 

organic coverage.

Continuous Improvement Still Needed:

Through public comments and various farmer and crop insurance agent interviews, we have heard that 

while significant progress has been made, there is still work to be done to level the playing field for 

organic producers. At a minimum, by offering risk management options that do not disincentivize the 

transition from conventional production to organic, the opportunity to participate in the organic 

marketplace will expand to more producers. Additionally, those certified producers will benefit from 

more robust, equitable risk management options. 

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Because the organic marketplace is unique, organic farmers frequently face different risks than their 

conventional counterparts. The following list includes over-arching opportunities that producers and 

agents mentioned through public comments and various interviews on how to improve crop insurance 

to better help organic producers mitigate risk. 

Please note, opportunities 1 and 3, while specific examples, also fall into the greater theme that we 

heard: organic is unique and would benefit from having a distinct section in the loss adjustment manual. 

Opportunities for Improvement: 

1. Quality Factor Consideration During Loss Adjustment: because of the dynamic food market that 

corresponds to a more diverse cropping rotation, organic producers raise crops that, to meet 

the market demand, must meet high-quality specifications. Because they are unique and not 

readily substitutable into the conventional commodity supply chain, these crops may only have 

a secondary market, like feed, if they meet the specifications. For this reason, if a farmer does 

not experience a yield loss but rather a quality loss due to a climatic event, it can be as 

economically devastating as a complete yield wipeout. For example, when raising blue corn, if a 

farmer does not have a yield loss but does have a quality loss, they will not be able to sell into 

the food market. They also cannot sell into the organic feed market as their blue corn may 

discolor chicken eggs. Their corn cannot be sold into the conventional market because of the 

colors. Therefore, with no quality coverage, the farmer raising this otherwise in-demand-forfood crop will be left with only the option to compost it—a complete loss with no coverage even 

though yields were “fine.” *Note: specific loss adjusting standards for quality are available for 

some specialty crops, including produce crops. 

2. Organic crop insurance requires additional expertise to help farmers maximally. Modeled after 

the newly created agent finder for Whole Farm Revenue Protection/Micro Farm Landing Page 

hosted by RMA, it would be an excellent service to organic producers for RMA to create a similar 

landing page for adjusters and insurance agents who have specific knowledge of organic policies 

and are interested in working with organic farmers. There are many excellent crop insurance 

agents and crop adjusters around the country. Still, a farmer's ability to find them is relative to 

their network in the organic farming world. It is a distinct disadvantage to producers new to 

organic or farmers outside of organic agricultural hot spots. 

3. The time frame for adjusters to review a loss and visit a crop in-field can be the difference 

between an organic farmer saving the crop after weather damage (currently, adjusters are to 

visit a field 7-13 days after a climatic event). For example, if a producer has a hail event before 

organic crops have time to canopy, the producer will experience a burst of weed pressure within 

one day of the hail event. Because of the potential delay in receiving a visit from an adjuster, the 

farmer is not allowed to get in the field and address the weeds mechanically without risking 

losing coverage for the crop. All organic crops need specific “in-field” adjusting standards 

specific to organic producers. 

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Other challenges that producers and agents mentioned include:

1. By resetting T-yield at the start of transition, producers’ coverage is generally decreased 

compared to conventional counterparts. Note: T-yield, coverage level, and price are the three 

main factors determining loss payout.

2. There is not a clear path to provide feedback for the Launch of the Good Farming Practices 

Updated Handbook.

3. Whole Farm Revenue Program (WFRP) – agents cite the complexity (a 50-75 page application) of 

the program and the lower agent compensation as compared to other insurance as a 

disincentive for writing those policies. 

4. The time required to develop yield history on new crops insured under written agreements can 

slow their adoption which in turn disincentives producers to diversify their rotation. 

5. Producer awareness and understanding of RMA’s current policies and programs is inconsistent 

across the country.

6. The “Transition System Plan” or “Transition Producer Plan” is new and producers transitioning 

to organic may not have sufficient help to understand the role of the Transition plan in obtaining 

coverage. 

7. Required planting dates can conflict with diverse crop rotations including the incorporation of 

cover crops. 

Questions for Stakeholders: 

In addition to the summary above, CACS is interested in hearing how T-yields affect transition and 

organic farmers around the country and what possible solutions we could offer to address them. In 

addition, CACS is eager to receive more examples and personal stories about how crop insurance can be 

improved for organic producers. 

1. T-yields (Assigned yields when a producer doesn’t have production history): 

a. Would organic producers be open to using transitional yield history to accelerate t-yield 

replacement to build organic yield history faster?

b. Would “buy up” coverage above 85%, which is the current limit, to 120% be of interest 

to obtain more coverage?

c. Suppose you have a currently approved production history (APH) for organic production. 

Would you be interested in having a percentage of that APH carried over to your 

transition or organic t-yields? 

2. What other concerns remain?

Subcommittee Vote

Motion to accept the discussion document on Climate-Induced Farming Risk and Crop Insurance

Motion by: Amy Bruch

Seconded by: Nate Lewis 

Yes: 6 No: 0 Abstain: 1 Recuse: 0 Absent: 1

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