FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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IMPROPER PAYMENT CORRECTIVE ACTIONS SECTION

In the spring of 2020, Department of Agriculture (USDA) agencies analyzed transactions from 

fiscal year (FY) 2019 as described in the Agency Financial Report (AFR). Please keep in mind 

that since USDA reports improper payments 1 year in arrears, corrective actions taken to reduce 

improper payments in FY 2019 have not been reflected in the improper payment amount of this 

report. USDA continues to enact specific corrective actions to resolve root causes of improper 

payments and strategically strengthen program integrity while ensuring access to program and 

activities. 

Programs and activities determined to have improper payments exceeding the susceptible to 

significant improper payment threshold (per Office of Management and Budget (OMB) OMB18-20) must put in place a corrective action plan to prevent and reduce the improper payment 

amount. The tables below describe the actions taken and planned for each high-risk program that 

is above the aforementioned reporting threshold. Beginning in FY 2019, USDA asked high-risk 

programs reporting over the statutory threshold to categorize improper payments into “sub root 

causes,” which provide an additional breakdown of OMB root causes of error. The goal of the 

sub root cause is to help USDA obtain a clearer understanding of what truly caused the improper 

payments to occur.

OMB-18-20, states: “Agencies should also describe the results of actions taken to address the 

root causes and the planned or actual completion date of the actions taken to address each root 

cause.” Some of the corrective actions offer an indication of the impact it will have on 

addressing a root cause; however, in most cases, a series of corrective actions have cumulative 

impacts in improving payment accuracy. 

HIGH RISK PROGRAMS:

• The Agriculture Risk Coverage (ARC) and Price Loss Coverage (PLC) Programs

• Livestock Forage Program (LFP)

• Market Facilitation Program (MFP)

• Noninsured Crop Disaster Assistance Program (NAP)

• Trade Mitigation Program (TMP)

• Wildfires and Hurricanes Indemnity Program (WHIP)

• Emergency Conservation Program (ECP) Hurricane Harvey1

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FSA’s ECP Hurricane Harvey payment integrity testing results estimated a payment error rate of 18.74% with $8 million dollars in 

payments not made properly. Since the $8 million dollar result is below the $10 million dollar reporting threshold, ECP is not required to 

publish corrective actions. However, the 18.74% error rate places the program above the IPERA statutory threshold of 10%. Thus, ECP 

will be considered IPERA non-compliant after OIG audit concludes its IPERA Compliance Audit in May 2021. FSA’s ECP program 

manager and agency management are proactively working on strategies that will address root causes, improve payment integrity rates, and 

demonstrate improved stewardship over program resources.
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA ARC/PLC

Root Cause (See Root Causes Table)  Administrative or Process Error Made by 

Federal Agency

USDA’s Sub Root Cause 

• County Office employees did not 

follow procedure in approving and 

documenting such approval of 

ARC/PLC contracts.

• County Offices did not follow late-filed 

provisions for acreage reports 

according to established procedures.

Amount Associated with the Root Cause 

(See Root Causes Table)  $19.98 ($ in millions)

Corrective Actions Completion Date

A notice wasissued identifying this finding and reiterating the applicable policy. May 2020 

Weekly 

Ongoing

Deputy Administrators will reiterate the importance of following existing 

policies regarding signing and approving contracts before indicating approval 

in the applicable system to State Office leadership through weekly or biweekly leadership calls.

May 2020 

Weekly 

Ongoing

Internal reviews are conducted that enable us to identify earlier the types of 

errors that are occurring, the underlying reasons, and communicate how 

policies and procedures should be applied.

May 2020 

Weekly 

Ongoing
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA ARC/PLC

Root Cause (See Root Causes Table)  Insufficient Documentation to Determine

USDA’s Sub Root Cause  County offices did not adequately document 

eligibility forms.

Amount Associated with the Root Cause 

(See Root Causes Table)  $31.53 ($ in millions)

Corrective Actions Completion Date

A notice wasissued identifying this finding and reiterating the applicable policy. May 2020 

Weekly 

Ongoing

Deputy Administrators will reiterate the importance of following existing 

policies regarding signing and approving contracts before indicating approval 

in the applicable system to State Office leadership through weekly or biweekly leadership calls.

May 2020 

Weekly 

Ongoing

Internal reviews are conducted that enable us to identify earlier the types of 

errors that are occurring, the underlying reasons, and communicate how 

policies and procedures should be applied.

May 2020 

Weekly 

Ongoing
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA LFP

Root Cause (See Root Causes Table)  Inability to Authenticate Eligibility

USDA’s Sub Root Cause  An acceptable written acreage lease, rental 

agreement, or CCC-855 is not on file.

Amount Associated with the Root Cause 

(See Root Causes Table)  $6.5 ($ in millions)

Corrective Actions Completion Date

A notice will be issued identifying this finding and reiterating the applicable 

policy. October 2021

LFP refresher training will be held in each State/county that meet/trigger the 

drought monitor criteria that the county is eligible for LFP. Root causes of 

improper payments will be stressed throughout several presentations.

October 2021

A request for funding has been submitted to enhance LFP software with the 

ability to interface with farm record data to automatically generate a CCC855, if needed, for owners/operators to complete to meet eligibility 

requirements. NOTE: Software enhancements are contingent upon budget.

October 2021
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA LFP

Root Cause (See Root Causes Table)  Failure to Verify (Other)

USDA’s Sub Root Cause 

• Signature authority is not on file for 

person signing program documents in 

a representative capacity.

• AGI compliance is not met before 

payment is issued.

Amount Associated with the Root Cause 

(See Root Causes Table)  $0.33 ($ in millions)

Corrective Actions Completion Date

A notice will be issued identifying this finding and reiterating the applicable 

policy. December 2020

LFP refresher training will be held in each State/county that meet/trigger the 

drought monitor criteria that the county is eligible for LFP. Root causes of 

improper payments will be stressed throughout several presentations.

December 2020
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA LFP

Root Cause (See Root Causes Table)  Insufficient Documentation to Determine

USDA’s Sub Root Cause 

• An acceptable FSA-578 is not on file for 

all grazing acres for which a loss is 

claimed.

• CCC-853 is approved before the CCC902 or AD-1026 is on file.

Amount Associated with the Root Cause 

(See Root Causes Table)  $18.25 ($ in millions)

Corrective Actions Completion Date

Program Managers, Compliance Division, and Program Delivery Branch are 

identifying areas where software can be enhanced to mitigate these errors, 

policy clarified, and training provided. This process will enable us to identify 

earlier the types of errors that are occurring, the underlying reasons, and 

communicate how policies and procedures should be applied. 

December 2020

A notice will be issued identifying these errors and referencing applicable 

policy. December 2020
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA LFP

Root Cause (See Root Causes Table)  Administrative or Process Errors Made by 

Federal Agency

USDA’s Sub Root Cause 

• Approved CCC-853 includes ineligible 

acreage

• Carrying Capacity is incorrect on CCC853

Amount Associated with the Root Cause 

(See Root Causes Table)  $ 4.9 ($ in millions)

Corrective Actions Completion Date

LFP refresher training will be held in each State/county that meet/trigger the 

drought monitor criteria that the county is eligible for LFP. Root causes of 

improper payments will be stressed throughout several presentations.

December 2020

A notice will be issued identifying these errors and referencing applicable 

policy. December 2020
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA MFP

Root Cause (See Root Causes Table)  Administrative or Process Errors Made by 

Federal Agency

USDA’s Sub Root Cause 

County Office employees did not follow 

procedure in documenting re-delegation of 

authority prior to approving contracts.

Amount Associated with the Root Cause 

(See Root Causes Table)  $187.53 ($ in millions)

Corrective Actions Completion Date

The Market Facilitation Program (MFP) and Trade Mitigation Program (TMP) are 

considered MFP programs; however, the MFP designation covers the 2018 

program year and the TMP designation covers the 2019 program year. The basic 

difference between the two designations is that 2018 MFP paid on actual 

harvested production for non-specialty crops and specialty crops. In FY 2019,

TMP paid on the number of acres planted for non-specialty and specialty crops, 

including prevented planted acres of non-specialty crops provided it was 

followed by a cover crop. Please see the TMP corrective action below. 
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA MFP

Root Cause (See Root Causes Table)  Insufficient Documentation to Determine

USDA’s Sub Root Cause 

• Handbook 5-PL policy, which requires 

participants to complete the CCC-902, 

Producer Farm Operating Plan, is not 

being followed. 

• Handbook 6-CP policy, which requires 

participants to complete the AD-1026, 

HELC/WC Certification, is not being 

followed. 

• FSA-578 Crop Acreage Reports are 

required to report ownership share in 

non-specialty crops and specialty 

crops.

Amount Associated with the Root Cause 

(See Root Causes Table)  $290.06 ($ in millions)

Corrective Actions Completion Date

MFP and TMP are considered MFP programs; however, the MFP designation 

covers the 2018 program year and the TMP designation covers the 2019 

program year. The basic difference between the two designations is that 2018 

MFP paid on actual harvested production for non-specialty crops and specialty 

crops. In FY 2019, TMP paid on the number of acres planted for non-specialty 

and specialty crops, including prevented planted acres of non-specialty crops 

provided it was followed by a cover crop. Please see the TMP corrective action 

below. 
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA NAP

Root Cause (See Root Causes Table)  Administrative or Process Errors Made by 

Federal Agency

USDA’s Sub Root Cause  Errors were made that did not affect the 

calculation of a payment.

Amount Associated with the Root Cause 

(See Root Causes Table)  $ 9.84 ($ in millions)

Corrective Actions Completion Date

An updated NAP 770 Checklist has been issued that will assist NAP specialists to 

complete applications thoroughly with less administrative data missing. The 

NAP-770 Checklist is required to be completed when an application for payment 

is filed.

August 31, 2020

The Safety Net Division’s Disaster Assistant Section (DAS) is planning to 

complete additional NAP training targeting States with high error rates in 

order to educate states and prevent future errors.

December 31, 2020
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA NAP

Root Cause (See Root Causes Table)  Insufficient Documentation to Determine

USDA’s Sub Root Cause  Data required to accurately complete acreage 

reports, production, yields, etc., is incomplete.

Amount Associated with the Root Cause 

(See Root Causes Table)  $9.87 ($ in millions)

Corrective Actions Completion Date

Notices have been issued identifying this finding and reiterating the applicable 

policy August 5-9, 2019 

Deputy Administrator Farm Programs (DAFP), Safety Net Division’s DAS has 

expanded NAP’s 770 Checklist, which is now required to be completed when 

an application for payment is filed.

August 31, 2020

The Safety Net Division’s DAS is planning to complete additional NAP training 

targeting States with high error rates. The root causes of improper payments 

will be stressed throughout several presentations reiterating the importance 

of issuing proper payments.

December 31, 2020
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA NAP

Root Cause (See Root Causes Table)  Failure to Verify (Other)

USDA’s Sub Root Cause 

• Handbook 5-PL policy which requires 

participants to complete the required 

CCC-902, Producer Farm Operating 

Plan, is not being followed.

• Documenting the determination on the 

CCC-903, County FSA Committee (COC) 

determination is not being performed.

Amount Associated with the Root Cause 

(See Root Causes Table)  $ 0.99 ($ in millions)

Corrective Actions Completion Date

Software enhancements were discussed by the Agency to require the Business 

File records to be read during the NAP payment process. NOTE: Software 

enhancements are contingent upon budget.

August 31, 2020

The Safety Net Division’s DAS is planning to complete additional NAP training 

targeting states with high error rates. The root causes of improper payments 

will be stressed throughout several presentations reiterating the importance 

of issuing proper payments.

December 31, 2020
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA TMP

Root Cause (See Root Causes Table)  Administrative or Process Errors Made by 

Federal Agency

USDA’s Sub Root Cause 

County Office employees did not follow 

procedure in documenting re-delegation of 

authority prior to approving contracts. 

Amount Associated with the Root Cause 

(See Root Causes Table)  $157.23 ($ in millions)

Corrective Actions Completion Date

State Office designee verified that redelegation of authority is recorded in 

Executive Session Minutes prior to any applications being approved other than by 

the County Office Committee. 

May 31, 2020

Deputy Administrators will reiterate the importance of following existing policies 

regarding signing and approving contracts before indicating approval in the 

applicable system to State Office leadership through weekly or bi-weekly 

leadership calls.

May 31, 2020

Ongoing
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA TMP

Root Cause (See Root Causes Table)  Insufficient Documentation to Determine

USDA’s Sub Root Cause 

• Handbook 5-PL policy which requires 

participants to complete the CCC-902, 

Producer Farm Operating Plan, is not 

being followed. 

• Handbook 6-CP policy which requires 

participants to complete AD-1026, 

HELC/WC Certification, is not being 

followed. 

• FSA-578 Crop Acreage Reports are 

required to report ownership share in 

non-specialty crops and specialty 

crops.

Amount Associated with the Root Cause 

(See Root Causes Table)  $143.71 ($ in millions)

Corrective Actions Completion Date

County Office will verify the required payment eligibility forms are on file for the 

applicant before payment is disbursed. December 31, 2020

Deputy Administrators will reiterate the importance of following existing policies 

regarding signing and approving contracts before indicating approval in the 

applicable system to State Office leadership through weekly or bi-weekly 

leadership calls.

December 31, 2020
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA TMP

Root Cause (See Root Causes Table)  Failure to Verify (Other)

USDA’s Sub Root Cause 

Handbook 5-PL policy which requires 

participants to complete the CCC-941, 

Certification of Adjusted Gross Income, is not 

being followed.

Amount Associated with the Root Cause 

(See Root Causes Table)  $7.07 ($ in millions)

Corrective Actions Completion Date

County Office (COF) will verify the correct determination is recorded in the 

subsidiary file for the applicant before payment is disbursed. December 31, 2020

Deputy Administrators will reiterate the importance of following existing policies 

regarding signing and approving contracts before indicating approval in the 

applicable system to State Office leadership through weekly or bi-weekly 

leadership calls.

December 31, 2020
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA WHIP

Root Cause (See Root Causes Table)  Administrative or Process Errors Made by 

Federal Agency

USDA’s Sub Root Cause 

Administrative and/or process errors needed to 

verify producer eligibility and/or approval of a 

payment.

Amount Associated with the Root Cause 

(See Root Causes Table)  $118.03 ($ in millions)

Corrective Actions Completion Date

A CCC-770 WHIP Checklist will be provided which will assist WHIP specialists to 

complete applications thoroughly with less administrative data missing. The CCC770 WHIP Checklist is suggested to be completed prior to issuing WHIP payment 

and to help fulfill 2nd party reviews.

December 31, 2020
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA WHIP

Root Cause (See Root Causes Table)  Insufficient Documentation to Determine

USDA’s Sub Root Cause  Data required to accurately complete acreage 

reports, production, yields, etc., is incomplete.

Amount Associated with the Root Cause 

(See Root Causes Table)  $101.69 ($ in millions)

Corrective Actions Completion Date

Notices will be issued identifying this finding and reiterating the applicable policy. December 31, 2020

Notice IA-3 will be issued identifying improper payment findings and referencing 

1-WHIP handbook policy guidance. December 31, 2020

Notice AO-1740 will be issued implementing a new review process to support 

and enhance integrity and accountability in FSA. The new internal review process 

will enable us to identify errors earlier in the process, the reasons why they are 

occurring and improve communication

December 31, 2020
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA WHIP

Root Cause (See Root Causes Table)  Inability to Authenticate Eligibility

USDA’s Sub Root Cause 

Valid documents needed for producer eligibility 

are not completed to verify approval of a 

payment.

Amount Associated with the Root Cause 

(See Root Causes Table)  $1.55 ($ in millions)

Corrective Actions Completion Date

A CCC-770 WHIP Checklist will be provided that will assist WHIP specialists to 

complete applications thoroughly with less administrative data missing. The CCC770 WHIP Checklist references eligibility documents and is suggested to be 

completed prior to issuing WHIP payment. In addition, 1-WHIP par4E requires 

second party reviews be performed prior to payments being made.

December 31, 2020

To ensure eligibility requirements are met and all documents are completed and 

timely, 1-WHIP par4A requires the first five applications of an employee in the 

service center be reviewed by a State Office representative.

December 31, 2020
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA WHIP

Root Cause (See Root Causes Table)  Failure to Verify (Other)

USDA’s Sub Root Cause 

• Handbook 5-PL policy which requires 

participants to complete the required 

CCC-902, Producer Farm Operating 

Plan, is not being followed.

• Documenting the determination on the 

CCC-903, County FSA Committee (COC) 

determination is not being done.

Amount Associated with the Root Cause 

(See Root Causes Table)  $3.3 ($ in millions)

Corrective Actions Completion Date

Software enhancements are being discussed by the Agency to require the 

Business File records to be read during the WHIP payment process. 

NOTE: Software enhancements are contingent upon budget. 

December 31, 2020