FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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IMPROPER PAYMENT CORRECTIVE ACTIONS SECTION

In the spring of 2021, Department of Agriculture (USDA) agencies analyzed transactions from fiscal 

year (FY) 2020 as described in the Agency Financial Report (AFR). Please keep in mind that since 

USDA reports improper payments one year in arrears, corrective actions taken to reduce improper 

payments in FY 2020 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. 

All programs reporting an improper payment estimate plus an unknown payment estimate exceeding the 

statutory thresholds (per Office of Management and Budget (OMB) OMB-21-19) must put in place and 

annually report on their corrective action plan to prevent and reduce the improper payment and 

unknown payment amounts. The tables below describe the actions taken and planned for each high-risk 

program that is above the aforementioned reporting threshold. Beginning in FY 2020, 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.

“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

• Emergency Conservation Program (ECP) Disaster 

• Livestock Forage Program (LFP)

• Market Facilitation Program (MFP) 1

• Noninsured Crop Disaster Assistance Program (NAP) 2

• Trade Mitigation Program (TMP)

• Wildfires and Hurricanes Indemnity Program (WHIP) 3

• Wildfires and Hurricanes Indemnity Program Plus (WHIP+)

1 FSA’s MFP payment integrity testing results estimated a payment error rate of 15.52% with $7.4 million dollars in payments not 

made properly.

2 FSA’s NAP payment integrity testing results estimated a payment error rate of 12.30% with $9.8 million dollars in payments not 

made properly.

3 FSA’s WHIP payment integrity testing results estimated a payment error rate of 10.75% with $4.5 million dollars in payments not 

made properly.

Since the dollar results are below the $10 million dollar reporting threshold, these programs are not required to publish corrective 

actions. However, the error rate places the programs above the PIIA statutory threshold of 10%. Therefore, we anticipate they will be 

considered PIIA non-compliant after OIG concludes its PIIA Compliance Audit in May 2022. FSA’s program managers 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)  Failure to access data/information

Explanation of Cause  The county office official did not follow the well 

documented program requirements.

Amount Associated with the Root Cause 

(See Root Causes Table)  $ 62.94 ($ in millions)

Corrective Action(s) Taken  Training 

Corrective Action Completion Date

Established a weekly call with state offices to provide training, updates, timely 

release guidance through FSA Notices and Handbook amendments to ensure any 

policy changes are documented in writing to field staff.

9/30/21

Impact of Corrective Action 

Anticipated impact is to gain greater knowledge of program requirements.
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

3

PROGRAM: FSA ECP-DISASTER

Root Cause (See Root Causes Table)  Failure to access data/information

Explanation of Cause  Oversight not performed, program policy not 

clear, and required forms not completed.

Amount Associated with the Root Cause 

(See Root Causes Table)  $ 17.39 ($ in millions)

Corrective Action(s) Taken  Training 

Corrective Action Completion Date

Handbook revised and training provided to staff. A program checklist was created to 

capture reviews at approval, payment, and lifespan. Program is scheduled to be 

added to the FSA Internal Review Documentation and Tracking System in 

September 2022.

9/16/2021

Impact of Corrective Action 

Anticipated impact is to ensure all necessary forms and reviews are being 

completed timely. Also, all results are monitored and evaluated to ensure policies 

are being followed. Checklists and transition to payment schedule cost lists provide 

standardized cost to ensure payment consistency, prevent ineligible cost, and 

ensure the correct reimbursement rates are used.
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA LFP

Root Cause (See Root Causes Table)  Failure to access data/information

Explanation of Cause 

Application was not approved by an authorized 

agency representative prior to payment and 

required supporting documentation was not 

obtained, or filed in error to determine acreage, 

producer eligibility prior to payment.

Amount Associated with the Root Cause 

(See Root Causes Table)  $ 12.72 ($ in millions)

Corrective Action(s) Taken  Training 

Corrective Action Completion Date

National trainings conducted and directives issued that reviewed PIIA results with 

state and county offices. The manual District Directors’ internal quality checks 

process will be incorporated into a national internal review system in FY 2022. 

9/30/21

Impact of Corrective Action 

Anticipated impact of corrective action is to mitigate errors in subsequent years.
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA TMP

Root Cause (See Root Causes Table)  Failure to access data/information

Explanation of Cause 

Acreage report was not on file to substantiate 

the applicant's acreage and share claimed on the 

CCC-913.

Amount Associated with the Root Cause 

(See Root Causes Table)  $ 84.07 ($ in millions)

Corrective Action(s) Taken  Automation 

Corrective Action Completion Date

Weekly calls with STO's provided updates & training to properly determine eligible 

acreage, including excepted acres. 9/30/21

Impact of Corrective Action 

Ensure reviews are completed prior to approval for manual entries, including COC 

Assigned Acres.
FARM SERVICE AGENCY (FSA) CORRECTIVE ACTION PLAN

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PROGRAM: FSA WHIP+

Root Cause (See Root Causes Table)  Failure to access data/information

Explanation of Cause 

Administrative processing errors occurred due to 

insufficient documentation, failure to verify 

eligibility data and inability to authenticate 

eligibility data.

Amount Associated with the Root Cause 

(See Root Causes Table)  $ 67.21 ($ in millions)

Corrective Action(s) Taken  Training 

Corrective Action Completion Date

Checklist provided to employees to review application prior to payment. First 5

applications must be reviewed. Notices issued to assist with findings & new review 

process. Weekly calls on policy & questions. Policy revised for clarification.

3/31/21

Impact of Corrective Action 

Anticipated impact is to mitigate processing errors.