Crop Insurance: In Areas with Higher Crop Production Risks, Costs Are Greater, and Premiums May Not Cover Expected Losses
Released: 2015-03-11T00:00:00

Letter

Background

The authorizing legislation for the federal crop insurance program states that the purpose of the program is to promote the national welfare by improving the economic stability of agriculture. According to RMA’s mission statement, the agency provides risk-management tools, such as crop insurance, to strengthen the economic stability of agricultural producers and rural communities. Specifically, RMA’s fiscal years 2011 to 2015 strategic plan states that the agency’s goal for the federal crop insurance program is that it will provide a broad-based financial safety net for producers. The fiscal years 2011 to 2015 strategic plan includes the agency’s strategic goals and core values in support of its mission. These goals are, among other things, to continue to expand participation, ensure actuarially sound products, safeguard the integrity of the program, and to do so as responsible stewards of taxpayer dollars and with transparency.

Through the federal crop insurance program, farmers insure against losses on more than 100 crops. These crops include the five major crops (corn, soybeans, wheat, cotton, and grain sorghum), as well as nursery crops and certain fruits and vegetables. According to an RMA document, the amount of federal crop insurance purchased based on planted acres is relatively high in comparison with the past for the five major crops. In 2012, corn acreage was 84 percent insured, soybean acreage was 84 percent insured, wheat acreage was 83 percent insured, cotton acreage was 94 percent insured, and grain sorghum acreage was 74 percent insured.

As shown in table 1, the federal government’s crop insurance costs generally increased for fiscal years 2003 through 2013. A widespread drought and crop losses in crop year 2012 contributed to the spike in government costs to $14.1 billion in fiscal year 2012.weather conditions were more favorable, so government costs were lower than in fiscal year 2012. According to an April 2014 CBO estimate, for fiscal years 2014 through 2023, program costs are expected to average $8.9 billion annually.

In crop year 2013, The 2014 farm bill included a provision that affects the dollar value that a farmer can insure when the farmer’s county has experienced substantial crop losses in previous years. RMA uses the actual production history (APH)—4 to 10 years of historical crop yields— to establish a farmer’s insurance guarantee. Existing law before the 2014 farm bill allowed a farmer to replace a low actual yield in the APH with a yield equal to 60 percent of the historical county crop yield. The 2014 farm bill enhanced this provision by allowing farmers to exclude without replacement any recorded or appraised yield from the APH calculation if the average crop yield in the county for any particular year is less than 50 percent of the 10-year county average. According to a USDA document, this provision will provide relief to farmers affected by severe weather, including drought, by allowing them to have a higher approved crop yield. In general, RMA will set increased premium rates for farmers who choose to use this option, meaning the subsidy provided by the federal government will increase. CBO estimated that this provision change will cost $357 million over the 10 years from fiscal year 2014 through fiscal year 2023.

The Government’s Crop Insurance Costs Are Greater in Areas with Higher Crop Production Risks

The government’s crop insurance costs are substantially higher in areas with higher crop production risks than in other areas. From 2005 through 2013, government costs per dollar of crop value in areas with higher crop production risks were over two and a half times the costs in other areas. However, RMA does not monitor and report on the government’s crop insurance costs in these higher risk areas.

According to an RMA official, RMA’s county target premium rates are the best available measure of crop production risks. In the 20 percent (510) of U.S. counties with the highest average county target premium rates, these rates ranged from 20 percent to 83 percent, with a median rate of 25 percent. In comparison with other types of property and casualty insurance, 25 percent is a relatively high premium rate. For example, at 25 percent, the annual homeowner’s insurance premium on a house valued at $400,000 would be $100,000. The remaining 80 percent (2,044) of U.S. counties had lower average county target premium rates. Those rates ranged from 0.6 percent to nearly 20 percent, with the median rate of 9 percent.

Figure 1 shows counties organized in groups of 20 percent based on average county target premium rates, with the darker areas representing counties with higher average county target premium rates. The color- shaded counties represent all 2,554 counties that had county target premium rates for at least one of the five major crops.

Figure 2 shows the riskiest 20 percent of counties (510) in terms of average county target premium rates. These 510 higher risk counties are color-shaded on the basis of their 2013 premium dollars to show which counties purchased the most crop insurance. The Great Plains, which has areas with relatively high drought risk, had a large portion of the higher risk counties’ premium dollars.

Figure 3 compares the estimated government crop insurance costs per dollar of expected crop value for the five major crops in the 510 higher risk counties with the costs in the 2,044 other U.S. counties from 2005 through 2013.year depending on weather-caused crop losses, crop prices, and farmers’ decisions about how much insurance coverage to purchase. To control for variations in crop prices and farmers’ purchase decisions, and to normalize the costs for higher risk counties and lower risk counties while still reflecting weather-caused crop losses, we expressed the estimated government costs in relation to expected crop value. As shown in figure 3, the costs in higher risk counties were substantially greater. Over the 9- year time frame, government costs averaged 14 cents per dollar of expected crop value in the higher risk counties and 5 cents per dollar in the other counties. For example, if two farms each had an expected crop value of $1 million, the higher risk farm would have had an average annual government cost of $140,000, and the lower risk farm would have had an average annual government cost of $50,000. In 2013, the higher risk counties had a government cost of 17 cents per $1 of expected crop value, 3 cents higher than the average during the time frame, and the other counties had a government cost of 5 cents per $1 of expected crop value, the same as the time frame average.

RMA Premium Rate Changes in Areas with Higher Production Risks May Not Cover Expected Losses

RMA implemented changes to premium rates in 2014, decreasing some rates and increasing others, but our analysis of RMA data shows that, for some crops, RMA’s higher risk premium rates may not cover expected losses. RMA made changes to premium rates from 2013 to 2014, but its practice of phasing in changes to premium rates over time could have implications for actuarial soundness. Further, many premium rates in areas with higher production risks were lower than they should have been to cover expected losses and RMA’s increases to these premium rates were not as high as they could have been under the law to fully cover expected losses.

RMA Made Changes to Premium Rates in Areas with Higher Crop Production Risks in 2014

We found that RMA adjusted higher risk county base premium rates and county target premium rates from 2013 to 2014 for the five major crops. The revisions in premium rates were in response to a 2010 study of its methodology and its periodic reviews of crop loss history. The changes included increases and decreases of higher risk county base premium rates and county target premium rates for each of the five major crops. On average, RMA’s various changes to premium rates from 2013 to 2014 resulted in decreases to county base premium rates and county target premium rates for corn and soybeans and increases for grain sorghum.These changes also represented an increase in the percentage of county base premium rates that were aligned with county target premium rates for corn, soybeans, cotton, and grain sorghum, but not for wheat.

RMA has indicated in agency documents that it phases in new rates, especially those that require an increase, to keep premiums stable and provide farmers with predictable rates. For example, in a 2013 document, the agency reported that it planned to slowly phase in changes to county base premium rates to mitigate the impact of a 2012 drought. However, phasing in changes to premium rates can have implications for improving actuarial soundness. For example, USDA’s Office of Inspector General (OIG) reported in 2005 that, from crop years 2000 through 2003, when cotton crop losses were high relative to premiums, premium rates for cotton were decreased, unchanged, or increased only moderately and, in these same 4 years, premiums were not sufficient to cover losses. An RMA official told us that RMA uses judgment when changing county base premium rates, factoring in the agency’s goal of maintaining stability for farmers in its decisions.

Many County Base Premium Rates Are Less Than the County Target Premium Rates

When county base premium rates are lower than county target premium rates, RMA is required by statute to limit annual increases in premium rates to 20 percent of what the farmer paid for the same coverage in the previous year. However, RMA uses discretion in deciding whether to raise rates by the full 20 percent or by a lesser amount (as indicated by its practice of phasing in rate changes). Based on our analysis, for the higher risk premium rates, half of county base premium rates for corn, cotton, and grain sorghum, and nearly half of county base premium rates for wheat are lower than the county target premium rates.the lower risk premium rates, most of the county base premium rates for In contrast, for corn, cotton, grain sorghum, and wheat meet or exceed county target premium rates. Figure 7 shows the percentage of county base premium rates that meet, exceed, or are lower than county target premium rates in 2014.

We calculated percentage differences between county base premium rates and county target premium rates. This provided a measure of the gap between the premium rate RMA charges a farmer (the county base premium rate) and the premium rate RMA should charge a farmer (the county target premium rate). For example, for nonirrigated cotton, one county had a county base premium rate of 26 percent and a county target premium rate of 32 percent. Thus, the county base premium rate was 6 percentage points less than the county target premium rate; however, the percentage difference was 23 percent.

For most higher risk premium rates where the county base premium rates were lower than the county target premium rates, the higher risk county base premium rates were within 20 percent of the county target premium rates in 2014, meaning RMA could fully align the rates in a single year. As shown in table 2, across the major crops, a larger percentage of county base premium rates are lower than county target premium rates by 20 percent or more for higher risk premium rates as compared to the lower risk premium rates.

Based on our analysis, from 2013 to 2014, RMA changed some county base premium rates by the full 20 percent allowed by the law. However, we also found that from 2013 to 2014, RMA did not raise county base premium rates as high as the law allows for many of the higher risk premium rates. For example, as shown in table 3, RMA made a lesser adjustment in about half of the county base premium rates for corn and cotton, and nearly half for grain sorghum that required a change of 20 percent or more to either meet or move closer to the county target premium rate. Table 3 shows the percentage of premium rates where a change of at least 20 percent was necessary to move the county base premium rate closer to the county target premium rate and where RMA did not use the full 20 percent authorized in statute.

An RMA official told us that the agency strives for actuarial soundness not only nationwide, but also, at the county and crop level. Without sufficient increases to premium rates, where such increases are necessary, RMA’s premium rates may not cover expected losses and may not be as high as they could be under the law, which may have implications for the actuarial soundness of the program. Among the higher risk premium rates, if the county base premium rates and the county target premium rates were identical, the federal government’s total program costs in these areas would be lower because more premium dollars would be collected. For example, in analyzing data on premium dollars for 2013, our analysis showed that had the county base premium rates been aligned with the county target premium rates in higher risk counties, the federal government could have potentially collected tens of millions of dollars in additional premiums.

However, the federal government’s total program costs would not be reduced by the same amount as the additional premiums. The amount of the premium that the federal government provides on behalf of farmers (premium subsidy), about 62 percent, on average, would increase, but the portion of the premium that farmers pay would also increase. Thus, the additional premiums would reduce the government’s costs. Also, when county base premium rates are lower than county target premium rates, farmers’ production decisions may not be based on the true cost of their risk of loss due to weather-related events, such as drought; and, the federal government does not have information about the full amount of premium dollars the federal government should collect from farmers. Ensuring that the federal government has information about the full amount of premium dollars it should collect from farmers would be an activity consistent with RMA’s core values.

Conclusions

Federal crop insurance plays an important role in protecting farmers from losses from natural disasters and price declines, and the federal crop insurance program has become one of the most important programs in the farm safety net. RMA has overall responsibility for administering the program, including controlling costs. With increasing budgetary pressures, it is critical that federal resources are targeted as effectively as possible. One of USDA’s strategic objectives is to maximize the return on taxpayer investment in the department through enhanced stewardship activities of resources and focused program evaluations. Such evaluations could include an analysis of the government’s crop insurance costs in higher risk areas, where, as our analysis found, government costs are substantially higher than in other areas. However, RMA does not monitor and report on the government’s crop insurance costs in higher risk areas to identify potential cost savings, which would be consistent with USDA’s strategic objective. Without additional information from RMA on the government’s crop insurance costs in higher risk areas, Congress may not have all the information it needs to make future assessments of the crop insurance program’s design and costs.

In implementing premium rates, RMA seeks to balance its goals for participation and ensuring stability for farmers with maintaining an actuarially sound program. RMA updates its premium rates periodically, but there are continuing gaps between county base premium rates and county target premium rates. RMA has the ability to make changes to more quickly achieve greater actuarial soundness at the county and crop level but is not always doing so for areas with higher production risks. Without sufficient increases to premium rates, where applicable, RMA may not be taking all the actions available to achieve greater actuarial soundness. Additionally, moving to ensure that more county base premium rates meet county target premium rates will provide more information about the full costs to the federal government for insuring farmers in higher risk areas, consistent with the core value in RMA’s fiscal years 2011 to 2015 strategic plan, and could also save federal funds.

Recommendations for Executive Action

To better inform Congress in the future about crop insurance program costs, reduce present costs, and ensure greater actuarial soundness, we recommend that the Administrator of the U.S. Department of Agriculture’s Risk Management Agency take the following two actions:

Monitor and report on crop insurance costs in areas that have higher crop production risks.

As appropriate, increase its adjustments of premium rates in areas with higher crop production risks by as much as the full 20 percent annually that is allowed by law.

Agency Comments and Our Evaluation

We provided USDA with a draft of this report for review and comment. We received written comments from the RMA Administrator. These comments are summarized below and reproduced in appendix III. In these comments, RMA disagreed with our first recommendation and agreed with our second recommendation. RMA stated that, consistent with the second recommendation, it will continue to revise premium rates in an appropriate, prudent, and actuarially sound manner, taking proper account of current rates and premium rate targets consistent with generally accepted actuarial practices.

In its written comments, RMA disagreed with our first recommendation to monitor and report on crop insurance costs in areas that have higher crop production risks and said it currently provides crop insurance data that have all the information necessary to determine crop insurance costs in all areas. RMA’s website provides some information—such as county- level data on premiums, premium subsidies, loss claim payments, and loss ratios—that enables others to do some analysis of crop insurance costs. However, that information is not complete for the purpose of analyzing the government’s costs and is not organized in a way that facilitates an understanding of the government’s costs in higher risk areas. For example, regarding data on loss ratios (i.e., loss claim payments divided by premiums) that is on RMA’s website, a recent article by an agricultural economist from the University of California notes that this loss ratio information for crop insurance (1) is not informative about and misrepresents the actuarial exposure borne by the program and (2) by excluding administrative expenses, understates the extent of public expenditure on the program. We agree with this assessment. Furthermore, placing data on a website does not constitute the monitoring of crop insurance costs. We continue to believe RMA can and should do more to monitor and report on crop insurance costs in higher risk areas, where we found government costs to be substantially higher than in other areas. As we said in this report, without additional information from RMA on the government’s crop insurance costs in higher risk areas, Congress may not have all the information it needs to make future assessments of the crop insurance program’s design and costs.

In addition, RMA commented on our analysis of the government’s cost of the crop insurance program in higher risk areas. RMA said it has developed a definition of high-risk land, mapped out these areas, and applied significant premium surcharges. RMA said our definition of what we deem to be “higher risk areas” is much broader. RMA defines “high- risk land” as acreage with identifiable physical limitations, such as floodplains and high sand content soils. Our identification of higher risk areas (i.e., the 20 percent of counties that had the highest weighted average county target premium rates) enabled us to broadly assess crop insurance costs, and we believe this approach, which we discussed with RMA officials, was consistent with our purpose.

In its comment letter, RMA said our use of crop insurance costs (or benefits to farmers) per dollar of expected crop value “appears to exaggerate the difference in program costs in higher-risk areas versus other areas, or at least masks some important details.” To present another perspective, RMA compared corn premium subsidies per acre for two states that had a large number of higher risk counties with two states that had no higher risk counties and stated that the premium subsidies per acre were similar amounts. We believe our use of a dollar-based measure (i.e., premium subsidies per dollar of expected crop value) is more appropriate than a physical measure (i.e., acres) for comparisons between costs and farmer benefits in higher risk areas and other areas. This is consistent with the methodology of a 2013 article by agricultural economists from The Ohio State University and the University of Illinois that compared net farm insurance payments using a dollar-based measure.

Moreover, the use of a dollar-based measure is consistent with property insurance methods, which are based on the value of the property being insured. RMA stated that coverage levels were another offsetting effect, noting that growers in higher risk areas tend to choose lower coverage levels than in other areas, because higher premium rates make higher coverage less affordable. RMA appears to be suggesting that our analysis overlooks this difference, which is not true. As explained in our report, one of the reasons that we expressed estimated government costs in relation to expected crop value was to control for variations in farmers’ purchase decisions. Farmers’ decisions in selecting coverage levels vary between higher risk areas and other areas. According to our analysis, in 2013, farmers in higher risk counties chose to insure, on average, 67 percent of their expected crop value, while farmers in the other counties chose to insure, on average, 76 percent of their expected crop value. Thus, we used expected crop value—which is not affected by coverage levels—rather than insured crop value so that our analysis would not be distorted by differences in coverage levels.

RMA agreed with our second recommendation that, as appropriate, RMA increase its adjustments of premium rates in areas with higher crop production risks by as much as the full 20 percent annually that is allowed by law, saying it mirrors how premium rate adjustments are currently administered. However, RMA stated it disagreed with our assessment of the extent to which premium rates need to be adjusted to the full amount allowed by statute and that adjusting premium rates fully to changes in premium rate targets would undercut the basic purpose of insurance—to provide financial stability. We continue to believe RMA’s adjustment of premium rates should be consistent with insurance principles and the statutory directive to set premium rates that improve actuarial soundness. Furthermore, in its discussion of premium rates in “higher-risk” areas, RMA states that the report makes certain assumptions about premium rate targets in high risk areas that are not completely accurate and do not necessarily result in improved actuarial soundness. RMA further states that following each random variation to its fullest can subject growers to a roller-coaster ride of ups and downs in their premiums. RMA presented a simulation of yields and losses, showing that adjusting premium rates by less than needed to meet the premium rate target leads to a smaller variation in rates.

RMA’s simulation suggested that the agency’s current method of adjusting premium rates will yield an average premium rate that is actuarially sound at the national level. We agree that RMA’s average premium rate, nationwide, may allow the program to be considered actuarially sound. However, our analysis focused on RMA’s practices in charging premium rates in areas with higher production risks that may be lower or higher than the actuarially sound premium rate. In addition, RMA’s simulation did not account for systematic variation in risk at the county and crop level. As we concluded, RMA could more quickly achieve actuarial soundness at the county and crop level. Moreover, as we stated, charging premium rates that are less than the actuarially sound premium rates could also have implications for total costs to the federal government in areas with higher production risks. Thus, we continue to believe that increasing the adjustments of premiums rates in areas with higher crop production risk by as much as the full 20 percent annually that is allowed by law is prudent and in keeping with sound fiscal practices.

As agreed with your offices, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date. At that time, we will send copies of this report to the appropriate congressional committees; the Secretary of Agriculture; the Administrator of USDA’s Risk Management Agency; the Director, Office of Management and Budget; and other interested parties. In addition, this report will be available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please contact me at (202) 512-3841 or morriss@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Key contributors to this report are listed in appendix IV.

Appendix I: Objectives, Scope, and Methodology

Our objectives were to determine, for areas with higher crop production risks, (1) the government’s cost of the crop insurance program and (2) the extent to which RMA’s premium rates, as implemented, cover expected losses.

To address these objectives, we reviewed relevant provisions of the Food, Conservation, and Energy Act of 2008 (2008 farm bill) and the Agricultural Act of 2014 (2014 farm bill); other statutes; and U.S. Department of Agriculture (USDA), regulations; and we analyzed crop insurance program data from RMA. We interviewed USDA officials, including officials from RMA, and reviewed documents they provided, such as, descriptions of the agency’s methodology for calculating premium rates.

We selected 2013 because it was the most recent year for which complete RMA data on program costs was available at the time we performed this analysis.

We recognize that an area or location may be high risk for one crop or crop type or practice type but not for a different crop. However, by using 2013 premium dollars to weight the average of the different target rates used in a given county, we maintain that such a calculation allows a reasonable average approximation of a location’s production risk. practice, and crop-type combinations RMA used for premium calculations in 2013. Additionally, the use of a weighted-average county target premium rate allowed us to calculate a single measure for each county by which we could examine government costs in specific geographic areas. We then ranked the counties from the highest to lowest weighted average target rate. We defined those counties ranked in the top 20 percent as “higher risk counties” and the remaining 80 percent of counties as “lower risk counties.” To calculate total government costs in these higher risk counties, we analyzed RMA data for 2005 through 2013. We used the expected crop value to compare the costs in areas with higher production risks to the costs in other areas. Expected crop value is equal to the expected crop production multiplied by the expected (or elected) crop price. However, we did not have information on expected crop prices, so we calculated expected crop value by dividing the liability dollars by the coverage rate. Finally, to address the first objective we interviewed RMA officials, reviewed USDA’s and other studies that examined the costs of the crop insurance program and the role of premium subsidies, and consulted documents from other stakeholders, including farm industry groups.

To address the second objective, we analyzed RMA data on production- based (or yield) premium rates for the five major crops (corn, cotton, grain sorghum, soybeans, and wheat) for crop years 2013 and 2014. Production-based premium rates are RMA’s premium rates for production-based policies and are used to determine the premium rates for revenue policies.and crop-type combination, on the county base premium rate and the county target premium rate. We used the same 2013 data on county target premium rates to identify higher risk counties in our first objective. Using the 2013 premium rate data, we ranked the county target premium rates from highest to lowest and identified the highest 20 percent of county target premium rates for each crop, practice, and crop-type combination. For a given crop, a single county may have multiple county target premium rates, depending on the number of combinations of practices (e.g., irrigated and nonirrigated) and crop types (e.g., winter wheat and spring wheat) insured in the county. For example, for wheat, a county may have county target premium rates for two practice and crop- type combinations—nonirrigated winter wheat and nonirrigated spring wheat―in which one or both of the premium rates may fall in the highest 20 percent in 2014. For example, for wheat, County A in state B had county target premium rates for two practice and crop-type combinations—nonirrigated winter wheat and nonirrigated spring wheat— that were in the highest 20 percent in 2014. In total, there were 40 combinations or rankings of crops, practices, and crop types. Thus, if a county target premium rate fell into the top 20 percent in its ranking, that county target premium rate was placed in the “higher risk premium rate” category. The remaining 80 percent were placed in the “lower risk premium rate” category. We compared each county base premium rate with the applicable county target premium rate identified above. In each instance, we compared the county base premium rate with the county target premium rate for a single practice, and crop-type combination, and calculated the percentage difference. We calculated the percentage difference by subtracting the county base premium rate from the county target premium rate and dividing the result by the county base premium rate. If the percentage difference between the county base premium rate and the county target premium rate was zero, we considered the county base premium rate as having met the county target premium rate. If the percentage difference was greater than zero, we placed the county base premium rate in the “lower than” category; and, if the percentage difference was less than zero, we placed the county base rate in the “higher than” category. Table 4 provides details on the crop-type and RMA provided us with data, for each crop, practice, practice combinations included in this review. Finally, we interviewed RMA officials in headquarters and two field offices regarding the agency’s method for setting and implementing changes to county premium rates. We judgmentally selected the field offices based on the offices having had experience implementing premium rates in areas with higher production risks. We also reviewed studies that examined the agency’s methodology for assigning premium rates and reviewed relevant audits by USDA’s Office of the Inspector General.

For the various data used in our analyses, as discussed, we generally reviewed related documentation, interviewed knowledgeable officials, and reviewed related internal controls information to evaluate the reliability of these data. In each case, we concluded that the data were sufficiently reliable for the purposes of this report.

We conducted this performance audit from December 2013 to February 2015 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our objectives.

Appendix II: Premiums in the 10 Percent of Counties with the Highest Premium Rates, 2013

Figure 8 shows the 255 counties that were the riskiest 10 percent of counties in terms of average county target premium rates. These counties are shaded on the basis of their 2013 premium dollars to show which risky counties had the most crop insurance.

Appendix III: Comments from the U.S. Department of Agriculture

Appendix IV: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the individual named above, Thomas M. Cook, Assistant Director; Kevin S. Bray; Mark Braza; Gary Brown; Michael Kendix; Tahra Nichols; Susan Offutt; Ruth Solomon; and Frank Todisco made key contributions to this report. In addition, Cheryl Arvidson, and Kiki Theodoropoulos made important contributions to this report.

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