Responses to Comments - Attachment to Question 8

Comments from the "Request for Information Solicited by USDA on July 19, 2011
Questions	Comments	Company	Responses from USDA
What are the potential benefits and limitations for reliability, accuracy and practicality?	There is a need to synchronize reporting deadlines, entity types as well as acreage reporting process.	Northwest/Farm Credit	Response to Question 1: The project is to standardize to the extent practical, acreage reporting processes, program dates, and data definitions across the various USDA programs. The Under Secretary of FFAS directed the RMA and FSA Administrators to implement common acreage reporting dates starting with 2012 spring crops. The following recommendations are in the final stages of review and are planned to be implemented in the next 90 days: • Single list of common business entity types to be used by RMA/FSA/NRCS/RD to be implemented beginning in 2012 and 2013. • Combining all of the crops and commodities in RMA, FSA, NRCS and NASS programs into a USDA Commodity Validation Table. • Common production terms and units of measure for all commodities The approved standards will be published to allow the commercial agricultural industry to determine if it would want to incorporate them into their products that producers use. The team has been collaborating with representatives of the commercial agricultural industry to develop these standards. The project is focusing on developing processes that will share the common data between the FSA Crop Acreage Reporting System (CARS) and the AIPs systems used by agents. The ACRSI will provide data to FSA and AIP systems to reduce the amount of time and resources required to enter the common acreage information. A key component of the project is to develop a USDA web site to allow a producer to report their common acreage data directly to USDA. The project is developing; create a file format and intake process so producers can use information from their Farm Management and Precision Ag systems for reporting production, planted and harvested acreage, and other information required for participation in USDA programs.
	The primary benefit of using information directly from Precision Ag Technology and Farm Management Software (FMS) is that data is reported directly from the producer and it is tied specifically to the land either through selection of the field on a map or utilizing the Geographic Information System (GIS) coordinates captured by Precision Ag technology.	Precision AG
	A secure transaction maintains the privacy of this information while making it available for a producer or their designee to report the information.	AgDoc
	We feel strongly that the private delivery system for Crop Insurance has been key to its growth and success through the years and that whatever is done to achieve efficiencies within USDA must not undermine that system and specifically the quality service that qualified agents provide.	CIPA
	NAWG believes that better access to modern technology will allow these employees to better utilize their time more efficiently and would benefit both USDA and the producer in the field.	NAWG
	While standardizing the acreage reporting dates between RMA and FSA will benefit producers, many of the proposed acreage reporting date changes would present a variety of challenges to agents, the crop insurance industry, and the program itself. In our view, these issues must be resolved before any final revisions are implemented. Given the magnitude and importance of this initiative to reconcile RMA and FSA acreage reporting dates, we believe that greater consideration must be given to the impact on the private sector delivery system, program integrity, and workload implications in addition to making the program more convenient for producers.	RH
	A single source reporting system will be the catalyst for data standardization within production agriculture and is the key that will unlock the benefits of reduced redundancy, reduced confusion, reduced costs, improved accuracy, improved timeliness, and improved producer service and satisfaction.	ProAg
Questions	Comments	Company	Response from USDA
What would be consistent and uniform standards for the collection and reporting data to multiple USDA agencies?	Because of these complicated differences, current FSA acreage data must be restructured before it can be used for crop insurance acreage reporting purposes Conflicting formats in acreage reporting practices create complications in sharing data and administering programs for both FSA and RMA programs. FSA reporting is based on field boundaries, “tracts”, which do not align with RMA crop insurance programs.	Northwest/Farm Credit	Response to Question 2: USDA programs cover a wide variety of crop, commodities and agricultural products. In many cases the same crop is not identified in the same manner across agencies. ACRSI is creating a single USDA Commodity Validation Table to standardize and identify over 250 commodities to be used in administering USDA programs. USDA programs also have many ways to use production information in order to establish benefits or to determine payments. ACRSI has developed a USDA Production Validation Table to identify common and unique units of measure (e.g., Gross Production, Adjusted Production, Net Production, etc.) to better utilize production information needed to establish cross agency program benefits. Producers and USDA have several different methods to identify the location of the acreage. The project will implement the FSA Common Land Unit (CLU) that is identified by the Farm, Tract and Field number on the county maps, as the standard USDA acreage location identifier. The overall goal of ACRSI Data Governance Charter, Data Governance Process and Procedures Guide is to describe the activities and workflow to establish and maintain USDA data standards (Agriculture Domain) in the National Information Exchange Model, NIEM Repository. This will result in the use of common terms, definitions and data format by participating USDA programs for the collection and use of program information. The project members have been working collaboratively with members of the commercial agricultural industry on developing procedures, processes and standards to allow producers to use information from their Farm Management and Precision Ag systems for determining acreage, production and other key information needed to participate in USDA programs.
	Work with various private sector groups, such as AgGateWay, to develop standard terminology and definition. Work with various private sector groups, such as AgGateWay, to develop standard terminology and definition.	AgDoc
	USDA should carefully examine opportunities to use improved interagency communication and sharing of reporting information through the use of available technology where possible.	NAWG
	If some crop insurance acreage reports will be collected by FSA, FSA must fully commit to immediately providing the information to the crop insurance company and agent.	RH
	The model to use to assure the consistent and uniform standards for the collection and reporting of data is the current crop insurance collection and data transmission system utilized by the RMA. This system has a proven record of consistent and uniform standards for the collection and reporting of producer’s information.	ProAg

Questions	Comments	Company	Response from USDA
How can USDA assure the proper calibration and integrity of the data so the data cannot be manipulated or modified from the original readings or output?	These tried and trusted programs allow producers to manage their risk through effective, market-based, reliable risk management solutions.	Northwest/Farm Credit	Response to Question 3: Producers can currently use information from their Farm Management and Precision Ag systems to assist in meeting RMA reporting requirements for production, planted and harvested acreage. The ACRSI project is working with the commercial agricultural industry that provide Farm Management and Precision Ag systems for determining acreage, production and other key information, to develop procedures, processes and standards to allow producers to use information needed to participate in USDA programs. The systems need to identify if and how the yield information was calibrated. The project is considering the following: 1) Yield information was not calibrated; 2) Sensor yield equipment was calibrated according to manufactures requirements in the field (during harvest); and 3) Yield map information was post calibrated using the total weighed or determined farm stored. The systems also need to identify if the reported acres is adjusted for overlap. To support the calibration statements and use by USDA, the system needs to provide a report of calibration activities. This would identify the calibration adjustments, location, pre and post calibration yields, time and day, crop etc. The report information has to be the raw system information, in a manner that it cannot be manipulated.
	If the USDA would establish calibration and integrity standards, the private sector will respond to the business need of the producer and will address the issue of calibration and integrity of data.	ProAg

Questions	Comments	Company	Response from USDA
How can USDA have compatibility with automated systems of FSA and RMA to facilitate transmission and sharing data?	With proper alignment information received by crop insurance providers and reported to RMA can be sent electronically to FSA. AIP’s and private insurance agents’ technology has evolved and progressed with the industry in order to stay competitive and efficient. The IT systems maintained by AIP and the private sector are updated, current and reliable and can deliver information to FSA if FSA was ready to receive with reliable systems. Because of the short reporting times and accelerated billing date for 2012 time and accuracy is critical. FSA 578 information is often missing data or has information that contains errors.	Northwest/Farm Credit	Response to Question 4: The ACRSI workgroup is in the process of defining and redesigning individual agency business processes and standardizing reporting requirements that are common across agencies to reduce or mitigate to the extent practical unnecessary differences between agency programs. This allows for program data that is common across agencies to be collected once and utilized by or redistributed to agency programs in which the producer chooses to participate. ACRSI recommendations include the use of ANSI State and County Codes over currently used FIPS and FSA codes. To reduce the reporting burden on producers, USDA agencies are to develop policy and procedure to allow producers to submit crop acreage information electronically and to modify the applicable automated systems to use common data already reported. The plan is to improve system capacity to collect common information and redistribute for RMA and FSA program use on an hourly basis to reduce current reporting time
	Standardization of county codes based on the American National Standards Institute (ANSI) requirements is also planned for a 2013 implementation. This will involve eliminating three county designations used in the crop insurance program that are not part of the ANSI standard, and will involve agents working directly with thousands of impacted producers to ensure their policies are modified correctly to reflect this program change.	NCIS/FMHIC/ARMtech/NAU
	While USDA officials at RMA, FSA and NRCS are generally well trained in executing administrative duties, NAWG believes that providing these employees with improved technology and information gathering capabilities could make these employees even more effective, to benefit both the taxpayer and the farmer.	NAWG
	To address the question on integrity of the data the farmer should be able to produce the “raw” data collected by his precision ag system if needed to support an audit or claim. This would insure that the data had not been modified by his FMS software.	AgDoc
	A significant improvement for the producer would be to minimize the number of trips a farmer has to make to the FSA office.	NAWG
	Currently, FSA data is updated only twice a year into the Common Land Unit (“CLU”) database for crop insurance purposes This is primarily due to Farm Serial Number (“FSN”) reconstitutions. This lack of current information makes it impossible for AIPs and/or RMA to stay connected to daily FSA activity as it relates to CIMS and CLU data.	ProAg

Questions	Comments	Company	Response from USDA
Are there reporting requirements that have become outdated and, if so, how can they be modernized to accomplish their objectives better?	Agents are providing reliable timely service that is not restricted to federal budgets for overtime, cars, and travel cost. In addition to customer access, insurance companies and agencies technology is evolving with the farming technology, to capture data electronically for efficiency.	Northwest/Farm Credit	Response to Question 5: • Crop insurance companies and agents will continue to provide critical programs to producers, just as the FSA State and County workers do. This project will not reduce the services that both Crop Insurance and FSA Farm programs provide. It will determine if individual business processes can share common data across multiple agencies. Collecting data once and sharing it will reduce or mitigate to the extent practical, duplicative producer reporting. • This will allow for common data to be collected once and used by other agency programs in which the producer chooses to participate. This will decrease the amount of duplicated or similar information that is collected from producers, rather it will enable companies, agents and FSA staff to focus on better servicing producers instead of spending time collecting and entering duplicative information.
	Any single source of reporting effort must originate with the crop insurance agent first and foremost.	NCIS/FMHIC/ARMtech/NAU
	The current reporting guidelines are built around manual collection methodology and technology which has been the same for more than 75 years. Few guidelines within the USDA recognize the use of new technology; no software or technology is in the scope of current USDA reporting requirements.	AgDoc
	While GPS monitoring equipment can do incredible things in a controlled environment, we are concerned about overreliance upon it in the uncontrolled environment of a busy planting or harvest season.	CIPA
	The determination of common guidelines in conjunction with the standardized terminology and definitions that will occur through the ACRSI project will allow modernization of the reporting process to occur.	ProAg

Questions	Comments	Company	Response from USDA
Do USDA agencies currently collect information that they do not need or use effectively to achieve regulatory objectives?	Requiring non-program participants to report to FSA to collect insurance acreage data would increase government cost. There is not consistent cross over with program crop participants (FSA) and crop insurance customers (RMA).	Northwest/Farm Credit	Response to Question 6: The project is to simplify and standardize to the extent practical acreage reporting processes, program dates, and data definitions across the various USDA programs. The objective of the ACRSI workgroup is to establish common data standards and automated processes across USDA to simplify and reduce the reporting burden on producers while simultaneously reducing USDA administrative and operating costs by sharing similar data across participating agencies.
	USDA collects only the information needed to administer USDA programs. However, there is a lack of continuity and/or consistency of the information collected between the various USDA agencies and the programs they administer because of the various definitions for the same term, (i.e., entity). These varying definitions for similar terms create inefficient and confusing data collection for the producer.	ProAg

Questions	Comments	Company	Response from USDA
Is there information that agencies should begin to collect to achieve the required objectives?	Farmers should be able to choose the point of reporting acres. The varying definitions for similar terms create inefficient and confusing data collection for the producer. There is a disconnection between the unit of insurance for crop insurance purposes and the CLU. Reporting requirements are driven by data definitions and information needs which means data standardization and makes data publicly available.	RH	Response to Question 7: The project is standardizing acreage reporting processes and data definitions across the various USDA programs so the common data can meet the basic program data requirements. Producers will still need to work with their USDA representative to meet specific program information requirements. The objective of the ACRSI workgroup was to reduce unnecessary data definitions differences and to establish common data standards and automated processes across USDA. The common data standards will still be the common data to meet specific program requirements, such as acreage reported by common land units to be identified by crop insurance units.
	The statutory and regulatory requirements that govern the current acreage reporting processes between FSA and RMA are being completely ignored specifically; the crop insurance policy obligates the producer to provide their agent an annual acreage report "on our form for each insured crop in the county on or before the acreage reporting date contained in the Special Provisions". Similarly it is not clear there is statutory authority for either a crop insurance agent or a crop insurance company to collect acreage reports on behalf of FSA. These statutory, regulatory and contractual issues have to be addressed before development of a single source acreage reporting capability should begin.	NCIS/FMHIC/ARMtech/NAU

Questions	Comments	Company	Response from USDA
Are there reporting requirements, or application processes that are unnecessarily complicated, or that could be streamlined to achieve the objective in ways that are more efficient?	Acreage reporting dates are set by FCIC and have been changed to an earlier billing due date of August for 2012. Strict deadlines are in place and require prompt delivery to the customer to meet the premium due date. There is definitely no room for delay. FSA allows for recertification of errors well beyond the established crop insurance reporting deadlines. The recertification process doesn’t impact the FSA programs but does have a significant negative impact on the crop insurance policy.	Northwest/Farm Credit	Response to Question 8: The Acreage Crop Reporting Streamlining Initiative (ACRSI) is to establish common Acreage Reporting Dates (ARDs) for producers to annually report their acreage data to RMA and FSA. This is the first step in a larger effort to simplify and consolidate information collection. The pilot will provide USDA with the ability to evaluate different methods of reporting and data processing. The standards will also identify if certain determinations or modifications have been made to the acreage report information. Depending on the program rules, these changes may or may not impact the eligibility of program benefits.
	The CIMS single database concept is sound, yet single source reporting at this stage is problematic and not a well-developed concept or alternative.	NCIS/FMHIC/ARMtech/NAU
	The farmer should have the capability to use his/her technology to obtain data from the USDA and report data to the USDA and all related USDA programs. The ACRSI initiative needs to be supported and completed until the data is standardized and is publicly available.	AgDoc
	While we see the merits of moving toward common land descriptions, we think this need to be pursued from a more practical standpoint, such that the common land unit would also be the best or most relevant land unit description today.	CIPA
	Reconciling the reporting requirements – for both the data needed and the deadline for reporting the information – should be a major goal for USDA during the review of process improvements. A single report that could be used by both Agencies would also eliminate small inadvertent discrepancies that can occur when duplicate reports for the same field are filled out multiple times, which can trigger penalties for inaccurate reporting and fraud concerns. Producers have also noted that reporting requirements can vary considerably from county to county, and our members urge USDA to encourage consistency among the counties to the greatest extent possible.	NBGA/NSA/USCA/UDPLC
	USDA must balance the burden of the reporting requirements and the farmer’s task of farming. For example, reporting acreage should not hinder a producer’s ability to get the crop harvested in a timely manner while navigating weather conditions during the harvest season. We are concerned with the growing disparity between “production reports” and “APH databases” since APH databases cannot be established below crop/county/unit/P/T/TMA and a handful of other exceptions, but the production reporting requirement appears to be heading toward the time when production reports are to be set up, processed and submitted to RMA by CLU.	RH
	The capability to provide “farm-field” data directly from the CIMS system would create a solid foundation for the producer to supply the required “farm-field” information accurately and efficiently to the USDA.	ProAg
	To maximize efficiencies and minimize duplication of efforts, we have strived to obtain land use data from the USDA Farm Service Agency with very little success, and realize that language in the current Farm Bill prohibits FSA from sharing their data.	WSDA

Questions	Comments	Company	Response from USDA
Are there application processes or reporting requirements that have been overtaken by technological developments? Can new technologies be used to modify, streamline, or do away with existing reporting requirements?	Satellite imagery does not work for all crops. Crop insurance requires field splits based on practice, type, and variety that are consistent with diversified farming practices. Those splits do not necessarily display on Satellite imagery.	Northwest/Farm Credit	Response to Question 9: There are many technologies available today to assist in producer reporting. These technologies may not support all data reporting requirements. Privacy and secured access to protected information is the highest priority of this project. The Food, Conservation, and Energy Act of 2008, Title 1, Subtitle F, Section 1619 established strict limits on what data can be shared with whom. The USDA eAuthentication system enables individual producer’s access to their farm information. The initial pilot will not include RMA data since a majority of it does not contain the FSA Farm number. Recommendations will incorporate more of the USDA identifiers in the RMA data standards.
	Can CIMS be made directly accessible by an authorized user without having to access it via a 3rd party such as an AIP? The ability for a farmer to garner services beyond FSA's office hours gains my vote and support for RMA to be the lead for ACRSI (if that is an idea or process being considered).	CIS
	The current “eAuthentication” system does not link to RMA or any precision ag technology that the producer may have in use in the farming operation -- this must be changed. It is recommended that the USDA look into creating a one unique identification for the producer to use for all systems. This would help link systems together, improve data accuracy, and simplify the single source process.	ProAg