FSA and the Next Farm Bill

NASCOE views the development of the next Farm Bill as an immense opportunity for Congress and the Administration to meet agricultural challenges and to provide opportunities for the future.  The employees of the Farm Service Agency stand prepared to provide the means for Congress to administer many of the programs and duties provided for in the next Farm Bill.  Since the 1930’s the Farm Service Agency and its predecessors have been USDA’s most efficient and effective agency for administering farm programs. With a grass roots system of locally elected farmers and ranchers serving each county, and a committed staff of county office employees who are accountable to both USDA and the locally elected committee, the system is a shining example of government of the people and by the people. FSA has provided one of the only systems in government where local control and national direction work hand in hand to accomplish the goals set forth by Congress and directed by the President.

As Congress develops the Farm Bill, NASCOE asks that you consider the following suggestions for effective implementation of current and future farm and commodity programs:

• Designate FSA as the sole Agency for the collection of crop acreage reports.
• Utilize FSA resources and skills by appointing FSA the centralized data management agency within USDA.
• Consider expansion of the Noninsured Assistance Program (NAP) to provide needed assistance to specialty crop producers.
• Information Technology Initiatives implemented by USDA should be more accountable. 
• With a proven track record in administering payment programs FSA should be assigned any new payment programs developed by Congress such as: Permanent Livestock and Crop Disaster Programs, Crop Revenue Programs, and Energy-Based Programs.

Programs administered by FSA are vital to American agriculture, family farms, and the rural economies of the communities in which we serve.  Since 1993 FSA staffing levels have been drastically reduced to a level where our excellent service could be compromised. With the current level of program delivery NASCOE feels we must be staffed with 9800 employees.  This level will protect our infrastructure, program delivery, and ensure that the required checks and balances are properly executed. In the future we must continue to staff according to our program delivery needs.  If a permanent disaster program is developed or a disaster type program implemented we ask that a level of temporary employees be written into the legislation to be aligned with the size of the disaster.  

To meet the changing needs of our agency we must maintain integrity in our mandated programs at the least cost of delivery.  We must make the most of our limited fiscal budgets and use our resources wisely.  We hope you will consider the items contained in this paper for the future of American Agriculture.

         EMPLOYEE BENEFITS

The 109^th Congress of the United States attempted passage of several pieces of legislation supported by NASCOE and RASCOE.  NASCOE and RASCOE applaud those Congressional Representatives supporting this legislation. It is hoped that the 110^th Congress will, at a minimum, address the inequities described below;

• Social Security Windfall Elimination Provision. The formula for calculating a federal employee’s retirement under this provision reduces the earned annuity by as much as 60%.
• HR 82 and SB 206 introduced in the 110^th Congress address this inequity. 

• Government Pension Offset. The law requires two-thirds of a government annuity be offset from a spousal social security benefit.
• HR 82 and SB206 also correct this situation.
• Retirement.  Federal County Office Employees dedicate their career to serving the Agricultural Community with a promise of certain retirement benefits.  Many federal employees would be very disappointed if Congress made a change in the retirement formula at this time.

• Cost of Living Adjustments.  The 1990 Federal Employee Pay Comparability Act was designed to equalize pay between federal and non-federal workers within 10-years.  The average pay for FSA employees lags 8 to 12% behind comparable jobs in the private sector.  Congress needs to act to correct this disparity.

• Health Insurance.  NASCOE and RASCOE support several changes to the health insurance programs offered our employees. Items of concern include; premiums continue to rise approximately 10% each year, non-participants should receive monetary compensation, the age of discontinuing coverage for dependents should be raised from 22 to 25, the law should allow retirees to use pre-tax dollars to pay health costs (H.R. 1110 provides this correction for our retirees), and we support the availability of affordable dental and vision coverage. Our membership is counting on Congress to assure that our employees carrying health insurance during the last 5 years of their federal employment maintain eligibility for full health benefits into retirement. Your support of legislation addressing our member’s concerns for improved health insurance benefits will improve working conditions for all federal employees. 
• Leave. Federal Employees covered under the Federal Employee Retirement System (those hired since 1/1984) should be rewarded for conserving their sick leave. We support removal of the requirement that GS and CO employees be from the same employee system to utilize donated leave. Finally donated leave should not be limited to annual leave.

• Liability Protection.  Congress must act to revise 7 CFR Subtitle A to include former USDA employees. Employees leaving USDA should be protected from lawsuits generated from actions taken during their official employment.

• Whistleblower Act. Federal Law, Title 5, U.S.C. Sec 1213 and Sec 2302, provides a secure channel for current, former, and prospective federal employees to make confidential disclosures of the following: abuse of authority, violations of law, gross mismanagement, waste of federal funds and evidence of specific danger to public health and safety. Federal Law also protects these groups from retaliation related to any persons that have filed a whistle blower complaint. Title 7 Employees  (non-federal County Committee employees) should be afforded the same protection offered other Federal Employees under the Whistleblower Act. This oversight could be addressed by Congress by including our members in the Whistleblower Protection Enhancement Act (H.R.985) and the Executive Branch Reform Act (H.R.984).

NASCOE and RASCOE ask that Congress consider ways to make federal employment more comparable to the private sector.  We believe enactment of legislation to address the above issues will allow USDA to continue providing the high quality of service the farm community has become accustomed to, and to continue to attract high quality employees in the future.

Farm Service Agency and Efficient Conservation Title Implementation

The primary goal of the National Association of FSA County Office Employees (NASCOE) and the employees of the Farm Service Agency is to support American Agriculture. NASCOE members are dedicated to implementing all federal agriculture programs as efficiently and effectively as possible.

The development of the new farm bill will offer many challenges and also opportunities to improve the quality and efficiency of farm bill delivery.

As the farm bill develops, it is imperative that all avenues are explored and comments considered creating, the most functional and monetarily efficient bill possible.

There are numerous areas of duplication currently occurring within USDA that can be corrected during this farm bill that will provide budget savings to assist with financing infrastructure needs without additional burden to taxpayers.

The primary purpose of this paper is to specifically address conservation administration. At many of USDA’s farm bill forums, frequent comments from producers suggested operational changes. Some of these comments were:

 • NRCS staff needs to be back in the field working with individual farmers and ranchers, not working at their office computer

• Some comments suggested streamlining and consolidating NRCS conservation programs

• A few comments wanted USDA to eliminate loopholes and simplify, streamline, consolidate, and coordinate programs, and they noted confusion with various acronyms

• The application process for EQIP needs to be simplified and timely for the participants.

• NRCS spends too much time doing compliance and status reviews on conservation programs rather than helping clients. In addition to creating a more efficient operation that is more seamless in it's delivery for all conservation programs such as CSP, WRP, WHIP, EQIP and GRP, realignment of conservation duties should help USDA’s bottom line.

There are two primary agencies responsible for delivery of conservation programs at the field level. Farm Service Agency (FSA) has by and large been known as an administrative agency with over 60 years of success in that area. Natural Resources Conservation Service (NRCS) has generally been known as a technical agency with many years of success in that area. The 2002 farm bill blurred these duties by assigning some administrative and technical responsibilities to both agencies.

A resolution passed by National Association of Conservation Districts (NACD) on February 9, 2005 addressed these concerns in stating, “The recent increase in program administration by NRCS has created a tremendous and burdensome workload for NRCS staff at the field office level. Technical staff now spends a great deal of time processing contracts, following paper and electronic project files, and tracking payment requests. This additional workload did not come with additional staff. Therefore, existing staff that have vast experience and knowledge in varied technical fields of natural resources are not able to provide either the quality or the quantity of technical assistance that is needed. This transfer of work has resulted in a fundamental shift from the purpose for which the agency was originally created. That mission was to provide technical assistance to producers and resource users that address conservation needs with consideration for local priorities and conditions.” NACD also expresses the same concerns in their Farm Bill Core Statements adopted by the board of directors February 7, 2007 which states, “The delivery of technical assistance is the most critical element to the adoption of conservation practices and participation in Farm Bill conservation programs. NACD supports efficiencies and allocation of assets to allow technical personnel more time in the field.”

The dual roles have caused inefficiencies within FSA as well. Many times producers are required to make multiple office visits for eligibility determinations required by conservation programs. This could have been avoided if all of the administrative responsibilities of application processing, eligibility determination, maintenance, and payments were completed by one agency.

NASCOE supports a realignment of conservation responsibilities to take advantage of FSA’s long history of conservation program administration and NRCS’s expertise in providing conservation program technical assistance.

The NASCOE leadership is willing to discuss all suggestions of local authority, streamlining, and simplification made by producers and our partners as long as those discussions will create a better, more efficient USDA and stronger support of American Agriculture.