Emergency Conservation Program

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Program level Payment Integrity results

Sponsoring agency: Department of Agriculture

View on Federal Program Inventory

PROGRAM METRICS

$129 M

in FY 2021 outlays, with a

86.5%

payment accuracy rate

PROGRAM METRICS

$61 M

in FY 2022 outlays, with a

70.8%

payment accuracy rate

PROGRAM METRICS

$85 M

in FY 2023 outlays, with a

59.6%

payment accuracy rate

PROGRAM METRICS

$101 M

in FY 2024 outlays, with a

54.8%

payment accuracy rate

PROGRAM METRICS

$133 M

in FY 2025 outlays, with a

44.5%

payment accuracy rate

  • Improper payment estimates over time
    View as:

    Chart toggle amounts:
    Proper payments
    Overpayment
    Underpayment
    Technically improper
    Unknown

Payment Integrity results

  • FY 2021 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    10/2019 - 09/2020


    Confidence interval:

    >90%


    Margin of error:

    +/-3.0

Overpayments

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $9.3 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $9.3 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $0.0 M

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $0.14 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.14 M

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $7.95 M

Additional information

$8.09 M

Unknown Payment Details

Evaluation of corrective actions

The following actions were put into place fall of this year and should show profound reductions in IP during the 2022 review:

1. FSA updated and revised Handbook 1-ECP, May 4, 2021 (rev 6) and Rev 7 on September 16, 2021. This handbook provides guidance to Field offices and sets forth policy regarding ECP program management, provides updates of new requirements and provides clarification to previous existing requirements.

2. FSA recognizes the need for improvements regarding documenting installation costs to ensure producer documentation is sufficient, prevent ineligible costs, and ensure the correct reimbursement rates are used.
As a result, in FY 2020, FSA established a Payment Scenario Development Team, whose role is to assist in the development and training of payment scenarios to ensure ECP payments are being applied correctly and documented properly. The rollout of the payment scenarios software occurred September 16, 2021 and will included an updated handbook and joint training with FSA and Natural Resources Conservation Service (NRCS) field offices to discuss the new policy. Training occurred as follow:
• July 27, 2021 – training to review the policy change as well as how the software will compliment this new change
• July 28, 2021 – training to review the handbook revision that includes the new policy
3. Notice CP-74 was issued on July 7, 2021 providing procedure for completing compliance reviews and performing spot checks. The Notice can be found at (https://www.fsa.usda.gov/Internet/FSA_Notice/cp_764.pdf).
4. CCC-770 ECP-1 checklist was revised to require DD signature during the ECP implementation, approval, payment, and spot check process. The revised form will be issued with the next version of the handbook update.

Future payment integrity outlook

Emergency Conservation Program has established a baseline.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $154.52 M
Current year +1 estimated future improper payments $15.44 M
Current year +1 estimated future unknown payments $0 M
Current year +1 estimated future improper payment and unknown payment rate 9.99 %

The program's current year improper payment and unknown payment rate of 13.5 % has not been achieved with a balance of payment integrity risk and controls and does not represent the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is not the tolerable rate.

Steps Planned
1. New software to process ECP cost share applications and payments more efficiently and to reduce errors is essential to improve program delivery. A project development schedule has been designed; however, implementation will be based on the Agency IT budget availability and the completion of its current IT priority list.

2. FSA has planned to implement the ECP district director review process to the new FSA Internal Review Document and Tracking System (IRDTS) to ensure reviews are being completed timely and results are monitored and evaluated to ensure ECP policies are being followed. FSA’s IRDTS is a new centralized, automated internal control tracking system that allows management at all levels to complete and track program audits and reviews.

• In May 2019, FSA leadership approved the funding and selected the platform for the development of the IRDTS software.
• By September 30, 2021, FSA will have incorporated its first phase (Phase 1) of programs that have review processes being completed manually.
• By December 1, 2021, FSA will begin the second phase (Phase 2) of incorporating FSA program reviews into IRDTS, which will include ECP. By using the IRDTS solution for applicable FSA Oversight Assessments, FSA will be able to plan, sample records, conduct assessment reviews, and document the results over time to score and track errors found during the reviews. FSA will use this data to improve processes and policies, identify areas where additional employee training is needed and understand trends and systemic issues occurring at the state and county levels.

NOTE: Implementation of ECP into IRDTS is subjected to Agency budget availability and the priority of other program review candidates that are scheduled to be implemented. All phases of the integration of ECP district director reviews into IRDTS are estimated to be completed by September 30, 2022.

Additional programmatic information

  • FY 2022 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    10/2020 - 09/2021


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-3.0

Overpayments

In preventing or reducing improper payments in program, the agency has implemented the following measures: Handbook 1-ECP (Revision 7) was issued, joint training with Farm Service Agency and Natural Resource Conservation Service state and county offices to discuss the new policies and procedures was held on July 7, 2021. Trainings are posted on the Agency’s Deputy Administrator for Farm Programs internal training website and available to all Farm Service Agency employees. Communications were made by establishing monthly teleconferences with State Offices with the main purpose of focusing on program deficiencies for improving improper payment percentages and providing policy updates and ad-hoc trainings. Refresher trainings will be developed to specifically address common fiscal year 2022 Payment Integrity Information Act findings across programs, to include agency representative approval procedures, acceptable producer and affiliate filing requirements, as well as County Office Committee/County Executive Director redelegations of authority for approval of documents. Budget requests were initiated to fund a complete re-write of the Emergency Conservation Program cost share software to incorporate the use of geographic information system mapping to identify areas of damage, automated calculations to validate total payment for a single event, payment scenarios as a basis of payment rate, and build into the software monitoring requirements to validate proper completion of approvals and payments. In August 2021, Farm Service Agency implemented the use of payment scenarios for Emergency Conservation Program. The use of payment scenarios eliminated the requirement for county offices to compute cost share from documentation submitted by the producer. Budget request of $1.8 million to fund a complete re-write of the Emergency Conservation Program cost share software to incorporate the use of geographic information system mapping to identify areas of damage, automated calculations to validate total payment for a single event will not exceed 50 percent of the agricultural value of the land, incorporate payment scenarios as a basis of payment rate, and establish a monitoring process to validate proper completion of CCC-770 before application approval and payment. In addition, the software will incorporate a monitoring process related to validation of county executive directors spot check review. A revised CCC-770 checklist has been developed that will capture District Director review during approval, payment, and lifespan of the practice.
Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $1.29 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $1.29 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $0.0 M

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $0.11 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.11 M

Technically improper payments

The county offices did not follow statutory requirements related to FSA-848A (Cost Share Agreement) which were not signed by an authorized Farm Service Agency representative before payments were issued.
The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $16.42 M

Additional information

$16.53 M

Unknown Payment Details

Evaluation of corrective actions

Some of the causes of improper payments were due to statement of producers own contribution were not on file or were inadequate. In August 2021, Farm Service Agency implemented the use of payment scenarios for Emergency Conservation Program. The use of payment scenarios eliminated the requirement for county offices to compute cost share from documentation submitted by the producer. This action will assist with developing and implementing a standardized format for documenting installation costs to ensure producer documentation is sufficient, prevent ineligible costs, and ensure the correct reimbursement rates are used.

Future payment integrity outlook

Emergency Conservation Program has NOT established a baseline.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $100 M
Current year +1 estimated future improper payments $10 M
Current year +1 estimated future unknown payments $0 M
Current year +1 estimated future improper payment and unknown payment rate 10.0 %

The program's current year improper payment and unknown payment rate of 29.17 % has not been achieved with a balance of payment integrity risk and controls and does not represent the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is not the tolerable rate.

Farm Service Agency continues to strategically take the necessary steps to strengthen internal controls measures, establish uniform consistency for compliance processes, and improve accountability. Farm Service Agency’s aim is to not only make these improvements at the program specific level but to initiate transformation at the overall arching and broader Agency level.

Farm Service Agency will require key resources to continue its progression towards strengthening internal controls and addressing the inconsistencies with certain programs reporting more than the statutory improper payment threshold in fiscal year 2022.

Human Capital Needs: National and State Office Compliance Resources - To resolve the Agency’s noncompliance issues in a timely manner, strengthen program integrity and accountability and maintain an ongoing compliance oversight strategy, additional compliance staff will be crucial for Farm Service Agency to build a comprehensive and robust compliance program.

Farm Service Agency once had staff positions whose main responsibility involved monitoring and addressing compliance related issues within states known as Farm Service Agency County Operations Reviewer, but these positions were transferred in fiscal year 2019 from Farm Service Agency to the Farm Production and Conservation Business Center, Performance, Accountability and Risk Division during the Farm Production and Conservation Business Center reorganization. This transfer caused a hardship on Farm Service Agency’s internal controls program and significant resource and specialized knowledge gaps are still prevalent today, which is contributing to Farm Service Agency’s capacity to timely and adequately address various compliance issues and requirements. Farm Service Agency and Performance, Accountability and Risk Division are evaluating the current set up to seek improvements as it relates to Farm Service Agency program compliance. In addition, Farm Service Agency’s existing staff continues to be stretched with the responsibilities of training new staff, administering Farm Service Agency programs, performing existing County Operations Reviewers duties, and addressing new compliance requirements, all as collateral duties. Farm Service Agency and Performance, Accountability and Risk Division are developing a new work plan to better address this issue and goal by first quarter fiscal year 2023 to define an improved workplan to support compliance review.

Information Systems’ Needs – Farm Service Agency is positioning itself to take preventive measures through automated processes that are built into business systems to reduce errors. Automation improves productivity and enforces procedural compliance; therefore, Farm Service Agency is exploring better approaches to integrate internal controls functions into the implementation of programs, as well as maintenance of an existing program systems. Given these efforts, the Agency is planning to request Congressional funding for enhancing: 1) transactional program systems/software to quickly meet the implementation demands of pandemic, emergency, and disaster programs and 2) interface systems to allow data sharing and eliminate manual/duplicative entries and processes.

Several transactional program systems and software “work arounds” and manual processes still exist that are contributing to the increase of program improper payments. Funding is needed to resolve current deficiencies and build internal controls requirements within these systems.

From an internal controls oversight perspective, Farm Service Agency has invested in the Internal Review Documentation and Tracking System and continues to incorporate manual-paper based program reviews and spot-checks into automated processes within the system. The objectives for Internal Review Documentation and Tracking System are to improve oversight capabilities to State and National program managers, supplement data mining efforts and formally document review results for program analysis and enrichment. This effort is ongoing and is planned through fiscal year 2024.

Other Infrastructures Needs - As part of the Agency’s new integrated compliance plan, the design will incorporate further actions to address meeting program reduction targets, including but not limited to: 1) changing the current sampling methodology to using better sound statistical, survey, and data collection methodologies that elevate past issues of “oversampling” and inefficient use of resources, while also ensuring the program dollars are delivered to all producers who are legally entitled to them; 2) utilizing a risk-based approach, where program risks and risk tolerances are identified to allow the right internal controls to be put in place, establish program metrics that gages the success of meeting objectives and need for improvements; 3) integrating a more proactive use of data mining to identify program key performance indicators, anomalies, fraud, waste, and abuse; and 4) performing a validity reassessment of current program oversight processes, such as oversight checklists, redelegation of authorities for approvals, etc.

These actions will also assist in capturing program impacts to targeted arenas of the historically underserved groups and determining where increased efforts are needed to improve accessibility to Farm Service Agency programs and services. For example, implementing routine sampling of denied applications on historically underserved groups to verify if approval and disapproval decisions are being made accurately.

Farm Service Agency is also coordinating with Farm Production and Conservation Business Center and the Department on the multi-year data management efforts to improve transparency, data mining, intelligence dashboards, and program analysis. Equally, significant investments in the development and utilization of program dashboards and visualizations have been made by Farm Service Agency. These efforts are helping to increase transparency, augment analytics capacity and make data readily available to support important mission-focused decision-making.

Farm Service Agency has built a number of dashboards to provide visualizations for its major Farm Programs and Farm Loan Programs, such as Coronavirus Food Assistance Program 1, Coronavirus Food Assistance Program 2, Wildfires and Hurricanes Indemnity Program Plus, Dairy Margin Coverage, Agriculture Risk Coverage and Price Loss Coverage, Conservation Reserve Program, Farm Loan Program Direct Loan Portfolio, Farm Loan Program Loan Obligations, program payments, acreage reporting, etc. Nationwide administrative dashboards to view office workload, productivity, and the geographic servicing areas for Farm Service Agency leadership and managerial staff have also been developed throughout fiscal year 2022.

The Agency is planning to request Congressional funding for enhancing: 1) transactional program systems/software to quickly meet the implementation demands of pandemic, emergency, and disaster programs and 2) interface systems to allow data sharing and eliminate manual/duplicative entries and processes.

Additional programmatic information

  • FY 2023 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    10/2021 - 09/2022


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-3.0

  • Actions taken & planned to mitigate improper payments

    Mitigation strategy Description of the corrective action Completion date Status
    Training
    Farm Service Agency has developed new program payment scenarios which eliminates the County Office requirement to compute cost share items considered eligible. The agency has provided policy on the use of the new payment scenarios and continues to provide training and assistance as we transition to this new method.
    FY2022 Q1
    Completed
    Change Process
    The requirement to have an FSA-23 on file before the cost share agreement is approved and included on the CCC-770 Checklist. Farm Service Agency has revised the CCC-770 checklist to capture the District Director reviews during approval, payment, and lifespan of the practice. In addition, the agency will incorporate Emergency Conservation Program-Disasters into the Internal Review Document Tracking System to track actions.
    FY2023 Q4
    Completed
    Training
    The root cause of improper payments was failure to access data/information. Errors resulted from the payment calculations using old calculation methods. The eligible cost of practice or component were calculated incorrectly. Farm Service Agency has developed new program payment scenarios which eliminates the county office requirement to compute cost share items considered eligible. The agency has provided policy on the use of the new payment scenarios and will continue to provide training and assistance in the transition of these new methods. It is the goal of the agency to prevent ineligible costs and ensure the correct reimbursement rates are used.
    FY2024
    Planned
    Change Process
    The root cause of improper payments was failure to access data/information. Improper payment findings were related to the FSA-23 not being on file before the cost share agreement was approved. The requirement to have an FSA-23 on file before the cost share agreement is approved is included on the CCC-770 Checklist. The agency will revise the CCC-770 checklist to capture the District Director reviews during approval, payment, and lifespan of the practice. This will allow the District Directors to ensure and verify that the FSA-23 approval is completed before the cost share agreement is approved. The checklist covers each step of the program process, including requesting cost share, approval, and payment. The District Director is required to review and sign at each item on the checklist to ensure accuracy. The change process corrective actions planned are to ensure reviews are being completed timely and results are monitored and evaluated to ensure program policies are being followed. The agency will also incorporate the program into the Internal Review Document Tracking System to track actions.
    FY2024
    Planned

Overpayments

The Farm Service Agency administers all of its programs within the agency. The root cause of the improper payment findings was related to statutory requirements of the program not being met. The majority of the findings were related to the producer statement not being signed and missing practice installation documentation. To address these issues, the Farm Service Agency has revised the 770 checklist that will capture District Director review during approval, payment, and lifespan of the practice. Emergency Conservation Program also be incorporated into the Internal Review and Data Tracking System. In addition, webinar/virtual training sessions will occur at least quarterly to ensure all State staff are aware of updated policy requirements and clarifications to all requirements.
Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $21.08 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $21.08 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $0.0 M

Overpayment type Eligibility element/information needed Eligibility amount
Overpayments Within Agency Control Affiliation $21.08 M

Overpayment type Mitigation strategies taken Mitigation strategies planned
Overpayments within the agency’s control Change Process Change Process

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $0.04 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.04 M

Eligibility element/information needed Eligibility amount
Affiliation $0.04 M

Mitigation strategies taken Mitigation strategies planned
Change Process Change Process

Technically improper payments

The root cause of the improper payment findings was related to statutory requirements of the program not being met. The majority of the findings related to the producer statement not being signed and missing practice installation documentation.
The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $13.25 M

Mitigation strategies taken Mitigation strategies planned
Training Training

Additional information

$13.29 M

Unknown Payment Details

Evaluation of corrective actions

The requirement to have an FSA-23 on file before the cost share agreement is approved and included on the CCC-770 Checklist as well as an update to the checklist to address the revised FSA-848-A without signatures by the participant before the payment was issued. The agency has revised the CCC-770 checklist to capture the District Director reviews during approval, payment, and lifespan of the practice. This will allow the District Directors to ensure and verify that the FSA-23 approval is completed before the cost share agreement is approved and the FSA-848-A is signed by agency and the participant before the payment is issued. The checklist covers each step of the program process, including requesting cost share, approval, and payment. The District Director is required to review and sign at each item on the checklist to ensure accuracy.

Future payment integrity outlook

Emergency Conservation Program has established a baseline.

With the implementation of the current corrective actions and the planned corrective actions for the program, it is the agency’s anticipation that the projected reduction target will be less than the estimated future improper payment rate.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $90 M
Current year +1 estimated future improper payments $8.99 M
Current year +1 estimated future unknown payments $0 M
Current year +1 estimated future improper payment and unknown payment rate 9.99 %
Current year +1 estimated future improper payment and unknown payment reduction target 9.99 %

The program's current year improper payment and unknown payment rate of 40.41 % may or may not be the tolerable rate. The agency has not yet determined the tolerable rate for this program.

The agency does not have sufficient resources to add needed internal controls, human resources, and information systems to reduce the improper payment and unknown payments. The agency will continue to strategically take the necessary steps to strengthen internal control measures, establish uniform consistency for compliance processes, and improve accountability. A continuous evaluation system which monitors the effectiveness of internal controls is in place but is not sufficient to reduce improper payments rates. Lastly, agency will require key resources to continue its progression towards strengthening internal controls and addressing the inconsistencies with certain programs reporting more than the statutory improper payment threshold.

Emergency Conservation Program does not have sufficient resources to add needed internal controls, human resources, and information systems to reduce the improper payment and unknown payments. Emergency Conservation Program leverages the existing internal controls environment and accountability processes to provide reasonable assurances that internal controls are in place and operating effectively. A continuous evaluation system which monitors the effectiveness of internal controls is in place but is not sufficient to reduce improper payments rates.

The fiscal year 2024 President’s Budget and the fiscal year 2025 Department Estimates submitted to Office of Management and Budget does not include funding levels to support the required software enhancements to increase application controls. Due to budget constraints for the agency approved funding levels, the funding required to build automated internal controls within the existing systems is not included.

Additional programmatic information

The Conservation Division within Farm Service Agency has historically communicated to field employee’s improper payment percentages and findings which influence the program’s annual proper payment percentage. National training and monthly calls are provided for field staff covering program policies and payment errors. Online training materials such as PowerPoint presentations, recorded trainings, worksheets, videos, forms, and specialized third-party crop resources are made available for field staff.

  • FY 2024 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    10/2022 - 09/2023


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-3.0

  • Actions taken & planned to mitigate improper payments

    Mitigation strategy Description of the corrective action Completion date Status
    Automation
    The root cause for this category was related to not following statutory requirements. New Software Platform - The new Emergency Conservation Program-Disasters software was released into production in January 2024 and applies to disasters occurring Fiscal Year 2024 and forward. An introductory training for the Emergency Conservation Program-Disasters software was conducted nationwide on December 6, 2023, and January 9 and 10, 2024. Farm Service Agency developed new software to process Emergency Conservation Program-Disasters cost share applications and payments more efficiently and reduce administrative errors. The new application software contains validations to prevent many of the common Payment Integrity Information Act errors described such as performs eligibility checks for the status of the CCC-902 and AD-1026 in the subsidiary to meet statutory requirements without impacting application approval. However, agreements prior to Fiscal Year 2024 that are loaded in Cost Share Software do not include eligibility checks in the software. Therefore, it is a manual process to check subsidiary for CCC-902s and AD-1026s for older agreements. Continued training will help to address this issue until old contracts and the old system is phased out.
    FY2024 Q1
    Completed
    Training
    The root cause for this category was related to not following statutory requirements. Additional webinar/virtual training sessions are held on an as-needed-basis as well as the third Thursday of each month, to ensure all State Office staff are aware of updated policy requirements and clarifications to all requirements. Training topics include not only hot topics, but also topics that target Payment Integrity Information Act deficiencies. Emergency Conservation Program-Disasters Training Series for all Farm Service Agency employees with Emergency Conservation Program-Disasters responsibilities. The first training occurred on June 5, 2024, with over 760 attendees. The series resumed July 17, after acreage reporting was complete through September 11, 2024. Trainings will cover policy and software pain points as well as Payment Integrity Information Act findings and root causes. Deputy Administrator for Farm Programs provided In-person trainings June 13-21, 2024, in Florida which covered many of the Payment Integrity Information Act findings, policy pain points, and software pain points.
    FY2024 Q4
    Completed
    Change Process
    The root cause for this category was related to not following statutory requirements. A new CCC-770 ECP-3 was issued on Feb 12, 2024, to accompany the new Emergency Conservation Program-Disasters software. The new CCC-770 combined the previous CCC-770 ECP-2 and CCC-770 ECP-1 Checklist and separated into multiple parts to better document reviews. The CCC-770 ECP-1 Checklist also incorporated items to address common audit findings. The updated form reflects new software function and validations. As an actionable item, a decision memorandum of new policy has been approved by Deputy Administrator for Farm Programs (July 2024) to require employees: • Prior to Approval: the CCC-770 be completed by Program Technicians and County Executive Directors in its entirety for all Emergency Conservation Program-Disasters and Emergency Forest Restoration Program applications. Require the District Directors to review and sign the CCC-770 for the first 5 applications prior to County Office Committee approval, or 10 applications if the County Office has not implemented Emergency Conservation Program-Disasters within the last 2 years. • Prior to Payment: the CCC-770 be completed by Program Technicians and County Executive Directors in its entirety (excluding spot check) for all agreements prior to payment. Require the District Directors to review and sign the CCC-770 in its entirety (excluding spot check) for the first 5-10 applications prior to payment. • A percentage of paid Emergency Conservation Program-Disasters agreements to be reviewed by the State Office Program Specialist to ensure adherence to policy and proper payments. A minimum of 5% of paid agreements will be required for State Office review. Selections will be determined by State Office and State Office reviewers will report deficiencies to the State Executive Director and require corrective actions, if necessary. The State Executive Director will have discretion to require additional State Office reviews based on the results of 5% review. These efforts will ensure the maintenance of employee accountability at all levels. The following are related to the CCC-770 checklist: • Implementation: This section of the form assists County Offices in the Emergency Conservation Program-Disasters application processing phase or signup phase, ensuring all eligibility requirements are met and the required forms are completed. District Director concurrence is included. • Approval: This section of the form assists County Offices in the application approval phase ensuring all eligibility is completed, required producer signatures are obtained and that proper delegations of authority are completed and documented in County Office Committee minutes. This will also ensure that applications and revised applications contain all required producer signatures as well as Farm Service Agency representative approval signatures before obligating funds for the application. • Processing Cost Share: This section of the form assists County Offices in the processing cost share phase. This review ensures all required supporting documentation is on file and second party reviews have been completed. This will serve as another level of review ensuring revised applications because of practice extents changing and all required producer signatures and Farm Service Agency representative signatures are obtained. • Payments: This section of the form assists County Offices ensure producers meet all eligibility requirements and all producers receiving shares are listed on the FSA-801C’s, before any payments are issued. District Director concurrence is required prior to payment, and concurrence is documented on the form. • Producer Spot Checks: This section of the form assists County Offices in the process of producer spot checking Emergency Conservation Program-Disasters practices within the lifespan of the practice.
    FY2024 Q4
    Completed
    Predictive Analytics
    The root cause for this category was related to not following statutory requirements. The new software will require time to adequately analyze if the new software functionality meets the goal of reducing administrative errors. The completion of the CCC-770 ECP-1 or ECP-3 ensures compliance of all statutory requirements. If the preparers, County Executive Directors and District Directors sign the CCC-770s without meeting the statutory requirements, then as stated on this form, the CCC-770 will be used to hold the responsible party accountable. Training feedback from State and County Offices has been very positive. The trainings have helped them understand subjects that they previously misunderstood handled incorrectly.
    FY2024 Q4
    Completed
    Statutory Change
    Null.
    FY2024 Q4
    Completed
    Automation
    The root cause of these improper payments was failure to access data. Internal Review Documentation and Tracking System - The integration of Emergency Conservation Program-Disasters into the Internal Review Documentation and Tracking System is planned for August 31, 2024. Farm Service Agency is initiating/transitioning the Emergency Conservation Program County Executive Director and District Director review process and producer spot checks to Internal Review Documentation and Tracking System, with full implementation expected in Fiscal Year2024. Internal Review Documentation and Tracking System will serve as Farm Service Agency’s tool to make certain reviews are timely completed and review results are monitored and evaluated to ensure Emergency Conservation Program-Disasters policies are being followed. Farm Service Agency’s Internal Review Documentation and Tracking System is a centralized, automated internal control tracking system that allows users and management at all levels to complete and track program audits and reviews.
    FY2025
    Planned
    Training
    The root cause of these improper payments was failure to access data information. Additional webinar/virtual training sessions will be held on an as-needed-basis as well the third Thursday of each month, to ensure all State Office staff are aware of updated policy requirements and clarifications to all requirements. Training topics include not only hot topics, but also topics that target Payment Integrity Information Act deficiencies.
    FY2025
    Planned
    Change Process
    The root cause of these improper payments was failure to access data. New policy will be implemented to require: Prior to Approval, the CCC-770 will be completed by Program Technicians and County Executive Directors in its entirety for every Emergency Conservation Program-Disasters and Emergency Forest Restoration Program application. Also, require the District Directors to review and sign the CCC-770 for the first 5 applications prior to County Office Committee approval, or 10 applications if the County Office has not implemented Emergency Conservation Program-Disasters within the last 2 years. Prior to Payment, the CCC-770 will be completed by Program Technicians and County Executive Directors in its entirety (excluding spot check) for every agreement prior to payment. Require the District Directors to review and sign the CCC-770 in its entirety (excluding spot check) for the first 5-10 applications prior to payment. A percentage of paid Emergency Conservation Program-Disasters agreements to be reviewed by the State Office Program Specialist to ensure adherence to policy and proper payments. A minimum of 5% of paid agreement will be required for State Office review. Selections will be determined by State Office and State Office reviewers will report deficiencies to State Executive Director and require corrective actions, if necessary. State Executive Director will have discretion to require additional State Office reviews based on result of 5% review.
    FY2025
    Planned
    Audit
    The root cause of these improper payments was failure to access data. Internal Review Documentation and Tracking System - The integration of Emergency Conservation Program-Disasters into the Internal Review Documentation and Tracking System is planned for August 31, 2024. Farm Service Agency is initiating/transitioning the Emergency Conservation Program County Executive Director and District Director review process and producer spot checks to Internal Review Documentation and Tracking System, with full implementation expected in Fiscal Year2024. Internal Review Documentation and Tracking System will serve as Farm Service Agency’s tool to make certain reviews are timely completed and review results are monitored and evaluated to ensure Emergency Conservation Program-Disasters policies are being followed. Farm Service Agency’s Internal Review Documentation and Tracking System is a centralized, automated internal control tracking system that allows users and management at all levels to complete and track program audits and reviews. A division Integrity and Accountability notice will be issued outlining the fiscal year 2023 Payment Integrity Information Act findings and root causes. The notice will re-iterate policy related to each finding.
    FY2025
    Planned
    Predictive Analytics
    The root cause of these improper payments is failure to access data. Utilizing the Internal Review Documentation and Tracking System for the oversight of the County Executive Director and District Director reviews, will give Farm Service Agency the ability to plan, sample program records, conduct assessment reviews, monitor reviews, and document the results. The final objective will be analyzing the results to assist in improving processes and policies, identifying areas where additional employee training is needed and understanding trends and systemic issues occurring at the State and county levels. The completion of the CCC-770, ECP-1 or ECP-3 for every application at time of approval and before every payment will ensure compliance of all statutory requirements. If the preparers, County Executive Directors and District Directors sign the CCC-770s without meeting the statutory requirements, then as stated on this form, the CCC-770 will be used to hold the responsible party accountable. Additional trainings will help the field offices understand subjects that they previously misunderstood handled incorrectly. Issuing an Integrity and Accountability notice will re-iterate policy related to each finding.
    FY2025
    Planned

Overpayments

The root cause of these improper payments was failure to access data. The following describe the findings: • FSA-848A (Cost-Share Agreement) was not signed by the participant before payment was issued. • FSA-848B (Cost-Share Performance Certification and Payment) was not signed by the participant before payment was issued. • Evidence to determine proper cost-share payment was not on file or was inadequate. The completion of the CCC-770 ECP-1 or ECP-3 in its entirety for every approval and every payment ensures compliance and access to all data needed. If the preparers, County Executive Directors and District Directors sign the CCC-770s without meeting the current policy requirements, as stated on the CCC-770, the CCC-770 will be used to hold the responsible party accountable. Farm Service Agency incorporated an accountability mechanism into the performance plans applicable to supervisory positions, as specified in Notice PM-3076 “Fiscal Year 2024 Performance Plans” (published October 30, 2023), to ensure adequate internal controls compliance for all programs are in place to improve future program delivery and reduce improper payments. The standards require supervisors to: • Timely address any Payment Integrity Information Act findings and that training is provided to employees to improve future program delivery and reduce improper payments. • Ensure automation specialists are including program integrity in software. • Work collaboratively to proactively include processes for program integrity and proper audit trail in software. • Proactively includes processes for program integrity in procedure, provides timely monitoring of program administration, alerts supervisor immediately as issues of potential concern arise. • Alert supervisor immediately as issues of potential concern arise.
Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $43.32 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $43.32 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $0.0 M

Overpayment type Eligibility element/information needed Eligibility amount
Overpayments Within Agency Control Affiliation $43.32 M

Overpayment type Mitigation strategies taken Mitigation strategies planned
Overpayments within the agency’s control Automation, Change Process, Predictive Analytics, Training Audit, Automation, Change Process, Predictive Analytics, Training

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $1.68 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $1.68 M

Eligibility element/information needed Eligibility amount
Affiliation $1.68 M

Mitigation strategies taken Mitigation strategies planned
Automation, Change Process, Predictive Analytics, Training Audit, Automation, Training

Technically improper payments

The root cause for this category was related to not following statutory requirements. The agency’s internal assessment of Emergency Conservation Program-Disasters identified the leading causes for improper payments to be administrative in nature, resulting in processing errors, insufficient documentation, and inability to authenticate producer eligibility. These errors included applications for ineligible participants and/or land; incomplete or improperly filed documentation supporting proper cost share payment; and missing, incomplete, or improperly filed Farm Service Agency or Commodity Credit Corporation forms required for Emergency Conservation Program-Disasters. Lack of sufficient documentation from the producer was also a factor in making it difficult to reliably authenticate the eligibility of claims, resulting in inaccurate payments. Emergency Conservation Program-Disasters is not a recurring program that Farm Service Agency personnel administer on a regular basis. Rather, Emergency Conservation Program-Disasters is a program administered following a qualifying disaster event and limited to the impacted area. Years may pass between a disaster event and program implementation in a state or county/parish. The levels of experience and quality of training for personnel responsible for making program determinations or certifying payments is a contributing factor to the non-compliance.
The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.47 M

Mitigation strategies taken Mitigation strategies planned
Automation, Change Process, Predictive Analytics, Training Audit, Change Process, Predictive Analytics, Training

Additional information

$2.15 M

Unknown Payment Details

Evaluation of corrective actions

Farm Service Agency developed new software to process Emergency Conservation Program-Disasters cost share applications and payments more efficiently and reduce administrative errors. The new software will require time to adequately analyze if the functionality meets the goal of reducing administrative errors.

The completion of the CCC-770 ECP-1 or ECP-3 in its entirety for every approval and every payment ensures compliance of all statutory requirements. If the preparers, County Executive Directors and District Directors sign the CCC-770s without meeting the statutory requirements, then as stated on the CCC-770, the CCC-770 will be used to hold the responsible party accountable.

Training feedback from State and County Offices has been very positive. The trainings helped to understand topics that were previously misunderstood or handled incorrectly.

A forthcoming Payment Integrity Information Act Notice will reiterate policy related to the Fiscal Year 2023 findings and root causes.

Internal Review Documentation Tracking System will give Farm Service Agency the ability to plan, sample program records, conduct assessment reviews, monitor reviews, and document the results.

These corrective actions are sufficient to mitigate program’s improper dollars of $0.47 million related to statutory requirements not met.

As it relates to “statutory requirements not met”, The completion of the CCC-770 ECP-1 or ECP-3 in its entirety for all approvals and payments ensure compliance of all statutory requirements. If the preparers, County Executive Directors and District Directors sign the CCC-770s without meeting the statutory requirements, then as stated on the CCC-770, it will be used to hold the responsible party accountable.

Providing additional webinar/virtual training will ensure all State Office staff are aware of updated policy requirements and clarifications to all requirements. Training topics include not only hot topics, but also topics that target Payment Integrity Information Act deficiencies.

Issuing a division notice (Integrity and Accountability series) outlining the Fiscal Year 2023 Payment Integrity Information Act findings and root causes, will re-iterate policy related to each finding.

Utilizing the Internal Review Documentation Tracking System for the oversight of the County Executive Director and District Director reviews, will give Farm Service Agency the ability to plan, sample program records, conduct assessment reviews, monitor reviews, and document the results.

The above corrective actions are adequate to address the cause of the improper payments.

As it relates to “statutory requirements not met,

• The completion of the CCC-770 ECP-1 or ECP-3 in its entirety for every approval and every payment ensures compliance of all statutory requirements. If the preparers, County Executive Directors and District Directors sign the CCC-770s without meeting the statutory requirements, then as stated on the CCC-770, the CCC-770 will be used to hold the responsible party accountable.

• Utilizing the Internal Review Documentation Tracking System for the oversight of the County Executive Director and District Director reviews, will give Farm Service Agency the ability to plan, sample program records, conduct assessment reviews, monitor reviews, and document the results.

The above corrective actions are focused on the cause of the improper payments.

Farm Service Agency developed new software to process Emergency Conservation Program-Disasters cost share applications and payments more efficiently and reduce administrative errors. The new software will require time to adequately analyze if the functionality meets the goal of reducing administrative errors.

New policy to complete the CCC-770, ECP-1 or ECP-3 in its entirety for every approval and every payment will ensure compliance of all statutory requirements. If the preparers, County Executive Directors and District Directors sign the CCC-770 without meeting the statutory requirements, then as stated on the CCC-770, the CCC-770 will be used to hold the responsible party accountable.

Incorporating Emergency Conservation Program-Disasters into Internal Review and Documentation Tracking System will allow Program Managers the ability to:
• conduct and monitor assessment reviews, monitor reviews, and
• document the results of the reviews
• evaluate the progress of the corrective actions with timely follow-up and status updates of any corrective actions.

The above corrective actions will be effectively implemented and prioritized within the agency to reduce improper payments.

Future payment integrity outlook

Emergency Conservation Program has established a baseline.

With the implementation of the current corrective actions and the planned corrective actions for the program, it is the agency’s anticipation that the projected reduction target will be less than the estimated future improper payment rate.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $150 M
Current year +1 estimated future improper payments $60.62 M
Current year +1 estimated future unknown payments $0 M
Current year +1 estimated future improper payment and unknown payment rate 40.41 %
Current year +1 estimated future improper payment and unknown payment reduction target 40.41 %

The program's current year improper payment and unknown payment rate of 45.16 % may or may not be the tolerable rate. The agency has not yet determined the tolerable rate for this program.

The agency’s target rate for Emergency Conservation Program-Disasters is to have an improper payment percentage below 10 percent, however this may not represent the definition of a “tolerable rate”. All corrective actions taken by the agency have been implemented with the goal to be within the 10 percent threshold.

The agency has not established a tolerable rate for Emergency Conservation Program-Disasters.

At this time, it is determined that a minimum of $200,000 will be needed for future software enhancements. The new Emergency Conservation Program-Disasters software (released January 2024) will be enhanced as the needs are identified, prioritized and approved for provisioning. Such enhancements will improve the Agency’s ability to monitor program implementation.

Software Enhancements - At this time, it is determined that a minimum of $200,000 will be needed for future software enhancements. The new Emergency Conservation Program-Disasters software (released January 2024) will be enhanced as the needs are identified, prioritized and approved for provisioning. Such enhancements will improve the Agency’s ability to monitor program implementation.

Due to Farm Service Agency information technology budget constraints, Farm Service Agency will request funding above the information technology budget through the Fiscal Year 2025 Commodity Credit Corporation budget drills and Department Working Capital Fund.

Additional programmatic information

Accountability for detecting, preventing, and recovering improper payments

Farm Service Agency incorporated an accountability mechanism into the performance plans applicable to supervisory positions, as specified in Notice PM-3076 “Fiscal Year 2024 Performance Plans” (published October 30, 2023), to ensure adequate internal controls compliance for all programs are in place to improve future program delivery and reduce improper payments. The standards require supervisors to:

• Timely address any Payment Integrity Information Act findings and that training is provided to employees to improve future program delivery and reduce improper payments.

• Ensure automation specialists are including program integrity in software.

• Work collaboratively to proactively include processes for program integrity and proper audit trail in software.

• Proactively includes processes for program integrity in procedure, provides timely monitoring of program administration, alerts supervisor immediately as issues of potential concern arise.

• Alert supervisor immediately as issues of potential concern arise.

Senior Agency Officials will be accountable for the compliance progress for Emergency Conservation Program-Disasters, engaging field staff when applicable, and oversight support of the Office of Management and Strategy follow up activities:

· John J. Berge, Acting Deputy Administrator for Farm Programs (DAFP)
· Marcus Graham, Deputy Administrator for Field Operations (DAFO)

  • FY 2025 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    10/2023 - 09/2024


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-9.356

Causes

The causes of improper payments are related to not following statutory requirements related to missing or incomplete eligibility documents.

Additionally, improper payments caused failure to access data errors related to calculation errors, incomplete environmental compliance documentation, incomplete applications, incomplete producer certifications, and Cost Share Software (CSS) data load errors.

Specific scenarios that caused the improper payments are:
Missing or incomplete conservation documentation
Missing or incomplete forms reflecting environmental compliance
Missing or incomplete producer contribution statements
Missing or incomplete performance certifications
Missing or incomplete cost share itemization statements

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $61.72 M
Amount of overpayments outside the agency's control $0.0 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
Amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
Amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $61.72 M

Underpayment root cause Underpayment amount
Amount of underpayments $10.8 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $10.8 M

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $1.2 M

The amount that could either be proper or improper but the agency is unable to determine whether it was proper or improper as a result of insufficient or lack of documentation $0.0 M

Prevention

FSA’s corrective actions efforts for the ECP program focused on addressing these (5) improper payment issues:
1) Program eligibility for supporting documentation of actual cost is not on file or was inadequate; ineligible land/crop; environmental documentation was missing or was inadequate; the FSA-23 (Determining Agricultural Market Value and Cost Share Per Acre Worksheet) was missing or was inadequate
2) Application/Contract/Agreement for performance not verified on FSA-848B (Cost-Share Performance Certification and Payment); missing producer signature for FSA-848A (Cost-Share Agreement) or FSA-848B; FSA-848A not approved; or Revised FSA-848A not on file or was not signed by the participant
3) Incorrect values entered or applied for cost share exceeded 50% of the agricultural market value of the land; ineligible cost; incorrect cost share level; cost of practice or component were calculated incorrectly; incorrect component rates; incorrect payment scenario rates; incorrect allowable cost of payment scenarios was used in the payment calculation.
4) Conservation compliance – AD-1026 (Highly Erodible Land Conservation and Wetland Conservation) not on file.
5) Payment eligibility – CCC-902 (Farm Operating Plan) was not on file or was inadequate.

To correct these deficiencies and strengthen overall program integrity, FSA implemented a comprehensive set of corrective actions across (4) major areas – Policy, Software Enhancements, Training, and Internal Control Processes. The paragraphs below describe the actions taken or planned within each of these categories to mitigate and reduce improper payments and improve program compliance.
Policy:
• FSA issued Notice ECP-95: New Requirements for Using CCC-770 ECP Checklists, in January 2025, which required a checklist for:
o all submitted agreements through approval
o all agreement revisions through approval
o issuance of a partial payment
o issuance of final payments.
One of the key objectives of the FSA CCC-770 ECP Checklist is to assist staff in ensuring that all eligibility, documentation and program specific requirements are properly reviewed and completed before payment is approved. Expanding on the requirement to conduct these quality assurance reviews is expected to reduce administrative errors. Results are to be reported annually in January.
• FSA re-issued Notice ECP-98: Supporting Documentation of ECP Certification and Performance in September 2025, to strengthen supporting documentation for program eligibility and revises the requirement for ECP participants to submit documentation of performance and cost. Actions are ongoing.
• FSA annually issues an internal directive for field staff that identifies common/program specific error findings, the applicable policy references, and instructions for resolving errors identified through the National Payment Integrity Review. The Agency anticipates releasing a notice for fiscal year 2025 National Payment Integrity Review findings, with a planned completion date of January 2026.
• Additionally, FSA’s Administrator issued an internal compliance memo to all FSA employees on April 18, 2025, which reinforced the importance of program integrity, set expectations for staff to proactively address internal and external compliance findings and corrective actions and announced planned and reiterated existing compliance activities to strengthen FSA programs through risk management and accountability.
Software Enhancements:
The new software enhancements implemented in January 2024 and apply to disasters occurring fiscal year 2024 and forward, contain validations to prevent many of the frequent payment integrity findings and are active for future ECP applications. The new software enhancements:
• Verify subsidiary flags (AD-1026 Compliance) and business file (CCC-902 Farm Operating Plan).
• Require the FSA-23 (Determining Agricultural Market Value and Cost Share Per Acre Worksheet) to be uploaded into the software with automated calculations to ensure the total payment for a single event will not exceed 50 percent of the agricultural value of the land/or value of animal units after calculated and entered into software; and
• Incorporate geographic information system (GIS) mapping to more accurately identify areas of damage and acreages instead of using paper maps and estimating acres affected by the disaster.
• Automate scenarios by location of the damage. Only scenarios available for that state will appear in the software. This change should lower the risk of typos.
• Prevent allowable costs from being entered into the software. Rather, the completed extent of the practice is entered, and the software calculates the flat rate of the allowable cost and the payment automatically, reducing potential manual errors. The Internal Review and Documentation Tracking System (IRDTS) will serve as FSA’s tool to make certain reviews are timely completed and review results are monitored and evaluated to ensure ECP policies are being followed.
Training:
• Webinar/virtual training sessions on an as-needed-basis as well the 3rd Thursday of each month were established and are ongoing, to ensure all State Office staff are aware of updated policy requirements and clarifications to all requirements. Training topics include not only hot topics, but also topics that target payment integrity deficiencies.
Internal Control Process:
• Completed March 2025, FSA published the Payment Integrity Information Act Dashboard that includes all high risk tested programs (including ECP) and based on improper payment findings from fiscal 2021-2024. This dashboard adds another data source for FSA, providing the ability to identify targeted training needs across States and County Offices and helps to assess if current root causes are new or perennially repeated.
• In addition, ECP is planned to be incorporated into the IRDTS February 2026, to electronically track County Executive Director (CED) and District Director (DD) reviews, and producer spot-check findings and corrective actions captured by the FSA 770 Checklists.
• Spot checks/data mining activities to detect anomalies are being conducted to ensure training is provided at critical times and prior to deadlines. These actions are ongoing.
• FSA has required all identified high risk programs to have a Program Internal Control Plan (ICP) that outlines program risks, their risk levels and a Risk Matrix that identifies internal control actions taken to mitigate risks. ECP’s ICP has been amended, and a Risk Matrix has been developed September 2025, to assist in improving program integrity.
Although the ECP improper payment rate increased from fiscal year 2024, the agency implemented several enhancements that will reduce improper payments in future years.

FSA’s corrective actions efforts for the ECP program focused on addressing these (5) improper payment issues:
1) Program eligibility for supporting documentation of actual cost is not on file or was inadequate; ineligible land/crop; environmental documentation was missing or was inadequate; the FSA-23 (Determining Agricultural Market Value and Cost Share Per Acre Worksheet) was missing or was inadequate. (estimated $43.4M)
2) Application/Contract/Agreement for performance not verified on FSA-848B (Cost-Share Performance Certification and Payment); missing producer signature for FSA-848A (Cost-Share Agreement) or FSA-848B; FSA-848A not approved; or Revised FSA-848A not on file or was not signed by the participant. (estimated $14.5M)
3) Incorrect values entered or applied for cost share exceeded 50% of the agricultural market value of the land; ineligible cost; incorrect cost share level; cost of practice or component were calculated incorrectly; incorrect component rates; incorrect payment scenario rates; incorrect allowable cost of payment scenarios was used in the payment calculation. (estimated $12.1M)
4) Conservation compliance – AD-1026 (Highly Erodible Land Conservation and Wetland Conservation) not on file. (estimated $2.7M)
5) Payment eligibility – CCC-902 (Farm Operating Plan) was not on file or was inadequate. (estimated $340K)

FSA, in coordination with the Performance, Accountability and Risk Division of the Farm Production and Conservation (FPAC) Business Center, conducts a comprehensive analysis of improper payment results on an annual basis. This analysis relates specific findings to the associated amount of improper dollars and the frequency of the occurrence of improper payment findings. This in-depth level of analysis affords FSA the ability to plan corrective actions proportional to the severity of the associated improper payments all while being cognitive of available resources and burdens. These efforts help ensure corrective actions are directly linked to specific findings and are carried out with the intent of reducing future improper payments. FSA’s corrective actions related to policy, software enhancements, training, staff development and internal control process improvements address the causes of improper payments and are proportional to the severity of improper payments.

Based on the scope and impact of the root causes, corrective actions may include spot checking/data mining for programmatic anomalies, recommending policy or procedure changes, and issuing or implementing other targeted initiatives. This strategic, coordinated approach ensures that corrective actions are both effective and aligned with broader compliance and program integrity goals.
FSA’s comprehensive analysis of improper payment finding types enables the development of targeted corrective action plans based on cause category, error types, locations, and other key variables. From there, corrective action plans are designed to influence or change behavior, update current procedures, disseminate informational memorandums, revise policy language, introduce new policy language or procedures, and leverage data analytics. They are also closely integrated with ongoing internal processes such as internal control plans and risk matrices. Although the ECP improper payment rate increased from fiscal year 2024, the agency implemented several enhancements that will reduce improper payments in future years. These corrective actions are effectively implemented and prioritized within the agency to reduce improper payments.

Payment type Mitigation strategies taken Mitigation strategies planned
Overpayments Change Process Change Process
Underpayments Change Process Change Process
Technically improper payments Change Process Change Process

Additional information

FSA’s Emergency Conservation Program (ECP) provides financial and technical assistance to farmers and ranchers to repair and restore farmland affected by natural disasters such as floods, hurricanes, wildfires, and droughts. The program is crucial in assisting in implementing emergency conservation measures to rehabilitate damaged land, restore agricultural production, and prevent further environmental degradation.
Despite the increase of ECP’s improper payment from fiscal year 2024 to fiscal year 2025, FSA remains fully committed to strengthening program integrity and reducing improper payments. The corrective actions outlined in the improvement plan - such as enhanced internal controls, targeted training, and strengthened verification procedures - will be used to drive measurable reductions in future error rates. These efforts reflect FSA ongoing dedication to improving program stewardship and ensuring the ECP program continues to serve producers with accountability and transparency.

Reduction target

45.07 %

The Agency does not have what is needed with respect to internal controls, human capital and information system and other infrastructure to reduce improper payments and unknown payments to a level below which further expenditures to reduce improper payments would cost more than the amount those expenditures would save in prevented or recovered improper payments. Due to reductions in FSA’s budget, staffing losses and recent retirements, FSA has found it challenging to sustain a consistent internal control effort and maintain the capacity required to further decrease improper payment risks. These resource constraints limit the Agency ability to fully implement and sustain systems and oversight mechanisms necessary to bring improper payments to their lowest achievable level.

FSA requested $2 million for several program system enhancements to include critical enhancements across all farm programs to maximize the impact of the limited funding and support the most essential internal control improvements achievable within the reduced budget.

In fiscal year 2022, to address program integrity and accountability deficiencies, FSA incorporated internal control accountability requirements into annual performance plans beginning with FSA Notice PM – 3051. These added criteria require supervisors to establish, document and maintain adequate internal controls to support compliant program delivery and reduce improper payments.
In FSA Notice PM – 3068, issued in fiscal year 2023, FSA expanded these accountability standards to both supervisory and non-supervisory headquarter positions, modifying the “Mission Results” element to include explicit expectations for internal control compliance, monitoring and corrective action implementation. These performance expectations have been carried forward and are now included in performance plans every fiscal year for all supervisory and non-supervisory positions.
Annual performance plan criteria require personnel, especially supervisors, to ensure improper payments are prevented through control activities and overpayments are promptly detected, documented, reported and recovered in accordance with program policy. Supervisors are evaluated on their ability to make sure staff follow required review procedures, maintain accuracy in program certifications and take timely corrective actions when errors or deficiencies are identified.
Internal control accountability applies to:
• supervisors at all levels, who must establish and maintain an effective control environment, conduct oversight and ensure corrective actions are implemented;
• non-supervisory program and operational staff, who must follow established internal control procedures, maintain accurate documentation and support integrity reviews; and
• headquarter program managers, who must implement internal control guidance and ensure National policies support proper payment and error reduction.

Per FSA Notice PM 3088 supervisors are specifically responsible for:
• ensuring internal controls are implemented and functioning as intended;
• monitoring compliance with program policy;
• supporting internal and external audit activities; and
• ensuring timely corrective action and resolving deficiencies identified through reviews.

Steps taken to hold personnel accountable are:
• internal control expectations are embedded in annual performance plans for supervisors and staff forming part of their formal performance evaluation;
• quarterly progress performance reviews assess whether personnel are meeting internal control requirements supporting timely course correction; and
• supervisors must document actions taken to strengthen controls, address program errors and ensure payment accuracy.

Actions taken to monitor progress include:
• FSA conducts monitoring through quarterly performance discussions, internal control reviews and spot checks and quality control findings;
• supervisors are required to provide oversight of program internal controls implementation, verify staff compliance and report progress of completing corrective actions; and
• national spot checks and reviews, including external payment integrity reviews by FPAC-PAR, serve as validation checkpoints to measure whether the control environment is preventing improper payments and correcting deficiencies.

$12 M