oversight

Farm Programs: Finality Rule Should Be Eliminated

Published by the Government Accountability Office on 1997-03-07.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States General Accounting Office

GAO              Report to the Secretary of Agriculture




March 1997
                 FARM PROGRAMS
                 Finality Rule Should Be
                 Eliminated




GAO/RCED-97-46
                   United States
GAO                General Accounting Office
                   Washington, D.C. 20548

                   Resources, Community, and
                   Economic Development Division

                   B-275791

                   March 7, 1997

                   The Honorable Dan Glickman
                   The Secretary of Agriculture

                   Dear Mr. Secretary:

                   The U.S. Department of Agriculture’s (USDA) Farm Service Agency (FSA)
                   pays billions of dollars annually to farmers for programs such as disaster
                   assistance and agricultural conservation. Occasionally, because of errors,
                   FSA pays farmers too much. In November 1990, as part of the 1990 farm
                   bill, the Congress enacted the “90-day rule,” known alternatively as the
                   “finality rule.” According to this rule, a farmer does not have to repay an
                   overpayment unless (1) it is discovered within 90 days of the date of the
                   payment or the application for program benefits, (2) fraud on the part of
                   the farmer is involved, or (3) the farmer was aware that an error had
                   occurred.1 According to its legislative history, the rule was designed to
                   protect farmers from the hardship of repaying large sums of money long
                   after payments were made.

                   To assess the impact of the finality rule, we reviewed the (1) number and
                   dollar amount of overpayments not repaid by farmers under the rule since
                   its inception in November 1990 and the characteristics of individual
                   overpayments and (2) actions FSA has taken to reduce the number of
                   finality-rule cases and associated dollar amounts.


                   From November 1990 through September 1996, FSA applied the finality rule
Results in Brief   to 10,694 cases in which overpayment errors were not discovered within
                   90 days of the date of payment or the filing of a program application. The
                   rule allowed farmers to keep about $4.2 million in overpayments—an
                   average of $395 per case. Almost 90 percent of the overpayments involved
                   payments made under the disaster assistance and acreage reduction
                   programs. Although the finality rule sought to protect farmers from the
                   hardship of repaying large sums long after payments were made, most of
                   the overpayments to which the finality rule was applied in fiscal years 1995
                   and 1996 involved small amounts of money, represented only a small
                   percentage of the correct payments, and were discovered within a




                   1
                    Prior to October 1994, FSA used the date of payment as the starting date of the 90-day period.



                   Page 1                                                               GAO/RCED-97-46 Finality Rule
             B-275791




             relatively short time—9 months or less.2 During these 2 fiscal years, about
             (1) 86 percent of the finality-rule cases involved $500 or less,
             (2) 59 percent had overpayments amounting to 10 percent or less of the
             correct payment amounts, and (3) 67 percent were discovered within 9
             months of the date of payment or the filing of a program application. While
             most overpayments were small, a few large payments accounted for most
             of the total dollar value of overpayments.

             In recent years, several actions by the FSA and the Congress have reduced
             the number of finality-rule cases and associated overpayments. For
             example, the agency has taken action to improve the accuracy of disaster
             assistance information before payments are made by including district
             directors and county office review staff in the review of the applications
             and by targeting for closer review applications for disaster assistance from
             farms that might have had questionable activity in the past. In addition, the
             Federal Crop Insurance Reform and Department of Agriculture
             Reorganization Act of 1994 reduced the potential for disaster assistance
             payments by requiring farmers to rely primarily on crop insurance for
             certain crops rather than disaster assistance, and the 1996 farm bill ended
             the acreage reduction program, thereby eliminating potential
             overpayments under this program.


             The Food, Agriculture, Conservation, and Trade Act of 1990 (the 1990 farm
Background   bill) established the finality rule. According to this act, the decisions of
             FSA’s state and county committees, or employees of the committees, that
             were made in good faith in the absence of misrepresentation, false
             statement, fraud, or willful misconduct by the farmer are final within 90
             days, and no action should be taken to recover an erroneous overpayment
             unless the farmer had reason to believe that the payment was in error.
             According to its legislative history, this provision was intended to protect
             a farmer from the hardship of having to repay large amounts of money
             long after the payments were received. Prior to the 1990 farm bill, the
             Secretary of Agriculture had historically forgiven, on an individual basis,
             an overpayment to a farmer if the Secretary had determined that a
             hardship existed. The Federal Crop Insurance Reform and Department of
             Agriculture Reorganization Act of 1994 made changes to the finality rule,
             including establishing the start of the 90-day period as the date the farmer
             files an application for benefits. The finality rule applies to all FSA and


             2
              Detailed information on individual finality-rule cases is available from headquarters beginning on
             October 1, 1994. For the period November 28, 1990, through September 30, 1994, FSA headquarters has
             only summary information.



             Page 2                                                            GAO/RCED-97-46 Finality Rule
                         B-275791




                         Commodity Credit Corporation programs that provide payments to
                         farmers.


                         From November 1990 through September 1996, the finality rule was
Dollar Amount and        applied to 10,694 cases, thereby allowing farmers to keep about
Characteristics of       $4.2 million in overpayments by FSA—an average of $395 per case. Most of
Erroneous                these overpayments occurred under the disaster assistance and acreage
                         reduction programs. Additionally, although the finality rule sought to
Overpayments             protect farmers from the hardship of repaying large sums long after
                         payments were made, most overpayments in fiscal years 1995 and
                         1996—the period for which detailed information on individual
                         overpayments was available—generally involved (1) small amounts of
                         money, (2) represented only a small percentage of the correct payment
                         amounts, and (3) were discovered within a relatively short time.


Most Overpayments Fell   The disaster assistance and acreage reduction programs accounted for
Under the Disaster       most of the finality-rule cases. As figure 1 shows, from November 1990
Assistance and Acreage   through September 1996, the disaster assistance program had about
                         56 percent of the cases (6,038) and about 53 percent of the overpayment
Reduction Programs       amounts ($2,227,625). The acreage reduction program had the next highest
                         number of cases (3,934) and overpayment amounts ($1,394,847). The
                         acreage reduction program accounted for about 37 percent of the
                         finality-rule cases and about 33 percent of the dollar amounts. (See app. I
                         for more detailed information.)




                         Page 3                                            GAO/RCED-97-46 Finality Rule
                                     B-275791




Figure 1: Percent of Finality-Rule
Cases and Dollars Involved by        100
Program, November 1990 Through
September 1996

                                      75




                                      50




                                      25




                                       0

                                              Percent   Percent
                                              of        of dollar
                                              cases     amount


                                                        Other programs

                                                        Acreage reduction program

                                                        Disaster assistance program



                                     Source: GAO’s analysis of FSA’s data.




Most Overpayments Were               We found that most finality-rule cases involved small amounts of money,
Small                                as figure 2 shows. For fiscal years 1995 and 1996, there were a total of
                                     1,259 finality-rule cases involving a total of $612,671. During this period,
                                     about 86 percent of the cases involved overpayments of $500 or less. On
                                     the other hand, 7 percent of the cases involved overpayments of $1,001 or
                                     more and made up most of the total overpayment amount. More
                                     specifically, the 85 cases involving payments exceeding $1,000 accounted
                                     for 70 percent of the total overpayment amount. (See app. II for more
                                     detailed information.)




                                     Page 4                                             GAO/RCED-97-46 Finality Rule
                                         B-275791




Figure 2: Number and Amount of
Finality-Rule Cases, Fiscal Years 1995
and 1996                                                                                     8%
                                                                                             Finality-rule cases of $501 to
                                                                                             $1,000 ($65,361)

                                                                                             7%
                                                                                             Finality-rule cases of $1,001 or
                                                                                             more ($430,634)




                                                           •

                                                      •




                                                                 86% •                       Finality-rule cases of $500 or less
                                                                                             ($116,676)




                                         Notes: Total number of cases for the period was 1,259. Total does not equal 100 percent because
                                         of rounding.

                                         Source: GAO’s analysis of FSA’s data.




                                         In addition to involving relatively small overpayment amounts, most
                                         finality-rule cases involved overpayment amounts that were only a small
                                         percentage of the correct payment amounts. As figure 3 shows, during
                                         fiscal years 1995 and 1996, about (1) 59 percent of the total finality-rule
                                         cases had overpayments amounting to 10 percent or less of the correct
                                         payments, (2) 18 percent had overpayments amounting to 11 to 25 percent
                                         of the correct payments, (3) 8 percent had overpayments amounting to 26
                                         to 50 percent of the correct payments, and (4) 15 percent had
                                         overpayments amounting to 51 percent or more of the correct payments.
                                         While most of the overpayment amounts were small, a few large




                                         Page 5                                                           GAO/RCED-97-46 Finality Rule
                                       B-275791




                                       overpayments represented the bulk of the total dollar value of
                                       overpayments. (See app. III for more detailed information.)


Figure 3: Finality-Rule Cases by
Percent of Overpayment, Fiscal Years
1995 and 1996                                                                  8%
                                                                               Overpayment equals 26% to 50%
                                                                               of correct payment ($68,263)

                                                                               Overpayment equals 51% or more
                                                                               of correct payment ($369,307)




                                                     • 15%

                                                 •


                                                18%                   59% •    Overpayment equals 10% or less
                                                  •                            of correct payment ($94,958)




                                                                               Overpayment equals 11% to 25%
                                                                               of correct payment ($80,144)


                                       Source: GAO’s analysis of FSA’s data.




Most Overpayments Were                 Most finality-rule cases were identified within a relatively short time.
Discovered Within 9                    Specifically, about 67 percent of the finality-rule cases identified during
Months of Payment or                   fiscal years 1995 and 1996 were discovered within 9 months (270 days) of
                                       the date of payment or the date the program application was filed. Figure 4
Filing of Application                  shows the percentage of finality-rule cases discovered for different periods
                                       from the date of payment or filing of a program application: About
                                       (1) 44 percent of the total number of finality-rule cases were discovered
                                       between 91 and 180 days; (2) 23 percent, between 181 and 270 days;
                                       (3) 9 percent, between 271 and 365 days; and (4) 24 percent, more than 365
                                       days. (See app. IV for more detailed information.)




                                       Page 6                                            GAO/RCED-97-46 Finality Rule
                                           B-275791




Figure 4: Percent of Finality-Rule
Cases Discovered Within Various Time                                                More than 365 days after payment
Periods After the Date of Payment or                                                or filing date
Filing of Application, Fiscal Years 1995
and 1996


                                                    • 24%

                                                                           44% •    91 to 180 days after payment or
                                                                                    filing date
                                                    •




                                                        23%
                                                          •


                                                                                    181 to 270 days after payment or
                                                                                    filing date

                                                                                    9%
                                                                                    271 to 365 days after payment or
                                                                                    filing date



                                           Source: GAO’s analysis of FSA’s data.




                                           Most overpayments were discovered after 90 days primarily because most
                                           of FSA’s internal reviews and USDA’s Office of Inspector General audits
                                           were not performed within the 90-day limit. Thus, errors discovered by
                                           internal reviews and audits were generally discovered too late for
                                           overpayments to be collected.

                                           If the time limit for the finality rule were extended to 270 days, 67 percent
                                           of the known overpayments discovered during fiscal years 1995 and 1996
                                           for which FSA cannot now seek repayment could be pursued for collection.
                                           These overpayment cases involved 44 percent of the overpayment
                                           amounts. (See app. V for other time periods.) According to officials in
                                           USDA’s Office of General Counsel, there is no clear-cut rationale for 90 days
                                           as the cutoff point for overpayment collections. USDA did not conduct a
                                           study to support using 90 days as the appropriate time period for the rule.



                                           Page 7                                              GAO/RCED-97-46 Finality Rule
                      B-275791




                      While all of FSA’s programs that provide payments operate under the
                      finality rule, most other USDA programs require program participants to
                      repay any overpayments they receive. For example, the Food Stamp
                      Program requires the state agencies administering the program at the local
                      level to establish an administrative error claim against any household that
                      has received more food stamp benefits than it is entitled to receive as a
                      result of a state agency’s action or failure to take action. According to the
                      time criteria for establishing an administrative claim, (1) at a minimum,
                      the state agency is to take action on those claims for which 12 months or
                      less has elapsed between the month an overissuance occurred and the
                      month the state agency discovered the overissuance, (2) states may
                      choose to take action on those claims for which more than 12 months has
                      elapsed, and (3) state agencies shall not take action on claims for which
                      more than 6 years has elapsed. To settle claims, program participants can
                      repay overpayments of food stamps they received either through cash
                      payments or a reduction in their monthly food stamp allotments.


                      In recent years, FSA has taken various actions to reduce the number of
Actions Taken to      cases and associated overpayments under the finality rule. For example,
Reduce Overpayments   the agency has taken action to improve the accuracy of disaster assistance
Under the Finality    information before payments are made. FSA has performed national
                      assessments of disaster program payments for the 1990 through 1993 crop
Rule                  years to collect historical payment data on individual farms. FSA used these
                      data to identify areas of concern or discrepancies, such as unusual
                      increases in the acreage planted or payment amounts or farmers who
                      continually file for disaster benefits. FSA also used these data to review
                      applications for the 1994 crop year disaster assistance before it made
                      payments. In addition, FSA has included district directors and county office
                      review staff in the application review process for disaster payments to
                      ensure that disaster payments are properly distributed.

                      Furthermore, recent legislation has resulted in fewer finality-rule cases in
                      fiscal years 1995 and 1996 than in previous years. For example, the Federal
                      Crop Insurance Reform and Department of Agriculture Reorganization Act
                      of 1994 reduced the potential for disaster assistance payments by requiring
                      farmers to rely primarily on crop insurance for certain crops rather than
                      disaster assistance. In addition, the 1996 farm bill ended the acreage
                      reduction program and thus eliminated potential overpayments under this
                      program.




                      Page 8                                             GAO/RCED-97-46 Finality Rule
                     B-275791




                     Finally, FSA has attempted to get the finality rule repealed or revised. In
                     April 1995, in response to an audit report by USDA’s Office of Inspector
                     General, FSA recommended to the Under Secretary for Farm and Foreign
                     Agricultural Services that the administration’s proposals for the new farm
                     bill include a proposal to eliminate the finality rule or, at a minimum,
                     restrict its application to those situations for which relief is justified
                     because of the meritorious circumstances of the case. However, the
                     provision was not included in the administration’s proposed farm bill.


                     While the finality rule was designed to protect farmers from having to
Conclusions          repay large overpayments discovered long after they were made, we found
                     that most finality-rule cases generally involved relatively small amounts of
                     money, represented only a small percent of the correct payment amounts,
                     and were discovered within a relatively short time. On the basis of these
                     findings, we believe that the finality rule could be eliminated. Such an
                     action would make the treatment of overpayments to farmers more
                     consistent with all other USDA programs, which generally require program
                     participants to repay overpayments made to them regardless of whether
                     the overpayments were made in error or the repayment would cause them
                     a hardship.


                     To reduce the overpayments by the federal government associated with
Recommendation to    the finality rule, we recommend that you submit a legislative proposal to
the Secretary of     the Congress to eliminate the finality rule.
Agriculture
                     We provided a draft of this report to USDA for its review and comment. The
Agency Comments      Department agreed with the report’s findings and conclusions and part of
and Our Evaluation   our original recommendation to eliminate the finality rule. However, the
                     Department disagreed with the part of our recommendation to continue
                     the finality rule’s application in hardship cases. The Department believed
                     that continuing the rule in hardship cases would duplicate procedures
                     already in place. We agree and have revised our original recommendation
                     to eliminate the portion relating to limiting the finality rule to hardship
                     cases. USDA’s written comments are included as appendix VI.


                     To determine the number, dollar amount, and characteristics of
Scope and            overpayments covered by the finality rule since its inception in
Methodology          November 1990, we reviewed finality-rule data compiled by USDA’s Kansas



                     Page 9                                             GAO/RCED-97-46 Finality Rule
B-275791




City Management Office. We also reviewed the legislative history of the
rule and discussed its origin with officials in USDA’s FSA and its Office of
General Counsel. To determine the actions FSA has taken to minimize
overpayments under the rule, we reviewed FSA’s policies and procedures
on the rule and discussed the matter with FSA headquarters officials.

We conducted our review from August 1996 through February 1997 in
accordance with generally accepted government auditing standards.


This report contains a recommendation to you. As you know, the head of a
federal agency is required by 31 U.S.C. 720 to submit a written statement
of the actions taken on our recommendations to the Senate Committee on
Governmental Affairs and the House Committee on Government Reform
and Operations not later than 60 days after the date of this letter and to the
House and Senate Committees on Appropriations with the agency’s first
request for appropriations made more than 60 days after the date of this
letter.

We are sending copies of this report to the congressional committees with
responsibility for appropriations and legislative matters for USDA and to the
Administrator of FSA. We will also make copies available to others on
request.

Please contact me at (202) 512-5138 if you or your staff have any questions.
Major contributors to this report are listed in appendix VII.

Sincerely yours,




Robert A. Robinson
Director, Food and
  Agriculture Issues




Page 10                                             GAO/RCED-97-46 Finality Rule
Page 11   GAO/RCED-97-46 Finality Rule
Contents



Letter                                                       1


Appendix I                                                  16

Number of Cases and
Dollars Involved by
Program for
Finality-Rule Cases
Identified From
November 1990
Through September
1996
Appendix II                                                 17

Number of Cases and
Dollars Involved for
Finality-Rule Cases
Identified for Fiscal
Years 1995 and 1996
Appendix III                                                18

Finality-Rule
Overpayments as a
Percent of the Correct
Payment Amount,
Fiscal Years 1995 and
1996




                         Page 12   GAO/RCED-97-46 Finality Rule
                        Contents




Appendix IV                                                                                        19

Number of
Finality-Rule Cases
and Dollars
Discovered Within
Various Time Periods
After the Date of
Payment or Filing of
Application, Fiscal
Years 1995 and 1996
Appendix V                                                                                         20

Analysis of Fiscal
Year 1995 and 1996
Finality-Rule Cases
Under Alternative
Time Periods
Appendix VI                                                                                        21

Comments From the
U.S. Department of
Agriculture
Appendix VII                                                                                       22

Major Contributors to
This Report
Figures                 Figure 1: Percent of Finality-Rule Cases and Dollars Involved by            4
                          Program, November 1990 Through September 1996
                        Figure 2: Number and Amount of Finality-Rule Cases, Fiscal                  5
                          Years 1995 and 1996




                        Page 13                                           GAO/RCED-97-46 Finality Rule
Contents




Figure 3: Finality-Rule Cases by Percent of Overpayment, Fiscal            6
  Years 1995 and 1996
Figure 4: Percent of Finality-Rule Cases Discovered Within                 7
  Various Time Periods After the Date of Payment or Filing of
  Application, Fiscal Years 1995 and 1996




Abbreviations

FSA        Farm Service Agency
GAO        General Accounting Office
USDA       U.S. Department of Agriculture


Page 14                                          GAO/RCED-97-46 Finality Rule
Page 15   GAO/RCED-97-46 Finality Rule
Appendix I

Number of Cases and Dollars Involved by
Program for Finality-Rule Cases Identified
From November 1990 Through September
1996
               Program                                 Number of cases                Dollar amount
               Acreage Reduction                                 3,934                    $1,394,847
               Agricultural Conservation                          163                         90,228
               Compliance                                           9                          2,045
               Conservation Reserve                               117                         33,120
               Dairy Refund Payment                                 8                          2,851
               Disaster Assistance                               6,038                     2,227,625
               Emergency Conservation                              32                         36,415
               Emergency Feed                                       1                            167
               Forest Incentive                                    23                         22,735
               Integrated Farm Management                           1                            244
               Livestock Feed                                     193                        111,961
               Payment Limitation                                  23                        159,845
               Price Support                                      120                        127,669
               Sugar                                                1                          5,144
               Tree Assistance                                      2                          3,832
               Water Bank                                           7                          5,341
               Wetland Conservation                                 5                          3,577
               Wool and Mohair                                     17                          2,264
               Total                                            10,694                    $4,229,909
               Source: GAO’s analysis of FSA’s data.




               Page 16                                                   GAO/RCED-97-46 Finality Rule
Appendix II

Number of Cases and Dollars Involved for
Finality-Rule Cases Identified for Fiscal
Years 1995 and 1996

                   Number of       Cumulative           Cumulative                           Cumulative        Cumulative
Range in dollars      cases    number of cases     percent of cases        Dollar amount   dollar amount percent of dollars
$100 or less            704                  704                    56           $27,665         $27,665                  5
101 to 250              221                  925                    73            35,102          62,727                 10
251 to 500              154              1,079                      86            53,909         116,676                 19
501 to 1,000             95              1,174                      93            65,361         182,037                 30
$1,001 and over          85              1,259                    100            430,634       $612,671                 100
Total                  1,259                                                   $612,671
                                   Source: GAO’s analysis of FSA’s data.




                                   Page 17                                                      GAO/RCED-97-46 Finality Rule
Appendix III

Finality-Rule Overpayments as a Percent of
the Correct Payment Amount, Fiscal Years
1995 and 1996

                                                                                                                 Cumulative
Percent of correct   Number of       Cumulative           Cumulative                       Cumulative dollar      percent of
amount                  cases    number of cases     percent of cases        Dollar amount          amount           dollars
1 or less                 207                  207                    16            $8,288            $8,288               1
2 to 10                   537                  744                    59            86,669            94,958              15
11 to 25                  228                  972                    77            80,144           175,101              29
26 to 50                   96              1,068                      85            68,263           243,364              40
51 or more                191              1,259                    100            369,307         $612,671              100
Total                    1,259                                                   $612,671
                                     Source: GAO’s analysis of FSA’s data.




                                     Page 18                                                     GAO/RCED-97-46 Finality Rule
Appendix IV

Number of Finality-Rule Cases and Dollars
Discovered Within Various Time Periods
After the Date of Payment or Filing of
Application, Fiscal Years 1995 and 1996
Days after      Number of       Cumulative           Cumulative                              Cumulative        Cumulative
applicationa       cases    number of cases     percent of cases        Dollar amount      dollar amount percent of dollars
91 to 180            548                  548                    44          $194,708            $194,708                         32
181 to 270           288                  836                    67             72,214             266,921                        44
271 to 365           117                  953                    76             44,010             310,931                        51
More than 365        301               1,254                    100            300,376           $611,307                         100
Total               1,254                                                    $611,307
                                a
                                  Includes some cases in which the date of the government payment was the starting date for the
                                90-day time limit.

                                Note: Table does not include five cases with overpayments of $1,364. These cases erroneously
                                showed less than 91 days between the date of payment or filing of application and the date FSA
                                discovered the error.

                                Source: GAO’s analysis of FSA’s data.




                                Page 19                                                           GAO/RCED-97-46 Finality Rule
Appendix V

Analysis of Fiscal Year 1995 and 1996
Finality-Rule Cases Under Alternative Time
Periods

               Various time              Cumulative
               periods under a            number of         Cumulative         Cumulative           Cumulative
               revised finality                cases         percent of      dollar amount           percent of
               rule                       eliminated             cases           eliminated             dollars
               180 days                           548                  44          $194,708                     32
               270 days                           836                  67           266,921                     44
               365 days                           953                  76           310,931                     51
               Over 365 days                    1,254                 100          $611,307                     100
               Note: Table does not include five cases with overpayments of $1,364. These cases erroneously
               showed less than 91 days between the date of payment or filing of application and the date FSA
               discovered the error.

               Source: GAO’s analysis of FSA’s data.




               Page 20                                                          GAO/RCED-97-46 Finality Rule
Appendix VI

Comments From the U.S. Department of
Agriculture




              Page 21           GAO/RCED-97-46 Finality Rule
Appendix VII

Major Contributors to This Report


                       Ronnie E. Wood, Assistant Director
Resources,             Richard B. Shargots, Evaluator-in-Charge
Community, and         Michelle Knox Zaloom, Evaluator
Economic
Development Division




(150716)               Page 22                                    GAO/RCED-97-46 Finality Rule
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