“Verifiable production evidence” is what the Farm Service Agency calls the paperwork required to update your program yields under the 2002 farm bill. You may come up with a more colorful description.
According to USDA's Farm Service Agency (FSA), landowners must have verifiable production evidence in order to prove a yield for counter-cyclical payment purposes when updating crop bases, and in order to prove a yield for soybeans for direct payment purposes when adding an oilseed base.
Ideally, county FSA offices would like producers to submit a completed FSA-658P form, along with any required documentation, when signing up for the new program. This will allow the county office to check your calculations, and should help alleviate potential problems later down the line.
“Let's make sure we get it right on the front end, because Lord knows nobody wants me to come back down the line three years from now and say you owe us money back on the 2002 program,” says Robin Richardson, county director for the Farm Service Agency in Sunflower County, Miss. “At the same time, this is the most time-consuming process in the whole deal. The more legwork you can do in preparation for sign-up, the less time it is going to take you at the county office.”
According to USDA, production can be substantiated by the following documentation: warehouse receipts; warehouse ledgers; warehouse load summaries; settlement sheets; scale tickets; gin records; and computer-generated documents from a licensed warehouse that contain the required information. Weight slips can be used if supported by other evidence such as sales documents, and LDP records provided by the producer can be used if they are substantiated by verifiable production evidence.
If production records are co-mingled, production will be prorated to the separate farms based on harvested acreage, unless documentation acceptable to the County Committee to substantiate another method is provided.
“In most cases, soybeans are going to be co-mingled. If you've got some other documentation submit it, and we'll have to make the decision whether we can accept it or not,” Richardson says.
For production that is commercially sold, stored or disposed of off the farm, acceptable production evidence must show the producer's name, commodity, buyer or storing facility, transaction or delivery date, and quantity, according to USDA.
Richardson says for grain crops that's a load summary, settlement sheet, or something of that nature. For cotton, it's gin records. “Right now, that's not a 503 form from the cotton buyer, or the cotton warehouse, or the gin. We may be able to use 503s, but nobody is willing to put their name on the dotted line and put it in writing for us,” he says. “I want to be able to accept a 503. I don't want to take gin records bale by bale, and I don't want you to have to go to your gin to pull all of that information. At the same time, all production documentation must be verifiable, and if the ginner is giving the certification of pounds, and he doesn't have the bale information in his records to support it, how is it verifiable?”
Crop insurance records can only be used to substantiate the split or the division of production, and they must be supported by verifiable production evidence. Richardson explains, “When you turn your production into crop insurance, the majority of folks pick up the telephone and say I made X number of bushels on this farm, and X number of bushels of that farm and then never turn any documentation in, and crop insurance has never spot-checked.”
“Loan Deficiency Payment records are acceptable, but only if provided by the producer and supported by acceptable production evidence,” Richardson says. “I don't have the manpower to go back through LDP records, nor do I know where they are all located in the office in some cases. This is where you need to help us out. The more legwork you can do on this thing as far as getting yield information to me, the easier it's going to make both our jobs. Please work with us on this one.”