I've voiced concerns over the conjunction of a new farm bill and extensive changes in FSA operations. However, my concerns may be misplaced. It's true, I believe, the 2012 farm programs are safe, given the impending passage of the ag appropriations for the 2012 FY. If the sequestration provisions of the debt ceiling legislation which set up the super committee are invoked, there still won't be any effect on the major programs.
So if the 2012 farm bill is passed as part of the super committee's compromise legislation, then FSA and its contractors might have a whole year to plan for its implementation, to write the regulations, and develop the software required. That assumes the new farm bill keeps a major place for FSA-type programs, rather than shifting almost entirely to crop insurance style risk management. That assumption seems to be safe, at least as of now, given the apparent inability of the different commodity groups to come together. Of course, if there's separate programs for wheat and feed grains, cotton, and rice and peanuts that will increase the workload and the administrative headaches. [Update: see Larry Combest's take on the situation from yesterday, via Farm Policy]
However, there's many a slip twixt cup and lip. It seems to me if the super committee can come up with agreed legislation which is passed, there will be a long period, say from January to next elections, during which the farm bill provisions will be reviewed and questioned. Not the cuts, particularly, it would be hard to come back in the spring or summer of 2012 and provide more money. But commodity groups could very well ask for changes in the provisions, which could be passed so long as the overall impact on the budget is neutral.
Another unknown, at least to me, is the degree of flexibility RMA has in implementing legislative changes in its crop insurance policies. I assume from past experience they've less flexibility than FSA.
Interesting times.
No comments:
Post a Comment