Informational Memorandum: PM-20-086
Recognizing continued challenges due to COVID-19, RMA has issued new actions that supplement the earlier relief authorized by Manager’s Bulletins: MGR 20-005, MGR 20-008, MGR 20-009, MGR 20-010, MGR 20-013, and MGR 20-026.
The new actions have been summarized below. Follow the link to the Manager’s Bulletin for the complete details and requirements.
Relief under Manager’s Bulletin MGR 20-026 is extended through July 15, 2021, for all applicable crop years, authorizing notifications to be sent electronically between the policyholder and their Approved Insurance Provider (AIP)/agent.
For crop policies with a SCD between December 15, 2020 through March 15, 2021, AIPs are authorized to use the temporary yield procedure contained in the Crop Insurance Handbook (CIH) when a policyholder is unable to timely provide a production report due to their physical inability to meet the PRD deadline as a result of being directly impacted by COVID-19.
Producers may be able to submit a request for a written agreement after the SCD, but on or before the ARD, if they are able to demonstrate the physical inability, including self-certification of COVID-19 related issues, to submit the request (or required additional documentation) on or before the SCD.
For written agreement requests that have a submission deadline prior to July 1, 2021, AIPs now have until 30 business days after the applicable producer submission deadline to submit the Request for Actuarial Change form and all applicable documentation into the RMA ROE system.
If a written agreement offer is provided to the producer, but the producer fails to sign the offer by the expiration date identified on the offer, the producer’s signature after the expiration date may still be accepted if the producer show that COVID-19 caused a physical inability to sign the offer by the expiration date.
Only written agreement offers issued by RMA on or before June 30, 2021, with an expiration date on or before July 30, 2021, allow producer signatures to be accepted after the expiration date. All documentation and signatures for these offers must be completed no later than August 2, 2021.
Any written agreement offers with an expiration date after July 30, 2021, must be signed by the expiration date identified in the written agreement offer.
If a written agreement offer is issued requiring a crop inspection, the crop inspection is subject to the same dates required for the written agreement offer, unless RMA specifies otherwise in the written agreement offer.
For Reinsurance Year 2021, AIPs are allowed to accept Determined Yield, Master Yield, and Irrigated Determined Yield requests for Category B (annual) crops with a PRD within RY 2021. The completed requests can be accepted by the AIP by the earlier of the ARD or applicable deadline plus 30 calendar days. Requests required to be submitted to RMA for review must be submitted to the RO no later than the earlier of the ARD or applicable deadline plus 30 calendar days.
For RO Determined Yield, Master Yield, and Irrigated Determined Yield requests, in which the RY 2021 ARD occurs before the release of this bulletin, the AIP has until the applicable deadline plus 30 calendar days.
If, due to COVID-19 impacts, additional time is needed for submission of RY 2021 Category C (perennial) crop(s) RO Determined Yield requests, AIPs can request an additional 30-day extension.
Relief under Manager’s Bulletin MGR 20-026 for certified organic crops is extended through June 30, 2021, for all applicable crop years. AIPs may allow a policyholder to report acreage as certified organic, or as acreage in transition to organic, when the policyholder certifies that they have requested a written certification or other written documentation from a certifying agent on or before the ARD. This relief also applies to the Whole-Farm Revenue Protection policy.
Policyholders must notify their agent within 30 calendar days of receiving notification from their certifying agent that their organic plan or certificate was not approved.
Relief under Manager’s Bulletin MGR 20-026 is extended through June 30, 2021, for all applicable crop year’s replant notifications. AIPs are authorized to allow self-certification replant inspections for up to 100 gross acres (before considering share) per unit in lieu of 50 acres.
In addition, AIPs are authorized to allow policyholders that have elected Basic (BU) or Enterprise Units (EU), to apply the 100-acre limitation, and perform self-certification replant inspections up to 100 acres, for each of the underlying databases that could qualify as separate optional units (OU) under the BU; or separate OUs or BUs under the EU.
Relief under Manager’s Bulletin MGR 20-026 is extended through June 30, 2021, for all applicable crop years, AIPs are authorized to waive the witness signature requirement for approval of Assignments. The policyholder’s and creditor’s signature on the Assignment continues to be required in a pen and ink signature and in the hand of the person whose signature is required or an acceptable electronic (digital) signature.
For the 2021 calendar year, AIPs are authorized to count dumped milk towards the milk marketings (for DRP) or actual marketings (for LGM-Dairy) regardless of whether the milk was sold. Producers will still have to provide supporting documentation to the AIP from the cooperative or milk handler verifying the actual pounds dumped and that the milk dumped. The amount of eligible indemnity payment is unaffected by this change. Rather, this avoids imposing a penalty that was not intended to apply in cases where a dairy producer had produced a volume of milk that is consistent with the amount of coverage purchased.
In addition, RMA is also removing the testing requirements for dumped milk under the DRP program for producers insuring milk under the component pricing option forced to dump milk. AIPs may use the average butter fat and protein levels for dump milk not tested.