Conservation Security Program:

Despite Cost Controls, Improved USDA Management Is Needed to Ensure Proper Payments and Reduce Duplication with Other Programs

GAO-06-312: Published: Apr 28, 2006. Publicly Released: Apr 28, 2006.

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The Conservation Security Program (CSP)--called for in the 2002 farm bill and administered by the U.S. Department of Agriculture's (USDA) Natural Resources Conservation Service (NRCS)--provides financial assistance to producers to reward past conservation actions and to encourage further conservation stewardship. CSP payments may be made for structural or land management practices, such as strip cropping to reduce erosion. CSP has raised concerns among some stakeholders because CSP cost estimates generally have increased since the 2002 farm bill's enactment. For example, the Congressional Budget Office's estimate increased from $2 billion in 2002 to $8.9 billion in 2004. GAO determined (1) why CSP cost estimates generally increased; (2) what authority USDA has to control costs and what cost control measures exist; and (3) what measures exist to prevent duplication between CSP and other USDA conservation programs and what duplication, if any, has occurred.

Various factors explain why estimates of CSP costs generally increased since the 2002 farm bill's enactment. Of most importance, little information was available regarding how this program would be implemented at the time of its inception in 2002. As more information became available, cost estimates rose. In addition, the time frames on which the estimates were based changed. While the initial estimates covered years in which the program was expected to be nonoperational or minimally operational, subsequent estimates did not include these years. The farm bill provides USDA general authority to control CSP costs, including authority to establish criteria that enable it to control program participation and payments and, therefore, CSP costs. For example, NRCS restricts participation by limiting program enrollment each year to producers in specified, priority watersheds. NRCS also has established certain CSP payment limits at levels below the maximum allowed by the statute. However, efforts to control CSP spending could be improved by addressing weaknesses in internal controls and inconsistencies in the wildlife habitat assessment criteria that NRCS state offices use, in part, to determine producer eligibility for the highest CSP payment level. Inconsistencies in these criteria also may reduce CSP's conservation benefits. The farm bill prohibits duplicate payments for the same practice on the same land made through CSP and another USDA conservation program. Various other farm bill provisions also reduce the potential for duplication. For example, as called for under the farm bill, CSP may reward producers for conservation actions they have already taken, whereas other programs generally provide assistance to encourage new actions or to idle or retire environmentally sensitive land from production. In addition, CSP regulations establish higher minimum eligibility requirements for CSP than for other programs. However, despite these legislative and regulatory provisions, the possibility that producers can receive duplicate payments remains because of similarities in the conservation actions financed through these programs. In addition, NRCS does not have a comprehensive process to preclude or identify such duplicate payments. In reviewing NRCS's payments data, GAO found a number of examples of duplicate payments.

Status Legend:

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  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: To improve NRCS's implementation of the Conservation Security Program, the Secretary of Agriculture should direct the Chief of NRCS to develop a comprehensive process, such as an automated system, to review CSP contract applications to ensure that CSP payments, if awarded, would not duplicate payments made by other USDA conservation programs.

    Agency Affected: Department of Agriculture

    Status: Closed - Implemented

    Comments: According to the Natural Resources Conservation Service (NRCS), it initiated a certification form (addendum) in the self assessment workbook for Conservation Security Program (CSP) sign-ups. This addendum informs an applicant that the Farm Bill prohibits duplicate payments made through CSP and another program on the same land, at the same time, for a similar conservation activity. In part, the addendum asks applicants to certify whether or not they are receiving payments from another conservation program on any of the land being offered for enrollment in CSP, and if so, to provide information on the sources and purposes of these payments. The addendum was issued to all NRCS state offices in National Bulletin 300-6-36. In addition, NRCS revised the CCC-1200 contract appendix (an applicant enters into a contract with NRCS to enroll land in CSP) to include a statement about prohibitions on duplicate payments. Subsequently, according to NRCS, it created an automated system with its ProTracts contracting software to compare existing Wildlife Habitat Incentives Program, Agricultural Management Assistance, and Environmental Quality Incentives Program (EQIP) contracts with new CSP applications to identify potential areas of overlapping practices. Using this system, NRCS officials indicated in March 2009 that they identified nearly 400 scheduled payments totaling more than $500,000 under CSP and EQIP that would have been duplicates. NRCS was able to preclude these payments from being made.

    Recommendation: To improve NRCS's implementation of the Conservation Security Program, the Secretary of Agriculture should direct the Chief of NRCS to include a reference to the national guidance for wildlife habitat assessment criteria in NRCS's Conservation Programs Manual.

    Agency Affected: Department of Agriculture

    Status: Closed - Implemented

    Comments: According to Natural Resources Conservation Service (NRCS) officials, the agency updated the "CSP manual" [i.e., the Conservation Security Program (CSP) section of the Conservation Programs Manual] to be in compliance with the direction provided by the NRCS Chief. Specifically, Exhibit 518.155, a Technical Reference Document describing the agency's wildlife habitat assessment criteria, was added to section 440 of the Conservation Programs Manual. Among other things, this document outlines the procedure to be used to determine the minimum eligibility criteria for fish and wildlife resources on CSP-enrolled land, as well the minimum criteria for "models for species of conservation concern" that represent habitats in a significant state of decline.

    Recommendation: To improve NRCS's implementation of the Conservation Security Program, the Secretary of Agriculture should direct the Chief of NRCS to review and field check each NRCS state office's wildlife habitat assessment criteria to ensure that states use consistent criteria and achieve the habitat benefits intended by the national guidance.

    Agency Affected: Department of Agriculture

    Status: Closed - Implemented

    Comments: According to Natural Resources Conservation Service (NRCS) officials, the agency directed its state offices to submit a copy of their wildlife habitat assessment criteria for all proposed Conservation Security Program (CSP) watersheds. These criteria were examined for consistency with NRCS's national CSP guidance [i.e., minimum national eligibility criteria for wildlife habitat] by the Deputy Chief for Science and Technology's National Biology Team in Ft. Worth, Texas. Discrepancies with the national guidance were resolved in cooperation with the relevant NRCS State Conservationists.

    Recommendation: To improve NRCS's implementation of the Conservation Security Program, the Secretary of Agriculture should direct the Chief of NRCS to develop a process to efficiently review existing CSP contracts to identify cases where CSP payments duplicate payments made under other programs and take action to recover appropriate amounts and to ensure that these duplicate payments are not repeated in fiscal year 2006 and beyond.

    Agency Affected: Department of Agriculture

    Status: Closed - Implemented

    Comments: According to the Natural Resources Conservation Service (NRCS), it created an automated system within its ProTracts contracting software to compare existing Wildlife Habitat Incentives Program, Agricultural Management Assessment, and Environmental Quality Incentives Program (EQIP) contracts with existing CSP contracts to reveal potential areas of overlapping conservation practices and payments. Using this system, NRCS officials indicated in March 2009 that they had identified more the 370 duplicate payments between CSP and EQIP totaling about $420,000. NRCS indicated that these cases of duplication were dealt with according to the NRCS contracting manual, although the agency did not identify the amount of duplicate payments recovered. In addition to creating this automated system, NRCS issued National Bulletin 300-7-1, Conservation Security Program (CSP) Potential Duplicative Payments, to enlist the assistance of its state offices to identify potential or actual duplicate payments between CSP and other programs, and to take action to modify contracts to preclude duplicate payments or recover duplicate payments already made. The bulletin notes that despite statutory provisions and previous NRCS actions to prevent CSP from duplicating other programs, GAO found that the potential for duplicate payments still exists and such payments have occurred. Among other things, the bulletin directs the state offices to compare conservation activities under CSP contracts with those under contracts related to other programs to determine whether duplicate payments are planned or have occurred. The bulletin also provides guidance on recognizing situations that constitute duplication, including examples of conservation activities under CSP and another program that would or would not be considered the same. In addition, the bulletin requires each state office to complete a Potential Duplicate Report and submit it to the Director of NRCS's Financial Assistance Programs Division.

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