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GAO-11-921R: 

United States Government Accountability Office: 
Washington, DC 20548: 

September 29, 2011: 

The Honorable Collin C. Peterson:
Ranking Member:
Committee on Agriculture:
House of Representatives: 

Subject: USDA's Application of Administrative PAYGO to Its Mandatory 
Spending Programs: 

Dear Mr. Peterson: 

In fiscal year 2010, about 80 percent of the U.S. Department of 
Agriculture's (USDA) total outlays of about $129 billion was used to 
fund mandatory spending programs--programs with at least some spending 
that is controlled through eligibility rules, benefit formulas, and 
other parameters that are set in law other than appropriations acts. 
At USDA, mandatory spending programs include the majority of the 
department's nutrition assistance, farm commodity, crop insurance, and 
export promotion programs, as well as a number of its conservation 
programs. 

To maintain spending discipline over the long-term, the President's 
budget for fiscal year 2006 proposed a number of changes that would 
affect the budget process, including having the Office of Management 
and Budget (OMB) implement a budget-neutrality requirement on agency 
administrative actions affecting mandatory spending programs. A May 
23, 2005, memorandum from the Director of OMB to the heads of 
departments and agencies provided guidance on a new OMB review process 
that would apply to administrative actions not required by law that 
would increase mandatory spending.[Footnote 1] As directed by the 
memorandum, in submitting to OMB for review such proposed actions, 
agencies must include one or more proposals for other administrative 
actions to be taken by the agency that would comparably reduce 
mandatory spending. This process for controlling spending is referred 
to as "administrative pay-as-you-go (PAYGO)." 

OMB's memorandum defines an increase in mandatory spending as an 
increase relative to the projection in the President's most recent 
budget or mid-session review of what is required, under current law, 
to fund mandatory spending programs. Administrative actions subject to 
administrative PAYGO include regulations, demonstrations, program 
notices, guidance to states or contractors, or other similar actions 
not required by law that would increase mandatory spending. Among 
other things, the memorandum states the following: 

* Proposals of actions subject to administrative PAYGO submitted 
without an offset will be returned to the agency for reconsideration. 

* Questions concerning whether a proposed administrative action is 
subject to administrative PAYGO will be resolved at the discretion of 
the OMB Director. 

* If an agency determines that a proposed administrative action that 
would increase mandatory spending is required by law and therefore not 
subject to administrative PAYGO, the agency's general counsel must 
provide an opinion explaining that conclusion. 

* The materials submitted to OMB on the proposed administrative action 
should include a first-year cost estimate and, whenever possible, 5-
and 10-year cost estimates. 

* When there is a difference between cost estimates for the action as 
submitted for review and as assumed in the most recent projection in 
the budget or mid-session review, the agency must explain the 
discrepancy. 

* If OMB determines that a proposed offset is inappropriate, OMB may 
request that an agency propose alternative offsets.[Footnote 2] 

* Exceptions to the budget-neutrality requirement set forth in the 
memorandum must be requested by the agency head and will be granted 
only when the OMB Director determines that the exception is 
appropriate in light of extraordinary need or other compelling 
circumstances. 

* The agency head may appeal the OMB Director's decision to the Budget 
Review Board. 

Separate from OMB's review process for agency proposals that would 
increase mandatory spending, the Congressional Budget Office (CBO) 
prepares a "baseline," in accordance with the provisions of the 
Balanced Budget and Emergency Deficit Control Act of 1985 (Deficit 
Control Act) and the Congressional Budget and Impoundment Control Act 
of 1974 and publishes this information annually in a report. CBO 
projects a baseline of revenues and spending for federal agencies and 
programs over the subsequent 10-year period. As stated in CBO's 
report, when estimating revenues and mandatory spending, CBO assumes 
that current laws will remain in place throughout the 10-year period. 
In contrast, to project discretionary spending (i.e., spending 
generally subject to the annual appropriations process), CBO adjusts 
current-year appropriations to reflect the effects of inflation and 
certain other factors, as specified in the Deficit Control Act. The 
resulting baseline projections, for mandatory and discretionary 
spending, are not intended to predict future budgetary outcomes; 
rather, they serve as the benchmark that lawmakers use during annual 
budget deliberations and as a way to measure the effects of spending 
or revenue proposals (also referred to as "scoring"). CBO updates its 
baseline projections annually to reflect legislative changes, such as 
additional projected outlays resulting from new legislation; economic 
changes, such as modifications to CBO's projections of inflation, the 
unemployment rate, interest rates, and other economic variables that 
affect outlays; and technical changes made in response to new 
information about the operations of programs. 

In this context, you asked us to review USDA's actions concerning 
administrative PAYGO. Our objectives were to determine (1) what 
additional guidance, if any, exists for the use of administrative 
PAYGO in mandatory spending programs; (2) the extent to which USDA 
applied administrative PAYGO to its programs during fiscal years 2005 
through 2010, documented these actions, and followed related guidance; 
and (3) the budgetary and operational impact, if any, of 
administrative PAYGO actions, as identified by USDA, OMB, and CBO. 

On June 17, 2011, we briefed your staff on the preliminary results of 
our work on USDA's administrative PAYGO actions. This report 
summarizes the information we presented in that briefing and provides 
additional detailed information on these actions. (See enclosures I 
and II.) 

To determine what additional guidance, if any, exists for the use of 
administrative PAYGO, we interviewed USDA, OMB, and CBO officials and 
conducted a literature review to identify applicable laws, executive 
orders, regulations, OMB circulars, or other federal guidance on the 
use of administrative PAYGO in mandatory spending programs. To 
determine the extent to which USDA applied administrative PAYGO, we 
obtained USDA's spreadsheet of its administrative PAYGO actions, 
referred to as the "scorecard," which is jointly maintained by USDA's 
Office of Budget and Program Analysis (OBPA) and OMB. We also 
interviewed USDA program officials to verify the savings and costs 
estimates in the scorecard and to obtain additional detail about the 
basis for each estimate. Based on the information we gathered through 
interviews, we determined these data are sufficiently reliable for our 
purposes. To determine the extent to which USDA documented these 
actions and followed applicable guidance, we interviewed USDA 
officials and reviewed documents that they provided to assess how 
consistently USDA had tracked the actions in the scorecard and 
followed guidance for estimating and offsetting the associated 
increases in mandatory spending. To determine the potential budgetary 
impacts of administrative PAYGO, we interviewed USDA, OMB, and CBO 
officials to obtain their views of the effects of administrative PAYGO 
actions on the baselines for USDA's mandatory spending programs, as 
well as how CBO learns of these actions. To determine the operational 
impact, if any, of administrative PAYGO, we interviewed USDA program 
officials and obtained documentation from them describing each 
administrative PAYGO action. We did not examine how USDA may track and 
use mandatory spending decreases for purposes other than 
administrative PAYGO offsets, such as for deficit reduction, because 
these issues were outside the scope of our work. 

We conducted this performance audit from November 2010 to September 
2011 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Summary: 

OMB has not provided further written guidance on the use of 
administrative PAYGO in mandatory spending programs since issuing its 
May 23, 2005, memorandum, and since the memorandum's provisions were 
incorporated into OMB's Circular A-11. USDA took no administrative 
PAYGO actions in fiscal year 2005, and from fiscal year 2006 through 
fiscal year 2010, USDA took 23 actions, including 16 actions that 
would increase mandatory spending by about $2.8 billion from fiscal 
years 2006 through 2015 and 7 actions as offsets that would decrease 
mandatory spending by about $3.0 billion over the same period for a 
net decrease of about $244 million, according to USDA data. USDA 
tracked these 23 actions in its scorecard, but it did not track 
decreases in mandatory spending that were not used as offsets. In 
addition, USDA estimated most increases in its scorecard for either 
the duration of the action or for 5 years, whichever was shorter, and 
offsetting decreases generally equaled or exceeded the increases in 
each fiscal year. With respect to budgetary and operational impacts, 
CBO generally reflects changes in USDA programs that result from 
administrative PAYGO actions as technical changes to the programs' 
budget baselines, according to CBO officials; however, USDA officials 
said they have not systematically studied the operational impacts 
specifically attributable to administrative PAYGO actions. 

Administrative PAYGO Guidance: 

OMB has not provided further written guidance on the use of 
administrative PAYGO in mandatory spending programs since issuing its 
May 23, 2005, memorandum. According to USDA and OMB officials, the 
memorandum remains the key guidance, and its provisions have been 
incorporated in OMB's Circular A-11 and referenced in the Analytical 
Perspectives: Budget of the U.S. Government.[Footnote 3] In addition, 
the guidance has been incorporated in USDA's Budget Manual and OMB's 
annual budget guidance to agencies.[Footnote 4] According to USDA 
officials, typically, in implementing this guidance, a proposed 
administrative PAYGO action that would increase mandatory spending is 
first discussed between OBPA and program officials and then between 
OBPA and OMB officials. During either discussion, the officials said 
that the proposed action may be dropped or determined not to be 
subject to administrative PAYGO. In its annual budget submission to 
OMB, USDA is asked to provide a list of administrative actions planned 
or anticipated that would increase mandatory spending. Between annual 
budget submissions, USDA is asked to advise OMB of any anticipated 
administrative action that would increase mandatory spending as soon 
as possible after the agency becomes aware that the action is likely 
to occur. To date, USDA's administrative PAYGO actions that have been 
identified on the scorecard have been identified during the course of 
the year and have been dealt with as they are proposed. During the 
budget formulation process, USDA officials said decisions are made 
concerning trade-offs between spending increases and decreases, but 
these decisions are not tracked on the administrative PAYGO scorecard, 
but rather as part of the overall President's budget proposal. 

Application and Documentation of Administrative PAYGO to USDA Programs: 

USDA took no administrative PAYGO actions in fiscal year 2005, and 
from fiscal year 2006 through fiscal year 2010, USDA took 23 actions, 
including 16 actions that would increase mandatory spending by about 
$2.8 billion from fiscal years 2006 through 2015 and 7 actions that 
would decrease mandatory spending by about $3.0 billion over the same 
period, according to USDA data. (See enclosure I.) The net offsets 
resulting from these 23 actions (i.e., decreases exceeded increases) 
of about $244 million were used for deficit reduction, according to 
USDA and OMB officials. The 16 administrative PAYGO actions that 
increased mandatory spending affected a total of nine programs in four 
agencies, as shown in table 1. 

Table 1: USDA Agencies and Programs Affected by Administrative PAYGO 
Actions That Increased Mandatory Spending, Fiscal Years 2006 through 
2010. 

Agency: Farm Service Agency; 
Program: Administrative support of Commodity Credit Corporation-funded 
programs; 
Amount of increase: $30.5 million 

Agency: Farm Service Agency; 
Program: Average Crop Revenue Election;
Amount of increase: $30.0 million 

Agency: Farm Service Agency; 
Program: Conservation Reserve; 
Amount of increase: $677.4 million 

Agency: Farm Service Agency; 
Program: Dairy Product Price Support; 
Amount of increase: $7.0 million 

Agency: Farm Service Agency; 
Program: Direct and Counter-Cyclical Payments; 
Amount of increase: $5.0 million 

Agency: Farm Service Agency; 
Program: Domestic and international food assistance programs; 
Amount of increase: $315.0 million 

Agency: Food and Nutrition Service; 
Program: Supplemental Nutrition Assistance; 
Amount of increase: 25.0 million. 

Agency: Forest Service; 
Program: Knutson-Vandenberg Trust Fund; 
Amount of increase: 69.0 million. 

Agency: Risk Management Agency; 
Program: Federal Crop Insurance; 
Amount of increase: 1,623.5 million. 

Agency: Total; 
Amount of increase: $2.782 billion. 

Source: GAO analysis of USDA's administrative PAYGO scorecard. 

As indicated in the table, most of the increases in mandatory spending 
(about $2.6 billion of about $2.8 billion) involved three programs: 
about $1.6 billion in the Federal Crop Insurance Program for new 
initiatives; about $677 million in the Conservation Reserve Program to 
enroll additional acres and to fund various initiatives; and $315 
million in food aid commodity swaps for domestic and international 
food assistance programs. Further detail on the purposes of these 
mandatory spending increases is presented in enclosure II. 

[End of table] 

The seven administrative PAYGO actions that decreased mandatory 
spending affected a total of four programs in four agencies, as shown 
in table 2. 

Table 2: USDA Agencies and Programs Affected by Administrative PAYGO 
Actions That Decreased Mandatory Spending, Fiscal Years 2006 through 
2010. 

Agency: Farm Service Agency; 
Program: Conservation Reserve; 
Amount of decrease: $181.7 million. 

Agency: Foreign Agricultural Service; 
Program: GSM-102 Export Credit Guarantee; 
Amount of decrease: $695.0 million. 

Agency: Forest Service; 
Program: Knutson-Vandenberg Trust Fund; 
Amount of decrease: $51.0 million. 

Agency: Risk Management Agency; 
Program: Federal Crop Insurance; 
Amount of decrease: $2.099 billion. 

Agency: Total; 
Amount of decrease: $3.027 billion. 

Source: GAO analysis of USDA's administrative PAYGO scorecard. 

Note: Column does not sum due to rounding. 

[End of table] 

As indicated in the table, most of this decrease in mandatory spending 
(about $2.8 billion of about $3 billion) involved two programs: about 
$2.1 billion in the Federal Crop Insurance Program mostly resulting 
from reductions in the reimbursements and returns paid to insurance 
companies, and $695 million in the GSM-102 Export Credit Guarantee 
Program resulting from the adoption of a new fee schedule based on a 
recipient country's risk of default. Further detail on the purposes of 
these mandatory spending decreases is presented in enclosure II. 

With respect to the extent to which USDA documented its administrative 
PAYGO actions, the department's use of the scorecard maintained by 
OBPA and OMB to track these actions was a mutual decision between USDA 
and OMB, according to officials of these agencies. USDA tracked the 23 
administrative PAYGO actions in the scorecard, but it did not track 
decreases in mandatory spending not used as offsets. For example, CBO 
estimated that renegotiating the Federal Crop Insurance Program's 
Standard Reinsurance Agreement would reduce the cost of operating the 
program by about $6 billion over 10 fiscal years.[Footnote 5] However, 
the scorecard reflects only $2 billion of these savings--the amount 
USDA used as offsets for increased mandatory spending in the 
Conservation Reserve Program (CRP) and the Federal Crop Insurance 
Program. The $4 billion of the savings not used as an offset was 
applied to deficit reduction, according to USDA and OMB officials, and 
thus was not tracked in the scorecard. In addition, USDA does not 
track administrative PAYGO actions that were approved but not 
implemented. For example, in an administrative PAYGO action during the 
previous Administration, the Farm Service Agency agreed to forgo the 
fiscal year 2009 general sign-up for CRP in return for funding an 
"open fields" initiative, under which landowners would be paid a fee 
by the agency to allow hunters, anglers, and other outdoor 
recreationists access to their CRP-enrolled land. The open fields 
initiative was later canceled because there was a similar program in 
the 2008 Farm Bill, and the funding for the initiative was applied to 
deficit reduction instead, according to USDA officials. Neither of 
these actions appears in the scorecard. For the administrative PAYGO 
actions noted in the scorecard, we found that many of the programs 
associated with these actions retained information on how the related 
savings or costs were estimated. However, according to USDA officials, 
administrative PAYGO rules do not require USDA to review whether the 
estimated savings or costs were actually achieved. 

With respect to following the guidance in OMB's memorandum, OMB 
officials indicated that the provision that agencies should estimate 
the increase in the first year, and whenever possible, increases over 
5-and 10-year periods, is not a rigid requirement and that some 
flexibility is allowed. USDA estimated most increases in its scorecard 
for either the duration of the action or for 5 years, whichever was 
shorter. However, in one instance, USDA estimated the increases for 
CRP for 6 years. Also, the guidance states that agencies must include 
one or more proposals for other administrative actions to be taken by 
the agency that would comparably reduce mandatory spending but does 
not specify whether offsetting decreases have to equal or exceed the 
increases in each fiscal year. However, according to USDA and OMB 
officials, OMB initially required decreases to completely offset 
increases in each fiscal year but now allows the net offset to occur 
over the duration of the action. 

Budgetary and Operational Impacts of USDA Administrative PAYGO Actions: 

CBO generally reflects changes in USDA programs that result from 
administrative PAYGO actions as technical changes to the programs' 
budget baselines, according to CBO officials who monitor the budget 
accounts related to USDA's programs. According to these officials, 
they generally were not aware of OMB's May 23, 2005, memorandum or the 
term "administrative PAYGO;" however, they were generally aware of the 
actions in USDA's scorecard. The officials said that CBO focuses on 
changes in USDA's mandatory spending programs that may affect 
baselines and attributes those changes to new legislation, updated 
economic assumptions, or technical changes in program operation. CBO 
officials said they are generally comfortable with their 
communications with USDA and stay informed of changes in how USDA 
implements mandatory spending programs through departmental press 
releases, Federal Register notices, and periodic conversations with 
USDA program officials. The CBO officials indicated they were 
confident that these mechanisms are sufficient to learn of these 
changes. 

USDA officials said they are not required to systematically examine 
the operational impacts of administrative PAYGO actions after their 
implementation. Moreover, they said that although they put a lot of 
forethought into how these actions might impact programs, it would be 
very difficult to isolate the actual impacts of administrative PAYGO 
actions versus other factors affecting program operations, such as 
changes in economic conditions or other programmatic activity. 
However, agency documents describing these actions provide some 
information on their operational impacts. For example, in July 2009, 
the Secretary of Agriculture announced a 3-month increase in the 
purchase prices offered under the Dairy Product Price Support Program 
for nonfat dry milk, block cheese, and barrel cheese because a widely 
used indicator of profitability had remained at historically low 
levels for these products in the several months preceding the action. 
This type of information for other USDA administrative actions is 
summarized in enclosure II. 

Agency Comments: 

We provided USDA with a draft of this report for review and comment. 
In an e-mail response, USDA indicated that it generally agreed with 
the information presented in the report. USDA also provided suggested 
technical corrections, which we incorporated as appropriate. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies of this report 
to the appropriate congressional committees, the Secretary of 
Agriculture, the Director of the Office of Management and Budget, and 
other interested parties. In addition, this report will be available 
at no charge on the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3841 or shamesl@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Enclosure III lists key contributors 
to this report. 

Sincerely yours, 

Signed by: 

Lisa Shames: 
Director, Natural Resources and Environment: 

Enclosures-3: 

[End of section] 

Enclosure I: Increases and Decreases in USDA Mandatory Spending 
Programs for Actions Subject to Administrative PAYGO: 

The U.S. Department of Agriculture (USDA) took no administrative PAYGO 
actions in fiscal year 2005. This enclosure provides information on 
actions subject to administrative PAYGO at USDA that were taken during 
fiscal years 2006 through 2010. For actions estimated to increase 
spending in mandatory spending programs for fiscal years 2006 through 
2015, see table 3; for actions estimated to decrease mandatory 
spending, see table 4; and for the net offsets resulting from these 
actions, see table 5. In some cases, the change in mandatory spending 
occurred in a single year, but in others, the change was made or was 
being made over several years. 

Table 3: Administrative PAYGO Actions That Increased Spending in USDA 
Mandatory Programs, Fiscal Years 2006 through 2015: 

Farm Service Agency/Administrative support of Commodity Credit 
Corporation-funded programs: 

Agency/program and administrative action: Section 4 limit; 
Fiscal year: 2006: $7.5 million; 
Fiscal year: 2007: $10.8 million; 
Fiscal year: 2008: $6.9 million; 
Fiscal year: 2009: $5.3 million; 
Fiscal year: 2010: [Empty]; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $30.5 million. 

Farm Service Agency/Average Crop Revenue Election Program: 

Agency/program and administrative action: Sign-up extension; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: [Empty]; 
Fiscal year: 2010: $30.0 million; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $30.0 million. 

Farm Service Agency/Conservation Reserve Program: 

Agency/program and administrative action: Wetland incentives; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: $7.8 million; 
Fiscal year: 2010: $14.6 million; 
Fiscal year: 2011: $17.3 million; 
Fiscal year: 2012: $19.2 million; 
Fiscal year: 2013: $20.8 million; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $79.8 million. 

Agency/program and administrative action: Conservation Reserve 
Enhancement Program incentives; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: $0.7 million; 
Fiscal year: 2010: $2.3 million; 
Fiscal year: 2011: $7.3 million; 
Fiscal year: 2012: $9.5 million; 
Fiscal year: 2013: $10.8 million; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $30.6 million. 

Agency/program and administrative action: 2009 extensions; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: $19.0 million; 
Fiscal year: 2010: [Empty]; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $19.0 million. 

Agency/program and administrative action: 2010 modification (Duck 
Nesting, Quail Habitat, State Acres for Wildlife Enhancement Program); 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: [Empty]; 
Fiscal year: 2010: $3.6 million; 
Fiscal year: 2011: $8.7 million; 
Fiscal year: 2012: $12.3 million; 
Fiscal year: 2013: $12.3 million; 
Fiscal year: 2014: $7.2 million; 
Fiscal year: 2015: $3.9 million; 
Fiscal year: Total: $48.0 million. 

Agency/program and administrative action: Initiatives and increasing 
the fiscal year 2010 general sign-up; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: [Empty]; 
Fiscal year: 2010: $500.0 million; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $500.0 million. 

Farm Service Agency/Dairy Product Price Support Program: 

Agency/program and administrative action: July 2009 increase in 
minimum dairy prices; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: $7.0 million; 
Fiscal year: 2010: [Empty]; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $7.0 million. 

Farm Service Agency/Direct and Counter-cyclical Payments Program: 

Agency/program and administrative action: Federal base acre 
reinstatement; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: $5.0 million; 
Fiscal year: 2010: [Empty]; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $5.0 million. 

Farm Service Agency/Domestic and international food assistance 
programs: 

Agency/program and administrative action: Food aid commodity swaps; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: $77.0 million; 
Fiscal year: 2008: $60.0 million; 
Fiscal year: 2009: $111.0 million; 
Fiscal year: 2010: $67.0 million; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $315.0 million. 

Food and Nutrition Service/Supplemental Nutrition Assistance Program: 

Agency/program and administrative action: Title XIX treatment 
facilities; 
Fiscal year: 2006: $3.0 million; 
Fiscal year: 2007: $4.0 million; 
Fiscal year: 2008: $6.0 million; 
Fiscal year: 2009: $6.0 million; 
Fiscal year: 2010: $6.0 million; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $25.0 million. 

Forest Service/Knutson-Vandenberg Trust Fund: 

Agency/program and administrative action: Change in Trust Fund 
spending; 
Fiscal year: 2006: $51.0 million; 
Fiscal year: 2007: $18.0 million; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: [Empty]; 
Fiscal year: 2010: [Empty]; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $69.0 million. 

Risk Management Agency/Federal Crop Insurance Program: 

Agency/program and administrative action: Factor removal; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: $0.4 million; 
Fiscal year: 2009: $2.7 million; 
Fiscal year: 2010: $8.3 million; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $11.4 million. 

Agency/program and administrative action: Crop coverage expansions; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: $0.6 million; 
Fiscal year: 2010: $12.8 million; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $13.4 million. 

Agency/program and administrative action: Pasture, Rangeland, and 
Forage Rainfall Index in Montana; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: $4.6 million; 
Fiscal year: 2010: $23.0 million; 
Fiscal year: 2011: $23.4 million; 
Fiscal year: 2012: $23.7 million; 
Fiscal year: 2013: $24.1 million; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $98.7 million. 

Agency/program and administrative action: Crop Insurance initiatives; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: [Empty]; 
Fiscal year: 2010: $1.500 billion; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $1.500 billion. 

Total increases in USDA mandatory program spending: 
Fiscal year: 2006: $61.5 million; 
Fiscal year: 2007: $109.8 million; 
Fiscal year: 2008: $73.3 million; 
Fiscal year: 2009: $169.6 million; 
Fiscal year: 2010: $2.168 billion; 
Fiscal year: 2011: $56.7 million; 
Fiscal year: 2012: $64.7 million; 
Fiscal year: 2013: $68.0 million; 
Fiscal year: 2014: $7.2 million; 
Fiscal year: 2015: $3.9 million; 
Fiscal year: Total: $2.782 billion. 

Source: GAO analysis of USDA's administrative PAYGO scorecard. 

Note: Some rows and columns do not sum due to rounding. 

[End of table] 

Table 4: Administrative PAYGO Actions That Decreased Spending in USDA 
Mandatory Programs, Fiscal Years 2006 through 2015: 

Farm Service Agency/Conservation Reserve Program: 

Agency/program and administrative action: 2008 $2-per-acre maintenance 
reduction; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: $0.1 million; 
Fiscal year: 2010: $0.6 million; 
Fiscal year: 2011: $24.6 million; 
Fiscal year: 2012: $28.7 million; 
Fiscal year: 2013: $31.6 million; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $85.6 million. 

Agency/program and administrative action: 2009 reduction in 
maintenance payments; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: $43.6 million; 
Fiscal year: 2010: $1.5 million; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $45.1 million. 

Agency/program and administrative action: 2010 modification (reduction 
in Bottomland Hardwood); 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: [Empty]; 
Fiscal year: 2010: $3.3 million; 
Fiscal year: 2011: $7.2 million; 
Fiscal year: 2012: $8.7 million; 
Fiscal year: 2013: $9.7 million; 
Fiscal year: 2014: $10.6 million; 
Fiscal year: 2015: $11.5 million; 
Fiscal year: Total: $51.0 million. 

Foreign Agricultural Service/GSM-102 Export Credit Guarantee Program: 

Agency/program and administrative action: Implementation of risk-based 
approach; 
Fiscal year: 2006: $139.0 million; 
Fiscal year: 2007: $139.0 million; 
Fiscal year: 2008: $139.0 million; 
Fiscal year: 2009: $139.0 million; 
Fiscal year: 2010: $139.0 million; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $695.0 million. 

Forest Service/Knutson-Vandenberg Trust Fund: 

Agency/program and administrative action: Increase timber and payment 
to state receipts; 
Fiscal year: 2006: $51.0 million; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: [Empty]; 
Fiscal year: 2010: [Empty]; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $51.0 million. 

Risk Management Agency/Federal Crop Insurance Program: 

Agency/program and administrative action: Terminations not previously 
counted; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: $4.6 million; 
Fiscal year: 2010: $23.0 million; 
Fiscal year: 2011: $23.4 million; 
Fiscal year: 2012: $23.7 million; 
Fiscal year: 2013: $24.1 million; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $98.7 million. 

Agency/program and administrative action: Standard Reinsurance 
Agreement; 
Fiscal year: 2006: [Empty]; 
Fiscal year: 2007: [Empty]; 
Fiscal year: 2008: [Empty]; 
Fiscal year: 2009: [Empty]; 
Fiscal year: 2010: $2.000 billion; 
Fiscal year: 2011: [Empty]; 
Fiscal year: 2012: [Empty]; 
Fiscal year: 2013: [Empty]; 
Fiscal year: 2014: [Empty]; 
Fiscal year: 2015: [Empty]; 
Fiscal year: Total: $2.000 billion. 

Agency/program and administrative action: Total decreases in USDA 
mandatory program spending; 
Fiscal year: 2006: $190.0 million; 
Fiscal year: 2007: $139.0 million; 
Fiscal year: 2008: $139.0 million; 
Fiscal year: 2009: $187.3 million; 
Fiscal year: 2010: $2.167 billion; 
Fiscal year: 2011: $55.2 million; 
Fiscal year: 2012: $61.1 million; 
Fiscal year: 2013: $65.4 million; 
Fiscal year: 2014: $10.6 million; 
Fiscal year: 2015: $11.5 million; 
Fiscal year: Total: $3.027 billion. 

Source: GAO analysis of USDA's administrative PAYGO scorecard. 

Note: Some rows and columns do not sum due to rounding. 

[End of table] 

Table 5: Net Offsets in Spending in USDA Mandatory Programs Related to 
Administrative PAYGO Actions, Fiscal Years 2006 through 2015: 

Total increases in USDA mandatory program spending; 
Fiscal year: 2006: $61.5 million; 
Fiscal year: 2007: $109.8 million; 
Fiscal year: 2008: $73.3 million; 
Fiscal year: 2009: $169.6 million; 
Fiscal year: 2010: $2.168 billion; 
Fiscal year: 2011: $56.7 million; 
Fiscal year: 2012: $64.7 million; 
Fiscal year: 2013: $68.0 million; 
Fiscal year: 2014: $7.2 million; 
Fiscal year: 2015: $3.9 million; 
Fiscal year: Total: $2.782 billion. 

Total decreases in USDA mandatory program spending; 
Fiscal year: 2006: $190.0 million; 
Fiscal year: 2007: $139.0 million; 
Fiscal year: 2008: $139.0 million; 
Fiscal year: 2009: $187.3 million; 
Fiscal year: 2010: $2.167 billion; 
Fiscal year: 2011: $55.2 million; 
Fiscal year: 2012: $61.1 million; 
Fiscal year: 2013: $65.4 million; 
Fiscal year: 2014: $10.6 million; 
Fiscal year: 2015: $11.5 million; 
Fiscal year: Total: $3.027 billion. 

Net offsets (total increases minus total decreases); 
Fiscal year: 2006: ($128.5 million); 
Fiscal year: 2007: ($29.2 million); 
Fiscal year: 2008: ($65.7 million); 
Fiscal year: 2009: ($17.6 million); 
Fiscal year: 2010: $0.3 million; 
Fiscal year: 2011: $1.5 million; 
Fiscal year: 2012: $3.6 million; 
Fiscal year: 2013: $2.6 million; 
Fiscal year: 2014: ($3.4 million); 
Fiscal year: 2015: ($7.6 million); 
Fiscal year: Total: ($244.1 million). 

Source: GAO analysis of USDA's administrative PAYGO scorecard. 

Note: Some columns do not sum due to rounding. 

[End of table] 

[End of section] 

Enclosure II: Descriptions of the 23 Actions Subject to Administrative 
PAYGO at the U.S. Department of Agriculture, Fiscal Years 2006 through 
2010: 

Agency: Farm Service Agency (FSA); 
Program: Administrative support of Commodity Credit Corporation (CCC)-
funded programs; 
CCC is a government-owned and operated entity that was created to 
stabilize, support, and protect farm income and prices. CCC also helps 
maintain balanced and adequate supplies of agricultural commodities 
and aids in their orderly distribution. The CCC Charter Act, as 
amended, aids producers through loans, purchases, payments, and other 
operations, and makes available materials and facilities required in 
the production and marketing of agricultural commodities. CCC is 
managed by a board of directors, subject to the general supervision 
and direction of the Secretary of Agriculture, who is an ex-officio 
director and chairperson of the board. The board consists of seven 
members, in addition to the Secretary, who are appointed by the 
President of the United States by and with the advice and consent of 
the Senate. All members of the board and corporation officers are USDA 
officials. CCC has no operating personnel. Its income support, 
conservation, and export programs and its domestic and foreign 
acquisition and disposal activities are carried out primarily through 
the personnel and facilities of FSA; 
Section 4--Outside Contracting: Section 4 of CCC's Charter Act lists 
the general powers of CCC, one of which addresses outside contracts 
for administrative support of CCC programs. OMB had established a 
mandatory passback spending level for section 4 of $11.5 million, 
which was the fiscal year 2005 spending level, less all "one time" 
activities, as well as a reduction of $0.8 million for foreign debt 
collection. Any amounts greater than $11.5 million are subject to 
administrative PAYGO; 
Administrative action: Section 4 limit; 
Total increase: $30.5 million, fiscal years 2006-2009; 
For fiscal years 2006 through 2009, USDA submitted and OMB approved 
apportionments for section 4 mandatory spending that exceeded the 
$11.5 million threshold. 

Agency: Farm Service Agency (FSA); 
Program: Average Crop Revenue Election (ACRE) Program; 
ACRE, new under the 2008 Farm Bill, is an alternative revenue-based 
safety net to the price-based safety net provided by the direct and 
counter-cyclical payments (DCP) program for crop years 2009 through 
2012.[A] A producer's decision to enroll and "elect" ACRE may be made 
in any of the crop years 2009-2012; however, ACRE election is 
irrevocable and cannot be changed from the time of election through 
the 2012 crop year. To participate in the program, producers must 
enroll in the program following their election to participate. 
Producers on farms that have elected ACRE still must decide annually 
whether to enroll in the program and may elect the ACRE alternative on 
a farm-by-farm basis. The deadline to elect and enroll in the program 
is June 1 of the program year; 
Administrative action: Sign-up extension; 
Total increase: $30.0 million, fiscal year 2010; 
The initial implementing regulations established an annual enrollment 
period that ends on June 1 of the respective fiscal year in which the 
payments are made.[B] The 2009 sign-up period was the first sign-up 
period for ACRE and did not begin until April 27, 2009, with about a 1-
month sign-up period ending on June 1, 2009. The sign-up period for 
subsequent years begins on October 1 and ends on June 1. Concerned 
that not enough time had been given to farmers to make an informed 
decision about staying with DCP for 2009 or switching to ACRE for crop 
years 2009-2012, in March 2009, FSA extended the 2009 enrollment 
period through August 14, 2009. Because this action could increase 
mandatory program outlays, the action was subjected to administrative 
PAYGO. The estimate of $30 million for fiscal year 2010 is based on 
the assumption that 2009 ACRE payments would be higher because 
producers would select the program with the highest return. 

Agency: Farm Service Agency (FSA); 
Program: Conservation Reserve Program (CRP); 
CRP is a voluntary program available to agricultural producers to help 
safeguard environmentally sensitive land. Producers enrolled in CRP 
plant long-term, resource-conserving vegetative covers to improve the 
quality of water, control soil erosion, and enhance wildlife habitat. 
FSA provides participants with annual payments, including certain 
incentive payments, and cost-share assistance. Contract duration is 
between 10 and 15 years. Participant and land eligibility requirements 
must be met before FSA can accept a participant's offer. FSA provides 
a per acre maintenance incentive payment to CRP participants using 
continuous sign-up practices. The revised per acre maintenance 
incentive payments apply to all new offers for CRP except for offers 
for the Conservation Reserve Enhancement Program (CREP). The CREP 
maintenance incentive rate is established according to the terms of 
each CREP agreement; 
Administrative action: 
2008 $2-per-acre maintenance reduction; 
Total decrease: $85.6 million, fiscal years 2009-2013; 
FSA reduced CRP maintenance payments in 2008 to offset (1) the cost of 
providing for incentives for 1 million acres of continuous sign-up 
wetland restoration practices, (2) three new CREP agreements, and (3) 
two amendments to existing CREP agreements. The reduction applied to 
all new CRP contracts from 2008 onwards, permanently reduced by $2 per 
acre the amount producers would receive for maintenance payments, and 
was implemented in April 2008. The revised payment amounts resulting 
from this action ranged from $2 to $7 per acre, depending on the type 
of maintenance practice used. This action was taken in conjunction 
with the wetland incentives and CREP incentives. 
Administrative action: 
2009 reduction in maintenance payments; 
Total decrease: $45.1 million, fiscal years 2009-2010; 
FSA made a second reduction of $2 per acre to the CRP maintenance 
allowance payments in 2009. This action was taken to offset the cost 
of extending CRP contracts set to expire on September 30, 2009, and 
was implemented in September 2009. The reduction was applied to all 
new CRP contracts from 2009 onwards and reduced by $2 per acre the 
amount producers would receive for maintenance payments. The revised 
payment amounts resulting from this action ranged from $0 to $5 per 
acre, depending on the type of maintenance practice used. This action 
was taken in conjunction with the 2009 CRP extensions. 
Administrative action: 2009 extensions; 
Total increase: $19.0 million, fiscal year 2009; 
FSA offered CRP contract extensions to allow landowners the option to 
continue to provide environmental benefits by keeping land in CRP in 
exchange for rental payments. This extension is USDA's standard 
practice and is normally funded through resources allocated to a 
general sign-up. The extension opportunity was announced in May 2009 
and required an administrative PAYGO offset because resources for a 
general sign-up were not in the baseline for fiscal year 2009. This 
action resulted in the extension of contracts on 1.1 million acres. In 
a previous administrative PAYGO agreement, FSA agreed to forgo the 
fiscal year 2009 general sign-up in return for funding an "open 
fields" initiative that was never initiated.[C] The funding for the 
open fields initiative was subsequently applied to deficit reduction; 
This action was taken in conjunction with the 2009 reduction in CRP 
maintenance payments. 
Administrative action: Initiatives and increasing the fiscal year 2010 
general sign-up; 
Total increase: $500.0 million, fiscal year 2010; 
FSA increased the acreage in the fiscal year 2010 CRP general sign-up 
and in the State Acres for Wildlife Enhancement (SAFE) program, and 
introduced other related initiatives, including CREP agreements. 
Specifically, FSA increased the acreage in the CRP general sign-up 
from the 2.9 million acres in the baseline to 4.3 million acres, thus 
allowing the program to reach its statutory enrollment cap of 32 
million acres. FSA also increased the allotment of acreage to the SAFE 
initiative by 200,000 acres. The fiscal year 2010 CRP general sign-up 
resulted in producers' enrolling 4.0 million acres in CRP; 
This action was taken in conjunction with the renegotiation of the 
Standard Reinsurance Agreement and crop insurance program initiatives. 

Agency: Farm Service Agency (FSA); 
Program: Wetlands Restoration Initiative: Through this initiative, FSA 
aims to restore the functions and values of wetland ecosystems that 
have been devoted to agricultural use. FSA seeks to set aside a total 
of 500,000 acres of wetlands and buffers within the 100-year 
floodplain and 250,000 acres of wetlands and buffers located outside 
the 100-year floodplain (non-floodplain). Eligible participants may 
receive annual rental, cost-share, and/or incentive payments; 
Administrative action: Wetland incentives; 
Total increase: $79.8 million, fiscal years 2009-2013; 
To increase participation because of a lower than expected enrollment 
in four wetland restoration initiatives, FSA offered signing incentive 
payments; practice incentive payments; and annual incentives to 
encourage participation.[D] The incentives were implemented in October 
2008. Enrollment of wetland restoration practices has increased, but 
according to USDA, it is difficult to determine the extent to which 
the increase was due to the incentives. Enrolled acres increased by 
343,386 from September 2008 through March 2011. This action was taken 
in conjunction with the 2008 $2-per-acre CRP maintenance reduction and 
CREP incentives. 

Agency: Farm Service Agency (FSA); 
Program: CREP; 
CREP, a derivative program of CRP, is a voluntary program that helps 
agricultural producers protect environmentally sensitive land, 
decrease erosion, restore wildlife habitat, and safeguard ground and 
surface water. CREP is a federal-state cooperative effort designed to 
target specific high-priority resource concerns. The program is a 
partnership among producers; tribal, state, and federal governments; 
and, in some cases, private groups. CREP agreements vary in the types 
and dollar amounts of incentives; 
Administrative action: Agency: CREP incentives; 
Total increase: $30.6 million, fiscal years 2009-2013; 
FSA proposed to implement five CREP agreements that included 
incentives to encourage landowners to enroll acres in CREP.[E]; 
This action was taken in conjunction with the 2008 $2-per-acre CRP 
maintenance reduction and wetland incentives. 

Agency: Farm Service Agency (FSA); 
Program: CRP Initiatives; 
Duck Nesting Habitat Initiative: This initiative seeks to restore 
200,000 acres of wetlands and wetland complexes that are located 
outside the 100-year floodplain by enhancing duck-nesting habitat on 
the most duck-productive areas of Iowa, Minnesota, Montana, North 
Dakota, and South Dakota. Eligible participants may receive annual 
rental, cost-share, and incentive payments. 
Habitat Buffer for Upland Birds (Quail) Initiative: This initiative 
seeks to introduce a conservation practice that creates 350,000 acres 
of successional grass buffers along agricultural field borders to 
create habitat for the northern bobwhite quail and upland birds. 
Enrollment is targeted to specific geographic areas in 31 states that 
have the highest potential to restore bobwhite quail habitat. 
SAFE: Owners and operators of certain cropland in designated 
geographic areas may enroll eligible land on a continuous (ongoing) 
basis to address state and regional high-priority wildlife objectives 
and achieve a total of 650,000 acres of wildlife habitat. Eligible 
participants may receive annual rental, cost-share, and incentive 
payments; 
Administrative action: 2010 modification (Duck Nesting, Quail Habitat, 
State Acres for Wildlife Enhancement Program); 
Total increase: $48.0 million, fiscal years 2010-2015; 
To strengthen conservation outcomes, FSA increased acreage allocations 
for Duck Nesting, Upland Bird (Quail), and State Acres for Wildlife 
Enhancement (SAFE). The increased allocations were announced in 
February 2010. The Duck Nesting allocation was increased by 50,000 
acres, the Upland Bird allocation was increased by 100,000 acres, and 
the SAFE allocation was increased by 150,000 acres. Estimates were 
made of the costs of the estimated additional enrollment acre 
allocations based on the incentives for the three initiatives. 
Enrollment in the initiatives increased the acres allocated, but other 
factors besides the increased allocations could have played a role in 
the increase. Enrollment between July 2010 and March 2011 showed an 
increase of 50,312 acres for duck-nesting habitat, 9,904 acres for 
quail habitat, and 323,000 acres for SAFE, for a total of 383,216 
additional acres. This action was taken in conjunction with the 2010 
CRP modification (reduction in Bottomland Hardwood). 

Agency: Farm Service Agency (FSA); 
Program: Bottomland Hardwood Initiative: This initiative seeks to 
restore 245,000 acres of flood plains through the restoration of 
primarily bottomland hardwoods that provide multipurpose forest and 
wildlife benefits. Eligible participants may receive annual rental, 
cost-share, and incentive payments; 
Administrative action: 2010 modification (reduction in Bottomland 
Hardwood); 
Total decrease: $51.0 million, fiscal years 2010-2015; 
FSA reduced the Bottomland Hardwood initiative acreage allocation by 
250,000 acres to offset the cost of increasing the allocations for 
other CRP initiatives by a total of 300,000 acres. The action was 
implemented through a CRP handbook amendment in July 2010.[F] This 
action was taken in conjunction with the 2010 CRP modification (Duck 
Nesting, Quail Habitat, SAFE). 

Agency: Farm Service Agency (FSA); 
Program: Dairy Product Price Support Program (DPPSP); 
Under DPPSP, FSA supports the price of nonfat dry milk, butter, and 
cheddar cheese made from cow's milk produced in the United States at 
statutory minimum levels through the purchase of such products. The 
established prices are uniform for all regions in the United States 
and may be increased by the Secretary of Agriculture when considered 
appropriate; 
Administrative action: July 2009 increase in minimum dairy prices; 
Total increase: $7.0 million, fiscal year 2009; 
The milk-to-feed price (MFP) ratio, a widely used indicator of 
profitability in the dairy sector, reached is lowest level in nearly 
35 years in May 2009, and was below its long-term average of 2.74 for 
19 consecutive months, from January 2008 through July 2009. The 
pressure on dairy returns was precipitated by higher feed costs. The 
dairy returns squeeze intensified in 2009 with the decline in the milk 
price brought about partly by the collapse in international demand for 
U.S. dairy products and partly by decreased domestic demand as a 
result of the U.S. recession. In recognition of the potential 
continuation of the low MFP ratios, in July 2009, the Secretary of 
Agriculture announced a 3-month increase in the purchase prices 
offered under DPPSP for nonfat dry milk, block cheese, and barrel 
cheese. OMB approved the action on July 30, 2009, and the new purchase 
prices were in effect on August 1, 2009. 

Agency: Farm Service Agency (FSA); 
Program: Direct and Counter-cyclical Payments (DCP) Program; 
DCP provides two types of payments to eligible producers--direct 
payments for certain eligible commodities based on base acreage and 
payment yield and counter-cyclical payments when market prices are low 
as part of a "safety net" in the event of low crop prices. Counter- 
cyclical payments for a commodity are only issued if the effective 
price for a commodity is below the target price for the commodity; 
Administrative action: Federal base acre reinstatement; 
Total increase: $5.0 million, fiscal year 2009; 
Regulations implementing provisions of the 2008 Farm Bill do not allow 
producers to establish crop acreage bases on land owned by federal 
agencies and terminated previously established base acreage on 
federally owned land.[G] USDA was concerned that terminating base 
acres would have hurt farmers across the United States and eroded the 
safety net for farmers and ranchers. Because including these acres in 
DCP resulted in an increase in mandatory spending, the action was 
subject to administrative PAYGO. The action was approved and 
implemented on April 1, 2009. In addition, county offices were 
instructed to reinstate base acres terminated on federally owned land 
and ensure that the owners and operators of federally owned land were 
notified that base acres on federally owned land would not be 
terminated. 

Agency: Farm Service Agency (FSA); 
Program: Domestic and international food assistance programs; 
FSA purchases and delivers processed commodities under domestic 
distribution programs such as the National School Lunch, Commodity 
Supplemental Food, Food Distribution on Indian Reservations, and 
Disaster Assistance Programs. FSA also purchases commodities for 
distribution to foreign countries under Title II of the Agricultural 
Trade Development and Assistance Act (commonly known as "Public Law 
480"); Food for Progress; section 416(b) of the Agricultural Act of 
1949, as amended; and the McGovern-Dole International Food for 
Education and Child Nutrition Program, through private voluntary 
organizations and the World Food Programme; 
Administrative action: Food aid commodity swaps; 
Total increase: $315.0 million, fiscal years 2007-2010; 
Since 2007, CCC has conducted numerous commodity swaps (barters) to 
provide supplemental meals for millions of needy people worldwide at a 
time when appropriated funding was inadequate to keep pace with high 
commodity and transportation costs. Bartering not only increased food 
assistance levels, it also reduced CCC costs associated with long-term 
storage of government-owned inventories. FSA initially conducted the 
barters on behalf of CCC but faced challenges when considering a 
barter of CCC-owned products for "unlike products" requested by the 
food aid recipient (e.g., the exchange of cotton for canned salmon). 
Accordingly, CCC entered into a contract with a third party to allow 
CCC barters without requiring a food supplier to accept in exchange 
commodities of "unlike products" in which the supplier has no 
interest. FSA continues to barter CCC inventories for "like products," 
and approximately $315 million worth of commodities have been 
exchanged since 2007. The $315 million is the increase in FSA program 
expenses that has been offset under administrative PAYGO. 

Agency: Food and Nutrition Service (FNS); 
Program: Supplemental Nutrition Assistance Program (SNAP); 
The purpose of SNAP--formerly the Food Stamp Program--is to promote 
the general welfare and to safeguard the health and well being of the 
nation's population by raising the levels of nutrition among low-
income households. Any firm desiring to participate in the program is 
to file an application that contains information that permits FNS to 
determine whether an applicant qualifies, or continues to qualify, for 
participation in the program; 
Administrative action: Title XIX treatment facilities; 
Total increase: $25.0 million, fiscal years 2006-2010; 
FNS implemented a policy change in March 2006 that addressed state 
certification for participation of alcohol and drug and treatment 
facilities in SNAP to include qualified faith-based rehabilitation 
facilities. Denial of these facilities' participation in SNAP was due 
to questions concerning whether state licensing is required for such 
participation, according to FNS officials. Prior to this change, 
treatment programs faced certification requirements that they were 
state-licensed before being authorized to participate in SNAP. In 
September 2005, the Secretary of Agriculture and the Secretary of the 
Department of Health and Human Services co-signed a letter to all the 
governors noting that state licensing is not required for 
participation by faith-based rehabilitation facilities. 

Agency: Foreign Agricultural Service (FAS); 
Program: GSM-102 Export Credit Guarantee Program; 
This program provides credit guarantees to encourage financing of 
commercial exports of U.S. agricultural products for periods not to 
exceed 3 years, while providing competitive credit terms to buyers. 
The program guarantees credit by the private banking sector (or the 
exporter) in the United States to approved foreign banks using dollar-
denominated, irrevocable letters of credit for purchases of U.S. food 
and agricultural products by foreign buyers. CCC underwrites the 
guarantees and approves which countries and banks may participate and 
the agricultural commodities and products that are eligible. CCC must 
qualify exporters to participate in the program before they can submit 
a guarantee application. Once qualified, exporters submit a guarantee 
application along with a fee calculated on the dollar amount 
guaranteed; 
Administrative action: Implementation of risk-based approach; 
Total decrease: $695.0 million, fiscal years 2006-2010; 
Between 2004 and 2006, FAS made changes to the GSM-102 program partly 
to settle a long-standing dispute filed with the World Trade 
Organization concerning export programs for upland cotton. In July 
2005, FAS implemented a risk-based fee schedule, with fees based on 
level of country risk.[H] FAS also ceased programming for certain 
countries classified as higher risk and ceased operation of its medium 
term credit guarantee program (3 to 7 year guarantees), GSM-103. 
Beginning in fiscal year 2006, FAS ceased operation of the Supplier 
Credit Guarantee Program. The 2008 Farm Bill repealed specific 
statutory authority for both the Supplier Credit Guarantee Program and 
the GSM-103 program. The Farm Bill also repealed a 1-percent cap on 
fees that could be charged under the GSM-102 program.i. 

Agency: Forest Service; 
Program: Knutson-Vandenberg Trust Fund; 
To fulfill its reforestation responsibilities, the Forest Service uses 
both appropriations and monies from trust funds, the largest being the 
Knutson-Vandenberg Trust Fund. This trust fund was established by the 
Knutson-Vandenberg Act of 1930 to collect a portion of timber sale 
receipts to cover the cost of reforesting the area from which the 
timber was cut; 
Administrative action: Change in Trust Fund spending; 
Total increase: $69.0 million, fiscal years 2006-2007; 
Increase timber and payment to state receipts; 
Total decrease: $51.0 million, fiscal year 2006; 
Congress, in the Department of the Interior, Environment, and Related 
Agencies Appropriations Act, 2006, modified limitations in the use of 
Knutson-Vandenberg receipts. In order to offset the increase in 
mandatory spending, the Forest Service, through two agencywide policy 
memos, rescinded its earlier policy and instructed regions that at 
least 25 percent of regional timber sale receipts are to be deposited 
into the National Forest Fund. In addition, the Forest Service 
directed that 25 percent of all national forest receipts be deposited 
into the National Forest Fund for payment to states' obligations. 
National forest receipts can come from several classes of receipts, 
including timber, grazing, recreation special uses, energy, minerals, 
and recreation user fees. These policies are still in place and part 
of normal operations. 

Agency: Risk Management Agency (RMA); 
Program: Federal Crop Insurance Program; 
RMA operates and manages the Federal Crop Insurance Program on behalf 
of the Federal Crop Insurance Corporation (FCIC), a government 
corporation managed by a board of directors and subject to the general 
supervision of the Secretary of Agriculture. The federal crop 
insurance program provides crop insurance on more than 100 crops to 
U.S. producers. RMA, through FCIC, develops and/or approves the 
premium rate; administers premium and expense subsidies; approves and 
supports products; reinsures companies; and sponsors educational and 
outreach programs and seminars on the general topic of risk management. 
The federal government encourages farmers' participation by 
subsidizing the insurance premiums and acting as the primary reinsurer 
for the 17 private sector insurance companies that sell and service 
the policies. These companies achieve underwriting gains when 
insurance premiums exceed the claims they must pay farmers for crop 
losses, and they incur underwriting losses if claims paid on the 
policies exceed the premiums. To cover the expenses of selling and 
servicing crop insurance policies, the federal government pays 
companies an administrative and operating (A&O) expense allowance. In 
turn, insurance companies use this money to cover, among other things, 
their overhead expenses, such as payroll and rent, and to pay 
commissions to insurance agencies and agents. Companies also incur 
expenses associated with verifying (i.e., adjusting) the amount of 
loss claimed. These loss adjustment expenses include, for example, 
travel expenses to farmers' fields; 
Administrative action: Factor removal; 
Total increase: $11.4 million, fiscal years 2008-2010; 
The FCIC Board authorized a revision to how indemnities are calculated 
for the Vegetation Index used in insurance coverage for the Pasture, 
Rangeland, and Forage (PRF) Insurance Program, effective for the 2010 
crop year. The revision removed temperature constraints that added 
complexity to the calculations and added little benefit. A simpler 
adjustment to the indemnity calculation was also introduced. The $1.6 
million-per-year estimate of the program cost was based on policy data 
from the most recent year for which data were generally available. The 
cost estimate was based on a recalculation of the policy premiums that 
would have occurred had the changes been in place. 
Administrative action: Crop coverage expansions; 
Total increase: $13.4 million, fiscal years 2009-2010; 
The FCIC Board authorized the expansion of regulatory crop insurance 
programs to additional counties. Expansions are based on demand for 
coverage as evaluated by RMA's regional offices and included a number 
of crops and counties. The cost of expansion is based on estimates of 
demand by RMA's regional offices. 

Agency: Risk Management Agency (RMA); 
Program: Federal Crop Insurance Program; 
Pasture, Rangeland, and Forage Insurance Program: PRF is a pilot 
program that uses two separate basic provisions: a Rainfall Index, 
which covers a single peril--lack of rain, and a Vegetation Index, 
which is based on data that measure vegetation greenness. Basic 
provisions are the terms and conditions included in all polices under 
these plans. These pilot programs are based on vegetation greenness 
and rainfall indices, and are designed to give forage and livestock 
producers the ability to buy insurance protection for losses of forage 
produced for grazing or harvested for hay. These two indices are being 
tested in select counties and states. The indices do not measure a 
producer's production or loss, but the producer is insuring a rainfall 
or vegetation index that is expected to estimate his production; 
Administrative action: Pasture, Rangeland, and Forage Rainfall Index 
in Montana; 
Total increase: $98.7 million, fiscal years 2009-2013; 
The FCIC Board authorized the expansion of PRF to Montana, effective 
for the 2009 crop year. The estimate of the cost was based on an 
assumed participation rate of about 10 percent. Given that level of 
participation, estimates of premium and program cost factors were 
calculated at about $23 million per year. This action was taken in 
conjunction with the action on terminations not previously counted 
described below. 
Terminations not previously counted; 
Total decrease: $98.7 million, fiscal years 2009-2013; 
The FCIC Board terminated the Group Risk Program for rangeland in 
Montana and Wyoming effective for the 2009 crop year because of 
performance issues and for replacement by the newly developed PRF 
product. RMA also terminated insurance coverage for a number of crops, 
such as strawberries, Asian citrus canker in Florida, apples, winter 
squash, cucumbers, onions in Michigan, mangoes and avocados in 
Florida, and fresh market beans. This action was taken in conjunction 
with the Pasture, Rangeland, and Forage Rainfall Index in Montana 
action. 
Administrative action: Standard Reinsurance Agreement; 
Total decrease: $2.0 billion, fiscal year 2010; 
In the 2008 Farm Bill, Congress revised the Federal Crop Insurance Act 
to allow FCIC the option to renegotiate the terms of the Standard 
Reinsurance Agreement (SRA) effective for the 2011 reinsurance year. 
FCIC elected to exercise this option in order to revise the terms of 
compensation provided to insurance companies and to make other 
technical changes to improve the operation of the crop insurance 
program. The SRA determines the amount of A&O reimbursement paid to 
insurance companies in exchange for selling and servicing crop 
insurance policies. The renegotiated SRA prescribes a maximum amount 
of A&O that could be paid to companies for most crop insurance 
policies, which produces savings for the federal government. The 
expected savings is about $350 million per year. The SRA also 
determines the terms of the reinsurance provided by FCIC to insurance 
companies. The renegotiated SRA outlines reinsurance terms that are 
generally less generous than the previous SRA and are expected to 
produce a lower average return to insurance companies, which produces 
savings for the federal government, according to RMA officials. The 
total estimated savings from the renegotiated SRA is about $600 
million per year. The savings is expected to continue until the SRA is 
renegotiated. This action was taken in conjunction with the CRP and 
crop insurance program initiatives. 
Administrative action: Initiatives; 
Total increase: $1.5 billion, fiscal year 2010; 
RMA expanded crop insurance to a number of new crops and initiated new 
product development efforts. The single largest expansion extended the 
PRF program to 19 states. The costs estimates are generally based on 
evaluations of likely levels of participation and premium volume. This 
action was taken in conjunction with the CRP initiatives and the 
renegotiation of the Standard Reinsurance Agreement. 

Source: GAO analysis of USDA data. 

Note: USDA took no administrative PAYGO actions in fiscal year 2005. 

[A] Food, Conservation, and Energy Act of 2008 (2008 Farm Bill), Pub. 
L. No. 110-246, 122 Stat. 1651. 

[B] 73 Fed. Reg. 79.284 (Dec. 29, 2008) (amending 7 C.F.R. pt. 1412). 

[C] The "open fields" initiative was later replaced by the Voluntary 
Public Access and Habitat Incentive Program, which section 2606 of the 
2008 Farm Bill directed the Secretary of Agriculture to establish. 

[D] The four initiatives are floodplain wetlands, non-floodplain and 
playa wetlands, bottomland hardwoods, and duck-nesting habitat. 

[E] The five CREP agreements are with the states of Arkansas, 
Colorado, Hawaii, Louisiana, and Maryland. The CREP agreement with 
Colorado has not yet been implemented. 

[F] Amendment 1 of CRP-2 (Rev. 5), dated July 28, 2010. 

[G] 73 Fed. Reg. 79.284 (Dec. 29, 2008) (amending 7 C.F.R. § 1412.45). 

[H] 73 Fed. Reg. 76.568 (Dec. 17, 2008) (amending 7 C.F.R. pt. 1413). 

[I] Pub. L. No. 110-246 § 3101. 

[End of table] 

[End of section] 

Enclosure III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Lisa Shames, (202) 512-3841 or shamesl@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, James R. Jones, Jr. (Assistant 
Director); Kevin Bray; Stephen Cleary; Cindy Gilbert; Carol Henn; Les 
Mahagan; and Carol Herrnstadt Shulman made key contributions to this 
report. 

[End of section] 

Footnotes: 

[1] OMB, Budget Discipline for Agency Administrative Actions, M-05-13 
(Washington, D.C.: May 23, 2005). 

[2] According to the memorandum, changes in baseline estimates due to 
economic or technical reasons, as opposed to policy actions, are not 
to be considered offsets. 

[3] OMB, Preparation, Submission, and Execution of the Budget, 
Circular No. A-11 (Washington, D.C.: August 2011). OMB's analytical 
perspectives provide contextual information on the federal budget, 
including economic and accounting analyses, information on federal 
receipts and collections, analyses of federal spending, information on 
federal borrowing and debt, baseline or current services estimates, 
and other technical presentations. 

[4] USDA Budget Manual, Chapter 12, Part II, Department Estimates, 
Fiscal Year 2011, Part 2, OMB Exhibits and USDA Crosscut Material, p. 
12P2-4. 

[5] USDA allows private insurance companies that participate in the 
Federal Crop Insurance Program to transfer a portion of their risk to 
the federal government. The Standard Reinsurance Agreement establishes 
the terms and conditions under which the federal government will 
provide subsidies and reinsurance on eligible crop insurance contracts 
sold or reinsured by the insurance company named on the agreement. 

[End of section] 

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