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Coronavirus Food Assistance Program: USDA Should Conduct More Rigorous Reviews of Payments to Producers

GAO-22-104397 Published: Sep 08, 2022. Publicly Released: Sep 08, 2022.
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Fast Facts

In 2020 and 2021, the Department of Agriculture's Farm Service Agency provided $31 billion in aid to over 950,000 producers of agricultural commodities—including crops, dairy, and livestock—to help offset losses and costs associated with the COVID-19 pandemic.

We found problems in the process the Farm Service Agency used to review the claims the producers submitted for payment—potentially making it harder to identify payment errors and fraud. For example, we reviewed the claims of 90 producers, and over half didn't provide support for their payments.

We recommended 4 changes to help the Farm Service Agency strengthen its claims review process.

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What GAO Found

The Coronavirus Food Assistance Program (CFAP) provided producers $31.0 billion for various commodities. Specifically, the U.S. Department of Agriculture (USDA) paid producers $13.8 billion for field crops; $9.8 billion for livestock; $3.0 billion for dairy; and $4.4 billion for other commodities, such as fruits, tree nuts, and vegetables. Of the total, $661.5 million—primarily for livestock and other commodities—went to high-income producers whose average annual adjusted gross income exceeded $900,000 over a 3-year period.

GAO reviewed a nongeneralizable sample of 90 producers whose CFAP claims GAO considered to have risk factors for improper payments. Such factors include large claims for commodities for which the USDA agency that administered the program—the Farm Service Agency (FSA)—has limited knowledge because the commodities are not typically eligible for FSA's farm programs. GAO found that over half of the producers (48 of 90) that GAO reviewed did not provide full support for their payments. The payments are therefore potentially improper.

Producers That GAO Selected for Review That Received Coronavirus Food Assistance Program (CFAP) Payments, Including Potentially Improper Payments


Number of producers

CFAP payments to producers


Number of producers receiving potentially improper payments

Amount of potentially improper payments







Other commodities















Source: GAO analysis of Farm Service Agency data. | GAO-22-104397

Note: For more details, see table 4 in GAO-22-104397.

For example, 33 producers provided support (e.g., sales receipts) for a lesser amount than they claimed, and nine producers did not clearly establish ownership of commodities they claimed. In some cases, GAO found indicators of fraudulent activity to obtain the payments. GAO referred the 48 producers with potentially improper payments to USDA's Office of Inspector General.

FSA conducted spot-check reviews of CFAP payments to ensure that producers' claims were accurate, but these reviews had limitations. For example:

  • Officials from FSA's national office selected producers for spot checks without fully considering risk factors, such as large claims for livestock.
  • In spot checks, FSA county offices accepted producer-generated documents, such as spreadsheets, which are difficult to verify, as support for claims.
  • FSA state offices did not monitor the quality of CFAP spot checks that the county offices conducted in 2021 and do not plan to monitor the quality of ongoing CFAP spot checks, according to FSA state officials.

By conducting additional and more rigorous reviews of producers' CFAP applications, FSA could better ensure the integrity of CFAP payments to producers impacted by the COVID-19 pandemic.

Why GAO Did This Study

To provide support for agricultural producers impacted by COVID-19, USDA distributed tens of billions of dollars in supplemental assistance to agricultural producers, such as farmers and ranchers. Part of this assistance was distributed under CFAP. USDA established CFAP to provide payments to producers that experienced price declines and higher costs to sell their commodities because of COVID-19.

Producers received payments based on signed statements certifying that the claims in their CFAP applications were correct. Producers also had to provide records supporting their claims to FSA and GAO, on request.

The CARES Act includes a provision for GAO to monitor and report on the federal response to the COVID-19 pandemic. In addition, GAO was asked to review CFAP payments and FSA's implementation and oversight of CFAP. This report examines (1) the distribution of CFAP payments, (2) the extent to which producers that GAO selected for review provided support for CFAP payments, and (3) the extent to which FSA verified producers' compliance with program rules.

GAO reviewed statutes, guidance, and other documents; analyzed FSA data on CFAP payments as of December 2021; reviewed CFAP claims and support from 90 producers that GAO selected based on risk factors; and interviewed agency officials.


GAO is making four recommendations for FSA to conduct more rigorous reviews of CFAP applications. FSA generally agreed with the recommendations.

Recommendations for Executive Action

Agency Affected Recommendation Status
Farm Service Agency
Priority Rec.
The Administrator of FSA should conduct additional spot checks of CFAP payments and use a more risk-based approach to selecting producers for review. This approach could include focusing on producers of commodities not generally covered by other FSA programs and producers that received large payments. (Recommendation 1)
FSA has developed a risk-based methodology to select additional producers for spot checks and directed its field offices to conduct spot checks in accordance with guidance the agency issued in July 2023. As of April 2024, FSA's county offices have completed the additional spot checks, but national-level reporting and analysis is ongoing. We will review FSA's process for these additional spot checks when complete and assess whether it is responsive to our recommendation.
Farm Service Agency The Administrator of FSA should issue guidance directing the agency to identify factors, such as large claims for commodities with which FSA is unfamiliar, that county offices should consider when selecting producers for CFAP spot checks. (Recommendation 2)
Closed – Implemented
FSA issued a Notice on March 31, 2023, providing guidance to state and county offices on risk-based factors to use for selecting producers for CFAP spot checks.
Farm Service Agency The Administrator of FSA should direct agency officials conducting CFAP payment spot checks to (1) use support generated by third parties; or (2) if such support is not available, document why support self-generated by the producer was accepted. (Recommendation 3)
Closed – Implemented
As of July 2023, FSA has issued a notice directing its state and county officials to contact third parties if documentation are provided that is deemed questionable.
Farm Service Agency The Administrator of FSA should direct state offices to monitor the quality of the county offices' spot checks for CFAP. Such monitoring could include a review of selected spot checks to ensure their accuracy. (Recommendation 4)
Closed – Implemented
As of July 2023, FSA has issued a notice instructing its state officials to review selected spot checks completed by county offices.

Full Report

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Agricultural commoditiesCropsEligibility criteriaFarmingFood assistance programsLivestockpandemicsPublic health emergenciesCommodities