Risk Management Agency Interpretation of Federal Crop Insurance Corporation Provisions - Request March 8, 2021 - WFRP Policy Substitute Schedule F

Sep 19, 2026

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Risk Management Agency interpretation addresses a March 8, 2021 request on whether subparagraph 51A(1) and (2) permit an Approved Insurance Provider to ask an insured for a Substitute Schedule F after a Schedule F has been filed with the IRS, and whether information from the substitute can be used to cancel a WFRP policy. It summarizes handbook procedures on verifiable records and substitute form requirements, contrasts requesters’ views, and states FCIC’s binding determination covering mediation, arbitration, and appeals.

LanguageEnglish

CategoryGeneral

FormatPDF

Pages2

Reading Time1 min

AccessFree to download

Subject and Request

Handbook Procedures (Subparagraph 51A(1)-(2))

Requester Interpretations

FCIC Determination

Binding Effect and Appeals

Risk Management Agency Interpretation of Federal Crop Insurance Corporation Provisions: Subject: Request dated March 8, 2021, to the Risk Management Agency (RMA) for an interpretation regarding whether subparagraphs 51A(1) and (2) allow an Approved Insurance Provider (AIP) to request a Substitute Schedule F from an insured when a Schedule F has been filed with the Internal Revenue Service (IRS) and then use the information in the Substitute Schedule F as cause to cancel the insured’s WFRP policy. The relevant handbook procedures provided by the requestor are subparagraphs 51A(1) and (2) : 51. IRS Tax Forms and Verifiable Records and/or Direct Marketing Sales Records A. IRS Tax Forms (1) Copies of the applicable IRS tax form(s), such as Schedule F, Form 1040, Form 1120, Form 1041, Form 1065, Form 1102S, and Form 4835, must be provided to the AIP for each tax year in the whole-farm history period. The AIP must request verifiable records and/or direct marketing sales records to verify the allowable revenue and allowable expenses on the Whole-Farm History Report when theAIP has reason to believe the farm tax form(s) do not provide adequate documentation of revenue or expenses for WFRP purposes. In such cases, theAIP must not accept any Whole-Farm History Report if the allowable revenue for any year cannot be verified through the requested verifiable records and/or direct marketing sales records. (2) Persons who do not file a Schedule F tax form must report and certify allowable revenue and expenses in the same manner as provided on a Schedule F tax form by completing a Substitute Schedule F. The Substitute Schedule F must contain all information that would appear on a Federal Schedule F tax form and must be sufficient to complete the Allowable Revenue Worksheet and Allowable Expense Worksheet. The person must use the same accounting period when completing the Substitute Schedule F as was used on the farm tax form they filed with the IRS for the applicable year. Interpretation Submitted by Requestor(s) The first requester interprets subparagraph 51(A)(1) as it is the AIP’s duty to request verifiable records and/or direct marketing sales records if the AIP has,“reason to believe the tax form(s) do not provide adequate documentation of revenue or expenses for WFRP purposes.” In cases where the AIP has reason to believe that the tax forms are not adequate or supported by verifiable records, the AIP must not accept the Whole-Farm History Report. However, if the AIP does request supporting documentation and accepts the Whole-Farm History Report, then the requester believes that the AIP has no basis for asking an insured to complete and submit Substitute Schedule F forms when the insured has filed Schedule F forms with the IRS and provided them to the AIP. The AIP may only accept a Substitute Schedule F to establish coverage when the insured does not file Schedule F tax forms with the IRS. The first requestor continues that when a Schedule F is filed with the IRS, provided to the AIP by the insured, and used to establish coverage, the first requester believes that the AIP should not subsequently require the insured to complete and submit Substitute Schedule Fs. Under these circumstances, information supplied by the insured on a Substitute Schedule F form cannot and should not be used by the AIP to retroactively cancel the WFRP Policy. The first requester believes that it is contrary to paragraph 51 of the 2018 WFRP Pilot Handbook for the AIP to compare and use information on a Substitute Schedule F (which should not have been requested) with information on the insureds’ Schedule F tax forms to cancel the insured’s policy. The second requester interprets subparagraph 51A(1) to mean that if the insured files a Schedule F and the AIP, after initially accepting the Whole-Farm Revenue History Report that relied on the information reported on the filed Schedule F forms, determines that or has reason to believe that the in

FAQs

What question does the March 8, 2021 request ask the RMA to interpret?

Whether subparagraphs 51A(1) and (2) allow an Approved Insurance Provider to request a Substitute Schedule F from an insured after Schedule F has been filed with the IRS, and whether the substitute information can be used to cancel the insured’s WFRP policy.

When can an AIP request verifiable records under subparagraph 51A(1)?

When the AIP has reason to believe the farm tax form(s) do not provide adequate documentation of revenue or expenses for WFRP purposes, and only to the extent necessary to verify allowable revenue and expenses.

What is FCIC’s binding determination regarding Substitute Schedule F forms?

FCIC agrees the AIP cannot require a Substitute Schedule F when the insured has filed Schedule F with the IRS, but additional information provided may still affect eligibility, and it states the interpretation is generally applicable and binding for mediation or arbitration.

Sep 19, 2026

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