Report GAO-22-104397 on the Coronavirus Food Assistance Program — Government Accountability Office

Summary

A report to congressional committees from the U.S. Government Accountability Office, GAO-22-104397, dated September 8, 2022, on the Coronavirus Food Assistance Program (CFAP). The report states that CFAP provided producers $31.0 billion, including $13.8 billion for field crops, $9.8 billion for livestock, $3.0 billion for dairy and $4.4 billion for other commodities, and that $661.5 million went to high-income producers. GAO reviewed a nongeneralizable sample of 90 producers selected on risk factors and found that 48 of 90 did not provide full support for their payments, which it calls potentially improper, and referred those 48 producers to USDA's Office of Inspector General. It finds that Farm Service Agency (FSA) spot-check reviews had limitations and makes four recommendations for more rigorous reviews of CFAP applications.

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United States Government Accountability Office

Report to Congressional Committees

September 2022

CORONAVIRUS
FOOD ASSISTANCE
PROGRAM
USDA Should
Conduct More
Rigorous Reviews of
Payments to
Producers

GAO-22-104397


September 2022

CORONAVIRUS FOOD ASSISTANCE
PROGRAM
Highlights of GAO-22-104397, a report to
congressional committees

USDA Should Conduct More Rigorous Reviews of
Payments to Producers

Why GAO Did This Study

What GAO Found

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.

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.

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.

What GAO Recommends

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
(dollars)

Number of producers
receiving potentially
improper payments

Amount of
potentially
improper
payments
(dollars)

Livestock
Other
commodities

44

78,172,476

24

45,094,863

24

39,337,428

15

26,095,044

Dairy

22

37,099,421

9

16,128,396

Total

90

154,609,325

48

87,318,303

Commodity

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.

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

•

View GAO-22-104397. For more information,
contact Steve D. Morris at (202) 512-3841 or
Morriss@gao.gov.

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.
United States Government Accountability Office


Contents

Letter

1
Background
FSA’s Distribution of CFAP Payments Varied by Commodity and
Type of Producer
About Half of the Producers Whose Claims We Reviewed Did Not
Provide Support for Their Payments, Which May Have Been
Improper
FSA Checked Producers’ Compliance with Program Rules, but
These Checks Had Limitations
Conclusions
Recommendations for Executive Action
Agency Comments

5

22
32
33
33

Appendix I

Objectives, Scope, and Methodology

37

Appendix II

Additional Information on the Distribution of
Coronavirus Food Assistance Program Payments

42

Appendix III

Comments from the U.S. Department of Agriculture

52

Appendix IV

GAO Contact and Staff Acknowledgments

57

11
16

Tables
Table 1: Basis for Calculating Payments for CFAP 1 and CFAP 2,
by Type of Agricultural Commodity
Table 2: CFAP Payments to Historically Underserved Groups, by
Type of Agricultural Commodity
Table 3: CFAP Payments to Entities, by Type of Agricultural
Commodity
Table 4: Selected Producers Receiving CFAP Payments,
Including Potentially Improper Payments
Table 5: Deficiencies in Producers’ Support for CFAP Payments
Table 6: Number of Producers and Overpayments in FSA CFAP 1
Spot Checks

Page i

8
13
14
18
19
26

GAO-22-104397 Coronavirus Food Assistance Program


Table 7: Distribution of CFAP Payments by State, and Average
Payments per Producer and Member
Table 8: Distribution of CFAP Payments, by State and Type of
Agricultural Commodity
Table 9: Producers That Received the Top 25 CFAP Payments

42
47
50

Figures
Figure 1: Examples of Eligible Commodities for CFAP, by Type
Figure 2: Distribution of All CFAP Payments, by Type of
Agricultural Commodity
Figure 3: CFAP Payments to High-Income Producers, by Type of
Agricultural Commodity
Figure 4: Average CFAP Payments per Producer in the
Contiguous U.S.
Figure 5: Total CFAP Payments per County in the Contiguous
U.S.

7
12
16
44
45

Abbreviations
AGI
Business Center
CFAP
FSA
LLC
OIG
USDA

adjusted gross income
Farm Production and Conservation Business
Center
Coronavirus Food Assistance Program
Farm Service Agency
limited liability company
Office of Inspector General
U.S. Department of Agriculture

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GAO-22-104397 Coronavirus Food Assistance Program


Letter

441 G St. N.W.
Washington, DC 20548

September 8, 2022
Congressional Committees
To provide support for agricultural producers impacted by COVID-19,
Congress appropriated, and the U.S. Department of Agriculture (USDA)
distributed, billions of dollars in supplemental assistance to farmers and
other producers of raw agricultural commodities. One of the largest
assistance programs was the Coronavirus Food Assistance Program
(CFAP), which USDA created to provide direct payments to agricultural
producers that experienced price declines and increased marketing costs
for their commodities. 1 Using funding made available through the CARES
Act; the Consolidated Appropriations Act, 2021; and the Commodity
Credit Corporation Act, among other authorities, USDA provided $31.0
billion to 965,651 producers in 2020 and 2021. 2 The assistance that
USDA provided through CFAP exceeded the amount that USDA provided
under other income support programs to producers in recent years.
USDA’s Farm Service Agency (FSA) administered CFAP, with assistance
from USDA’s Agricultural Marketing Service.
Under CFAP, FSA provided payments to producers of a wide variety of
agricultural commodities, including crops, dairy, and livestock. Many of
these commodities—such as eggs and nursery crops (e.g., containergrown plants)—are not eligible for programs authorized or reauthorized

1According to USDA’s website, USDA also provided or is providing pandemic assistance

through 19 other programs, which, as of June 2022, made available over $3.5 billion in
direct financial assistance and grants to dairy and livestock producers, seafood
processors, textile mills, and timber harvesters, among others.

2The CARES Act, Pub. L. No. 116-136, div. B, tit. I, 134 Stat. 281, 505 (2020),

appropriated $9.5 billion to the Office of the Secretary of Agriculture. Of the $9.5 billion
appropriated, $1 billion was repurposed by the Consolidated Appropriations Act, 2021,
Pub. L. No. 116-260, div. A, tit. VII, § 799C(b), 134 Stat. 1182, 1234, reducing the
appropriated amount to $8.5 billion. The Consolidated Appropriations Act, 2021, also
provides $11.2 billion to USDA’s Office of the Secretary to prevent, prepare for, and
respond to coronavirus by providing support for agricultural producers, growers, and
processors impacted by coronavirus. Of that $11.2 billion, $1.5 billion must be used to
purchase food and agricultural products, including seafood, to distribute to individuals in
need, leaving $9.5 billion available to support agricultural producers, growers, and
processors. Pub. L. No. 116-260, div. M, tit. VII, subtit. B, ch. 1, § 751, 134 Stat. 1182,
2105. USDA also authorized up to $20.5 billion from the Commodity Credit Corporation for
CFAP.

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under the Agriculture Improvement Act of 2018 (2018 Farm Bill). 3
Payments could go to individual producers directly or to legal entities that
producers operate, such as corporations. FSA generally calculated CFAP
payments to producers using commodity-specific rates (e.g., cents per
pound, dollars per head of cattle) multiplied by the amount of
commodities produced; sold; or held in inventory on certain dates,
depending on the type of agricultural commodity.
FSA generally paid producers based on the claims in their CFAP
applications regarding commodity ownership and other program
requirements. Producers self-certified the claims (i.e., signed a statement
that the information that they provided was true and correct), and FSA did
not require producers to provide evidence for their claims before issuing
payments. Instead, FSA planned to conduct postpayment reviews and
recovery audits. If producers are selected for these reviews and audits,
FSA requires producers to provide the agency and us (consistent with the
authority under the CARES Act) access to records, such as sales receipts
and income statements, to support the claims in their CFAP applications. 4
In contrast, participants in programs authorized or reauthorized under the
2018 Farm Bill, such as USDA’s Agriculture Risk Coverage and Price
Loss Coverage, are paid based on records or conditions that USDA
agencies must verify before issuing payments. According to a USDA
document, CFAP was designed as a self-certification program to expedite
payments to producers to help mitigate financial hardships associated
with COVID-19.
To receive CFAP payments, producers generally had to meet certain
eligibility requirements, such as (1) having ownership—subject to price

3Programs authorized by the Agricultural Act of 2014, Pub. L. No. 113-79, 128 Stat. 649,

and reauthorized by the Agriculture Improvement Act of 2018, Pub. L. No. 115-334, 132
Stat. 4490, include the Agriculture Risk Coverage, Price Loss Coverage, and marketing
assistance loans.

4Agencies can use postpayment reviews and recovery audits to determine whether

payments were made appropriately to eligible recipients, in correct amounts, and used by
recipients in accordance with law and applicable agreements. Agencies use the results of
such reviews and audits to recover or collect overpayments, unused payments, and
payments not made or used properly from recipients. For more information on the use of
postpayment reviews and recovery audits of programs involving emergency relief funds,
see GAO, Emergency Relief Funds: Significant Improvements Are Needed to Ensure
Transparency and Accountability for COVID-19 and Beyond, GAO-22-105715
(Washington, D.C.: Mar. 17, 2022).

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GAO-22-104397 Coronavirus Food Assistance Program


risk 5—in the commodities they produced, (2) complying with federal
conservation regulations for highly erodible land and wetlands, and (3)
meeting criteria related to adjusted gross income (AGI). 6 For example,
FSA required producers to certify that their average annual AGI over a
specified 3-year period was $900,000 or less. For producers with AGIs
exceeding $900,000—which we refer to in this report as “high-income”
producers—FSA required that they certify that at least 75 percent of their
income was derived from farming, ranching, or forestry-related activities.
As part of the CFAP application process, producers could voluntarily
certify that they belong to groups that USDA categorizes as historically
underserved. Such groups include producers that are beginning to farm,
have limited resources, are socially disadvantaged (i.e., have been
subject to racial, ethnic, or gender prejudice), or are military veterans.
FSA has established criteria to determine whether producers belong to
one or more of these historically underserved groups. 7 We have
previously reported on historically underserved producers and the specific
challenges that they have encountered in seeking services from USDA
and USDA’s progress toward addressing these challenges. 8
The CARES Act includes a provision for GAO to report regularly on the
federal response to the COVID-19 pandemic. Specifically, the CARES Act
requires us to monitor and oversee the federal government’s efforts to
prepare for, respond to, and recover from the pandemic. 9 In addition, we
5“Subject to price risk” means any production, sales, or inventory not subject to an agreed-

upon price through a forward contract, agreement, or similar binding document, according
to an FSA CFAP handbook.

6With assistance from the Internal Revenue Service, FSA determines whether producers
meet income eligibility requirements based on average AGI for 3 consecutive tax years
that precede the year for which the payment is made.
7To be determined socially disadvantaged, producers voluntarily certify their status (i.e.,

their race, ethnicity, or gender) on an FSA form. For beginning, limited-resource, and
veteran status, FSA determines if producers meet the criteria to qualify based on
supplemental information they are required to provide.

8See, for example, GAO, Agricultural Lending: Information on Credit and Outreach to

Socially Disadvantaged Farmers and Ranchers Is Limited, GAO-19-539 (Washington,
D.C.: July 11, 2019); U.S. Department of Agriculture: Progress toward Implementing
GAO’s Civil Rights Recommendations, GAO-12-976R (Washington, D.C.: Aug. 29, 2012);
and Beginning Farmers: Additional Steps Needed to Demonstrate the Effectiveness of
USDA Assistance, GAO-07-1130 (Washington, D.C.: Oct. 18, 2007).

9Pub. L. No. 116-136, § 19010(b), 134 Stat. 281, 580 (2020). All of GAO's reports related

to the COVID-19 pandemic are available on GAO's website at
https://www.gao.gov/coronavirus.

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were asked to review CFAP payments and aspects of FSA’s
implementation and oversight of CFAP. This report examines (1) FSA’s
distribution of CFAP payments by commodity and type of producer, (2)
the extent to which producers we selected for review provided support for
CFAP payments, and (3) the extent to which FSA verified producers’
compliance with program rules.
For all of these objectives, we reviewed relevant statutes and regulations;
FSA handbooks, application forms, and other documents; and relevant
GAO and Congressional Research Service reports. To examine FSA’s
distribution of CFAP payments by commodity and type of producer, we
analyzed FSA payment and other data as of December 2021. We
assessed the reliability of FSA’s data and determined that the data were
sufficiently reliable for the purpose of providing information on the
distribution of payments by agricultural commodity; type of producer; and
location; as well as for selected producers, such as those that received
the largest payments.
To examine the extent to which producers that we selected for review
provided support for CFAP payments, we selected a nongeneralizable
sample of 90 producers and reviewed their claims and supporting
documents that we obtained from FSA and the producers. We selected
these 90 producers using risk factors that made them potentially more
susceptible to receiving improper payments, including improper payments
resulting from fraudulent activity (e.g., intentional false claims to receive a
government benefit). 10 For example, we focused on producers that
received large CFAP payments for inventory claims of agricultural
commodities about which FSA has limited knowledge, such as cattle,
hogs, tree nuts, and vegetables. Therefore, our results are not
representative of all CFAP claims. (See app. I for more detail on our
review of the claims of the 90 producers that we selected.)

10The Payment Integrity Information Act of 2019 defines an improper payment as any
payment that should not have been made or that was made in an incorrect amount
(including overpayments and underpayments) under statutory, contractual, administrative,
or other legally applicable requirements. It includes any payment to an ineligible recipient,
any payment for an ineligible good or service, any duplicate payment, any payment for a
good or service not received (except for such payments where authorized by law), and
any payment that does not account for credit for applicable discounts. 31 U.S.C. §
3351(4). Further, when an executive agency’s review is unable to discern, because of
lacking or insufficient documentation, whether a payment was proper, the agency must
treat the payment as improper in producing an improper payment estimate. 31 U.S.C. §
3352(c)(2).

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To examine the extent to which FSA verified producers’ compliance with
CFAP requirements, we reviewed FSA’s methodology for selecting
samples of payments for its reviews and the summary results. We also
interviewed knowledgeable officials from FSA’s national office and a
nongeneralizable sample of officials from five states and a county in each
of the five states that conducted spot checks. In some cases, we received
written responses regarding the methodology and summary results. We
reviewed a provision in the 2018 Farm Bill and FSA’s handbook on
integrity and accountability and CFAP internal control plans and assessed
whether the design of FSA’s reviews was consistent with these
documents. We also reviewed GAO’s Fraud Risk Framework and used it
to identify leading practices that may be used to effectively prevent
instances of potential fraud. 11
In addition, we reviewed documents and interviewed officials from
USDA’s Farm Production and Conservation Business Center (Business
Center) regarding their review of national random samples of CFAP
payments in fiscal years 2020 and 2021. Similarly, we reviewed
documents and interviewed officials from USDA’s Office of Inspector
General (OIG) regarding their ongoing review and investigations of CFAP
payments.
We conducted this performance audit from August 2020 to September
2022 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.

Background

USDA’s supplemental assistance programs provide payments to eligible
producers that have been affected by a variety of situations or events,
including financial hardship or crop damage and loss following natural
disasters. These supplemental assistance programs are often reactive to
particular adverse events, rather than long-standing programs designed
to cover regular market and weather fluctuations, such as many farm bill

11See GAO, A Framework for Managing Fraud Risks in Federal Programs,

GAO-15-593SP (Washington, D.C.: July 2015).

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programs, including Agriculture Risk Coverage or Price Loss Coverage. 12
In addition to CFAP, USDA’s Market Facilitation Program is another
supplemental assistance program administered by FSA. As we previously
reported, the Market Facilitation Program provided approximately $23
billion to offset losses in U.S. agricultural export sales caused by
international trade disruptions and tariffs in the 2018 and 2019 calendar
years. 13

Time Frame and Eligibility

FSA provided multiple opportunities for producers to apply for CFAP
payments in 2020 and 2021 and made various changes to expand the
program over the course of its duration. FSA generally accepted
applications for the first round of payments, known as CFAP 1, from May
2020 through September 2020. From September 2020 through December
2020, FSA accepted applications for the second round of payments,
known as CFAP 2. In April 2021, FSA provided additional assistance to
cattle producers that received payments under CFAP 1 and field crop
producers that received payments under CFAP 2. 14 In March 2021, USDA
announced that it was extending the application deadline for all eligible
producers into April 2021. Later, in August 2021, FSA allowed producers
to apply for CFAP 2 through October 2021. Also, in August 2021, FSA
made payments available for contract producers of livestock and eggs,
which were previously not eligible. 15 Throughout this period, FSA also
made several other adjustments to CFAP program rules, including adding
eligible commodities. Figure 1 lists examples of the more than 200
agricultural commodities for which producers could apply for CFAP
payments.

12Agriculture Risk Coverage program payments are triggered when a crop’s revenue (i.e.,
the amount produced, multiplied by the market price) is below a guaranteed level. Price
Loss Coverage payments are based on a crop’s market price.
13GAO, USDA Market Facilitation Program: Oversight of Future Supplemental Assistance

to Farmers Could Be Improved, GAO-22-104259 (Washington, D.C.: Jan. 4, 2022).

14FSA made these payments, also known as “top-up” payments, in accordance with the
Consolidated Appropriations Act, 2021, Pub. L. No. 116-260, div. M, tit. VII, subtit. B, ch.
1, § 751, 134 Stat. 1182, 2105.
15According to an FSA CFAP handbook, a contract producer is a producer that grows or
produces an eligible commodity under contract on behalf of another person or legal entity.
The contract producer does not own the commodity and is not entitled to a share of the
proceeds from sales of the commodity.

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Figure 1: Examples of Eligible Commodities for CFAP, by Type

Note: Other commodities may include additional agricultural commodities produced in the U.S. and
marketed for commercial production that have been designated as eligible for the Coronavirus Food
Assistance Program (CFAP).
a
Aquaculture includes any species of aquatic organisms grown as food for human consumption, fish
raised as feed for fish that are consumed by humans, and ornamental fish propagated and reared in
an aquatic medium. Eligible aquaculture species must be raised by a commercial operator and in
water in a controlled environment.

Other livestock must be commercially raised for food, fur, fibers, or feathers.

b

Specialty crops include fruits, horticulture (e.g., certain herbs, spices, and medicinal plants), tree
nuts, and vegetables.
c

Nursery crops include plants grown in a container or controlled environment for commercial sale.

d

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For both CFAP 1 and CFAP 2, producers had to meet the same eligibility
requirements related to federal conservation regulations and income.

Payment Structure and
Approval

For both CFAP 1 and CFAP 2, USDA determined payment rates based
on factors that varied by commodity, primarily utilizing information on
price declines or wholesale values between or on certain dates in 2020. 16
CFAP 1 was to compensate producers for losses in the first quarter of
2020, and CFAP 2 was to compensate producers for losses in the second
through fourth quarter of 2020. For both CFAP 1 and CFAP 2, FSA
generally determined payments using a commodity-specific payment rate
or percentage, multiplied by the production, sales, or another basis, as
shown in table 1.

Table 1: Basis for Calculating Payments for CFAP 1 and CFAP 2, by Type of Agricultural Commodity
FSA generally accepted applications for the first round of payments, known as CFAP 1, in May to September 2020 and for the second round, known as
CFAP 2, in September to December 2020 and April to October 2021.

Type of
agricultural commoditya

CFAP 1

CFAP 2b

Dairy

Production in January 2020 through March 2020

Production in April 2020 through August
2020

Field crops

2019 production not sold as of January 15, 2020, not to
exceed 50 percent of total 2019 production

2020 eligible acresc

Livestock

Unpriced inventory as of January 15, 2020, that (1) the
producer owned on a date selected by the producer from
April 16, 2020, to May 14, 2020; and (2) sales from
January 15, 2020, to April 15, 2020

Inventory (excluding breeding stock) on a
date that the producer selected from April
16, 2020, to August 31, 2020

Other commodities

Depending on the type of commodity, one or more of the Depending on the type of commodity, (1)
following: (1) 2019 production not sold as of January 15, sales for calendar year 2018, 2019, or
2020, not to exceed 50 percent of total 2019 production; 2020; or (2) production in calendar year
(2) sales, volume of production shipped but not sold, or
2019
acres with production not shipped and not sold, from
January 15, 2020, to April 15, 2020; (3) value of inventory
as of April 15, 2020; or (4) production in January 2020
through March 2020

Source: GAO analysis of Farm Service Agency (FSA) documents. | GAO-22-104397
a
For the purposes of this report, types of agricultural commodities include (1) dairy; (2) field crops,
which are alfalfa, amaranth grain, barley, buckwheat, canola, corn, cotton, crambe, einkorn, emmer,
flax, guar, hemp, indigo, kenaf, khorasan, millet, mustard, oats, peanuts, quinoa, rapeseed, rice, rye,
safflower, sesame, sorghum, soybeans, spelt, sugar beets, sugarcane, sunflowers, teff, triticale, and

16According to a Congressional Research Service report, USDA’s determination of CFAP
1 and CFAP 2 payment rates differed in that USDA determined payment rates to
producers for CFAP 1 by estimating economic damages from price declines or increased
marketing costs; but for CFAP 2, USDA assumed economic damage for nearly all
commodities. See Congressional Research Service, USDA’s Coronavirus Food
Assistance Program: Round Two (CFAP 2), R46645 (Washington, D.C.: Dec. 21, 2020).

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wheat; (3) livestock, which includes cattle, hogs, pigs, and sheep; and (4) other commodities, which
include aquaculture (e.g., food and ornamental fish), eggs, fruits, nursery crops (e.g., container-grown
plants), tobacco, tree nuts, vegetables, and wool.
b
Contract producers could also receive payments from the Coronavirus Food Assistance Program
(CFAP) 2 for certain livestock and eggs based on their claimed revenue losses between 2018 and
2020, or 2019 and 2020.
c
Eligible acres include those acres that producers planted with eligible crops, as shown on FSA’s
acreage report.

In accordance with FSA’s handbooks for CFAP 1 and CFAP 2, FSA
county committees were to review and approve all CFAP applications and
any adjustments that FSA made to claims by producers that FSA selected
for spot-check review. 17 Producers generally self-certified their claims, but
county committees were to review claims for reasonableness and could
request additional documents and adjust the quantities claimed by
producers prior to approving a CFAP application.

Reviews of Improper
Payments, Internal
Controls, and Fraud Risk
Management

As part of USDA’s efforts to ensure that producers comply with eligibility
requirements and that internal controls are in place to recover any
improper payments, USDA, including FSA and other agencies, typically
conducts postpayment reviews and recovery audits, known as spot
checks.
In September 2021, FSA issued a handbook on internal controls and
accountability on program integrity, addressing FSA staff responsibilities
and oversight of the agency’s internal control program, among other
issues. 18 FSA issued this handbook in response to, among other
authorities, a provision in the 2018 Farm Bill directing USDA to use
targeted activities to identify and reduce errors, waste, fraud, and abuse
in FSA’s programs. 19 For both CFAP 1 and CFAP 2, FSA also issued

17Members of county committees are elected by local producers to administer FSA
programs in each county or area.
18U.S. Department of Agriculture, Farm Service Agency, Integrity and Accountability in
FSA Programs, Handbook 1-IA, Amendment 1 (Washington, D.C.: Sept. 30, 2021).
19Agriculture Improvement Act of 2018, Pub. L. No. 115-334, § 1705(a), 132 Stat. 4490,

4526.

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program-specific internal control plans, including spot checks of payments
to selected producers. 20
As a further effort to ensure the integrity of USDA payments, the Business
Center—which provides shared services across several USDA
agencies—conducts reviews to identify, report, and reduce improper
payments. 21 The Business Center reviewed CFAP 1 payments in fiscal
year 2020 and CFAP 1 and CFAP 2 payments in fiscal year 2021 in
accordance with payment integrity requirements in statute. 22 USDA’s
Business Center 2021 payment integrity review for CFAP estimated that
CFAP had a significant improper payment rate for fiscal year 2020. 23
Specifically, as part of a risk assessment, the Business Center estimated,
according to errors that it found, that $449,871,216 (about 4.4 percent) of
CFAP payments were improper and, thus, that the program is susceptible
to significant improper payments. Consequently, USDA will be required to
estimate and report improper payments for any future payments in the
program.
We and OIG have noted the potential for improper CFAP payments
involving fraud. In November 2021, OIG reported that it continued to
prioritize the assessment of allegations of fraud associated with COVID-

20U.S. Department of Agriculture, Farm Production and Conservation, Farm Service
Agency, Coronavirus Food Assistance Program (CFAP) Internal Controls and Integrity
Plan (Washington, D.C.: May 12, 2020); and Coronavirus Food Assistance Program
(CFAP) 2 Internal Controls and Integrity Plan (Washington, D.C.: Sept. 18, 2020).
21The Business Center was created in October 2018 to provide administrative services,

such as financial management, human resources, and information technology, to FSA and
two other USDA agencies.

22USDA’s Business Center conducted its review of payments made in fiscal year 2021
under the authority of the Payment Integrity Information Act of 2019, Pub. L. No. 116-117,
§ 2, 134 Stat. 113, 113 (2020) (codified at 31 U.S.C. §§ 3351-3358). The Business Center
conducted its reviews of payments made in fiscal year 2020 under the authority of the
Improper Payments Information Act, Pub. L. No. 107-300, 116 Stat. 2350, as amended by
the Improper Payments Elimination and Recovery Act of 2010, Pub. L. No. 111-204, 124
Stat. 2224, and the Improper Payments Elimination and Recovery Improvement Act of
2012, Pub. L. No. 112-248, 126 Stat. 2390 (2013) (codified as amended at 31 U.S.C. §
3321 note).
23Under the Payment Integrity Information Act of 2019, improper payments are considered
significant if in the preceding fiscal year they may have exceeded either (1) 1.5 percent of
program outlays and $10 million or (2) $100 million (regardless of the improper payment
rate). 31 U.S.C. § 3352(a)(3).

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19 pandemic relief, including CFAP 2. 24 In our most recent CARES Act
oversight report, issued in April 2022, we included information on federal
fraud-related cases, including those involving CFAP payments. 25 As
described in our Fraud Risk Framework, 26 fraud risk exists when
individuals have an opportunity to engage in fraudulent activity. According
to the Fraud Risk Framework, a “fraud risk factor” describes what
conditions or actions are most likely to cause or increase the chances of
fraud occurring. Although the existence of fraud risk factors does not
necessarily indicate that fraud exists or will occur, these factors are often
present when fraud does occur. Further, while not all improper payments
are the result of fraudulent activity, they are indicators of fraud risk.

FSA’s Distribution of
CFAP Payments
Varied by Commodity
and Type of Producer
FSA Distributed Almost
Half of CFAP Payments for
Field Crops

Field crops, such as corn and soybeans, accounted for almost half of
CFAP payments—$13.8 billion of the $31.0 billion in total CFAP
payments that FSA distributed as of December 2021. 27 FSA distributed
about a third of all payments ($9.8 billion) for livestock, such as cattle and
hogs. Of the remaining payments, FSA distributed $3.0 billion for dairy
and $4.4 billion for other commodities, which include aquaculture (e.g.,
food and ornamental fish), fruits, nursery crops (e.g., container-grown
plants), tree nuts, vegetables, and wool. Figure 2 shows FSA’s
distribution of all CFAP payments, by type of agricultural commodity.

24U.S. Department of Agriculture, Office of Inspector General, Semiannual Report to
Congress Second Half April 1, 2021 – September 30, 2021, Number 86 (Washington,
D.C.: Nov. 19, 2021).
25GAO, COVID-19: Current and Future Federal Preparedness Requires Fixes to Improve

Health Data and Address Improper Payments, GAO-22-105397 (Washington, D.C.: Apr.
27, 2022).

26In 2015, we published the Fraud Risk Framework to establish a comprehensive set of
leading practices that serve as guidance for agencies to use when developing or
enhancing efforts to combat fraud in a strategic, risk-based manner. See GAO-15-593SP.
27FSA uses the terms “nonspecialty crops” in CFAP 1, and “acreage-based crops” in
CFAP 2, in its application forms, to refer to field crops. We aggregated payments across
CFAP 1 and CFAP 2 for reporting purposes.

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Figure 2: Distribution of All CFAP Payments, by Type of Agricultural Commodity

Notes: Coronavirus Food Assistance Program (CFAP) payments include all payments that FSA made
as of December 2021, including for CFAP 1 and CFAP 2.
For the purposes of this report, types of agricultural commodities include (1) field crops, which are
alfalfa, amaranth grain, barley, buckwheat, canola, corn, cotton, crambe, einkorn, emmer, flax, guar,
hemp, indigo, kenaf, khorasan, millet, mustard, oats, peanuts, quinoa, rapeseed, rice, rye, safflower,
sesame, sorghum, soybeans, spelt, sugar beets, sugarcane, sunflowers, teff, triticale, and wheat; (2)
livestock, which includes cattle, hogs, pigs, and sheep; (3) other commodities, which include
aquaculture (e.g., food and ornamental fish), eggs, fruits, nursery crops (e.g., container-grown
plants), tobacco, tree nuts, vegetables, and wool; and (4) dairy.

Payments Varied by Type
of Producer, with
Historically Underserved
Producers Receiving a
Small Percentage of CFAP
Payments

Individual producers directly received just over half (51 percent) of all
CFAP payments, or $15.9 billion; producers operating various types of
entities—which may have individuals or other entities as members—
received the remaining $15.0 billion. Among individual producers,
producers that certified that they belong to one or more historically
underserved groups received a total of $1.5 billion, or 5.0 percent of all
CFAP payments. The average payment for producers that certified that
they belong to one or more historically underserved groups was $21,055,
which is less than the average payment of $24,403 across all individual
producers. 28 CFAP did not offer special benefits for historically
underserved groups, and FSA did not require individuals to certify that
they belong to such groups for the purpose of the CFAP. Because FSA
28Historically underserved producers are one or more of the following: beginning, limited
resource, socially disadvantaged, or veterans. We included individual producers, including
those that are members of entities, in this analysis. Entities may also qualify for one or
more of these historically underserved groups based on criteria outlined in FSA
documents.

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did not necessarily categorize these producers as historically
underserved when they received payments, the numbers of such
individuals and the payments they received may be greater than shown in
table 2.
Table 2: CFAP Payments to Historically Underserved Groups, by Type of Agricultural Commodity
The average payment for all individual producers—including those not certified as belonging to historically underserved groups—was $24,403.

CFAP payments, by type of agricultural commoditya (dollars)
Historically
underserved
group

Livestock

Other
commodities

Total CFAP
payment
(dollars)

Average
CFAP
payment per
individual
producer
(dollars)

137,127,569

99,922,152

24,711,864

289,315,629

24,732

80,205,109

276,823,148

365,080,488

147,558,501

869,667,246

20,396

17,594

33,546,307

134,998,947

145,804,321

35,047,712

349,397,287

19,859

1,922

1,738,385

1,778,884

10,786,429

5,174,599

19,478,297

10,134

70,393

140,382,567

539,119,469

601,377,442

201,253,711

1,482,133,189

21,055

Number of
individual
producers

Dairy

Field crops

Veterans

11,698

27,554,043

Socially
disadvantaged

42,640

Beginning
Limited resource
All historically
underservedb

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

Note: Coronavirus Food Assistance Program (CFAP) payments include all payments that FSA made
as of December 2021, including for CFAP 1 and CFAP 2.
a
For the purposes of this report, types of agricultural commodities include (1) dairy; (2) field crops,
which are alfalfa, amaranth grain, barley, buckwheat, canola, corn, cotton, crambe, einkorn, emmer,
flax, guar, hemp, indigo, kenaf, khorasan, millet, mustard, oats, peanuts, quinoa, rapeseed, rice, rye,
safflower, sesame, sorghum, soybeans, spelt, sugar beets, sugarcane, sunflowers, teff, triticale, and
wheat; (3) livestock, which includes cattle, hogs, pigs, and sheep; and (4) other commodities, which
include aquaculture (e.g., food and ornamental fish), eggs, fruits, nursery crops (e.g., container-grown
plants), tobacco, tree nuts, vegetables, and wool.
b
Historically underserved producers are those that certified they are beginning, limited resource,
socially disadvantaged, veterans, or some combination of these types. Historically underserved
producers and their payments are not a sum of the other categories because producers may qualify
for more than one historically underserved group (e.g., they can have both socially disadvantaged
and veteran status).

Entities received an average CFAP payment of about $77,880 per entity.
Of the various types of entities that producers may operate, general
partnerships and joint ventures received among the largest average
payments for CFAP, about $128,048 and $102,669, respectively, but
some received CFAP payments totaling millions of dollars (see app. II).
Variations in the average payments between individuals and entities and
among different types of entities may be related to FSA’s provisions on
payment limitations. Historically, FSA has limited the amount that
producers could receive in payments from many of its programs, including

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some supplemental disaster programs. 29 Similar to several programs
reauthorized in the 2018 Farm Bill, individual producers could receive a
limited amount from CFAP 1 and CFAP 2 each year. Specifically, each
individual could receive up to $250,000 from CFAP 1 and up to $250,000
from CFAP 2 (for a total of up to $500,000), which FSA refers to as the
“payment limit.” 30 General partnerships and joint ventures could receive
up to $250,000 for each of their members, regardless of the number of
members.
For certain legal entities, FSA set the payment limit criteria to potentially
allow for larger total payments compared with Farm Bill programs subject
to payment limitation. Specifically, Farm Bill programs establish a single
payment limit for legal entities. In contrast, for CFAP 1 and CFAP 2,
producers that were corporations, limited liability companies (LLC), limited
partnerships, trusts, or estates could receive up to three payment limits
(i.e., up to $750,000) each for CFAP 1 and for CFAP 2. 31 As shown in
table 3 below, the largest share of CFAP payments that entities of all
types received was for field crops.
Table 3: CFAP Payments to Entities, by Type of Agricultural Commodity
The average payment per entity was $77,880.

CFAP payments, by type of agricultural commodityb (dollars)
Type of
entitya
General
partnerships

Number
of
entities

Dairy

Field crops

23,464

394,820,407

1,738,136,167

Livestock

Other
commodities

Total CFAP
payments
(dollars)

Average
CFAP
payment
per entity
(dollars)

466,363,321

405,197,650

3,004,517,544

128,048

29According to the Congressional Research Service, since 1970, Congress has used
various policies to address the issue of who should be eligible for farm program payments
and how much an individual should be eligible to receive in a single year. In recent years,
congressional policy has focused on tracking payments through multiperson entities to
individuals, ensuring that payments go to individuals or entities actively engaged in
farming and capping the amount of payments that a qualifying individual may receive in
any 1 year. See Congressional Research Service, U.S. Farm Programs: Eligibility and
Payment Limits, R46248 (Dec. 7, 2020).
30This payment limit also applied to certain types of entities, including charities, churches,
nonprofit organizations, and public schools.
31For CFAP 1 and CFAP 2, producers organized as corporations, estates, limited

partnerships, LLCs, or trusts could claim payment limits for up to three members, if the
three members certified that they contributed at least 400 hours per year of personal labor
or active personal management.

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CFAP payments, by type of agricultural commodityb (dollars)

Livestock

Other
commodities

Total CFAP
payments
(dollars)

Average
CFAP
payment
per entity
(dollars)

1,495,025,901

1,452,116,286

5,418,432,816

103,220

240,964,844

72,970,529

56,761,905

441,888,177

102,669

124,278,898

107,314,174

182,983,297

139,971,659

554,548,029

91,843

63,687

1,149,626,575

1,291,749,166

1,366,258,836

1,085,225,230

4,892,859,806

76,827

Individuals
operating as a
small business

3,244

68,282,808

52,712,219

35,527,516

54,780,150

211,302,692

65,136

Trusts

36,257

12,047,468

291,830,385

101,682,205

42,061,742

447,621,799

12,346

Estates

2,042

885,054

12,784,083

6,662,440

2,109,182

22,440,759

10,990

Number
of
entities

Dairy

Field crops

Corporations

52,494

533,671,658

1,937,618,972

Joint ventures

4,304

71,190,898

Limited
partnerships

6,038

Limited liability
companies

Type of
entitya

Other entities
Total

1,347

954,226

7,387,808

5,525,168

2,516,692

16,383,894

12,163

192,943

2,355,757,991

5,688,156,652

3,737,409,734

3,245,131,692

15,026,456,069

77,880

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

Note: Coronavirus Food Assistance Program (CFAP) payments include all payments that FSA made
as of December 2021, including for CFAP 1 and CFAP 2.
a
For the purposes of this report, types of entities include (1) corporations, which include subchapter S
corporations; (2) trusts, which include irrevocable and revocable trusts; and (3) other entities, which
include charities, churches, nonprofit organizations, and public schools. In addition, FSA distributed
$16.5 million to 66 “Indian tribal ventures,” which is the business type that FSA uses to identify tribes
and tribal ventures. According to an FSA handbook, tribes and tribal ventures are not subject to limits
regarding payments, so their average payments may be higher than those of other entities.
b
For the purposes of this report, types of agricultural commodities include (1) dairy; (2) field crops,
which are alfalfa, amaranth grain, barley, buckwheat, canola, corn, cotton, crambe, einkorn, emmer,
flax, guar, hemp, indigo, kenaf, khorasan, millet, mustard, oats, peanuts, quinoa, rapeseed, rice, rye,
safflower, sesame, sorghum, soybeans, spelt, sugar beets, sugarcane, sunflowers, teff, triticale, and
wheat; (3) livestock, which includes cattle, hogs, pigs, and sheep; and (4) other commodities, which
include aquaculture (e.g., food and ornamental fish), eggs, fruits, nursery crops (e.g., container-grown
plants), tobacco, tree nuts, vegetables, and wool.

Of the $31.0 billion in total CFAP payments, FSA distributed $661.5
million (2 percent) to producers that had average annual AGI above
$900,000 over a specified 3-year period. These high-income producers,
which include 1,682 individuals and 1,518 legal entities, qualified for
CFAP payments based on certifications that at least 75 percent of their
income was derived from farming, ranching, or forestry-related activities. 32
As shown in figure 3 below, a majority of the payments to high-income

32As we previously reported, FSA does not independently verify that producers qualify for

payments under the 75 percent rule. FSA relies on certifications signed by producers’
certified public accountants or attorneys. See GAO-22-104259.

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producers were for “other commodities,” which include specialty crops,
such as fruits, tree nuts, and vegetables.
Figure 3: CFAP Payments to High-Income Producers, by Type of Agricultural
Commodity
High-income producers received $661.5 million and were comprised of 1,682 individuals and 1,518
legal entities.

Notes: Coronavirus Food Assistance Program (CFAP) payments include all payments that FSA made
as of December 2021, including for CFAP 1 and CFAP 2.
High-income producers qualified for CFAP payments based on a certification that at least 75 percent
of their adjusted gross income was derived from farming, ranching, or forestry-related activities. Of
the total producers receiving these payments, 1,463 received the payments directly, and 1,737
received the payments indirectly as members of entities that producers operate.
For the purposes of this report, types of agricultural commodities include (1) dairy; (2) field crops,
which are alfalfa, amaranth grain, barley, buckwheat, canola, corn, cotton, crambe, einkorn, emmer,
flax, guar, hemp, indigo, kenaf, khorasan, millet, mustard, oats, peanuts, quinoa, rapeseed, rice, rye,
safflower, sesame, sorghum, soybeans, spelt, sugar beets, sugarcane, sunflowers, teff, triticale, and
wheat; (3) livestock, which includes cattle, hogs, pigs, and sheep; and (4) other commodities, which
include aquaculture (e.g., food and ornamental fish), eggs, fruits, nursery crops (e.g., container-grown
plants), tobacco, tree nuts, vegetables, and wool.

About Half of the
Producers Whose
Claims We Reviewed
Did Not Provide
Support for Their
Payments, Which
May Have Been
Improper

About half of the 90 producers whose claims we reviewed did not provide
support for some or all of their CFAP payments, which may have been

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improper and potentially the result of fraudulent activity. 33 We found
deficiencies in producers’ support related to six CFAP requirements that
resulted in potentially improper payments.

About Half of the
Producers We Reviewed
Received Potentially
Improper Payments

We found deficiencies in the support that 48 of the 90 producers we
reviewed provided for their CFAP payments; therefore, their payments,
totaling over $87 million, were potentially improper. Moreover, for 20 of
these 48 producers, either the FSA county offices that issued the
payments or the producers themselves acknowledged that the documents
provided as support did not align with the producers’ claims. We referred
the 48 producers to OIG for further review to determine whether to
investigate the claims or remand them to FSA to take administrative
action and recovery efforts, as appropriate.
We also found deficiencies in the support provided by an additional 12
producers, but the deficiencies either (1) would not have affected the
CFAP payments that the producers received because of payment
limitations (i.e., the producers had sufficient support for the amount of
payments they received) or (2) would not have caused a material
difference in the payments. For example, four of the 12 producers
provided support that was less than 10 heads of cattle or hogs short of
what they claimed.
The 48 producers that we found to have received potentially improper
payments varied in the type of commodities for which they received
payments, as shown in table 4 below.

33We selected producers for review based on risk factors, such as the largest payments
for dairy, livestock, and other commodities not generally provided by FSA.

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Table 4: Selected Producers Receiving CFAP Payments, Including Potentially Improper Payments
Selected producers that received potentially
improper CFAP payments

Selected producers
Number

CFAP payments
(dollars)

Number

CFAP payments
(dollars)

Livestockb

44

78,172,476

24

45,094,863

Other commoditiesc

24

39,337,428

15

26,095,044

Dairy

22

37,099,421

9

16,128,396

Total

90

154,609,325

48

87,318,303

Commodity typea

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

Note: We selected a nongeneralizable sample of 90 producers’ Coronavirus Food Assistance
Program (CFAP) claims for review based on risk factors for improper payments, such as receiving the
largest payments for dairy, livestock, and other commodities. We considered that a risk factor
because deficiencies in these claims could have resulted in larger improper payments than
deficiencies in smaller claims. We selected 41 producers that received among the largest payments
for CFAP 1 and 49 producers that received among the largest payments for CFAP 2. For producers
that received payments from both CFAP 1 and CFAP 2, we reviewed their claims in applications for
both programs, for a total of 176 claims.
a
Some producers received payments for more than one type of commodity; we list such producers
under the commodity type for which they received the largest CFAP payment.
b
Of these 44 livestock producers, 34 received CFAP payments primarily for cattle, and the remaining
10 received the payments primarily for hogs.
c
Other commodities may include aquaculture (e.g., food and ornamental fish), eggs, fruits, nursery
crops (e.g., container-grown plants), tobacco, tree nuts, vegetables, and wool.

We Identified Deficiencies
in Producers’ Support for
Payments Related to Six
CFAP Requirements

For the 48 producers (out of 90 we selected) that we found had received
potentially improper payments, we identified deficiencies in the support
that they provided for their payments related to six CFAP requirements. In
a majority of these cases, we did not identify indicators of potentially
fraudulent activity. (See table 5.)

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Table 5: Deficiencies in Producers’ Support for CFAP Payments
Of the 90 producers whose CFAP claims we selected for review, 31 provided support that had one deficiency, while the other 17 producers provided
support that had two or more deficiencies.

Reason deficiency is
a concern

Example of deficiency

Number of
selected
producers with
deficiency

CFAP requirement

Deficiency

Support must equal or
exceed claims for
inventory or sales

Support was for a
lesser amount of the
commodity than
claimed

Producer may have
A producer received over $1.3
received payments that million in CFAP payments for cattle,
were too large
including claimed inventory of over
5,000 fed cattle. The producer’s
documentation supported inventory
of fewer than claimed.

33

Support must show that
producers sold or owned
commodities during a
specified date rangea

Support was for
inventory or sales
outside the eligible date
range, or commodities
were prepriced

Producers may not
have suffered any
market price declines
from the pandemic

A producer received $1.5 million in
CFAP payments, including for cattle
sales that, according to the
producer, were priced before
January 15, 2020, which predated
the pandemic.

18

Support must show that
producer has an
ownership share in the
claimed commodity,
subject to price riskb

Support did not clearly
establish ownership

Producers may not be
entitled to the
payments

A producer received over $2 million
in CFAP payments for hogs
supported with documents in the
names of other entities.

9

Support must show that
up to three members of
certain entity types
provided at least 400
hours of personal labor
or active personal
management for the
entity to qualify for
additional payments

Support did not prove
eligibility to receive
additional payments

Producers may not
have been eligible to
receive more than
$250,000 each for
CFAP 1 and CFAP 2

A producer received over $1.3
million in CFAP payments for cattle
but did not provide documents
showing that three members made
the required contributions.

5

Support must show that Support was for
inventory or sales claims ineligible commodities
were for eligible
commodities

Producers may have
received CFAP
payments for ineligible
commodities

A producer received over $1.9
million in CFAP payments, including
for a claim for cotton. The support
showed that it was cotton seed,
which is not an eligible commodity.

3

Support must be
Support included sales
reasonable, upon review between affiliated
parties

Producer may have
received payments for
sales not based on fair
market prices

A producer received over $1.1
million in CFAP payments partially
supported with bank checks from a
buyer that is a wholly-owned
business of the producer.

2

Source: GAO analysis of Farm Service Agency (FSA) information. | GAO-22-104397

Notes:
We selected a nongeneralizable sample of 90 producers’ Coronavirus Food Assistance Program
(CFAP) claims for review based on risk factors for improper payments, such as having received the
largest payments for dairy, livestock, and other commodities not generally provided by FSA.
We discussed our findings with the relevant FSA state and county offices for each of the six examples
outlined in the table above. In two of the examples, FSA officials or the producer agreed with the

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deficiency that we identified. In two other examples, the additional information that FSA officials or the
producer provided did not fully address our concerns. In two other examples, FSA did not agree with
us that the discrepancies we identified were a concern.
a
Each commodity type had a specific eligible date range for inventory and sales claims. Generally,
CFAP 1 was to compensate producers for losses in the first quarter of 2020, and CFAP 2 was to
compensate producers for losses in the second through fourth quarter of 2020.
b
”Subject to price risk” means any production, sales, or inventory not subject to an agreed-upon price
through a forward contract, agreement, or similar binding document, according to an FSA CFAP
handbook.

As noted above, 17 of the producers we reviewed that received
potentially improper payments had deficiencies in the support for their
claims related to more than one CFAP requirement. The following are
three examples of such producers. 34

Unclear Ownership and No
Support for Cattle Sales

A cattle producer we reviewed provided documents that did not clearly
establish ownership of the cattle claimed and did not support the cattle
sales claimed as the basis for CFAP payments. This producer received
over $6 million in CFAP payments and was organized as a joint venture
with an effective date of January 1, 2020. The joint venture consists of 20
members, qualifying it for 20 payment limits (up to $10 million in CFAP
payments). However, just one of the members, the manager, held
signature authority for the entity.
We identified several deficiencies in the producer’s support, including
cattle inventory documents that did not identify the owner and purchase
receipts showing that the owner had a different name than the producer,
calling into question whether the producer owned the cattle and was,
therefore, entitled to payments. None of the documents that the producer
provided showed that the producer owned the cattle, and some of these
documents were in the name of an LLC that owned a cattle-feeding
operation.
The producer claimed to have purchased the cattle from the LLC.
According to an agreement between the producer and the LLC, the LLC
is serving as the operating agent for the joint venture. The bill of sale and
operating agreement documenting the relationship between the two
entities state that the sale and agreement are effective as of January 1,
2020, but the single wire transfer document that the producer provided to
support the purchase of the cattle from the LLC was dated April 2021,

34As noted above, we referred these producers to OIG for further review.

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which is outside the eligible date range for CFAP. 35 The producer did not
provide substantive responses to our requests for the date that it signed
the operating agreement, bill of sale, or promissory note for the cattle
purchase. According to the producer and an FSA county official, the
producer made additional payments for the claimed cattle, such as cash
and in-kind payments, but could not provide support for these payments.
In addition, the producer claimed sales of several thousand head of cattle
between January 15, 2020, and April 15, 2020. However, the sales
receipts that the producer provided did not identify the name of the seller
and did not support the quantity and type of cattle that the producer
claimed.

Specialty Crop Sales Outside
the Eligible Date Range and to
an Affiliated Party

A producer we reviewed claimed commodity sales outside the eligible
date range for CFAP and provided support that indicated that the sales
had occurred between affiliated parties, calling into question whether the
producer has suffered a price loss as a result of the pandemic. This
producer was organized as a general partnership and received over $2
million in CFAP payments for field and specialty crops.
The producer’s support included unnumbered invoices dated in January
2021 and April 2021 for a 2020 specialty crop, months after the eligible
date range for CFAP 2. 36 FSA state and county officials told us that sales
of this perishable commodity are unlikely to occur months after harvest.
Furthermore, the producer provided documents showing sales of field
crops in November 2019, outside of the eligible date range for CFAP 1. 37
Additionally, the producer provided invoices to a buyer that is (1) located
at the same physical address as the producer; and (2) affiliated with
owners that are also members of the producer, according to documents
that the producer filed with FSA, calling into question whether the terms of
the sales were reasonable.

35For CFAP 1, producers received payments for (1) unpriced inventory as of January 15,
2020, that producers owned on a specific date from April 16, 2020, to May 14, 2020; and
(2) sales from January 15, 2020, to April 15, 2020. For CFAP 2, producers received
payments for inventory (excluding breeding stock) on a specific date from April 16, 2020,
through August 2020.
36For CFAP 2, producers received payments based on sales in calendar years 2018,
2019, or 2020.
37For CFAP 1, producers received payments based on 2019 production not sold as of
January 15, 2020.

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GAO-22-104397 Coronavirus Food Assistance Program


Unclear Ownership, Lesser
Inventory of Cattle Than
Claimed and Outside of the
Eligible Date Range, and
Ineligible Field Crop

A producer provided documents to support its CFAP payment that (1) did
not clearly establish ownership of the cattle claimed, (2) were for a lesser
number of cattle than claimed, (3) were for inventory outside of the
eligible date range, and (4) were for ineligible commodities. This producer
was organized as a joint venture and received over $1 million of CFAP
payments for cattle and field and specialty crops.
The deficiencies we identified for this producer’s support included an
informal oral agreement to lease the cattle, according to an FSA county
official. Because of the informal nature of the agreement, it is unclear
what the terms of the “lease” were, and we were unable to determine if
the producer had ownership subject to price risk in the cattle and,
therefore, was entitled to payments for this commodity.
Support showed inventory for one category of cattle that did not clearly
match the category that the producer claimed. Further, none of the
records that the producer provided clearly supported the number of cattle
that the producer claimed or indicated what date or dates that the
producer had selected for its inventory claim, calling into question
whether the producer had received payments that were too large. This
producer also claimed production of a field crop that was part of a forage
mix, which, according to an FSA official, is not among the eligible
commodities for CFAP and, therefore, the producer should not have
received a payment for it.

FSA Checked
Producers’
Compliance with
Program Rules, but
These Checks Had
Limitations

To help ensure that producers’ claims in CFAP applications were
accurate, FSA conducted spot checks of a sample of producers that had
received CFAP payments, but these spot checks had limitations. These
limitations include that FSA’s (1) national office did not fully consider risk
factors when selecting producers for its sample, (2) county offices did not
consistently add producers with questionable claims to the spot-check
sample, (3) county offices accepted producer-generated documents as
support for producers’ claims, and (4) state offices did not monitor the
quality of county offices’ spot checks.

FSA Did Not Fully
Consider Risk Factors for
Selecting Producers for
CFAP Spot Checks

FSA selected two samples of producers’ claims to spot check for CFAP 1
and one sample for CFAP 2. In total, FSA selected 4,405 producers for
spot checks. FSA selected 3,523 (80 percent) of these producers using a

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stratified random sampling approach based on payment amounts. 38 This
approach also considered commodities in proportion to their share of the
overall payments. FSA’s state and county offices selected the remaining
producers’ claims to include in the spot checks. FSA sampled claims that
resulted in large payments at higher rates than claims that resulted in
small payments, but less than 1 percent of the producers whose claims
FSA sampled had received CFAP payments greater than $1 million, and
about half of the claims in the sample (53 percent) were for payments
less than $30,000. Moreover, FSA included in its spot checks 11
producers’ claims that resulted in payments under $100, the lowest of
which was $32. FSA did not consider other risk factors, such as whether
producers had received payments for inventory claims, which are more
likely to be supported with self-generated documents.
As noted earlier, in selecting our nongeneralizable sample of producers to
review, we considered risk-based factors, such as large payments for
inventory claims of agricultural commodities about which FSA has limited
knowledge. We found that about half of the producers in our sample of 90
had received potentially improper payments.
We recommended in our January 2022 report that FSA take a more
complete risk-based approach in selecting samples for future compliance
reviews (such as spot checks) of supplemental assistance programs. 39
FSA concurred with this recommendation. In a 2021 report, we found that
a risk-based approach enables agencies to (1) achieve their objectives (in
this case, ensuring that payments are based on accurate production
information) and (2) increase the efficiency of compliance reviews by
better focusing limited resources. 40
Officials from FSA’s national office we interviewed told us that they would
consider initiating additional rounds of CFAP spot checks. However, it is
unclear whether FSA will vary its approach for selecting producers in
38For one of its CFAP 1 samples, FSA sorted the payments that producers had received
into seven groups based on the size of payments, the first five of which each represented
approximately 20 percent of the payments. The top two groups comprised four payments
greater than $1.5 million and two payments greater than $1.75 million, respectively. FSA
randomly selected from the first five groups and selected all the payments from the top
two groups. FSA used variations on this same approach for the other samples.
39GAO-22-104259.
40GAO, Farm Programs: USDA Should Take Additional Steps to Ensure Compliance with

Wetland Conservation Provisions, GAO-21-241 (Washington, D.C.: Apr. 2, 2021).

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GAO-22-104397 Coronavirus Food Assistance Program


future spot checks because FSA did not change its approach when
selecting producers for its second CFAP 1 spot checks and its CFAP 2
spot checks. 41 For example, officials from FSA’s national office told us
that they intended to exclude field crops from the CFAP 2 sample
because payments for those crops were based on FSA’s existing records
and, therefore, were a lower risk. However, the officials said that FSA had
inadvertently included field crops in the CFAP 2 sample. Therefore, the
CFAP 2 methodology was similar to the methodology that FSA had used
for the CFAP 1 spot checks.
The 2018 Farm Bill requires the Secretary of Agriculture to establish
policies, procedures, and plans to improve program accountability and
integrity through targeted and coordinated activities to identify and reduce
errors, waste, fraud, and abuse in programs administered by FSA. The
FSA handbook on Integrity and Accountability in FSA Programs calls on
FSA’s national office to evaluate and validate program internal controls (in
this case, CFAP spot checks) and recommend changes to policy,
software, and organizational performance evaluations, as appropriate. By
conducting additional CFAP 1 and CFAP 2 spot checks that use a more
risk-based sampling methodology, FSA could improve the effectiveness
and efficiency of its efforts to identify potentially improper payments.

FSA’s County Offices Did
Not Consistently Select
Producers with
Questionable Claims for
CFAP Spot Checks

FSA authorized state and county offices to select producers to add to its
national sample for CFAP spot checks if the offices questioned the
validity of the producers’ claims for CFAP 1 or CFAP 2. 42
However, most FSA county offices for locations where producers had
received CFAP payments did not select any producers’ claims to add to
the spot checks. More specifically, FSA county offices selected claims
from producers for spot checks in 331 counties of the 3,058 counties (11
percent) where producers had received CFAP payments. According to
officials from the FSA national office, the remaining county offices did not
select claims from any producers to add to the spot checks. For example,
in California, the state with the second-largest CFAP payments spanning
41According to officials from FSA’s national office, FSA began its second round of CFAP 1
spot checks and its first round of CFAP 2 spot checks concurrently in February 2022.
These officials told us that FSA had finalized the sample in January 2022, when we issued
our report recommending that FSA take a more complete risk-based approach in selecting
samples for future compliance reviews of supplemental assistance programs.
42FSA’s analysis of the spot checks did not distinguish between producers that the
counties or the states selected for the spot checks, only between those that FSA offices
had selected and those identified by the stratified random sample.

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57 counties, FSA county offices selected seven producers’ claims out of
over 22,500 producers to add to the CFAP spot checks. CFAP payments
to producers in California were primarily for other commodities, such as
specialty crops that are generally not eligible for Farm Bill programs,
which can be an indicator of risk for improper payments.
Officials we interviewed from two county offices told us that they did not
always select producers’ claims for spot checks even if they questioned
their validity or were unfamiliar with the producer. For example, in one
county, according to an FSA county official, FSA did not review a
producer’s CFAP payment—whose claims we reviewed and found did not
have sufficient support—because the official was not sure if the reason
for questioning the producer’s claims (the producer’s recent formation)
was justifiable.
Officials from FSA’s national office told us that they did not provide
specific guidance on what constitutes a questionable claim for FSA’s spot
checks of CFAP 1 payments because county officials are most familiar
with producers in their counties. However, FSA officials we interviewed
from two states and one county told us that they distributed CFAP
payments to producers that were unknown to the officials and had not
previously participated in Farm Bill programs, which can be indicators of
risk for improper payments.
FSA analyzed the results of its CFAP 1 spot checks and found that
county offices that selected producers for spot checks were proficient at
identifying risks for overpayments, a subset of improper payments.
Specifically, in the CFAP 1 spot checks, FSA state and county offices
selected the claims of 213 of the 379 producers (56 percent) that were
found to have received overpayments. The remaining claims from 166
producers that received overpayments were selected using a stratified
random sample, as shown in table 6 below.

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GAO-22-104397 Coronavirus Food Assistance Program


Table 6: Number of Producers and Overpayments in FSA CFAP 1 Spot Checks
Producers in FSA’s stratified random sample had a lower rate of overpayments than producers that officials from FSA state and county offices selected
for the spot checks.

Producers in FSA
CFAP 1 spot checks

FSA’s stratified
random sample
FSA state and county
offices judgmental
sample
Total

Producers in FSA CFAP 1
spot checks that received overpayments

Number

CFAP payments
(dollars)

Number

Percent of
producers that
received
overpayments

1,066

133,699,740

166

16

10,511,781

8

768

59,680,006

213

28

11,494,636

19

1,834

193,379,746

379

21

22,006,417

11

CFAP
overpayments
(dollars)

Percent of
overpayment

Source: Farm Service Agency (FSA) data. | GAO-22-104397

Note: As of June 2022, FSA had not completed the second round of Coronavirus Food Assistance
Program (CFAP) 1 spot checks nor the CFAP 2 spot checks.

An FSA internal report analyzing the results of its CFAP 1 spot checks
recommended that FSA adopt the approach that county offices used to
select producers’ claims for its national sample. Officials we interviewed
from one state and two county offices told us that they selected
producers’ claims to add to the CFAP 1 spot checks for various reasons,
including when there were anomalies in these claims, repeated revisions
to applications for CFAP payments, or harvest or sales dates that did not
align with their commodities’ growing seasons. 43 Producers in two states,
whose claims county officials questioned, were investigated by OIG and
pled guilty to making false claims to obtain CFAP payments. 44
FSA state and county offices selected fewer producers’ claims for the
CFAP 2 spot checks (114) than they did for the first round of the CFAP 1
spot checks (768). 45 Officials from FSA’s national office told us that high
workloads may explain the drop in the number of producers’ claims that
FSA state and county offices selected for the CFAP 2 spot checks
43We interviewed FSA county officials from three counties that added producers to FSA’s
spot check and two that did not.
44OIG officials told us that as of May 2022, OIG had six open investigations of CFAP
payments, in addition to two closed cases.
45Officials from FSA’s national office did not offer state and county offices the opportunity
to select producers for the second CFAP 1 spot check. Officials from FSA’s national office
we interviewed stated that they had already offered this opportunity during the first round.

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GAO-22-104397 Coronavirus Food Assistance Program


compared with CFAP 1. However, FSA officials from one state and two
county offices told us that they added fewer, if any, producers’ claims to
the CFAP 2 spot checks because a notice from FSA’s national office
stated that state and county offices had to have a valid reason to question
producers’ claims. Officials from FSA’s national office stated that they
included this language in the notice because they had heard of cases
where county officials may not have had valid reasons for adding
producers to the spot checks. However, FSA’s analysis of CFAP 1 spot
checks found that state and county offices identified a higher proportion of
producers with overpayments compared with the random sample. The
FSA notice did not provide guidance on what constitutes a valid reason to
add producers’ claims to the spot checks.
FSA’s handbook on Integrity and Accountability in FSA Programs calls on
FSA’s national office to ensure that policy is clear and concise to
eliminate potential misinterpretation by state and county offices, among
others. By issuing guidance specifying factors that state and county
offices should consider when selecting producers to undergo spot checks,
FSA could better ensure that state and county officials identify producers
that may not have sufficient basis for CFAP payments and to recover
those payments, if warranted. Ensuring that state and county offices have
clear direction on selecting such producers is particularly important for the
integrity of CFAP because the program relies on producers’ selfcertification as the basis for payments.

FSA Accepted SelfGenerated Documents as
Support for Self-Certified
Claims

FSA accepts self-generated documents from producers, including
contemporaneous measurements, as support for their self-certified CFAP
claims in spot checks, in accordance with CFAP handbooks. 46 In our
reviews, we accepted self-generated supporting documents if the
documents met the requirements in CFAP handbooks, including if the
records were determined acceptable by the local FSA county committee
or FSA County Executive Director. 47 For some commodities—such as
46The FSA national office provided direction to state and county offices on CFAP 1 and
CFAP 2 spot checks in an FSA notice dated February 28, 2022. This notice identifies a
subparagraph from each of the CFAP 1 and CFAP 2 handbooks as the standard for
acceptable supporting documents in CFAP spot checks. Specifically, this subparagraph
lists examples of acceptable supporting documents for different commodities and specifies
that any other documents not listed are acceptable if the FSA county committee finds
them acceptable. Another subparagraph of the handbooks allows FSA county committees
to delegate their spot-check responsibilities to FSA County Executive Directors.
47For example, one producer we reviewed provided a typed document in which the

producer stated that on January 1, 2020, there was a specific amount of unpriced grain in
a bin.

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unpriced grain inventory that was later consumed on-farm by livestock
rather than sold, and cash sales of vegetables in local farmers’ markets—
third-party-generated documents may not exist, according to officials from
FSA’s national office. However, accepting self-generated documents as
support was a limitation of our review because we could not
independently verify the information in these documents.
Producers we reviewed generally used self-generated documents, such
as financial statements and harvest records from their own recordkeeping
systems, to support at least a portion of the commodity quantities that
they claimed. Of the 90 producers we reviewed, 70 producers relied in
part on self-generated documents to support their claims, and eight
producers relied entirely on self-generated documents to support their
payments of over $12 million. 48
Producers that made claims primarily for cattle used self-generated
documents as support to a greater extent than other producers’ claims
that we reviewed. Specifically, 33 of the 34 producers we reviewed that
received CFAP payments primarily for cattle used self-generated
documents to support at least a portion of their claims. 49 For example,
one of those cattle producers supported its CFAP 2 payment of over
$500,000 with five self-generated tables listing the total number of cattle
in various pens and feedlots. None of the spreadsheets included
information indicating when the spreadsheets were created or by whom.
In comparison, other cattle producers whose claims we reviewed
provided third-party support from the feedlots in which their cattle were
held, such as grain and feed invoices. These documents include
information on the producers’ ownership share in the cattle and other
details that could support the producers’ claims, such as the cattle’s
weight and dates they were in the feedlot.
In our reviews, some producers provided third-party-generated
documents—such as sales receipts, grain elevator tickets, and insurance
records—that would allow for independent verification of the producers’
claims. Notably, some producers had dairy cooperatives provide milk
production records directly to FSA on the producers’ behalf. For certain
48For three of these eight producers, with claims totaling $4.6 million, there were no
deficiencies, so we accepted their claims as supported.
49Of the 33 producers, five producers relied solely on self-generated documents to support

their cattle claims, and 28 producers provided a mix of self-generated and third-party
documents.

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categories, such as milk production, third-party-generated documents
may be more readily available than other categories.
FSA does not collect information on the extent to which the agency
accepted self-generated documents from producers to support their
claims, according to written responses from officials in FSA’s national
office. The agency does not distinguish between self-generated and thirdparty-generated documents in its guidance for conducting spot checks or
in its program records.
Officials from FSA’s national office noted that FSA handbooks specify that
in spot checks, FSA county committees, composed of local citizens who
are nominated and elected by local producers, determine whether the
supporting documentation is acceptable. Officials from FSA’s national
office told us that county committees are knowledgeable about local
producers, especially larger operations, and should be able to effectively
determine if the documentation is reasonable, even if it is selfgenerated. 50 According to these officials, county committees review selfgenerated documents and third-party-generated documents using the
same standards. Specifically, county committees are tasked with ensuring
that the documents support the producers’ claims and meet program
requirements. However, as previously noted, officials from two states and
one county we interviewed told us that they distributed CFAP payments to
some producers that were unknown to the FSA officials and had not
previously participated in Farm Bill programs. In addition, two county
officials told us that they did not always select producers for review, even
if they questioned the validity of their claims.
In our prior work, we have focused on the inadequacies of using
voluntary, self-reported information without independent verification and
review. Independent verification is a key component of fraud prevention
and detection. According to GAO’s Fraud Risk Framework, 51 a leading
practice to effectively prevent instances of potential fraud is for agencies
to verify reported information, particularly self-reported data and other key
50However, state and county officials told us that their knowledge was limited in part
because of the large number of commodities in CFAP that are not generally eligible for
FSA farm programs. For example, FSA state officials in California told us that about 90
percent of the producers that applied for CFAP were unknown to FSA and that most of
these producers grew specialty crops.
51GAO-15-593SP.

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data necessary to determine eligibility for government programs. 52 Thirdparty-generated documents may be validated by the third-party sources
that generated the documents. In addition, FSA may use other means of
verification, such as site visits, interviews with individuals knowledgeable
about the operation, and comparisons with historical data to help validate
producer claims.
By relying on self-generated documents in the CFAP spot-check
reviews—particularly in combination with an approach that accepts selfcertification for eligibility and claims—FSA limits its ability to verify
producer information and eligibility and, consequently, its ability to prevent
and detect fraud and improper payments. With the passage of time, more
producers could reasonably be expected to have obtained third-partygenerated documents, such as sales receipts for commodities that they
had not yet sold at the time that they made inventory claims in their CFAP
applications. FSA could improve the rigor of future spot checks by
requiring producers to provide third-party-generated documents to
support producers’ claims, when possible. In circumstances where thirdparty-generated documents may not exist, FSA could allow officials to
accept self-generated documents but require officials to document why
third-party-generated documents were not available. 53

FSA State Offices Did Not
Monitor Spot Checks for
Quality

According to FSA national and state officials we interviewed, FSA state
offices did not monitor the quality of the CFAP 1 spot checks that the
county offices conducted in 2021 nor do they plan to monitor the quality of
the county offices’ ongoing CFAP spot checks. 54 In contrast, for programs
authorized by the 2018 Farm Bill, FSA state offices regularly examine

52See GAO, Aviation: FAA Needs to Better Prevent, Detect, and Respond to Fraud and
Abuse Risks in Aircraft Registration, GAO-20-164 (Washington, D.C.: Mar. 25, 2020), for
more information on the risks of relying on self-reported information.
53Other FSA programs require agency officials to justify why they were unable to obtain
certain evidence as part of annual reviews. For example, a required form in a handbook
for payment limits and eligibility for a variety of FSA programs requires officials conducting
reviews of producer eligibility and payment limits to interview producers unless the reason
for not interviewing a producer is obvious and adequately justified in writing.
54Even in cases where states selected producers for review, county offices conducted the
reviews.

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GAO-22-104397 Coronavirus Food Assistance Program


determinations that county offices make, and a handbook provides
guidance for such reviews. 55
FSA officials from three of the five state offices we interviewed told us that
they were not sure, on the basis of questions from county officials, if the
results of the CFAP 1 spot checks accurately record whether producers
fully supported their claims. For example, two state officials stated that it
was not clear to county officials whether they were to use a “yes” or a “no”
response for a producer that provided only partial support for a CFAP
payment.
In addition, we found, according to our review of claims and interviews
with FSA officials, that CFAP’s complexity and coverage of commodities
with which FSA is unfamiliar could make it difficult for county offices to
determine if producers supported their claims. For example, for CFAP 1,
FSA provided different payments for livestock, such as cattle and hogs,
based on weight and other factors. For other commodities, FSA provided
three different types of payments depending on whether the producer
sold the commodity, shipped the commodity but was not paid, or whether
the commodity was not shipped or sold. 56 FSA state and county officials
told us that the categories for livestock were confusing and not well
understood by county reviewers.
FSA national and state officials told us that they provided guidance and
other assistance to county offices reviewing CFAP claims. For example,
national and state officials stated that they assisted county offices with
specific issues, such as interpreting contract language to determine
whether commodities were unpriced as of a certain date and ensuring
that the county offices completed the spot checks. As a result of meeting
with us and the CFAP 1 spot-check analysis, FSA revised its guidance for
the second round CFAP 1 spot checks and CFAP 2 spot checks to help
reviewers more accurately complete them. Because the spot checks were
55As we reported in 2020, FSA state offices conduct annual compliance reviews of a
sample of producers that participate in programs authorized by the 2018 Farm Bill that are
subject to actively engaged in farming requirements. See GAO, Farm Programs: USDA
Has Improved Its Completion of Eligibility Compliance Reviews, but Additional Oversight
Is Needed, GAO-21-95 (Washington, D.C.: Oct. 30, 2020).
56For example, for perishable commodities such as fruits and vegetables, FSA provided
payments for CFAP 1 under three categories: (1) sales of commodities; (2) commodities
producers shipped but for which they did not receive payments; and (3) commodities
producers did not sell or ship, which included commodities that producers did not harvest
and that subsequently spoiled.

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GAO-22-104397 Coronavirus Food Assistance Program


ongoing as of June 2022, it is unknown if the revisions to the guidance
addressed these issues.
FSA state officials we interviewed told us that they did not systematically
monitor the quality of the spot checks that the county offices completed
and that there was no guidance directing the state offices to do so, as
there is for other programs. 57 Moreover, officials in three of the five state
offices we interviewed told us that they did not have any role in the spot
checks other than to ensure that county offices conducted the spot
checks.
FSA’s handbook on Integrity and Accountability in FSA Programs directs
state offices to provide guidance to state and county employees on the
accurate interpretation of program policies and internal control
procedures to minimize risks and improve program performance.
Providing additional direction to state officials to monitor the quality of the
CFAP spot checks could help FSA effectively oversee payments worth
tens of billions of dollars.

Conclusions

USDA provided $31 billion in CFAP payments to producers to help offset
sales losses, market disruptions, and increased costs associated with the
COVID-19 pandemic. These payments were based on self-certified
claims but were subject to FSA postpayment reviews, including spot
checks to review producers’ claims and supporting materials. However,
we identified several limitations in FSA’s reviews that may have
undermined their effectiveness in detecting improper payments. These
limitations include that FSA’s (1) national office did not fully consider risk
factors when selecting producers for its sample, (2) county offices did not
consistently add producers with questionable claims to the spot-check
sample, (3) county offices accepted self-generated documents as support
for producers’ claims, and (4) state offices did not monitor the quality of
county offices’ spot checks.
In our review of CFAP claims of 90 producers, we found that over half of
the producers did not provide support for their claims. Thus, payments
that FSA made on these claims were potentially improper. While
programs such as CFAP may be developed and implemented quickly,
FSA could better ensure the integrity of billions of dollars in CFAP

57An FSA California State official told us that the state office conducted the CFAP 1 spot
checks; however, FSA county offices will conduct the CFAP 2 spot checks.

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GAO-22-104397 Coronavirus Food Assistance Program


payments by conducting additional reviews using a more rigorous
process that addresses the limitations that we identified.

Recommendations for
Executive Action

We are making the following four recommendations to FSA:
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)
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)
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)
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)

Agency Comments

We provided a draft of this report to USDA for review and comment. In its
written comments, which are reproduced in appendix III, USDA generally
agreed with the report’s four recommendations. USDA also described
actions that it intends to take that would address these recommendations.
With regards to the first recommendation to conduct additional spot
checks using a more risk-based approach for selecting producers for
review, we appreciate that FSA is considering a variety of risk-based
criteria and that FSA needs to secure a statistician to assist with
developing its sampling approach. We continue to believe that focusing
on producers with risk-based characteristics, such those receiving large
payments, will strengthen FSA’s ability to target its spot checks towards
detecting potentially improper payments for CFAP. We will monitor FSA’s
implementation of all the recommendations, including its sampling
approach for additional CFAP spot checks.

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GAO-22-104397 Coronavirus Food Assistance Program


We are sending copies of this report to the appropriate congressional
committees, the Secretary of Agriculture, the Administrator of FSA, and
other interested parties. In addition, the report is available at no charge on
the GAO website at https://www.gao.gov.
If you or your staff have any questions about this report, please contact
me at (202) 512-3841 or morriss@gao.gov. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made key contributions to this report
are listed in appendix IV.

Steve D. Morris
Director, Natural Resources and Environment

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GAO-22-104397 Coronavirus Food Assistance Program


List of Committees
The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Kyrsten Sinema
Chair
The Honorable James Lankford
Ranking Member
Subcommittee on Government Operations and Border Management
Committee on Homeland Security and Governmental Affairs
United States Senate

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GAO-22-104397 Coronavirus Food Assistance Program


The Honorable Rosa L. DeLauro
Chair
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives
The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives
The Honorable Richard Neal
Chairman
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives

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GAO-22-104397 Coronavirus Food Assistance Program


Appendix I: Objectives, Scope, and
Methodology
Appendix I: Objectives, Scope, and
Methodology

This report examines (1) the Farm Service Agency’s (FSA) distribution of
Coronavirus Food Assistance Program (CFAP) payments by commodity
and type of producer, (2) the extent to which producers we selected for
review provided support for CFAP payments, and (3) the extent to which
FSA verified producers’ compliance with program rules. For all objectives,
we reviewed relevant statutes and regulations; FSA application forms,
handbooks, notices, and other documents, such as FSA’s CFAP
methodology reports; and relevant GAO and Congressional Research
Service reports.
To examine FSA’s distribution of CFAP payments by commodity and type
of producer, we analyzed FSA data from December 2021 on payments
and information on producers that received these payments, such as
entity types, income, and status as historically underserved. We
aggregated and analyzed data for payments and producers for CFAP 1,
CFAP 2, top-up payments, and payments to contract producers. 1
For the purposes of this report, we combined types of commodities
across CFAP 1 and CFAP 2 into the following reporting categories: (1)
dairy (cow milk); (2) field crops, which include flat-rate crops and pricetrigger crops; (3) livestock, which includes beef cattle, hogs, lambs, pigs,
and sheep; and (4) other commodities, which include, among other
things, broilers, eggs, eligible contract livestock or poultry, and salesbased commodities. 2
For our analysis of payments by type of producer, we tailored our analysis
in the following ways:
•

For payments to historically underserved producers, we analyzed FSA
data to determine the number of such producers that participated in
CFAP and their associated payments. Our analysis of historically
underserved producers focused on individual producers, including
those that are members of legal entities.

1According to an FSA CFAP handbook, a contract producer grows or produces an eligible

commodity under contract on behalf of another person or entity. A contract producer does
not own the commodity and is not entitled to a share from sales proceeds of the
commodity.

2See 7 C.F.R. §§ 9.2, 9.101, 9.201, and 9.203(g)(1).

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Appendix I: Objectives, Scope, and
Methodology

•

For our analysis of payments to high-income producers, we included
the number of producers and members of entities that qualified for
CFAP under the 75 percent rule and their associated payments. 3

We assessed the reliability of FSA’s data by (1) reviewing information
about the data and the systems that produced them; (2) reviewing
relevant FSA handbooks, such as FSA’s handbooks for CFAP and for
payment eligibility; (3) interviewing agency officials knowledgeable about
the data; and (4) conducting electronic tests for anomalies and missing
data. We determined that the data were sufficiently reliable for the
purpose of providing information on the distribution of payments by type
of producer; location; and agricultural commodity; as well as for selected
producers, such as those that received the largest payments.
To examine the extent to which producers we selected for review
provided support for CFAP payments, we reviewed CFAP applications
and documents related to eligibility, inventory, production, and sales,
among others, of 90 producers. We selected these 90 producers using
risk factors, such as the largest CFAP payments for commodities for
which FSA has not generally provided payments or other assistance
under programs reauthorized by the 2018 Farm Bill. Specifically, we
selected from among producers that received the highest payments for
dairy, cattle, other livestock (e.g., hogs and sheep), and “other
commodities.” 4 We made our selections in March of 2021 from producers
that received among the 100 largest payments for CFAP 1 and CFAP 2.
As of December 2021, when we received updated payment data from
FSA, all but one of the producers in our sample had received among the
100 largest payments for dairy, cattle, other livestock, and other
commodities for CFAP 1 or CFAP 2. For producers that received CFAP 1
payments, we prioritized those that had received payments for inventory
claims, which are less likely to have third-party-generated documents.
When selecting producers, we excluded producers that were under

3Producers with average adjusted gross income (AGI) of $900,000 and above calculated

over a specified 3-year period could qualify for CFAP payments based on certifications
that at least 75 percent of their income was derived from farming, ranching, or forestryrelated activities.

4Other commodities include aquaculture (e.g., food and ornamental fish), eggs, fruits,

nursery crops (e.g., container-grown plants), tobacco, tree nuts, vegetables, and wool.

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Appendix I: Objectives, Scope, and
Methodology

review by the U.S. Department of Agriculture (USDA) at the time of our
selection. 5
Our sample consisted of 41 producers that received the largest CFAP 1
payments for dairy, cattle, other livestock, and other commodities and 49
producers that received the largest CFAP 2 payments for these same
commodities as of March 2021, the latest available payment data that we
received from FSA when we selected the sample. 6 In cases where the
producers we selected received both CFAP 1 and CFAP 2 payments, we
reviewed both applications. In total, we reviewed 176 CFAP applications
because 86 of the 90 producers we reviewed received both CFAP 1 and
CFAP 2 payments. These applications represented a small fraction of the
number of CFAP applications that FSA approved. 7
We requested that FSA obtain and provide us with supporting documents
for each producer in our review as well as producers’ CFAP applications.
FSA also requested additional documents and clarifications from
producers on our behalf and, in some cases, producers provided
documents and information to us directly.
We interviewed relevant FSA state and county officials to obtain
additional information and to clarify our understanding of the information
that they provided. We also spoke with two producers, at their request, to
provide clarifications and to obtain additional information.
Two GAO analysts independently reviewed the producers’ claims and
reached consensus on whether the claims aligned with the support
provided by FSA and the producers. If we were uncertain about the
support but FSA state or county officials told us that they would find it
acceptable, we generally accepted it, in accordance with FSA’s CFAP

5At the time we selected our sample, there were three reviews of CFAP producers by

USDA agencies: Farm Production and Conservation Business Center (Business Center),
FSA, and the Office of Inspector General (OIG).

6We selected an additional producer that had received the highest payments for CFAP 2

as of March 2021, but we did not review this producer because FSA later determined that
the producer was ineligible, and the producer refunded the entire CFAP payment that it
had received.

7As of July 10, 2022, FSA had approved 646,826 CFAP 1 applications and 919,368 CFAP

2 applications.

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Appendix I: Objectives, Scope, and
Methodology

handbooks that state producers may provide other documents than those
specified, if the county committees determined them to be acceptable.
Because of resource constraints, we did not independently verify the
accuracy of evidence that the producers provided, by, for example,
requesting independent support from vendors or customers. In addition,
we were generally not able to confirm if producers’ production was
unpriced as of January 15, 2020, in accordance with CFAP 1
requirements, because the absence of a contract or another relevant
agreement is generally not documented. 8 Because of the limitations in our
review, we cannot provide assurance that the remaining 42 producers we
reviewed fully supported their claims and, therefore, that their payments
are proper.
To examine the extent to which FSA verified producers’ compliance with
CFAP requirements, we reviewed documents describing how FSA
selected samples of payments for its spot-check reviews and the
summary results. We also interviewed knowledgeable FSA officials and
received written responses regarding the methodology and results of the
agency’s compliance reviews. We interviewed officials from FSA’s
national office who oversaw the sample selection and spot checks. We
also interviewed a nongeneralizable sample of officials from five states
and a county in each of the five states that conducted these spot checks.
•

We selected five states that (1) had among the largest CFAP 1
payments, (2) identified large numbers of overpayments, and (3) were
geographically dispersed.

•

We selected a county in each of these five states that made payments
to producers of a variety of different commodity types. We included a
mix of counties that selected producers to be added to FSA’s spot
checks and those that did not select producers to be added to the
spot-check list.

We assessed the design of FSA’s methodology for selecting and
reviewing producers’ applications for its CFAP spot checks to determine
whether the methodology was consistent with the direction in the
agency’s handbook on integrity and accountability. The handbook directs
FSA to evaluate and validate program internal controls metrics, issue
clear policy, and ensure that state and county employees are accurately
8Sales receipts evidencing a sale after the specified date on which the production needed

to be unpriced could support the production being unpriced on the specified date. We did
not require producers to provide such support.

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Appendix I: Objectives, Scope, and
Methodology

interpreting FSA’s policies and internal control procedures. We
determined that the methodology was sufficiently sound for the purpose
of describing the methodology and the results of the spot checks in this
report.
In addition, we reviewed documents and interviewed officials from
USDA’s Business Center regarding their review of national random
samples of CFAP payments made in fiscal years 2020 and 2021. We did
not independently verify the Business Center’s results. However, we
assessed the design of the agency’s sampling and analytical
methodologies and determined that they were sufficiently sound for the
purpose of summarizing the Business Center’s results in this report. We
also reviewed documents and interviewed officials from OIG regarding
their ongoing review of a national random sample of CFAP 1 payments
and investigations of producers that had received CFAP payments.
We conducted this performance audit from August 2020 to September
2022 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.

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Appendix II: Additional Information on the
Distribution of Coronavirus Food Assistance
Program Payments
Appendix II: Additional Information on the
Distribution of Coronavirus Food Assistance
Program Payments

Under the U.S. Department of Agriculture’s Coronavirus Food Assistance
Program (CFAP), the Farm Service Agency (FSA) distributed
approximately $31 billion to 965,651 producers, with payments varying by
location and commodity type. As shown in table 7, the average CFAP
payment per producer that received CFAP funding directly was $32,074,
and the average payment per member—including individual producers
and producers that received CFAP payments as members of entities—
was $24,390.
Table 7: Distribution of CFAP Payments by State, and Average Payments per Producer and Member
The average payments per member ranged from $48,049 in California to $9,381 in West Virginia.a

Share of total
Share of total
number of
number of
producers Number of
members
(percentage) members (percentage)

Average
payment
per
producer
(dollars)

Average
payment per
member
(dollars)

CFAP
payments
(dollars)

Percentage
of total
payments

Number of
producers

CA

2,199,839,040

7.1

22,535

2.3

45,783

3.6

97,619

48,049

ND

1,176,034,265

3.8

22,235

2.3

25,206

2.0

52,891

46,657

ID

586,956,741

1.9

9,171

1.0

13,742

1.1

64,001

42,713

NY

495,982,771

1.6

8,354

0.9

12,154

1.0

59,371

40,808

NJ

69,771,287

0.2

1,169

0.1

1,738

0.1

59,685

40,145

MN

1,826,443,904

5.9

39,912

4.1

48,063

3.8

45,762

38,001

CT

29,719,126

0.1

474

0.1

790

0.1

62,699

37,619

NV

56,735,785

0.2

976

0.1

1,541

0.1

58,131

36,818

WI

1,217,170,565

3.9

26,399

2.7

33,369

2.6

46,107

36,476

NM

236,382,143

0.8

4,958

0.5

6,786

0.5

47,677

34,834

SD

1,374,496,074

4.4

27,099

2.8

40,058

3.2

50,721

34,313

FL

462,903,870

1.5

8,436

0.9

13,606

1.1

54,872

34,022

ME

60,257,820

0.2

1,300

0.1

1,788

0.1

46,352

33,701

VT

79,702,024

0.3

1,663

0.2

2,399

0.2

47,927

33,223

MI

666,204,586

2.2

16,729

1.7

21,115

1.7

39,823

31,551

NE

2,021,330,214

6.5

49,098

5.1

65,237

5.1

41,169

30,984

IA

2,679,629,625

8.7

65,089

6.7

87,316

6.9

41,169

30,689

PA

406,283,302

1.3

10,599

1.1

13,717

1.1

38,332

29,619

CO

512,777,465

1.7

11,814

1.2

17,482

1.4

43,404

29,332

AZ

153,838,391

0.5

3,272

0.3

5,257

0.4

47,017

29,264

OR

353,164,593

1.1

7,594

0.8

12,095

1.0

46,506

29,199

UT

161,409,568

0.5

4,323

0.5

5,951

0.5

37,337

27,123

WY

187,215,573

0.6

4,838

0.5

7,145

0.6

38,697

26,202

State

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Appendix II: Additional Information on the
Distribution of Coronavirus Food Assistance
Program Payments

Share of total
Share of total
number of
number of
producers Number of
members
(percentage) members (percentage)

State

CFAP
payments
(dollars)

Percentage
of total
payments

Number of
producers

DE

30,156,285

0.1

759

0.1

HI

41,693,939

0.1

1,289

NC

425,767,214

1.4

14,461

GA

419,353,910

1.4

MT

656,376,857

MD

97,668,114

WA
SC
NH

Average
payment
per
producer
(dollars)

Average
payment per
member
(dollars)

1,162

0.1

39,732

25,952

0.1

1,648

0.1

32,346

25,300

1.5

17,032

1.3

29,442

24,998

14,147

1.5

16,915

1.3

29,643

24,792

2.1

15,356

1.6

27,795

2.2

42,744

23,615

0.3

3,052

0.3

4,250

0.3

32,001

22,981

523,407,144

1.7

11,023

1.1

23,047

1.8

47,483

22,710

117,381,961

0.4

4,727

0.5

5,504

0.4

24,832

21,327

12,172,602

0.0

420

0.0

621

0.1

28,982

19,602

OK

869,820,524

2.8

40,414

4.2

45,052

3.6

21,523

19,307

KS

1,620,758,474

5.2

64,677

6.7

84,331

6.7

25,059

19,219

TX

1,796,284,941

5.8

74,930

7.8

96,352

7.6

23,973

18,643

IN

914,008,850

3.0

37,063

3.8

49,163

3.9

24,661

18,591

VA

276,500,982

0.9

13,272

1.4

15,442

1.2

20,833

17,906

IL

1,736,992,582

5.6

75,646

7.8

99,413

7.8

22,962

17,472

OH

757,365,571

2.5

34,894

3.6

43,543

3.4

21,705

17,394

MA

39,635,475

0.1

1,646

0.2

2,334

0.2

24,080

16,982

MS

327,960,549

1.1

14,927

1.6

20,073

1.6

21,971

16,338

LA

287,114,838

0.9

12,922

1.3

17,636

1.4

22,219

16,280

RI

5,141,137

0.0

225

0.0

338

0.0

22,849

15,210

MO

1,069,606,959

3.5

58,653

6.1

71,061

5.6

18,236

15,052

AL

249,815,116

0.8

15,958

1.7

17,908

1.4

15,655

13,950

KY

502,324,322

1.6

34,487

3.6

37,838

3.0

14,566

13,276

AR

477,286,438

1.5

28,391

2.9

39,348

3.1

16,811

12,130

TN

381,199,195

1.2

30,206

3.1

32,751

2.6

12,620

11,639

AK

1,786,444

0.0

138

0.0

184

0.0

12,945

9,709

WV

56,099,509

0.2

5,690

0.6

5,980

0.5

9,859

9,381

30,707,928,662

100.0

957,410

100.0

1,259,059

100.0

32,074

24,390

Totalb

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

Notes: Coronavirus Food Assistance Program (CFAP) payments include all payments that FSA made
as of December 2021, including for CFAP 1 and CFAP 2.
We included individual producers in both the producers and members columns, so the number of
producers cannot be added across these columns.
a
The variation in payments from state to state is a result of the types and quantities of commodities
produced in each state and the CFAP payment rates for those types of commodities.

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Appendix II: Additional Information on the
Distribution of Coronavirus Food Assistance
Program Payments

b
In addition, FSA made CFAP payments totaling $100,660,060 to producers in U.S. territories. FSA
also made CFAP payments of $160,996,299 to producers for which there were missing or invalid
state codes. There were a total of 8,241 producers in these categories.

The average CFAP payment per producer ranged by county from over
$300,000 to less than $500. We found that 70 counties had average
payments of more than $100,000 per producer (see fig. 4).
Figure 4: Average CFAP Payments per Producer in the Contiguous U.S.

Note: Average Coronavirus Food Assistance Program (CFAP) payments include all payments that
FSA made as of December 2021, including for CFAP 1 and CFAP 2.

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Appendix II: Additional Information on the
Distribution of Coronavirus Food Assistance
Program Payments

Total CFAP payments per county ranged from over $325 million to less
than $1,000. We found that 30 counties had payments totaling over
$50,000,000 per county (see fig. 5).
Figure 5: Total CFAP Payments per County in the Contiguous U.S.

Note: Total Coronavirus Food Assistance Program (CFAP) payments include all payments that FSA
made as of December 2021, including for CFAP 1 and CFAP 2.

CFAP payments for field crops were about $13.8 billion, or about 45
percent of all CFAP payments, with producers in Iowa, Nebraska, Illinois,
Minnesota, and Kansas receiving the highest total payments. CFAP
payments for livestock were about $9.8 billion (about 32 percent), with
producers in Texas, Iowa, Nebraska, Kansas, and South Dakota
receiving the highest total payments. CFAP payments for dairy were

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Appendix II: Additional Information on the
Distribution of Coronavirus Food Assistance
Program Payments

about $3.0 billion (about 10 percent), with producers in Wisconsin,
California, New York, Minnesota, and Pennsylvania receiving the highest
total payments. CFAP payments for other commodities were about $4.4
billion (about 14 percent), with producers in California, Florida,
Washington, Idaho, and Oregon receiving the highest total payments.
Taking into account all commodities, producers in Iowa, California,
Nebraska, Minnesota, and Texas received the highest total CFAP
payments—about $10.5 billion, or 34 percent of all the payments.
Table 8 shows CFAP payments by state and type of agricultural
commodity.

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Appendix II: Additional Information on the Distribution of Coronavirus
Food Assistance Program Payments

Table 8: Distribution of CFAP Payments, by State and Type of Agricultural Commodity
FSA distributed $13.8 billion for field crops, $9.8 billion for livestock, $3.0 billion for dairy, and $4.4 billion for other commodities, with producers in Iowa, California, Nebraska, Minnesota, and Texas
receiving the highest total payments.

Dairy
State

Field crops

Livestock

Other commodities

Total

Dollars

Percentage

Dollars

Percentage

Dollars

Percentage

Dollars

Percentage

Dollars

Percentage

IA

89,285,173

2.9

1,652,754,340

12.0

914,815,212

9.4

22,774,900

0.5

2,679,629,625

8.7

CA

507,715,828

16.7

73,480,110

0.5

201,682,584

2.1

1,416,960,518

32.5

2,199,839,040

7.1

NE

18,683,698

0.6

1,165,984,899

8.5

822,072,111

8.4

14,589,506

0.3

2,021,330,214

6.5

MN

176,496,569

5.8

1,098,777,041

8.0

487,055,693

5.0

64,114,602

1.5

1,826,443,904

5.9

TX

102,967,664

3.4

666,829,091

4.8

942,609,513

9.7

83,878,673

1.9

1,796,284,941

5.8

IL

38,579,304

1.3

1,425,549,045

10.3

257,669,830

2.6

15,194,402

0.4

1,736,992,582

5.6

KS

23,015,040

0.8

936,667,559

6.8

653,739,145

6.7

7,336,730

0.2

1,620,758,474

5.2

SD

30,421,741

1.0

673,871,427

4.9

651,980,904

6.7

18,222,003

0.4

1,374,496,074

4.4

WI

564,917,732

18.6

419,279,650

3.0

168,869,425

1.7

64,103,758

1.5

1,217,170,565

3.9

ND

7,051,789

0.2

822,646,337

6.0

276,158,997

2.8

70,177,143

1.6

1,176,034,265

3.8

MO

16,033,508

0.5

529,397,104

3.8

508,130,197

5.2

16,046,151

0.4

1,069,606,959

3.5

IN

41,565,519

1.4

694,591,193

5.0

151,948,313

1.6

25,903,824

0.6

914,008,850

3.0

OK

5,223,682

0.2

211,617,945

1.5

636,759,763

6.5

16,219,134

0.4

869,820,524

2.8

OH

87,321,037

2.9

488,253,221

3.5

144,872,545

1.5

36,918,768

0.9

757,365,571

2.5

MI

160,671,931

5.3

272,273,834

2.0

91,927,578

0.9

141,331,243

3.2

666,204,586

2.2

MT

5,883,465

0.2

284,201,544

2.1

339,251,601

3.5

27,040,248

0.6

656,376,857

2.1

ID

133,834,385

4.4

127,808,659

0.9

160,388,578

1.6

164,925,119

3.8

586,956,741

1.9

WA

86,218,837

2.8

121,048,742

0.9

50,031,795

0.5

266,107,771

6.1

523,407,144

1.7

CO

49,728,992

1.6

189,443,227

1.4

223,957,286

2.3

49,647,960

1.1

512,777,465

1.7

KY

17,857,878

0.6

207,196,796

1.5

238,526,569

2.4

38,743,079

0.9

502,324,322

1.6

NY

278,871,595

9.2

89,775,288

0.7

34,094,283

0.4

93,241,605

2.1

495,982,771

1.6

AR

1,551,947

0.1

255,062,416

1.9

189,617,821

1.9

31,054,253

0.7

477,286,438

1.5

FL

24,689,562

0.8

17,496,221

0.1

104,250,136

1.1

316,467,951

7.3

462,903,870

1.5

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Appendix II: Additional Information on the Distribution of Coronavirus
Food Assistance Program Payments

Dairy
State

Field crops

Livestock

Other commodities

Total

Dollars

Percentage

Dollars

Percentage

Dollars

Percentage

Dollars

Percentage

Dollars

Percentage

17,813,253

0.6

172,712,427

1.3

84,346,838

0.9

150,894,696

3.5

425,767,214

1.4

GA

23,052,746

0.8

170,150,830

1.2

107,539,264

1.1

118,611,070

2.7

419,353,910

1.4

PA

170,608,156

5.6

104,015,817

0.8

61,820,435

0.6

69,838,894

1.6

406,283,302

1.3

TN

12,686,916

0.4

160,784,048

1.2

166,708,323

1.7

41,019,908

0.9

381,199,195

1.2

OR

36,807,283

1.2

44,772,230

0.3

111,276,653

1.1

160,308,427

3.7

353,164,593

1.1

MS

3,368,066

0.1

186,553,157

1.4

101,564,023

1.0

36,475,303

0.8

327,960,549

1.1

LA

3,430,409

0.1

119,969,644

0.9

58,856,331

0.6

104,858,454

2.4

287,114,838

0.9

VA

29,359,512

1.0

68,790,105

0.5

125,886,524

1.3

52,464,840

1.2

276,500,982

0.9

AL

1,241,285

0.0

81,524,377

0.6

130,065,853

1.3

36,983,602

0.9

249,815,116

0.8

NM

72,243,491

2.4

23,475,186

0.2

114,374,643

1.2

26,288,823

0.6

236,382,143

0.8

WY

2,097,205

0.1

23,474,555

0.2

158,491,485

1.6

3,152,329

0.1

187,215,573

0.6

UT

33,785,280

1.1

22,501,648

0.2

90,648,250

0.9

14,474,390

0.3

161,409,568

0.5

AZ

31,279,646

1.0

31,863,221

0.2

46,473,646

0.5

44,221,878

1.0

153,838,391

0.5

SC

4,689,339

0.2

55,732,980

0.4

29,735,111

0.3

27,224,530

0.6

117,381,961

0.4

MD

17,051,102

0.6

56,293,567

0.4

7,555,370

0.1

16,768,075

0.4

97,668,114

0.3

VT

57,682,035

1.9

5,807,365

0.0

4,318,573

0.0

11,894,051

0.3

79,702,024

0.3

NJ

2,162,326

0.1

9,676,087

0.1

1,821,191

0.0

56,111,683

1.3

69,771,287

0.2

ME

13,902,738

0.5

3,346,329

0.0

2,833,796

0.0

40,174,958

0.9

60,257,820

0.2

NV

9,094,940

0.3

7,371,854

0.1

37,805,905

0.4

2,463,086

0.1

56,735,785

0.2

WV

1,478,260

0.1

4,561,583

0.0

38,874,001

0.4

11,185,665

0.3

56,099,509

0.2

HI

160,922

0.0

1,047

0.0

9,642,620

0.1

31,889,350

0.7

41,693,939

0.1

MA

4,867,759

0.2

1,125,055

0.0

3,002,154

0.0

30,640,507

0.7

39,635,475

0.1

DE

1,521,714

0.1

18,783,894

0.1

516,321

0.0

9,334,356

0.2

30,156,285

0.1

CT

9,948,720

0.3

1,605,264

0.0

1,026,667

0.0

17,138,475

0.4

29,719,126

0.1

NH

5,738,474

0.2

812,798

0.0

1,182,871

0.0

4,438,459

0.1

12,172,602

0.0

NC

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GAO-22-104397 Coronavirus Food Assistance Program


Appendix II: Additional Information on the Distribution of Coronavirus
Food Assistance Program Payments

Dairy

Field crops

Livestock

Other commodities

Total

State

Dollars

Percentage

Dollars

Percentage

Dollars

Percentage

Dollars

Percentage

Dollars

Percentage

RI

167,476

0.0

63,440

0.0

224,394

0.0

4,685,826

0.1

5,141,137

0.0

AK
Totala

41,148

0.0

298,235

0.0

497,452

0.0

949,609

0.0

1,786,444

0.0

3,034,867,076

100.0

13,800,072,428

100.0

9,747,498,574

100.0

4,125,490,584

99.9

30,707,928,662

100.0

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

Notes: Coronavirus Food Assistance Program (CFAP) payments include all payments that FSA made as of December 2021,
including for CFAP 1 and CFAP 2.
For the purposes of this report, types of agricultural commodities include (1) dairy; (2) field crops, which are alfalfa, amaranth
grain, barley, buckwheat, canola, corn, cotton, crambe, einkorn, emmer, flax, guar, hemp, indigo, kenaf, khorasan, millet,
mustard, oats, peanuts, quinoa, rapeseed, rice, rye, safflower, sesame, sorghum, soybeans, spelt, sugar beets, sugarcane,
sunflowers, teff, triticale, and wheat; (3) livestock, which includes cattle, hogs, pigs, and sheep; and (4) other commodities,
which include aquaculture (e.g., food and ornamental fish), eggs, fruits, nursery crops (e.g., container-grown plants), tobacco,
tree nuts, vegetables, and wool.
a
In addition, FSA made CFAP payments to producers in U.S. territories totaling $100,660,060. FSA also made CFAP payments
of $160,996,299 to producers for which there were missing or invalid state codes. Total does not always equal 100 percent
because of rounding.

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GAO-22-104397 Coronavirus Food Assistance Program


Appendix II: Additional Information on the
Distribution of Coronavirus Food Assistance
Program Payments

The 25 producers with the highest CFAP payments received a total of
about $74.1 million (0.2 percent of total CFAP payments). As shown in
table 9 below, most of these 25 producers operate as general
partnerships, and about half of their payments were for livestock.
Table 9: Producers That Received the Top 25 CFAP Payments
These producers received the highest CFAP payments; the average payment for all producers was $32,071.

CFAP payments by type of agricultural commodityb (dollars)

Producer

U.S. Census
Bureau
regiona

Type of entity

1

West

2

Midwest

3

Dairy

Field crops

Livestock

Other
commodities

Total
(dollars)

Joint venture

0

0

6,758,056

0

6,758,056

General
partnership

0

0

6,530,823

0

6,530,823

West

General
partnership

0

45,642

0

3,930,581

3,976,223

4

South

General
partnership

1,975,876

1,434,139

252,936

275,844

3,938,795

5

Midwest

General
partnership

0

0

3,152,083

0

3,152,083

6

Midwest

General
partnership

0

333,393

2,762,536

44,232

3,140,162

7

West

General
partnership

0

48,871

104,217

2,846,912

3,000,000

8

Midwest

General
partnership

0

514,875

2,340,281

0

2,855,156

9

West

General
partnership

0

165,881

0

2,679,483

2,845,364

10

Midwest

General
partnership

0

347,137

2,204,596

137,040

2,688,772

11

Midwest

General
partnership

0

104,495

2,477,187

0

2,581,682

12

West

Indian tribal
venturec

0

2,003,915

0

566,650

2,570,565

13

West

General
partnership

0

24,032

0

2,527,722

2,551,754

14

South

General
partnership

0

1,519,031

953,199

63,041

2,535,271

15

South

General
partnership

0

2,377,721

150,341

0

2,528,062

16

West

General
partnership

0

35,297

0

2,464,703

2,500,000

17

West

General
partnership

1,647,441

105,532

30,256

707,248

2,490,478

Page 50

GAO-22-104397 Coronavirus Food Assistance Program


Appendix II: Additional Information on the
Distribution of Coronavirus Food Assistance
Program Payments

Producer

U.S. Census
Bureau
regiona

18

Midwest

19

CFAP payments by type of agricultural commodityb (dollars)
Dairy

Field crops

Livestock

Other
commodities

Total
(dollars)

General
partnership

0

0

2,306,909

0

2,306,909

Midwest

General
partnership

0

0

2,292,583

0

2,292,583

20

Midwest

General
partnership

0

2,183,893

0

59,797

2,243,690

21

South

General
partnership

0

849,830

0

1,351,170

2,201,000

22

West

General
partnership

2,148,174

22,225

0

0

2,170,399

23

Midwest

General
partnership

0

192,679

1,924,455

0

2,117,134

24

South

General
partnership

0

0

2,098,801

0

2,098,801

25

West

General
partnership

0

180

0

2,068,217

2,068,397

Total

—

—

5,771,491

12,308,769

36,339,259

19,722,640

74,142,160

Type of entity

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

Notes: Coronavirus Food Assistance Program (CFAP) payments include all payments that FSA made
as of December 2021, including for CFAP 1 and CFAP 2.
We analyzed FSA data to identify the 25 producers that received the highest CFAP payments.
To preserve producers’ confidentiality, we provide the U.S. Census Bureau region where each
producer is located to provide a general, rather than a specific, location (e.g., state or county).
a
The U.S. Census Bureau divides the 50 states among four regions—Northeast, South, Midwest, and
West. None of the 25 producers that received the highest payments were in the Northeast. The South
includes Alabama, Arkansas, Delaware, District of Columbia, Florida, Georgia, Kentucky, Louisiana,
Maryland, Mississippi, North Carolina, Oklahoma, South Carolina, Tennessee, Texas, Virginia, and
West Virginia. The Midwest includes Illinois, Indiana, Iowa, Kansas, Michigan, Minnesota, Missouri,
Nebraska, North Dakota, Ohio, South Dakota, and Wisconsin. The West includes Alaska, Arizona,
California, Colorado, Hawaii, Idaho, Nevada, New Mexico, Montana, Oregon, Utah, Washington, and
Wyoming.
b
For the purposes of this report, types of agricultural commodities include (1) dairy; (2) field crops,
which are alfalfa, amaranth grain, barley, buckwheat, canola, corn, cotton, crambe, einkorn, emmer,
flax, guar, hemp, indigo, kenaf, khorasan, millet, mustard, oats, peanuts, quinoa, rapeseed, rice, rye,
safflower, sesame, sorghum, soybeans, spelt, sugar beets, sugarcane, sunflowers, teff, triticale, and
wheat; (3) livestock, which includes cattle, hogs, pigs, and sheep; and (4) other commodities, which
include aquaculture (e.g., food and ornamental fish), eggs, fruits, nursery crops (e.g., container-grown
plants), tobacco, tree nuts, vegetables, and wool.
c
”Indian tribal ventures” is the business type that FSA uses to identify Indian tribes and tribal ventures.
According to an FSA handbook, payments made to Indian tribal ventures are not subject to payment
limits.

Page 51

GAO-22-104397 Coronavirus Food Assistance Program


Appendix III: Comments from the U.S.
Department of Agriculture
Appendix III: Comments from the U.S.
Department of Agriculture

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GAO-22-104397 Coronavirus Food Assistance Program


Appendix III: Comments from the U.S.
Department of Agriculture

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GAO-22-104397 Coronavirus Food Assistance Program


Appendix III: Comments from the U.S.
Department of Agriculture

Page 54

GAO-22-104397 Coronavirus Food Assistance Program


Appendix III: Comments from the U.S.
Department of Agriculture

Page 55

GAO-22-104397 Coronavirus Food Assistance Program


Appendix III: Comments from the U.S.
Department of Agriculture

Page 56

GAO-22-104397 Coronavirus Food Assistance Program


Appendix IV: GAO Contact and Staff
Acknowledgments
Appendix IV: GAO Contact and Staff
Acknowledgments

GAO Contact

Steve D. Morris at (202) 512-3841 or morriss@gao.gov

Staff
Acknowledgments

In addition to the contact named above, Thomas M. Cook (Assistant
Director), Ruth Solomon (Analyst-in-Charge), Rose Almoguera, Adrian
Apodaca, Howard Arp, Xiang Bi, Carolyn Blocker, Kevin S. Bray, Gary
Brown, Sara Daleski, Cindy Gilbert, Jill Lacey, Joe Maher, John Mingus,
Cynthia Norris, Isabel Rosa, Robert Sanchez, Rebecca Shea, Maria
Stattel, Tom Short, Lisa Vojta, and Khristi Wilkins also made important
contributions to this report.

(104397)

Page 57

GAO-22-104397 Coronavirus Food Assistance Program


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