Outdated Information Could Jeopardize Your Eligibility for FSA Programs

Key Takeaways
  • Keeping your Form CCC-902 current is essential to maintaining eligibility for FSA and NRCS programs that support your farm operation.
  • Even routine changes in ownership, structure, or management can impact payment eligibility and should be updated promptly to avoid penalties or loss of benefits.
  • An annual review, ideally ahead of the new crop year, helps ensure your farm operations and USDA records stay aligned, reducing compliance risk and audit exposure.

 

Farmers who participate in programs administered by the USDA Farm Service Agency (FSA) are familiar with Form CCC-902, Farm Operating Plan, which provides information that the FSA uses to determine eligibility for participating in USDA programs.

Form CCC-902-I, for farmers who are farming individually, and CCC-902-E, for producers who operate in a legal entity, establish payment eligibility, payment limitation and actively engaged in farming status.

Though the 902 forms are officially designated with the Commodity Credit Corporation — CCC — initials, they are commonly known in the agricultural community as FSA 902 because of their importance to FSA programs. They also are used to determine eligibility for programs under the Natural Resources Conservation Service.

Review Your Form CCC-902 Annually

While there is no specific deadline for filing the annual Form CCC-902, the information contained on the form is essential to determining eligibility for a host of FSA programs, so timeliness and accuracy are important.

It’s a good idea to review your Form CCC-902 at least once a year to make sure the information on it is still correct. Perhaps you acquired some land in the past year, or brought one of your children into the farm operation with you. These are among the changes that must be updated on your Form CCC-902.

An outdated Form CCC-902 can result in significant consequences, including loss of benefits and financial penalties. The FSA, on an annual basis, selects a random sample of 902 forms for audit. If an audit determines that a Form CCC-902 is inaccurate, the farmer may be barred from future program participation.

Since the FSA crop year extends from June 1 to May 31, late April would be a good time to review your Form CCC-902 and make any updates necessary to reflect the anticipated status of your farm operations in the 2026 crop year. Your farm operations and the information in your Form CCC-902 must be aligned at all times.

How to Update Your Form CCC-902

To make updates, request a copy of the current CCC-902 Farm Operating Plan from your local FSA office. You may work with the FSA office to make necessary changes, or you can contact your Adams Brown agriculture advisor for help.

What Changes Must Be Reported?

Under USDA regulations, a producer must update the Form CCC-902 when any change occurs that could affect payment eligibility, attribution, or limitation determinations, including:

  • Changes in farm operating structure, such as the creation of a new legal entity or joint operation, dissolution of an existing operation, conversion of an entity type (i.e., individual to LLC, or trust formation), or a merger, division or reorganization of farming entities.
  • Changes in ownership, such as addition or removal of partners, members, shareholders, beneficiaries, or joint operators; change in ownership percentages or profit-and-loss sharing arrangements; or death, incapacitation of succession of an owner or member.
  • Changes in capital, equipment, land, labor, or management contributions, such as capital or financing, equipment or machinery, land or lease arrangements, labor or personnel management changes during the applicable program year.
  • Changes affecting “Actively Engaged in Farming” status, such as reduction or cessation of labor or management contributions, changes in who provides day-to-day management, or shifts from active involvement to passive ownership arrangements.
  • Changes in tax identification status, such as a change in Tax Identification Number (TIN), assignment of benefits to a different entity or successor entity, or correction of previously reported taxpayer information.
  • Notification of interests and attribution changes, meaning producers must update their Form 902 when they acquire or dispose of an interest in another farming operation subject to Part 1400 attribution rules.
  • Program participation or new program application, meaning the Form 902 must be updated when applying for a USDA program subject to Part 1400 for the first time; when enrolling in additional programs during an existing year; or participation in NRCS programs where CCC-902 is required for payment eligibility.

In summary, USDA regulations require producers to update the Form 902 Farm Operating Plan whenever changes occur that affect ownership, structure, equipment, land, capital, labor &/or management contributions. Timely updates protect both the producer and the agency by ensuring accurate payment eligibility determinations and compliance with federal law.

Questions?

If you would like assistance with updating your Form CCC-902, contact an Adams Brown farm accountant.