Conservation Security Program: Despite Cost Controls, Improved USDA Management Is Needed to Ensure Proper Payments and Reduce Duplication with Other Programs

According to Natural Resources Conservation Service (NRCS) officials, the agency directed its state offices to submit a copy of their wildlife habitat assessment criteria for all proposed Conservation Security Program (CSP) watersheds. These criteria were examined for consistency with NRCS's national CSP guidance [i.e., minimum national eligibility criteria for wildlife habitat] by the Deputy Chief for Science and Technology's National Biology Team in Ft. Worth, Texas. Discrepancies with the national guidance were resolved in cooperation with the relevant NRCS State Conservationists.

According to Natural Resources Conservation Service (NRCS) officials, the agency updated the "CSP manual" [i.e., the Conservation Security Program (CSP) section of the Conservation Programs Manual] to be in compliance with the direction provided by the NRCS Chief. Specifically, Exhibit 518.155, a Technical Reference Document describing the agency's wildlife habitat assessment criteria, was added to section 440 of the Conservation Programs Manual. Among other things, this document outlines the procedure to be used to determine the minimum eligibility criteria for fish and wildlife resources on CSP-enrolled land, as well the minimum criteria for "models for species of conservation concern" that represent habitats in a significant state of decline.

According to the Natural Resources Conservation Service (NRCS), it initiated a certification form (addendum) in the self assessment workbook for Conservation Security Program (CSP) sign-ups. This addendum informs an applicant that the Farm Bill prohibits duplicate payments made through CSP and another program on the same land, at the same time, for a similar conservation activity. In part, the addendum asks applicants to certify whether or not they are receiving payments from another conservation program on any of the land being offered for enrollment in CSP, and if so, to provide information on the sources and purposes of these payments. The addendum was issued to all NRCS state offices in National Bulletin 300-6-36. In addition, NRCS revised the CCC-1200 contract appendix (an applicant enters into a contract with NRCS to enroll land in CSP) to include a statement about prohibitions on duplicate payments. Subsequently, according to NRCS, it created an automated system with its ProTracts contracting software to compare existing Wildlife Habitat Incentives Program, Agricultural Management Assistance, and Environmental Quality Incentives Program (EQIP) contracts with new CSP applications to identify potential areas of overlapping practices. Using this system, NRCS officials indicated in March 2009 that they identified nearly 400 scheduled payments totaling more than $500,000 under CSP and EQIP that would have been duplicates. NRCS was able to preclude these payments from being made.

According to the Natural Resources Conservation Service (NRCS), it created an automated system within its ProTracts contracting software to compare existing Wildlife Habitat Incentives Program, Agricultural Management Assessment, and Environmental Quality Incentives Program (EQIP) contracts with existing CSP contracts to reveal potential areas of overlapping conservation practices and payments. Using this system, NRCS officials indicated in March 2009 that they had identified more the 370 duplicate payments between CSP and EQIP totaling about $420,000. NRCS indicated that these cases of duplication were dealt with according to the NRCS contracting manual, although the agency did not identify the amount of duplicate payments recovered. In addition to creating this automated system, NRCS issued National Bulletin 300-7-1, Conservation Security Program (CSP) Potential Duplicative Payments, to enlist the assistance of its state offices to identify potential or actual duplicate payments between CSP and other programs, and to take action to modify contracts to preclude duplicate payments or recover duplicate payments already made. The bulletin notes that despite statutory provisions and previous NRCS actions to prevent CSP from duplicating other programs, GAO found that the potential for duplicate payments still exists and such payments have occurred. Among other things, the bulletin directs the state offices to compare conservation activities under CSP contracts with those under contracts related to other programs to determine whether duplicate payments are planned or have occurred. The bulletin also provides guidance on recognizing situations that constitute duplication, including examples of conservation activities under CSP and another program that would or would not be considered the same. In addition, the bulletin requires each state office to complete a Potential Duplicate Report and submit it to the Director of NRCS's Financial Assistance Programs Division.