The following are the comments the NACS Board sent to FSA on the proposed CBS structure.
NACS FSA CBS Structure Comments
The National Association of Credit Specialist of FSA has founding principles based upon service to rural America being our number one priority. NACS supports the modernization of FSA delivery systems;however, maintaining and strengthening the current elements of the Farm Loan Programs model that are resulting in quality loans and expansion of opportunities is essential.
Farm Loan Programs has been delivered using a similar structure of Type 1, 2 and 3 offices and offering FLP programs to multiple counties from a Central office location using a team of Farm Loan Program employees (FLM/SFLO, FLO, LA and FLP PT)
Most states have recently reevaluated their delivery of FLP in Type 1,2 and 3 offices based on current workload and the location of Type 1FLP offices should be considered when states are choosing locations of Central offices.
It should be recognized as the demand for Farm Loans provided by FSA is projected to increase given the increased funding and the continued decline in available credit from commercial lenders
In consideration of these factors, NACS would encourage the following in a Modernization plan for FSA:
1. Management of the Farm Loan Program and Loan Approvals should be done by GS employees hired under the federal employee system with farm loans being their area of specialty and full time responsibility.
2. Delivery of Farm Loan Programs in field offices should be done through Credit Teams managed by a Farm Loan Manger.
3. Placement of Farm Loan Teams in Central offices has to be based upon the existing workload in the area served by the Central office. The result may be not all central offices will have a farm loan team. NACS does not support staffing all Central offices with a FLP team. Workload does not support it and current staffing numbers would not allow it. The goal of the agency has to be to do the best job possible of not reducing service to an area but to have a plan in place that allows for increased service if an area shows a need for more service.
4. The CBS structure will result in a reduced foot print of FSA in rural areas. The result is that FLP delivery needs increased resources so that more can be accomplished remotely, ie mobile connectivity.
5. All current employees of FSA should be given the opportunity to compete for Farm Loan vacancies under the GS system, allowing pay retention while completing the Farm Loan Training program.
6. All FSA offices under the CBS structure should offer a minimum level of service to include release of normal income security, receiving loan payments, and providing application information. The services can be provided by GS and/or CO employees.
7. States should include state employee associations when developing state plans.
8. As states prepare their plans, they need to minimize the disruption of borrower/ loan officer relationships. When a loan is made to a customer, it becomes a long term relationship.
The National Association of Credit Specialists appreciates the opportunity to provide input on the proposed modernization of FSA via field realignment (CBS) and hopes that you will contact our Association for clarification and additional input.
Allen D. Hall
The images we old steadfastly in our minds over the years are not illusions; they are the patterns by which we are able to mold our own destinies. - Nathaniel Hawthorne
NACS Board Going to DC
I am please to announce that the NACS Board will be at the National Office on April 15th and 16th for a consultative meeting. The National Office has agreed to allow us to make the trip on government travel which we are very appreciative of.
We have meetings scheduled with Administrator, Juan Garcia; Associate Administrator Candy Thompson; DAFO, Greg Diephouse and staff; DAFLP, Chris Beyerhelm and staff; DAFP, Mike Schmidt; ACIO, Loretta Burns; DAM, Mark Rucker; and OBF, Bruce Ward.
The main topic of discussion will be the proposed CBS office structure and how loan programs will be delivered and serviced from this office structure.
Chris Beyerhelm, DAFLP has been telling us that we are going to have more loan funds in the coming year and the question is how are we going to be staffed to deliver and service the growing program.
The board needs to hear from the membership about what is working well under the current structure and what areas could be improved upon going forward. You can send emails to the board through the NACS website. The website emails go to our personal email addresses so we are able to receive them when we do not have access to our government email.
I hope every state is making plans to send delegates to National Convention in Chicago June 28th through July 2nd, 2014. It would be tremendous to have 100% of state associations represented.
Have an Unbelievable Day
Allen D. Hall
Before you can inspire with emotion, you must be swamped with it yourself. Before you can move their tears, your own must flow. To convince them, you must yourself believe. - Winston Churchill
Model Service Delivery
On Monday FSA Administrator Juan Garcia and DAFO, Greg Diephouse held a conference call with all employee association presidents and union contacts. The purpose of the call was to inform us of the Model Service Delivery (MSD) Concept. The implementation of MSD is the plan to implement Secretary Vilsack's vision of FSA offices being a resource for rural America. In a presentation to a senate subcommittee (see NACS Legislative Update) Vilsack talked about the possible closing of 250 offices nationwide.
During the call Greg Diephouse told us that agency staffing is down 20% (3000 FTE) since 2010. MSD has defined 4 ways that the agency feels will help it provide service to rural America with the reduced resources.
The meaning of the term fully staffed was not defined during the call but it does include a supervisor.
B - Branch offices will have assigned full time staff but no supervisor.
S - Satellite offices will have no full time staff and will serve as a location to meet with customers by appointment.
3. Office Consolidation which is the possible closing of the 250 offices. It was stated that no offices would be closed in 2014. Data from 2014 will be used to help determine where offices should be located and which offices should be closed. The 2008 guidelines for office closing are still applicable.
4. Modernize Mission and be a bridge to other services.
Juan Garcia emphasized the he wanted the agency to accomplish the following in the process.
Maintain a high level of customer service.
Maintain employment job security.
Provide employee training.
Maintain fiscal responsibility.
Juan and Greg asked that the association provide comments on the proposals by April 21.
I realize that the above information does not give you many answers and creates more questions. It is my understanding of the information presented. The NACS Board ask that you provide us with your comments and concerns as soon as possible.
Have an Unbelievable Day
Allen D. Hall
Any man can shoot a gun, and with practice he can draw fast and shoot accurately, but that makes no difference. What counts is how you stand up when somebody is shooting back at you. - Louis L'Amour
Denise is a Farm Loan Manager from Nebraska. She was elected NACS President at the June 2018 Convention.