Why CPA's Should Not Sign USDA Certification
We review the reasons why CPAs typically do not sign USDA certifications, but rather write a letter.
We continue to get questions regarding whether a CPA can sign various FSA forms such as CCC-942 (certifying Adjusted Gross Income (AGI)), FSA-510 (more than 75% of AGI from farming), etc.
Back in 2012, USDA sent over 15,000 letters to various producers either asking for three years of tax returns or a “certification” from CPAs that their AGI was under the required levels at that time.
Many CPAs were concerned about writing such a letter as was the American Institute of Certified Public Accountants (AICPA). In response the AICPA and Farm Service Agency worked together to create a sample letter that CPAs could write to meet both the FSA requirements and CPA ethics requirements.
The AGI sample letter continues to be used to certify those situations where farmers are over the AGI limit solely due to filing a married filing joint (MFJ) return. The letter is applicable if they would be under the AGI if they had in fact filed a married filing separate (MFS) tax return. They are not required to file such a return but simply allow the CPA to calculate their AGI as if they had filed MFS.
In subsequent years, various programs allowed producers to receive a larger payment or payment limit if their farm AGI was more than 75% of total AGI. In this case, the FSA created a separate sample letter that CPAs could use to “certify” those details.
We are attaching copies of the two sample letters that CPAs use. Some FSA offices may request the CPA to sign the appropriate form. This is not required and you should indicate the local office should read the pertinent sections of FSA Handbook 6PL or any appropriate handbook that may apply to that particular program.
