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How the Big Beautiful Bill Impacts FSA Farm Program Payments

Tyler Hohenstein, Tax Manager
September 17, 2025
How the Big Beautiful Bill Impacts FSA Farm Program Payments

The One Big Beautiful Bill Act (OBBB), signed into law on July 4, 2025, introduces significant updates to Farm Service Agency (FSA) programs. These changes directly affect commodity support, payment limits, eligibility rules, and base acres. 

 


Expanded Commodity Support Programs 

The OBBB strengthens Agriculture Risk Coverage (ARC) and Price Loss Coverage (PLC) programs, giving producers additional protection against market fluctuations: 

  • Agriculture Risk Coverage (ARC): Revenue guarantee increased from 86% to 90%, with the maximum payment rising from 10% to 12% of benchmark revenue. 
  • Price Loss Coverage (PLC): Reference prices for key crops such as corn, wheat, and soybeans increased by 10–21%. Beginning in 2031, reference prices will also adjust with inflation. 
  • Automatic Selection (2025 only): Farmers will automatically receive the higher ARC or PLC payments for each covered commodity. 

 

Higher FSA Payment Limits 

Payment limits are also expanding, offering greater flexibility for producers and larger operations: 

  • Individual Limit: Increased from $125,000 to $155,000 for Title I commodity programs. 
  • Entity Limit: Pass-through entities, including LLCs, S corporations, and limited partnerships, now qualify for equal treatment under attribution rules. Each member who contributes active labor or management may qualify individually. 
  • Inflation Indexing: Beginning in 2026, payment limits will be indexed annually to inflation

 

Updated Definition of Farming 

The Act also modernizes the definition of farming income for purposes of program eligibility. Producers who derive at least 75% of their average gross income from farming, ranching, or silviculture may be exempt from the $900,000 adjusted gross income (AGI) limit for certain conservation and disaster programs. 

Newly recognized farming activities include: 

  • AgriTourism   
  • Direct-to-consumer marketing of agricultural products 
  • Sale of agricultural equipment 

 

Eligibility Requirements Remain Unchanged 

While payment limits and definitions are expanding, the requirement for producers to be “actively engaged in farming” remains unchanged. Producers must contribute personal labor, management, or both, and those contributions must be documented and distinct from others in the operation. 

 

New Base Acre Allocations 

For the first time in years, USDA will open the door to additional base acres. Up to 30 million new base acres will be allocated to farms that have grown program crops but currently lack base acreage. Eligibility is based on planting history from 2019–2023, with allocations beginning in 2026. 

 

As a producer, what changes should you remember? 

 

What's Changing? 

Old Rule 

New Rule (2025) 

ARC Revenue Guarantee 

86% 

90% 

ARC Max Payment 

10% of the benchmark 

12% 

PLC Reference Prices 

Fixed 

+10-21%, indexed from 2031 

Individual Payment Limit 

$125,000 

$155,000, indexed 

Entity Eligibility 

Limited to general partnerships 

Expanded to LLCs, S- corps, LPs 

Base Acres 

No new allocation 

Up to 30M new acres 

 

At Lutz, our agriculture experts combine deep industry knowledge with practical solutions to help agriculture businesses thrive in a changing marketplace. Our team is here to provide the expertise and support you need for long-term success. Contact us to learn more.  

  • Achiever, Learner, Individualization, Arranger, Relator

Tyler Hohenstein

Tax Manager
Tyler Hohenstein, Tax Manager, began his career in 2014. He has developed extensive expertise in tax and client relations while also assisting with staff training and development through his leadership on the Grand Island office’s internship program.
 
Specializing in tax consulting and compliance, Tyler focuses on industries such as agribusiness, construction, real estate, and vehicle dealerships. He takes pride in seeing his clients succeed and grow, providing comprehensive solutions that address their unique challenges. His thoughtful approach to problem-solving helps him create practical strategies for complex tax matters.
 
Tyler lives in Palmer, Nebraska, with his wife Kara and their cat Louie. Outside the office, he can be found playing golf, working cattle, and smoking meat. Tyler also occasionally assists his veterinarian wife as a vet assistant.

308.385.1134

thohenstein@lutz.us

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