Testing What the Market Says
Each claim check takes a specific public statement and tests it against the final rule, the official FD-CIC, and available evidence. A request for review is not an accusation of fraud.
USDA's rule specifies that farm producers maintain their own records to be verified through an independent third-party verifier. The burden of data privacy is on the third-party verifiers and other entities in the supply chain participating in this program, including farm producers themselves. Enrollment in a specific company's technology system is not a USDA requirement for payment.
USDA understands the need for a standardized Biofuel Feedstock Report and has provided a list of all elements required in the Biofuel Feedstock Report included in 2100.031(e). In order to maintain flexibility in how farm producers create, maintain, and transmit this report, USDA does not specify a specific form or format to allow for a range of ways to meet this requirement including using paper records, farm management software, and digital files. The official FD-CIC tool includes a print option that enables farmers to provide field-level CI scores to buyers in a standard format. While the CI score is only a single part of the Biofuel Feedstock Report, it comes with the farmer's attestation that the farmer is meeting the record-keeping and reporting requirements. This flexibility has been intentionally designed to support farmers down to the use of paper records so that undue burden is not placed on farmers. The intent is to have the market makers who stand to profit from the tax credits create a market that incentivizes farms or offers solutions to help farmers participate if those companies want to achieve the maximum benefit.
A program may require a platform as a condition of its own workflow, but that does not make the platform a universal USDA requirement. The relevant question is what the rule and official calculator require, then what the buyer contract adds.
Product use alone does not establish an official CI reduction. The claim must identify the permitted input or documented outcome, supporting records, applicable definitions, and the timing of the result.
Enrollment is not the same as a purchase commitment or payment obligation. A farmer needs a named buyer, delivery path, formula, timing, funding source, and terms explaining when payment can be withheld.