As a follow-up to our December 1994 advisory memo to the regions which stated that this issue would be addressed in more detail in the future, this memo changes the existing FSMC reporting requirements policy to allow exception reporting by all state agencies.
This is to inform you of changes that will be made to the FMNP interim regulations. Because some aspects of this year's FMNP season have already begun, and the process of issuing regulations is long and complex, we wanted to offer state agencies the opportunity to implement the following provisions prior to publication of the final FMNP regulation.
We have concluded that neither the authorization of farmers or farmers' markets nor the exchange of a FMNP coupon between a certified FMNP recipient and an approved farmer or farmers' markets in the FMNP represents "covered transactions." Therefore, farmers or farmers' markets in the FMNP are not subject to the certification requirements.