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As the HPAI response winds down (hopefully), it’s a goodtime to reflect on what went well, what can be done better, and how to prepare for the inevitable return of the virus that has become so familiar to us over the past four years. I’m proud of what we have accomplished together. In Minnesota, we work as a team to share knowledge so we can protect our birds from current threats. We collaborate to ensure we identify potential infections rapidly. And we support each other through the painful process of responding to the disease including eliminating the virus from our farms and preventing spread to our neighbors. This collaboration protects our flocks, our industry, and our communities. I repeatedly hear from HPAI responders in other states how much they appreciate how well things go in Minnesota. We unfortunately have a lot of experience, and our communication and teamwork are where the rubber meets the road. Our relationships are what make Minnesota and our industry so successful.
This past year, we had to tackle a new challenge to HPAI response: BCAP audits. Since the start of the fall 2025 outbreak, 47 BCAP audits, and counting, have been conducted in Minnesota as part of the HPAI response. This has been a learning process for everyone involved – producers and auditors alike. Some audits have gone relatively well, some have required a lot of patience, persistence, and rounds of remediations to be successful. Let’s look into some of the areas of BCAP audits that have been most problematic.
BCAP audits are conducted by USDA-trained Auditors, which may be State or Federal individuals, and are sent to a Federal Veterinary Medical Officer (VMO) for final review. While we strive for consistency overtime and between auditors, there will always be some degree of subjectivity that occurs between different Auditors and different Audit Reviewers. To reduce individual subjectivity, biosecurity plans need as much detail and clarity as possible. Your biosecurity plan must reflect practices and protocols actually being conducted on the farm. Plans should be written in a way that someone with no experience in the industry can understand. What we may view as common sense or obvious, another person may not understand at all.
The BCAP audit tool (which is the same tool used for BIFA)can be found on the USDA website: https://www.aphis.usda.gov/sites/default/files/biosecurityaudit.pdfThe audit tool is divided into three sections. Section 1 is a review of the written complex/company biosecurity plan. The plan should be specific for the individual farm being audited. If the biosecurity plan covers multiple premises, premises-specific details must be included so the auditors know what the practices and protocols are for the farm being audited. Some growers have needed to write site-specific plans in addition to having a larger company plan that address different scenarios because generalized company plans did not address the differences that may occur between premises.
All questions in Section 1 must be addressed specifically in the written biosecurity plan. For example, question 3 states, “Biosecurity signs warning unauthorized visitors not to enter the farm or any of its buildings are required to be posted at all entrances to the PBA and LOS.” It is not enough to have the biosecurity signs posted on farm at the PBA and LOS. It must also be written in your plan that there are signs at the PBA and LOS. If it isn’t written, the auditor will assume it is not being done.
The auditor will be looking for how frequently certain items are conducted. Auditors will be verifying procedures are being conducted on a regular basis. Some audit points do not define or require a specific frequency, but your plan should! Your plan must define the frequency (daily, weekly, monthly, etc.) and must not state that it is done “regularly.” “Regularly” does not provide enough information to the auditors to understand farm practices.
Procedures that auditors conducting BCAP audits in Minnesota have frequently identified as not having enough detail written in the plan are:
1. The procedures for crossing the Line of Separation (LOS). Procedures must be described step-by-step with enough detail that anyone coming into the facility should be able to replicate.
2. Mortality disposal procedures. The specific steps for how mortalities are collected, removed from the barn and transferred from the barn to disposal site must be explained. Employees and equipment both need to be addressed when describing mortality disposal procedures.
Section 3 of the audit is the visual verification of the farm-specific procedures. This part of the audit will be conducted virtually for Buffer Zone Placement and BIFA audits and will be on-site for Infected Premises. The auditor (or farm representative) will walk around the perimeter of every barn and if there are no birds in the barn, will go into every barn. For virtual audits (Buffer Zone Placements), the auditor will likely only ask to see the barn entry areas as video coverage may be restricted by cell phone reception within the barns.
Prior to your scheduled audit, make sure the farm is set up as if there were birds on site. The auditor will need to verify all procedures are being conducted as stated in the written biosecurity plan. In preparing for the audit, make sure the following items are set up.
There is no gapping in doors, screens, or windows and there are no holes in the walls or by the floor that would allow wildlife access (> 1 inch).
Finally, while producers will now be expected to participate in different types of biosecurity plan auditing (the NPIP audit conducted by the Board of Animal Health once every two years, and the BCAP audits for buffer zone placements or restocking infected premises), biosecurity plans should be written to address the audit points on both types of audits. Producers should not have separate NPIP biosecurity plans and BCAP biosecurity plans.
AVAILABLE BIOSECURITY INCENTIVE OPTIONS
Biosecurity Compliance Audit (BCAP)
AVAILABLE TO: Commercial poultry premises as described in 9 CFR 53.11(f)(5) that intend to move poultry onto the premises and are either 1) HPAI-infected or 2) located in an active HPAI control area buffer zone.
PURPOSE: To verify that farm/premise biosecurity measures implemented are sufficient to mitigate the risk of introduction of HPAI, as a condition for receiving future indemnity from USDA APHIS VS if the premises is affected by HPAI. The audit will be used to identify biosecurity compliance concerns that require remediation for which the producer will be eligible to be reimbursed. Successfully passing the audit by completing all required biosecurity remediations will confer commercial poultry premises BCAP compliance for 6 months, in accordance with 9 CFR 53.11(f)(5).
Biosecurity Incentive-Focused Assessment (BIFA)
AVAILABLE TO: Poultry premises with ≥500 birds per year, not subject to the BCAP requirements.
PURPOSE: To identify biosecurity issues on a farm and mitigate the introduction of HPAI. The assessment will be used to identify biosecurity compliance concerns for proactive remediation for which the producer will be eligible to be reimbursed. Successfully passing the assessment by completing all required biosecurity remediations will confer commercial poultry premises BCAP compliance for 6 months, should a premise be included in a buffer zone, in accordance with 9 CFR 53.11(f)(5).
Wildlife Biosecurity Assessment (WBA)
AVAILABLE TO: All poultry premises with ≥500 birds per year.
PURPOSE: To reduce the risk of HPAI transmission from wildlife to commercial poultry. This assessment identifies wildlife attractants and potential breaches in biosecurity (including recommended repairs, structural or habitat modifications, and business practice alterations) that could allow wildlife to interact directly with poultry. Completion of the assessment will provide the Producer information to prioritize biosecurity hazards that may result in wildlife coming into direct contact with poultry stock, poultry handling equipment or surfaces, or crossing the barn exterior wall. To be eligible for reimbursement, prioritized (tier 1) direct wildlife contact hazards must be successfully addressed.
Biosecurity Supplemental Improvement Proposal (BSIP)
AVAILABLE TO: All poultry premises with ≥500 birds per year that have already successfully completed the Biosecurity Compliance Audit, the Biosecurity Incentive-Focused Assessment, or the Wildlife Biosecurity Assessment.
PURPOSE: To provide an avenue for producers to identify additional biosecurity improvements that can be implemented on their premises to mitigate the introduction and spread of HPAI. Approval of the proposal will provide cost share funding to implement advanced biosecurity mitigations beyond those recommended on USDA audits.
PROCESS: USDA recommends the Producer contact the Area Veterinarian In Charge to submit a proposal within 30 days of their last assessment. Proposals should provide a detailed description of the improvement, how it will improve HPAI biosecurity, and a cost estimate; funding is subject to availability and per-premise reimbursement limits. To be considered for reimbursement the proposal must be approved before the referenced improvements are implemented.
Email poultry.biosecurity@usda.gov orcall 844-820-2234 to request a BIFA, BSIP, and/or WBA.
Visit USDA-APHIS website for additional information and FAQs on Biosecurity Assessments https://www.aphis.usda.gov/livestock-poultry-disease/avian/avian-influenza/hpai-poultry/biosecurity-assessments
