Comments from Paul Mitchell, professor UW Ag Econ Dept. 5-30-19
At this time, it seems that USDA Risk Management Agency has not changed any of the rules about terminating cover crops before planting an insured crop after the cover crop. The existing rules require that cover crops in Wisconsin (zone 4) be terminated by 5 days after planting or before the cover crop heads or buds (https://www.rma.usda.gov/Fact-Sheets/National-Fact-Sheets/Cover-Crops-and-Crop-Insurance). Maps of other zones are here (https://efotg.sc.egov.usda.gov/references/public/WA/340_National_Termination_Guidelines_Ver_3_Sept_2014.pdf). Note that this second document (from Sept 2014) says that if the cover crop is part of a no-till system, you have up to 7 days later to terminate the cover crop, but still before crop emergence (and still before heading or budding). The first document (from Oct 2018) makes no mention of this, and so I am not sure it applies. I would contact your crop insurance agent to get clarity on this point if you want to use it and get it I writing such as an email or text that you have approval from the agent/company to use this option.
An issue for cover crops in 2019 is what to do on acres that have filed for prevented plant claims. There is a role for cover crops on these acres that are not planted with an insured crop. This Saturday June 1, WI farmers can claim prevented plant for corn. Many WI farmers will likely take late planting at first, just reduce their coverage on a few acres planted late, but some will take prevented plant payments. They can (and probably should) plant cover crops on these acres later. Note that they cannot harvest anything until after November 1 (in WI), then they can make dry hay from it or graze it. However November 1 is very late and do not recommend depending on this option for forage; it may provide some fall grazing if the quality is there. I recommend that if a farmer takes prevented plant and wants/needs forage, they have two options. 1) Take the full payment and then use the payment to buy forage or 2) Take the partial prevented plant payment (35% of the full payment) and plant a forage crop and harvest as they want. If they take the 1st option, they can also establish (but not harvest) alfalfa for 2020 production. If they take the 2nd option, they can establish alfalfa and harvest this year.
A video and 2 page document is available here: https://renk.aae.wisc.edu/, but note that these dates are for WI, other states will have other dates. I strongly recommend that farmers connect with their crop insurance agent if they have questions and that they get something in writing such as an email or text if they want to do something on prevented plant acres, evidence that the practices were approved by the company/agent.