Supporting statement for SFSP renewal 2-15-13 Final

SUMMER FOOD SERVICE PROGRAM

OMB CLEARANCE NUMBER 0584-0280

Bramaramba. J. Kowtha

Program Analyst

Food and Nutrition Service, USDA

Child Nutrition Division

Program Analysis and Monitoring Branch

Special Nutrition Program

3101 Park Center Drive

Alexandria, VA 22302

PH: 703-605-4390

bramaramba.kowtha@fns.usda.gov

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

This is a revision of a currently approved information collection. Section 13 of the National School Lunch Act (NSLA), as amended, authorizes the Summer Food Service Program for Children (SFSP). The SFSP is directed toward children in low-income areas when school is not in session. It is locally operated by approved sponsors, which may include public or private non-profit school food authorities (SFAs), public or private non-profit residential summer camps, or units of local, municipal, county or State governments or other private non-profit organizations that develop a special summer or other school vacation program providing food service similar to that available to children during the school year under the National School Lunch Program (NSLP), OMB Number 0584-006 which expires on August 31, 2015 and the School Breakfast Program (SBP) OMB Number 0584-0012 which expires on August 31, 2015.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate how the agency has actually used the information received from the current collection.

This information is required to administer and operate this program in accordance with the NSLA. State agencies enter into agreements with organizations for local level program operation and delivery of program benefits and services to eligible children. Program operators must submit monthly claims using FNS- 418 to its administering agency to receive reimbursement. All meals claimed for reimbursement must meet Federal requirements and be served to eligible children. While all SFSP meals are served at no charge, the sponsors of certain types of feeding sites must make individual determinations of eligibility for free or reduced price meals.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also, describe any consideration of using information technology to reduce burden.

FNS is committed to complying with the E-Government Act, 2002 to promote the use of the Internet and other information technologies to provide increased opportunities for citizen access to Government information and services. All program operation information and materials are available to agencies by downloading from the FNS website. FNS estimates that approximately 100% of the State agencies will submit reporting data electronically through FNS’ Food Programs Reporting System (FPRS) at https://fprs.fns.usda.gov/Home/Reminder.aspx. In addition, each state agency maintains its own website to communicate electronically with sponsors, camps, other sites, and households in their state.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Question 2.

There is no similar information data collection available. This SFSP is administered solely by FNS.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

Some local agencies and institutions meet the definition of “small organizations.” Information being requested or required has been held to the minimum required for the intended use. Although smaller State Agencies, Camps and Sponsors are involved in this data collection effort, they deliver the same program benefits and perform the same functions as larger ones. Thus, they maintain the same kinds of information on file. FNS estimates that 50% of sponsors or 2,377 sponsors, and 100% of camps, approximately 791 camps, are considered small entities. An estimated 3,168 of the respondents are small entities.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted, or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The SFSP has a short operating period and State agencies and sponsors would lose operating funds if claims for reimbursement are not submitted in a timely manner. In order to receive reimbursement for eligible meals served, sponsors must submit a claim for reimbursement within 60 days of the last day of operation and State agencies have 90 days to submit final claims from the last day of operation. The consequence for not collecting the information is the inability to proficiently operate the SFSP program.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secret, or other

confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to

the extent permitted by law.

This collection requires respondents to report information to the agency more often than quarterly. Sponsors must submit a claim for reimbursement within 60 days of the last day of operation and State agencies have 90 days to submit final claims from the last day of operation.

There are no other special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.5.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments.

A 60-day notice was published in the Federal Register on December 19, 2012 (Volume 77,

Number 244, pages 75106-75110). No comments have been received.

• Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting form, and on the data elements to be recorded, disclosed, or reported.

FNS consults with Regional Offices regarding any proposed changes as the result of legislative, regulatory, or administrative changes. Regional offices are in daily contact with State agencies, which provide feedback on FNS processes and procedures for this information collection.

9. Explain any decision to provide any payment or gift to respondents, other than re-enumeration of contractors or grantees.

No payment or gift will be provided to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The Department will comply with the Privacy Act of 1974 (5 USC 552a), which requires the safeguarding of individuals against invasion of privacy. No confidential information is associated with this information collection.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive nature included in this data collection.

12. Provide estimates of the hour burden of the collection of information. The statement should include:

Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

The attached Burden Table reflects the estimated burden associated with this information collection for each type of respondent. A summary table follows:

SUMMARY OF BURDEN (OMB #0584-0280)
TOTAL NO. RESPONDENTS	106,187
AVERAGE NO. RESPONSES PER RESPONDENT	6.3648
TOTAL ANNUAL RESPONSES	675,867
AVERAGE HOURS PER RESPONSE	.259506
BURDEN REQUESTED WITH SFSP REVISION	175,392
Current OMB Inventory	182,683
Change with this Revision	-7,292

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

• The estimate of respondent cost is based on the burden estimates and utilizes the U.S. Department of Labor, Bureau of Labor Statistics, May 2011 National Occupational and Wage Statistics, Occupational Group (25-0000) (http://www.bls.gov/bls/wages.htm). The hourly mean wage (for education-related occupations) for functions performed by State agency and local education agency staff are estimated at $24.46 per staff hour.

TOTAL COST TO PUBLIC = 175,392 hours X $24.46 per hour = $ 4,290,088

13. Estimate of other total annual cost burden to respondents or record keepers. Provide estimates of the total annual cost burden to respondents or record keepers resulting from the collection of information (do not include the cost of any hour burden shown in items 12 and 14). The cost estimates should be split into two components: (a) a total capital and start-up cost component annualized over its expected useful life; and (b) a total operation and maintenance and purchase of services component.

There is no start-up or annual maintenance costs for this collection of information.

13. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

Federal Cost

The Federal cost of collecting and processing data under Part 225, issuing Program regulations, guidance, and monitoring compliance with the regulations is presented below. FNS used the following procedure to estimate this cost:

1. FNS identified functions performed by FNSRO and Headquarters staff that benefits the SFSP and obtained estimates of the total number of staff hours spent performing these functions. For Headquarters and FNSRO, staff obtained estimates from personnel who perform the functions.

FEDERAL COSTS OF SFSP - PERSONNEL
(1)	(2)	(3)	(4)	(5)
FUNCTION	DONE BY	TOTAL STAFF HOURS	SFSP ALLOCATION PERCENTAGE	PORTION TO SFSP (3X4)
Professional Assistance to State agencies	FNS Regional Office	22,880 hours	20%	4,576 hours
Drafting/Clearing Regulations	HQ	14,560 hours	40%	5,824 hours
Policy Development Guidance	HQ	14,560 hours	40%	5,824 hours
TOTAL				16,224

Using the 2012 Federal Wage Salary Tables, we estimated the salary rate is $30.00 per hour (the average hourly salary for a GS 11/12 which is the grade level of staff who performs these functions). Our computations are:

FEDERAL SALARIES

Salaries (16,224 hours @ $30.00) $486,720.00

10 % for Administrative overhead $48,672.00.

Federal Cost $535,392

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.

This is a revision of currently approved collection. As a result of reevaluating the burden of existing program tasks, the reporting burden was significantly reduced by 42,693 hours since the last renewal. However, the recordkeeping burden was erroneously removed from the ICR in the prior submission. As a result of reinstating the recordkeeping burden, the burden increased by 35,401 hours due to this program change. The total burden reduction is 7,292 hours. The number of responses have increased in this ICR, from 238,593 to 675,867, due to increases in the number of respondents. The number of State Agencies increased from 52 to 53, the number of sponsors increased from 3,842 to 4,754, and the number of camps and other sites increased from 766 to 791. No substantive revisions have occurred to the form FNS-418.

16. For collections of information whose results are planned to be published,

Outline plans for tabulation and publication.

This collection does not employ statistical methods and there are no plans to publish the

results of this collection for statistical use.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

We are not seeking approval concerning the display of the expiration date.

18. Explain each exception to the certification statement identified in Item 19

"Certification for Paperwork Reduction Act."

There are no exceptions to the certification statement.