ATTACHMENT A - FMNP Burden Narrative

Estimate of the Collection of Information Burden for the WIC Farmers’ Market Nutrition Program (FMNP)

This document explains the calculation of the collection of information burden for the WIC Farmers’ Market Nutrition Program (FMNP) to establish reporting and recordkeeping requirements. Out of approximately 23,793 Farmers, Farmers’ Markets, and Roadside Stands, approximately (7,851.69) will be authorized annually during the three-year approval. Also, State agencies are required to monitor at a minimum 10 percent (2,793.30) of all authorized farmers, markets, and roadside stands annually. 

The reasons for the collection of information are discussed below. All regulatory citations refer to 7 CFR Part 248, the Federal FMNP Regulations.

STATE AGENCY REPORTING REQUIREMENTS

1. Section 248.4 requires the State Agency (SA) to submit a State Plan once to FNS for approval by November 15 of each year as a prerequisite to receipt of funds from FNS. The State Plan requires the State agency to outline the various aspects of its program operations. FNS estimates that each State agency will spend 40 hours annually producing the State Plan.

The number of State agencies increased from 45 to 47. Estimated total man hours: 1,880 (47 State agencies x 1 State Plan per respondent annually = 47 State Plans total annual responses x 40 hours per State Plan =1,880 burden hours). This results in an increase of 40 burden hours.

2. Section 248.10(a)(2)-(3) set forth State agency responsibilities regarding the selection and authorization of farmers, farmers’ markets, and roadside stands for the FMNP. FNS estimates that it takes one hour to review each application. Approximately half of the State agencies that currently administer the FMNP also administer the SFMNP; in most cases, the same farmers and farmers’ markets that are authorized to participate in one program will be automatically authorized to participate in the other. Therefore, we are projecting that 7,851.69 or 1/3 (.33) farmers’ market and/or roadside stand applications will need to be reviewed by FMNP State agencies.

The reported number of farmers’ market and roadside stand applications decrease from 7,947 to 7,851.69. FNS estimates the 47 State Agencies will review approximately 167.06 authorizations per SA annually for a total annual authorization of 7,851.69. We estimate it will take a total of 1 hour per agency for a total burden of 7,851.69 rounded up to 7,852 burden hours. This results in a decrease of 95.31 burden hours. The burden for this respondent type was identified incorrectly in the previous information collection request and has been changed from private sector (farmer’s market and roadside stand) to State Agency to correctly identify which group will assume the burden.

3. Section 248.10(e) requires that each FMNP State agency document specific information for all on-site monitoring visits. The requirement states that at least 10 percent of farmers, farmers’ markets, and roadside stands must be monitored annually. There are approximately (23,793) farmers’ markets and roadside stands. Ten percent of the farmers’ markets and roadside stands will be monitored each year (2,379.30 x 10%) for total of (2,379.30) farmers’ markets and roadside that will be monitored annually. FNS estimates that it takes 2 hours to monitor each market. Estimated total man hours: 2,379.30 (47 SA x 50.62 visit annually = 2,379.30 visits per SA annually x 2 man hours = 4,758.60 rounded up to 4,759 hours annually). This results in a decrease of 9.40 burden hours. The number of farmers’ market and roadside stand applications increased due to the addition of two State Agencies.

4. Section 248.10(f) requires that the State agencies control and provide accountability for the receipt and issuance of FMNP coupons, including the secure transportation and storage of unissued coupons. In addition, the State agency is responsible for designing and implementing a one- time coupon management system of review of FMNP coupons to detect errors. FNS estimates that 5 man hours per State agency will be necessary to complete these functions.

The number of State agencies increased from 45 to 47. Estimated total man hours: 235 (47 WIC FMNP State agencies x 1 average response annually = 47 total annual responses x 5 man hours = 235 total annual burden hours for this activity). This results in an increase of 15 burden hours.

5. Section 248.11 requires that once annually the State agencies maintain a financial management system including an accounting for all property and other assets and all FMNP funds received and expended each fiscal year. FNS has estimated that it takes 10 man hours per response to carry out this requirement.

The number of State agencies increased from 45 to 47. Estimated total man hours: 470 (47 WIC FMNP State agencies x 1 response annually = 47 total annually responses x10 man hours=470 total annual burden hours for this activity). This results in an increase of 20 burden hours.

6. Section 248.17(b)(2)(ii) requires that a State agency develop a corrective action plan for deficiencies found in a management evaluation, including timeframes for implementation to address the deficiencies and prevent their future recurrence. Out of the 46 participating FMNP State agencies, it is estimated that 9 will be required to submit corrective action plans for deficiencies. FNS estimates that each corrective action plan will take approximately 10 hours to develop.

Estimated total man hours: 90 (9 SA corrective action plans x 1 per agency = 9 total annual responses x 10 man hours = 90 total annual burden hours). There is no change in burden.

7. Section 248.18(b) requires the State agency to develop and submit a corrective action plan to FNS addressing the findings of USDA’s Office of the Inspector General (OIG), State, or local agency audits. It is estimated that of the 47 participating State agencies, 13 will have audit findings requiring corrective action plans, and that each corrective action plan will require 15 hours to develop and submit.

Estimated total man hours: 195 (13 State agencies x 1 response per agency =13 total annual responses x15 man hours per response=195 total annual burden hours). There is no change in burden.

8. Section 248.23(b) sets forth the financial and recipient reporting requirements for FMNP State agencies. The information to be provided through these yearly reports includes, but is not limited to: (1) the number and type of recipients served with Federal FMNP funds; (2) the value of coupons issued; (3) the value of coupons redeemed; and (4) the number of authorized outlets by type; i.e., farmers’ markets and roadside stands. FNS estimates that it will take each State agency approximately 3.50 hours to assemble the necessary information for these reports.

Burden for FNS 683 WIC Farmers' Market Nutrition Program (FMNP) Annual Financial Report and 203WIC Farmers' Market Nutrition Program Report has been removed and merged into OMB Control No: 0584-0594 Expiration Date: 06/30/2017. This adjusts has resulted in a decreased of 92 total annual responses and 184 burden hours.

STATE AGENCY RECORDKEEPING REQUIREMENTS

1. Section 248.9 requires that a State Agency (SA) wishing to coordinate nutrition education with another State agency or organization must enter into written cooperative agreements with such agencies or organizations. FNS estimates that 47 SA will maintain 1 request per agency = a total annual of 47 responses. Approximately 1 hour is required annually per participant for the nutrition education recordkeeping required by this provision for a total of 47 burden hours for this activity. This results in an increase of 2 burden hours due to the addition of two State agencies.

2. Section 248.10(b) - FNS has estimated that 47 SA will maintain 1 request per agency = a total annual of 47 responses for a total of 47 burden hours for this activity. Approximately 2 man hours are required annually of each of the 47 FMNP State agencies to maintain records of farmers’ market and roadside stands agreements for a total of 94 annual burden hours.

The number of State agencies increased from 45 to 47. Estimated total man hours: 94 (47 FMNP State agencies x 2 man hours). This results in an increase of 4 burden hours.

3. Section 248.10(e) – FNS has estimated that 47 SA will maintain 1 request per agency = a total annual of 47 responses for a total of 47 burden hours for this activity. Approximately 2 man hours are required annually of each of the 47 FMNP State agencies to maintain market and roadside stands monitoring records for a total of 94 annual burden hours.

The number of State agencies increased from 45 to 47. Estimated total man hours: 94 (47 FMNP State agencies x 2 man hours). This results in an increase of 4 burden hours.

4. Section 248.11(c) – FNS has estimated that 47 SA will maintain 1 request per agency = a total annual of 47 responses for a total of 47 burden hours for this activity. Approximately 2 man hours are required annually by each of the 46 FMNP State agencies to maintain financial management records for a total of 94 annual burden hours.

The number of State agencies increased from 45 to 47. Estimated total man hours: 94 (47 FMNP State agencies x 2 man hours). This results in an increase of 4 burden hours.

AFFECTED PUBLIC FARMS: FARMERS/MARKETS/ROADSIDE STANDS REPORTING REQUIRMENTS

1. Sections 248.10(a)(2), 248.10(a) (3),and 248.10(b) require farmers to prepare an application for authorization of farmers’ markets and roadside stands. FNS estimates that 1 hour is needed to prepare each application. There are currently 23,793 farmers’ markets and roadside stands authorized to accept FMNP coupons. However, FMNP authorization generally results in an agreement for which §248.10(b)(7) provides a three-year period. Thus, FNS estimates that one third of all authorized entities are authorized per year – 7,852 – as reflected on the attached chart. This results in a decrease of 95.31 burden hours

There are no recordkeeping requirements for this affected public.