Supporting statement for SFSP renewal 3 21 16

Burden Chart for 0584-0280 7 CFR Part 225 Summer Food Service Program
Estimate of the Information Collection Burden (narrative) for the Summer Food Service Program

JUSTIFICATION

A1. Circumstances that make the collection of information necessary.

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 Richard B. Russell National School Lunch Act (NSLA) (42 U.S.C 1758), 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) (which is covered under OMB Number 0584-0006 and expires on March 31, 2016) and the School Breakfast Program (SBP) (which is covered under OMB Number 0584-0012 and expires on October 31, 2018). This information collection is required to administer and operate this program in accordance with the NSLA. All of the reporting and recordkeeping requirements associated with the SFSP are currently approved by the Office of Management and Budget and are in force.

A2. Purpose and Use of the Information.

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. This program is administered at the State level and 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 Summer Food Service Program for Children to its administering agency to receive reimbursement. However, this form and its associated burden is now covered under OMB Control Number 0584-0594 Food Programs Reporting System (FPRS) (which expires on June 30, 2017). This form is now being removed from this collection. 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. All of the information collected from the state agencies, businesses, and the state, local, and tribal governments is required to obtain or retain benefits. A description of the reporting, recordkeeping, and public disclosure requirements, with their CFR citations, can be found in Attachment B.

A3. Use of the Information Technology and Burden Reduction.

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. FNS estimates that 100% of the responses will be collected electronically.

A4. Efforts to Identify Duplication.

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 collection available. Every effort has been made to avoid duplication. FNS has reviewed USDA reporting requirements and state administrative agency requirements. This SFSP is administered solely by FNS.

A5. Impacts on Small Businesses or Other Small Entities.

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 2,658 sponsors, and 100% of camps, approximately 662 camps, are considered small entities. An estimated 3,320 (approximately 3% ) of the respondents are small entities.

A6. Consequences of Collecting the Information Less Frequently.

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.

A7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5.

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;

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.

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.

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

A8. Comments to the Federal Register Notice and Efforts for Consultation.

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 16, 2015 (Volume 80,

Number 241, pages 78167-78169). The public comment period ended on February 16, 2016. 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.

A9. Explain any decision to provide any payment or gift to respondents.

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.

A10. Assurances of Confidentiality Provided to Respondents.

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

The Department complies 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.

A11. Justification for any questions of a sensitive nature.

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.

A12. Estimates of the Hour Burden of the Collection of Information.

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 (number of respondents, frequency of response, average time to respond, and annual burden hours) associated with this information collection for each type of respondent (Attachment A). A summary table follows:

SUMMARY OF BURDEN (OMB #0584-0280)
TOTAL NO. RESPONDENTS	106,621
AVERAGE NO. RESPONSES PER RESPONDENT	7.45168
TOTAL ANNUAL RESPONSES	794,506
AVERAGE HOURS PER RESPONSE	.248031
BURDEN REQUESTED WITH SFSP REVISION	197,062
Current OMB Inventory	175,391
Change with this Revision	21,671

B. 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 2014 National Occupational and Wage Statistics, Occupational Group (25-0000) (http://www.bls.gov/oes/current/oes_nat.htm). The hourly mean wage (for education-related occupations) for functions performed by State agency and local education agency staff are estimated at $25.10 per staff hour.

TOTAL COST TO PUBLIC = 197,062 hours X $25.10 per hour = $ 4,946,256.20.

A13. Estimate of Other Total Annual Cost Burden.

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 are no capital or start-up costs or annual operation or maintenance costs for this collection of information.

A14. Provide Estimates of Annualized Cost to the Federal Government.

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:

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 2016 Federal Wage Salary Tables, we estimated the salary rate at $38.59 per hour (the average hourly salary for a GS 11/12 which is the grade level of staff who performs these functions). We used the pay table for the Washington-Baltimore-Arlington, DC-MD-VA-WV-PA area and used the step 5 hourly wage to average the salary for 11 and 12 (35.11+42.08/2=38.59). Our computations are:

FEDERAL SALARIES

Salaries (16,224 hours @ $38.59) $626,084.16

10 % for Administrative overhead $62,608.41

Federal Cost $688,692

A15. Explanation of Program Changes or Adjustments.

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 the currently approved collection. The information collection is currently approved with 175,391 burden hours and 675, 867 responses. FNS estimates that this renewal will add 21,671 burden hours and 118,639 responses to the collection, for an estimated total of 197,062 burden hours and 794,506 responses. These increases are due to administrative changes. As a result of reevaluating the burden of existing program tasks, the reporting burden was slightly increased by 10,656 hours and the recordkeeping burden was increased by 8,356 hours since the last renewal. In addition, one reporting requirement and one public disclosure requirement that were overlooked in the last renewal were added during this renewal, which increased the reporting burden by 1,329 hours and added 1,329 hours as public disclosure burden to the collection. The increase in the number of responses is due to increases in the number of respondents. The number of State Agencies remained the same at 53, but the number of sponsors increased from 4,754 to 5,317, and the number of camps and other sites decreased from 791 to 662. The burden associated with FNS-418 is now covered under 0584-0594 FPRS, which removes 318 hours from the collection. The specific burden changes for this information collection can be found in Attachment B.

A16. Plans for tabulation, and publication and project time schedule.

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.

A17. Displaying the OMB Approval Expiration Date.

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

The agency plans to display the expiration date for OMB approval of the information collection on related instruments.

A18. Exceptions to the Certification Statement Identified in Item 19.

Explain each exception to the certification statement identified in Item 19 "Certification for Paperwork Reduction Act."

There are no exceptions to the certification statement.

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Supporting statement for SFSP renewal 3 21 16