OMB 584-0496_Supporting Statement_FY2017 Renewal_CPB Revisions_12-15-16

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. This information collection is necessary because it addresses the State agency reporting burden associated with the following State agency options under the Supplemental Nutrition Assistance Program (SNAP): Establishing and reviewing standard utility allowances (SUAs) and establishing methodology for offsetting cost of producing self-employment income. The Food and Nutrition Act of 2008 (the Act), as amended, establishes SNAP as a means-tested program under which low-income households may apply for and receive assistance to supplement their ability to purchase food. The Act specifies national eligibility standards and imposes certain administrative requirements on State agencies in administering the program.

The Federal procedures for implementing the certification processes in the Act are in Parts 271, 272, and 273 of Title 7 of the Code of Federal Regulations (CFR). Part 271 contains general information and definitions, Part 272 contains requirements for participating State agencies, and Part 273 contains procedures for the certification of eligible households.

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.

SNAP regulations at 7 CFR 273.9(d)(6)(iii) allow State agencies to establish standard utility allowances in place of the actual utility costs incurred by a household. State agencies are required to review and adjust SUAs annually to reflect changes in the costs of utilities. State agencies are required to review the standards annually and make adjustments to reflect changes in utility costs. States must provide the amounts of the standards to FNS when they have changed and submit methodologies used in developing and updating standards to FNS for approval when the methodologies are updated or changed. Most State agencies provide their SUA information on written letterhead and typically submit it via email.

SNAP regulations at 7 CFR 273.11(b) allow for self-employment income to be reduced by the cost of producing such income. The regulations allow the State agencies, with approval from FNS, to establish the methodology for offsetting the costs of producing self-employment income, as long as the procedure does not increase program costs. Most State agencies provide methodology information on written letterhead and typically submit it e via email. Once approved by FNS, States can use these methodologies to determine net self-employment income for SNAP eligibility purposes.

A3. Use of 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.

In compliance with E-Government Act of 2002 (E-Gov), State agencies have the authority to use the technology that best suits the needs of their individual or unique systems of operation to comply with the reporting and recordkeeping requirements contained in this submission. In addition to the submission of States SUA and self-employment methodology information sent to FNS via email, zero percent of this collection is collected via electronic methods.

FNS has made every effort to provide for electronic submission as an alternative to paper submission in compliance with the E-Gov. FNS provides funding to support the development of electronic systems through Federal matching of States’ administrative costs. All State agencies have automated their SNAP eligibility systems. In order to avoid duplication, this collection does use data from form FNS-388, (approved under OMB# 0584-0081 expiration date 3/31/2017), States send aggregate level data on participation, benefits issued, and other basic program information to FNS using the Food Programs Reporting System (FPRS) via the following website: https://fprs.fns.usda.gov. This collection is not seeking any additional burden hours for the use of this form. See Appendix B for FNS-388 screenshots.

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.

States are required to limit collection to information necessary to comply with the SNAP statutory requirements and to protect program integrity without imposing undue burden on respondents. FNS solely approves and monitors the standard utility allowances used by State agencies that have opted to use SUAs in place of actual costs in determining a household’s excess shelter deduction. This and other information already available may be used with appropriate modifications. There is no duplication of efforts.

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.

53 State agencies administer SNAP at the State level and collect the necessary data to ensure correct eligibility determinations and delivery of benefit. All State agencies deliver the same program benefits and perform the same function regardless of population size. Thus, they maintain the same kinds of information on file. Of the 53 SNAP State agencies, 53 have incorporated the options covered by this collection, and of these respondents, none 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.

This is an ongoing mandatory information collection request. The requirements to allow State agencies to use standard utility allowances and simplified methods of computing self-employment costs are necessary and collected in compliance with the law. FNS will only approve States’ standard utility allowances and simplified calculations of self-employment income if the methodologies are sound.

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;
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 special circumstances that cause this information collection to be conducted in a manner that is inconsistent with 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. Specifically address comments received on cost and hour burden.

FNS published a notice soliciting comments regarding this information collection on August 10, 2016, in the Federal Register at 81 FR 52820. One comment was received from the Florida Department of Children and Families (DCF). The State agency raised concerns that FNS’ burden estimate of 2.5 hours for reviewing a SUA methodology is not a true reflection of the time spent collecting this information (see Appendix A). While the State agency outlined the process it uses in constructing a SUA methodology, it did not provide FNS with its own proposed burden hour estimate.

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 format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years even if the collection of information activity is the same as in prior years. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

FNS has ongoing discussion with the FNS Regional Offices. Based on the comment received from Florida DCF, and after consulting with FNS Regional Offices, FNS has decided to revise its burden hour estimate for reviewing SUA methodologies from 2.5 hours up to 10 hours.

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

Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payments or gifts are provided to respondents under this collection.

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.

Section 11(e)(8) of the Food and Nutrition Act and section 272.1(c) of the regulations limit the use or disclosure of information obtained from applicant households or contained in the casefiles of participating households to persons directly connected with the administration or enforcement of the provisions of the Act or regulations, other Federal or federally assisted means-tested programs; persons directly connected with the administration or enforcement of programs required to participate in the State income and eligibility verification system; persons directly connected with the verification of immigration status of aliens; persons directly connected with the administration of the Child Support Program; employees of the Office of the Comptroller General of the U.S. for audit and examination authorized by other provisions of law; Local, State, or Federal law enforcement official investigating an alleged violation of the Act or regulations and law enforcement officers if the household member is a fleeing felon or a parole violator. FNS published the Privacy Act: System of Records Notice (SORN) on March 31, 2000, in the Federal Register (65 FR 17251) entitled “USDA/FNS-10 Persons Doing Business with the Food and Nutrition Service” to specify the uses of the information that is collected.

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.

No private or sensitive questions will be asked.

A12. Estimates of the hour burden of the collection of information.

Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

A. 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.

FNS is requesting 746 total annual burden hours and 127 total annual responses for this information collection. FNS estimates 53 State agencies will submit one request each to adjust the SUAs, for a total annual response of 53 requests at a minimum of 10 hours annually (53 State agencies x 1 SUAs request = 53 total annual responses x 10 hours = 530 hours). The total burden for this provision is estimated to be 530 hours per year. This is an increase of 400 hours from the previous submission for this specific activity, due to an increase in State agencies implementing this option and based on comments received from State agencies.

Based on the information provided in the Twelfth Edition of the SNAP State Options Report, out of the 53 State agencies, 21 State agencies have incorporated a methodology for determining the cost of doing business in self-employment cases. This is an increase from 18 States in the previously approved information collection. It is estimated that these 21 States will submit one request each, totaling 21 annual responses. States will incur a burden of at least 10 working hours gathering and analyzing data, developing the methodology, determining the cost implication and submitting a request to FNS, for a total burden of 210 hours annually (21 State agencies x 1 request = 21 total annual responses x 10 working hours = 210 burden hours). This is an increase of 30 burden hours from the previous submission. The estimated reporting burden for each individual component of this information collection, including the number of respondents, frequency of response, average time to respond and annual hour burden is shown and described below.

Record Keeping Burden Only

All 53 State agencies are required to keep and maintain one record of the information gathered and submitted to FNS for SUA and self-employment options. It is estimated that this process will take 7 minutes or .1169 hours per year for each State agency, resulting in a total annual burden of 6 hours (53 State agencies x 1 record = 53 total annual records x .1169 hours = 6 hours). This burden remains unchanged from the previous submission.

The following table illustrates the burden estimates associated with the State agency options included in this collection:

Respondent and Reporting Activities	Estimated # Respondent	Responses annually per Respondent	Total Annual Responses	Estimated Avg. # of Hours Per Response	Estimated Total Hours (Col. dxe)
Reporting Burden - Establishing and Reviewing Standard Utility Allowances (SUAs)
State, Local or Tribal Agencies	53	1	53	10	530
Reporting Burden - Establishing Self-Employment Costs Methodology
State, Local or Tribal Agencies	21	1	21	10	210
Total Reporting Burden	53		74		740
Recordkeeping Burden
State, Local or Tribal Agencies	53	1	53	0.1169	6
Total Recordkeeping Burden	53		53		6
Total Burden Summary for Reporting and Recordkeeping	53		127		746

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

SNAP information collection requirements described herein are imposed on State agency staff. The wage rates used in determining these public burden costs were based on the Bureau of Labor and Statistics (BLS) Occupational Employment Statistics estimates. Respondents involved in this collection will be State Agency staff, which corresponds to Bureau of Labor Statistics Category 43-4061, Eligibility Interviewers, Government Programs. Based on the most recent Occupational Employment and Wage Estimates from May 2015, this category of workers earns a mean hourly wage of $20.69¹. However, 50 percent of the administrative costs incurred by State agencies are reimbursed by FNS. According to the burden hours shown above, FNS estimates that this information collection will result in a total cost across State agencies of $15,442; however, final costs are estimated at $7,721 after 50 percent of the administrative costs incurred by State agencies are reimbursed by FNS.

State and Local Agency cost per hour ($20.69 x 50% Federal Share =$10.35)	Hours	Cost (US $)
Standard Utility Allowance	530	$5,485.50
Self-employment costs	210	$2,173.50
Recordkeeping	6	$62.10

Total State and Local Agency Cost	746	$7,721.10

A13. Estimates of other total annual cost burden.

Provide estimates of the total annual cost burden to respondents or recordkeepers resulting from the collection of information, (do not include the cost of any hour burden shown in questions 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/start-up or ongoing operation or maintenance costs associated with this information collection.

A14. Provide estimates of annualized cost to the Federal government.

Provide estimates of annualized cost to the Federal government. 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.

The total annual cost to the Federal government is $11,638.12. This cost includes reimbursement of fifty percent of the administrative costs incurred which we estimated at $7,721. Thus, the estimated wage rates for State agency staffs noted above have been reduced by 50 percent to reflect cost sharing.

Using the 2016 GS Federal Wage rate, the Federal cost associated with the preparation of this information collection package is $3,917.12. This includes Federal worker time at FNS that includes the following:

Burden – Review of State agency SUA and Self-Employment Methodologies	Hours	Estimated Hourly Wage Rate* ^²	Cost (US$) (approx.)*
Program Analyst (GS-13/1)	58	$44.15	$2,560.70
Branch Chief (GS-14/1)	26	$52.17	$1,356.42
Total			$3,917.12

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-I.

This is a revision of a currently approved data collection. The current burden inventory is 316 total annual burden hours and 122 total annual responses. As a result of program changes FNS is requesting 746 total annual burden hours and total annual responses are estimated at 127. This revision reflects an increase 430 total annual burden hours and 5 total annual responses. Additionally, based on public comments received from State agencies, FNS has increase the time per respondent from 2.5 hours to 10 hours a increase of 7.5 burden hours.

Currently there is a total of 52 State agencies who have established SUAs and will review them on an annual basis, FNS is requesting an increase to 53 State agencies who will submit this information. This request reflects an increase of 1 State Agency.

Currently there are 18 State agencies have incorporated a methodology for determining the cost of doing business in self-employment cases. FNS is requesting a total of 21 State agencies will submit this information. This revision request reflects an increase of 3 State agencies.

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.

There are no plans to publish statistical analyses.

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 all instruments.

A18. Exceptions to the certification statement identified in Item 19.

Explain each exception to the certification statement identified in Item 19 of the OMB 83-I" Certification for Paperwork Reduction Act."

There are no exceptions to the certification statement.

1 http://www.bls.gov/oes/current/oes434061.htm

2 Federal General Schedule Salary Table 2016-DCB: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/16Tables/html/DCB_h.aspx

File Type	application/vnd.openxmlformats-officedocument.wordprocessingml.document
File Title	Supporting Statement for OMB No
Author	USDA
File Modified	0000-00-00
File Created	2021-01-23