NH DHHS Outside Consultant Feedback

From: Lamere, Denise
To: Moore, Pat
Cc: Fettig, Samantha
Subject: RE: [External] State Agency Reporting-Burden Estimates
Date: Friday, November 15, 2019 9:11:19 AM

OMB
Information
Collection
Package

OMB
0584-0074

State agency
Reporting
Requirement
FNS Form 380

Current
Hrs Per
Response

Too
High?
Too
Low? or
Accurate
Too Low

8.9

Hi Pat and Samantha, Attached
is NH’s reply. Have a great day!

Denise
Denise Lamere, Administrator
Bureau of Improvement & Integrity
Quality Assurance & Federal Eligibility Review Unit

Reason(s) why?

30 minutes for interview time is not
reasonable. The calculation does
not appear to take into consideration
the SQCR travel to conduct face-toface interviews with clients. Our
estimate (rough) is Travel/Interview
3 hours; gathering, comparing,
analyzing, and 380 completion, is 7
hours for 10 hrs per response.

From:
To:
Cc:
Subject:
Date:
Attachments:

Moore, Pat
O"Neal, Lacy - FNS; Fettig, Samantha
Wilkinson, Tiffany - FNS
RE: [External] State Agency Reporting-Burden Estimates
Friday, November 15, 2019 2:50:05 PM
NCs Response - OMB Information Collection Package 2019.docx
NH Response - State Agency Reporting-Burden Estimates.pdf

Please find attached responses from NC and NH.  I received auto replies from
several people that they are out of the office.
I can ask the regional directors to share this with all of the states with a turnaround for
next week.  Just let me know.

Also, NC’s FNS 380 estimate is higher than yours and New Hampshire’s because we
have a complex State eligibility determination system that requires reviewing many
screens to obtain case info.

Pat Moore
Food & Nutrition Services Quality Control Program Administrator
Division of Social Services, Performance Management/Reporting & Evaluation Management Section
NC Department of Health and Human Services

Office: 919-527-6282
Fax: 919-334-1266
pat.moore@dhhs.nc.gov

820 S. Boylan Avenue, Hargrove Building
2416 Mail Service Center
Raleigh, NC 27699-2416

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Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties.

From: O'Neal, Lacy - FNS
Sent: Friday, November 1, 2019 1:36 PM
To: Moore, Pat ; Fettig, Samantha
Cc: Wilkinson, Tiffany - FNS
Subject: [External] State Agency Reporting-Burden Estimates

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to report.spam@nc.gov

Hello Pat and Samantha:

We would like to get feedback from the QC TAG on a few of SNAP QC’s estimated reporting burden
hours for three of our information burden packages:
1. OMB 0584-0074 (FNS Form 380)
2. OMB 0584-0299 (FNS Form 380-1)

From:
To:
Cc:
Subject:
Date:
Attachments:

O"Neal, Lacy - FNS
Moore, Pat; Fettig, Samantha
Wilkinson, Tiffany - FNS
State Agency Reporting-Burden Estimates
Friday, November 1, 2019 1:36:32 PM
Appendix C - 60 Day Notice.pdf
Appendix C - OMB 0584-0299 60 Day Notice Publication.pdf
OMB 0584-0303 275 SS after OIRA 7-14-17OFFICIAL.docx

Hello Pat and Samantha:

We would like to get feedback from the QC TAG on a few of SNAP QC’s estimated reporting burden
hours for three of our information burden packages:
1.       OMB 0584-0074 (FNS Form 380)
2.       OMB 0584-0299 (FNS Form 380-1)
3.       OMB 0584-0303 (FNS 275 regulations-Includes Sampling, Arbitration, Good Cause Appeals,
New Investment plan and progress report burden hours)
Packages one and two were published in the Federal Register on June 17, 2019 - they are the PDF
documents attached. We received comments from individual citizens but did not receive any comments
from State Agencies.  

We are also beginning our work on revising the burden estimates for the third package: FNS 275
regulations, which include burden estimates for states to update their sampling plans, do arbitrations,
time to appeal payment error rates through the good cause process, and create New Investment Plans
and progress report updates.  We have particular concerns regarding the current reporting estimate for
updating sampling plans in this package. The last OMB approved supporting statement for the FNS 275
regulation related burden is also attached.  

For TAG member convenience, we listed each reporting requirement below and are hoping to gain the
following information from TAG members:  Is the current state agency reporting burden too high, too low,
or accurate and reason(s) for that response.  For reasons why, feel free to respond outside of the table if
that is most helpful.  For more information, please refer to the attached documents.

OMB
Too
Reason(s) why?
Information
State agency
Current
High?
Collection
Reporting
Hrs Per
Too
Package
Requirement
Response Low? or
Accurate
OMB

FNS Form 380
8.9
0584-0074
OMB

0584-0299 FNS Form 380-1
1.056

Sampling Plan
5
Arbitration
24

Good Cause
160

OMB
New Investment

0584-0303
Plan Template
32

Form FNS 74 A
New Investment

Plan Template 
Form FNS 74 B

5

Please know that the Office of Management and Budget requires we submit commenter information with
our updated submissions.  This is standard procedure, just as with any federal register publication the
public is able to review on regulations.gov.  Thank you, in advance, for your assistance as we work to
improve the estimates of these QC related burdens.  Responses may be sent to me at
lacy.oneal@usda.gov by Friday, November 15, 2019, and I will route them to the appropriate team
members.

Thank you,

Lacy O’Neal
US Department of Agriculture
SNAP – Quality Control Branch
703-305-2516