Emergency Memo

1400 Independence Avenue, SW.
Room 1406-S, STOP 0244
Washington, DC 20250-0244

TO:

Elyse Greenwald
Desk Officer
Office of Management and Budget

THROUGH: Ruth Brown
Departmental Clearance Officer
Office of the Chief Information Officer
FROM:

Bruce Summers
Administrator
Agricultural Marketing Service

SUBJECT:
Request

Request for Emergency Review and Approval for a New Information Collection

BRUCE
SUMMERS

Digitally signed by BRUCE
SUMMERS
Date: 2020.07.13 09:53:12
-04'00'

We are requesting emergency review and approval of an information collection package for a
new grant program authorized by section 4206 of the Agriculture Improvement Act of 2018
(Pub. L. 115-334) (Farm Bill): the Micro-Grants for Food Security (MGFS) Program (7 U.S.C.
7518). A burden is being imposed on eligible State departments of agriculture for the collection
of reporting requirements. The emergency review is requested because the collection of
information is essential to the mission of the agency, and there are significant implications to
consider related to this program and its benefit to those affected by the unanticipated Novel
coronavirus (COVID-19).
The 2018 Farm Bill authorized the appropriation of $10 million in fiscal year 2019 and each year
thereafter. It directs “eligible states” to develop appropriate grant applications and the U.S.
Department of Agriculture (USDA) to adequately evaluate these new proposals and obligate the
funds. The following states and territories are “eligible States” as defined in the legislation:
Alaska, Hawaii, American Samoa, the Commonwealth of the Northern Mariana Islands, the
Commonwealth of Puerto Rico, the Federated States of Micronesia, Guam, the Republic of the
Marshall Islands, the Republic of Palau, and the United States Virgin Islands.
In January 2020, USDA determined that the MGFS Program would reside in the Agricultural
Marketing Service (AMS). Upon receiving this information, AMS expediently worked to
develop the documents required for the grant application process. To assist grant recipients as
soon as possible, AMS set a goal of awarding the funds within the calendar year 2020 growing
season, which varies greatly among the eligible grant recipients (i.e. Alaska’s shorter summer
season versus the consistently warmer island states and territories). For AMS’ purposes, we are
targeting the end of the fiscal year (September 30, 2020) as the final date of the growing season.
To meet that target, the grant application can go out no later than 30 days in advance. This
emergency will provide some flexibility in that timeline.
In April 2020, AMS confirmed that $5 million of the authorized $10 million had been
appropriated for fiscal year 2020. Additionally, AMS received confirmation in April 2020 from
USDA’s Office of the Chief Financial Officer that the Catalog of Federal Domestic Assistance
(CFDA) number, required of any Federal funding opportunity, had been assigned. Once AMS
received both the CFDA number and funding appropriation, AMS was able to immediately

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finalize and collate the documents to complete the full information collection package for the
Office of Management and Budget’s (OMB) emergency review and approval by May 18, 2020.
We request emergency approval of the information collection by July 15, 2020, to meet AMS’
goal to award the $5 million in MGFS Program funding by the end of the 2020 growing season.
Eligible states are required to follow new application procedures and to submit a plan for a
competitive grant process, as well as conduct outreach to communities or regions in that eligible
state with the highest degree of food insecurity. AMS will publish the Request for Applications
that establishes application requirements, the review and approval process, and grant
administration procedures. The MGFS Program is executed in accordance with the Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2
C.F.R. Part 200).
In addition to being critical to the Agency’s mission, the MGFS Program will specifically assist
with COVID-19 response. OMB recently recognized the importance of prioritizing Federal
efforts to respond to COVID-19 by directing “all Federal departments and agencies to marshal all
legally available federal resources to combat the crisis,” including issuance of two recent memos
(M-20-17 and M-20-20). This important program directly relates to the eligible State’s ability to
respond to food security issues, which have been exacerbated by the COVID-19 pandemic.
The States eligible for this grant import a significant amount of their food, resulting in high
prices, especially in rural areas. This puts their citizens at risk when food supply systems break
down, as has occurred during the COVID-19 pandemic. This specific program focuses on
individuals, tribes, communities, or nonprofits that wish to grow their own food, and the
streamlined application process reduces barriers that exist with other funding mechanisms. Funds
may be used for the purchase of tools, soil, seeds, plants, grow towers, composting units,
hydroponic and aeroponic gardening systems, and other necessities for growing and preserving
food. The funds can also be used to expand areas under cultivation and extend the growing
season to build or repair fencing for livestock, including reindeer, to participate in agricultural
education, to create or expand sale of locally grown crops and meats, and to engage in other
activities to increase food security.
The MGFS Program has received significant Congressional interest in expediting the awarded
funds, as this program can directly benefit those affected by disrupted food supply chains. Those
interested in the program may experience additional application burden should the MGFS
Program implementation be further delayed (i.e. limited time for sub-recipients to use the
funding for the 2020 growing season, short application turnaround time for eligible applicants
and sub-recipients, continued COVID-19-related business hardships, etc.).
In compliance with the Office of Management and Budget’s (OMB) regulations (5 C.F.R. Part
1320) which implement the Paperwork Reduction Act of 1995 (Pub. L. 104-13), the information
collection and recordkeeping requirements that may be imposed by this action are submitted to
OMB for emergency review and approval. The additional reporting requirements would not
become effective prior to OMB review. Once approved the collection will be merged with 05810240.
Attached are the OMB 83-I, the Supporting Statement, AMS-71 spreadsheet, and Congressional
Letter.