Approved until
12/2004 in order to allow remaining states to put EBT systems into
place. All 8 states that currently do not have full EBT systems
should have those systems in place by at least 12/2004. This
package is in violation of the PRA and should be reported as a
violation in the next ICB. In the last terms of clearance, OMB
explicitly required that FNS must display the expiration date on
the FNS-259. FNS has acknowledged that the requirement was placed
on them, but that they made a conscious decision to ignore that
term of clearance because they did not feel that reprinting the
form was cost-effective. That argument should have been made prior
to OMB clearance; FNS cannot choose to ignore terms of clearance
without violating the Paperwork Reduction Act. FNS shall ensure
that, in the future, such willful violations are not allowed to
occur.
Inventory as of this Action
Requested
Previously Approved
12/31/2004
12/31/2004
11/30/2002
800
0
4,104
67
0
342
0
0
0
FNS needs reports from states on
coupon mail issuance, replacements, and return to calculate and
establish state liabilities and for FNS accounting.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.