PART A Justification

ENHANCING FOOD STAMP CERTIFICATION:
FOOD STAMP MODERNIZATION EFFORTS

Supporting Statement for Request for Clearance
November 13, 2007

Prepared for:
U.S. Department of Agriculture
Office of the Chief Information Officer (OCIO)
Information Management Division (IMD)
1400 Independence Ave., S.W.
Washington, DC 20250

Prepared by:
The Urban Institute
2100 M Street, N.W.
Washington, DC 20037

November 13, 2007

Table of Contents
A. JUSTIFICATION............................................................................................................. 1
1.
Circumstances that make the collection of information necessary ...... 1
2.
How, by whom, and for what purpose the information is to be used . 2
3.
Use of automated, electronic, mechanical, or other technological
collection techniques or other forms of information technology ........... 3
4.
Efforts to identify duplication .............................................................................. 4
5.
Minimizing impact on small business or other small entities.................. 4
6.
Consequences if the collection is not conducted ......................................... 5
7.
Special circumstances ............................................................................................ 5
8.
Consultation with persons outside the agency............................................. 5
9.
Payment or gift to respondents.......................................................................... 6
10. Assurances of confidentiality ............................................................................... 7
11. Questions of a sensitive nature .......................................................................... 7
12. Burden estimates ..................................................................................................... 8
12(a). Estimate of respondent burden hours ..................................................... 8
12(b). Estimate of burden cost to respondents ............................................... 11
13. Total annual cost burden to respondents or record keepers ................ 12
14. Annualized cost to the Federal government................................................ 12
15. Reasons for any program changes or adjustments.................................. 12
16. Tabulation and publication ................................................................................. 12
17. Approval to not display the OMB expiration date...................................... 15
18. Exception to the certification statement ....................................................... 15
B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL
METHODS ................................................................................................................................ 16
1.
Potential respondent universe and sampling .............................................. 16
2.
Procedures for the collection of information................................................ 20
3.
Methods to maximize response rates and to deal with issues of nonresponse .................................................................................................................... 23
4.
Tests of procedures or methods to be undertaken................................... 25
5.
Individuals consulted on statistical aspects of the design and the
contractor .................................................................................................................. 28
APPENDICES
Appendix
Appendix
Appendix
Appendix

A:
B:
C:
D:

Appendix E:

State, Local, and Partner FSP Modernization Survey Instruments
Data Collection Guides for Case Study Visits
Chart of Objectives and Questions by Information Source
60-Day Notice of Information Collection as Published in the Federal Register
and Public Comments
Sample Advance Letters to Survey and Case Study Respondents

November 13, 2007

A.

JUSTIFICATION

The following supporting statement provides detailed information on the proposed
information collection activities for a three-year study entitled, “Enhancing Food Stamp
Certification: Food Stamp Modernization Efforts.” This study, led by the U.S. Department of
Agriculture (USDA), Food and Nutrition Service (FNS), will be a one-time information
collection to document and analyze Food Stamp Program (FSP) modernization efforts
undertaken by states.

1.

Circumstances that make the collection of information necessary

The Food Stamp Program provides low-income individuals and families with assistance
to purchase eligible food items for home consumption through state-operated programs. Over
the past decade, increased awareness of the importance of the FSP as a basic nutritional safety
net, as well as a critical work support, has led to a variety of federal and state efforts to increase
program access and participation. At the same time, states are focusing on ways to increase
operational and administrative efficiency and program integrity. To meet these goals, states are
making a variety of changes in their policy, procedural, and organizational approaches to food
stamp application, case management, and recertification.
Congress has allocated funds for the purpose of evaluating and collecting data on the FSP
as part of Section 17(a)(1) of the Food Stamp Act of 1977, as amended through P.L. 106-171,
February 11, 2000. The authorizing legislation states that “The Secretary [USDA] may, by way
of making contracts with or grants to public or private organizations or agencies, undertake
research that will help improve the administration and effectiveness of the food stamp program
in delivering nutrition-related benefits.”
In an effort to document, assess, and inform state modernization efforts, USDA’s Food
and Nutrition Service, which administers the FSP, initiated a comprehensive study to: 1)
develop a national inventory of FSP modernization efforts across states; 2) document key
features and outcomes associated with food stamp modernization; 3) systematically describe and
compare techniques states are using to modernize the FSP; and 4) identify promising practices.
Study results will inform FNS policy discussions, provide technical and procedurally relevant
information to states, and provide a comprehensive and centralized source of information for
assessing ways to improve food stamp certification and responding efficiently to the variety of
stakeholder queries received.
Specifically, the study will focus on four types of modernization to food stamp
application, case management, and recertification: 1) policy changes; 2) organizational
reengineering; 3) increased or enhanced use of technology; and 4) partnering arrangements with
businesses and nonprofit organizations. This three-year study will examine the outcomes
associated with program access and customer service, administrative costs, and program
integrity.

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November 13, 2007

To address these objectives, data will be obtained through two main collection methods:
large scale surveys of state and local food stamp administrators and community partners; and
case studies of a smaller set of states that have pursued different packages of modernization
strategies. In addition, this study will utilize the information available in FNS’ database on food
stamp waivers. The survey will collect data to develop a national inventory of modernization
efforts, conduct cross-state analyses, and select case study sites. The case studies, a more indepth examination of 14 states, will include interviews with local and state-level staff,
community organizations and for-profit contractors; and focus groups with food stamp
participants, applicants, and eligible nonparticipants. The case studies will provide a rich source
of qualitative data about FSP modernization activities from the perspective of workers,
participants, and partner organizations that will complement the survey data. The case studies
will incorporate extant data to describe FSP performance before and after the implementation of
state modernization efforts with respect to application approval rates, participation rates,
payment accuracy, administrative costs, and other outcomes that states may be tracking. (The
instruments for these activities can be found in Appendices A-B.)

2.

How, by whom, and for what purpose the information is to be used

This study presents an important opportunity for FNS to examine and promote successful
modernization efforts by providing a comprehensive, national picture about modernization
efforts, describing the perceived effect on program outcomes, sharing information to help avoid
implementation pitfalls, and promoting promising practices to multiple stakeholders. The key
audiences for the study’s results—disseminated through a final report, briefing materials, and a
public use database—are national and regional FNS officials, state and local food stamp
officials, non-profit service providers, and advocates.
The key objectives of the study—to be met by collecting and analyzing data from states
and local areas—are to:
1. Provide a national description and comparison of state efforts to modernize the FSP.
2. Describe the factors that drive states to modernize their food stamp services.
3. Describe and compare the policy changes pursued as part of food stamp modernization.
4. Identify the ways that states re-engineer administrative structure and organizational roles
as part of food stamp modernization.
5. Describe and compare technology initiatives made to support food stamp modernization.
6. Describe and compare the non-profit community organizations that states partner with to
support food stamp modernization.
7. To the extent possible, document the relationship among food stamp modernization
initiatives, stakeholder satisfaction, and program outcomes.

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November 13, 2007

A chart of the study’s objectives and research questions is provided in Appendix C of this
supporting statement. This chart lists the objectives with the accompanying research questions
and the data sources that show how these questions will be addressed through the study
methodology.

3.

Use of automated, electronic, mechanical, or other technological collection
techniques or other forms of information technology

Respondents will be able to choose whether to respond on-line to an electronic version of
the survey or respond on a paper version to be returned by surface mail. Based on the research
team’s experience with web-only and mixed-mode surveys, along with USDA’s and the U.S.
Government Accountability Office’s (GAO) experience administering surveys of state FSP
directors, 1 it is expected that all of the respondents will have on-line access and Internet
experience. Furthermore, we expect that nearly all of them will choose to respond to the on-line
version of the survey.
The web-based versions of the surveys will be created in Ultimate Survey, a commercial
software application for development and administration of on-line surveys. The advantage of
the on-line survey is the automatic tabulation of responses that reduces both the hours of staff
time needed for survey processing and the possibilities for introducing errors into the data. The
automated skip patterns of the on-line survey also place less of a burden on the respondent than
the customary “if-then go to” instructions of a mail questionnaire. The web and paper versions
of the questionnaire will both be in modular formats that allow the primary respondent to pass
sections or questions on to other staff members who may be better equipped to address particular
topics.
It is expected that only a few respondents will select to use a paper version of the survey,
and therefore, the surveys are designed for completion online. Accordingly, web features (autopopulation of responses, for example) are used that are somewhat different from the paper
version. Based on previous experience, the reduction in burden on respondents outweighs the
possible mode bias. However, we will treat survey mode as paradata and check for any
indication of bias.

1

See Olander, Carol. 2007. “Nutrition Education in the Food Stamp Program: A National Description.”
Presentation, Office of Analysis, Nutrition, and Evaluation, Food and Nutrition Service. Washington, DC, February
21; U.S. Government Accountability Office. 2007. “Use of Alternative Methods to Apply for and Maintain Benefits
Could Be Enhanced by Additional Evaluation and Information on Promising Practices.” Report to the Chairman,
Committee on Agriculture, Nutrition, and Forestry, U.S. Senate, May. Washington, DC; and U.S. Government
Accountability Office. 2004. “Farm Bill Options Ease Administrative Burdens but Opportunities Exist to Streamline
Participant Reporting Rules among Programs.” Report to the Committee on Agriculture, Nutrition, and Forestry,
U.S. Senate, September.
3

November 13, 2007

4.

Efforts to identify duplication

No systematic effort has been undertaken to catalogue, describe, compare, and assess the
full range of modernization efforts that are being planned and implemented across all the states.
The contractor for this study, the Urban Institute, conducted an in-depth literature review of
existing studies and reports on food stamp modernization efforts. The findings show that a
handful of states have taken the initiative to describe different aspects of their modernization
initiatives.
One of these studies is the FNS’ Case Study on Florida’s Food Stamp Modernization
Initiative. This project is in the final stages of data analysis and report writing (a draft report was
submitted to FNS in February 2007). This report, which provides a detailed description of the
modernization model in one state, will help to inform this study with respect to providing
considerable background information on Florida as well as suggested methods for categorizing
and analyzing information.
In addition, GAO recently completed a report to the U.S. Senate Chairman of the
Committee on Agriculture, Nutrition, and Forestry, entitled “Food Stamp Program: Use of
Alternative Methods to Apply for and Maintain Benefits Could Be Enhanced by Additional
Evaluation and Information on Promising Practices.” The GAO report, released in May 2007,
details a subset of the alternative methods to apply for and maintain food stamp benefits such as
use of call centers and on-line applications and recertifications. While the study collected data
from 50 state food stamp administrators and visits to five states, the range of modernization
strategies was more selective than the proposed study; outcome data were not included; and the
analysis of trends and patterns was limited. In fact, GAO recommended that FNS both
“disseminate and regularly update information on promising practices” and “include projects that
would determine the effects of alternative methods.” 2
This study will address the first GAO recommendation by comprehensively documenting
the modernization efforts across the 50 state programs (plus the District of Columbia) in each of
the broad but well-defined categories of food stamp modernization and by measuring any
changes in participation, administrative cost, and payment accuracy that occur with the
introduction of program changes. 3 Study results will be used to inform FNS and guide states as
they look to develop or enhance modernization efforts. In addition, this study will create a
national inventory of modernization efforts and a public use database for this information to be
disseminated.

5.

Minimizing impact on small business or other small entities

While the survey and case study respondents are mainly state and local government
officials, some of the local partner respondents may be small businesses (for-profit service
providers) and small entities (community-based and faith-based non-profit service providers). It
2

See U.S. Government Accountability Office 2007, p. 36.
To address the second GAO recommendation, a series of experiments with random assignment to alternative
program conditions would be required. Such a study exceeds the available resources.

3

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November 13, 2007

is important to collect data from these respondents to get a complete picture of how services are
delivered. We anticipate that only a very small portion of the 150 community representatives
and contractors surveyed and 84 community representatives and contractors interviewed will be
small entities. A shorter version of the survey (in Appendix A) and of the site visit discussion
guide (in Appendix B) will be administered to respondents who are local partners in order to
minimize their burden. The web versions of the surveys, including the one for the local partners,
incorporate skip patterns, so the local partner respondents can move through the survey questions
with efficiency, especially if they provide fewer services. The information requested in both the
survey and the case study data collection efforts has been held to an absolute minimum required
to answer the research questions and minimize the burden on the respondents.

6.

Consequences if the collection is not conducted

While several states have documented their efforts to modernize their FSPs, no
comprehensive cross-state documentation and analysis of these efforts are currently available.
This study will provide a national inventory of modernization efforts in all states and analysis to
identify the promising practices as well as challenges to implementing these efforts. Without
this study, FNS and state food stamp agencies will have to rely on the information that is
provided for individual modernization initiatives. Such information is not integrated, uniform, or
timely – thus making access and application a challenge.

7.

Special circumstances

This information collection has none of the following special circumstances that would
require respondents to: report information more than quarterly; prepare a written response fewer
than 30 days after receipt; submit more than an original and two copies of documents; and retain
records for more than three years. In addition, this collection does not require the use of
statistical data classification that has not been reviewed by OMB, or include a pledge of
confidentiality that cannot be supported by law, disclosure and data security policies that are
consistent with the pledge, and sharing of data with other agencies for compatible confidential
use.

8.

Consultation with persons outside the agency

A notice was published in the Federal Register (72 FR 32833) on June 14, 2007, to
solicit comments on the FNS data collection prior to submission of this OMB clearance request.
(A copy of this notice and any public comments are provided in Appendix D.)
One public comment was received in response to this notice. The commenter requested
that his organization be included in the sample for the survey and be interviewed during the case
study phase. While it is likely that this organization will be selected to complete the survey
because of its work with the state FSP on issues related to program accessibility and operations,
no change to the sampling strategy or the case study selection process will be made to include

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November 13, 2007

specific organizations. Another suggestion by the commenter was that there should be some
coordination between FNS’s data collection effort and the organization’s own surveys to avoid
duplication. The organization will survey food stamp participants in one state, so there is little
potential for duplication with this proposed national data collection effort that will survey
administrators and service providers. Therefore, no formal coordination will occur, but the
survey efforts will certainly be discussed with the organization should its state be selected for a
case study. In addition, the commenter suggested that the study should examine the
administrative costs of food stamp modernization efforts. While we will explore the subject of
administrative costs with case study respondents, the survey does not address administrative
costs as obtaining consistent information across the varied modernization initiatives would
dramatically increase the burden on respondents. Finally, the commenter suggested that the study
should conduct discussion groups with low-income individuals. This activity is currently planned
during the study as described in this Supporting Statement.
While no formal advisory group of outside experts was convened, representatives of
national organizations were interviewed about issues related to food stamp modernization efforts
in the states. Their feedback was used to select and frame topics to address in the data collection.
These organizations were:
x
x

American Public Human Services Association, Larry Goolsby and Elaine Ryan
National Governors Association Center for Best Practices, Susan Golonka and
Courtney Smith
National Conference of State Legislatures, Lee Posey and Anne Morse
Center on Budget and Policy Priorities, Stacy Dean, Dottie Rosenbaum, and Colleen
Pawling
Food and Research Action Center, Ellen Vollinger
Second Harvest, Doug O’Brien
U.S. Government Accountability Office, Cathy Roark

x
x
x
x
x

No contact was made with outside consultants on the estimated burden of the case study
instruments, nor on the design of the study. Survey instruments were reviewed by staff at the
GAO, the Washington, DC Department of Human Services, and the California Association of
Food Banks.

9.

Payment or gift to respondents

Focus group participants will receive a small remuneration of $20 plus a light meal or
refreshments to increase the participation numbers. These focus groups will be comprised of
food stamp participants, applicants, or eligible nonparticipants.
Incentives have been shown to be effective in increasing overall response rates in all
modes of surveys, 4 and by extension in focus groups. Remuneration is crucial to helping achieve
4

Singer, Eleanor (2002). “The Use of Incentives to Reduce Nonresponse in Household Surveys.” In Survey
Nonresponse, eds. Robert M. Groves, Dan A. Dillmon, John L. Eltinge, and Roderick J.A. Little. p. 163-77.

6

November 13, 2007

an unbiased sample of participants and eligible nonparticipants and to reach the target response
rates. The provision of such a fee will help with the recruitment of respondents to encourage
them to participate in the focus group. Further, some focus group participants may incur direct
costs for attending the focus group, and consequently might not be able to participate without
remuneration. Thus, $20 is a reasonable compensation for any inconvenience and cost
associated with participation in the focus group during the data collection period.

10.

Assurances of confidentiality

For the study, FNS’s contractor, the Urban Institute, will ensure that data are treated in a
confidential manner by: 1) releasing no data in a form that identifies individual respondents by
name; 2) only requiring focus group participants to provide their first name during the session
and implementing procedures to separately and securely store participant signature forms
required for accounting purposes to acknowledge receipt of the cash stipend; 3) keeping any
documents and notes that contain names from the focus groups in a locked drawer and
destroying them at the end of the project; and 4) combining information collected through
interviews across other respondents in the same category and reporting the information in
aggregate form.
This study is also under the purview of the Urban Institute’s Institutional Review Board
(IRB). To receive IRB approval for this study, the data collection effort must adhere to the
following principles:
x
x
x
x
x

Subjects are informed of the nature of the research and how it will be used, and their
consent either obtained or explicitly waived, where risks to them are determined to be
minimal.
Adequate provision is made to protect the privacy of subjects and to maintain
confidentiality of data, where promised and as appropriate.
Risks to subjects are minimized to the extent possible within research designs.
Risks to subjects (from the research) are reasonable in relation to anticipated benefits
(from the research).
The selection of subjects is as equitable as possible (the burdens and benefits of the
research are fairly distributed) and particular attention is paid to research involving
vulnerable populations and protected health information.

A copy of the IRB approval and standards will be available from the Urban Institute.

11.

Questions of a sensitive nature

Many modernization efforts, such as waiving face-to-face interviews and creating online
applications, are designed to improve access. These provisions may have differing effects on
individuals with disabilities. Therefore, we are asking one question of a sensitive nature related
to whether or not focus group participants have a disability that hinders their ability to work or
go outside of their homes. This question will be asked on the Focus Group Participant

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November 13, 2007

Information Form that will be completed by all focus group participants. No identifying
information will be collected in conjunction with this question.

12.

Burden estimates
12(a). Estimate of respondent burden hours

The data collection efforts will involve surveying and interviewing respondents
knowledgeable about modernization efforts at the state and local level. The response pool
includes state-level FSP officials and staff (e.g., directors, policy and operations staff,
management information systems and data reporting staff, call center staff); local food stamp
office staff (e.g., directors, office supervisors, eligibility workers, MIS/reporting staff); staff from
community organizations and contractors assisting with food stamp modernization efforts; and
food stamp applicants, participants, and eligible nonparticipants.
It is estimated that the study will collect data from approximately 1,275 respondents.
This estimated number represents the sum of 135 state-level FSP staff, 402 local-level FSP staff,
234 community organization or contractor staff involved in food stamp modernization efforts,
and 504 food stamp applicants, participants, and eligible nonparticipants. Most state and some
local FSP staff and community organization and contractor staff may receive the survey and be
interviewed for this study, but this overlap cannot be predicted.
The times estimated in the table below are based on a pretest of the survey and case
study instruments. Please refer to Appendices A and B for the study’s data collection instruments
and to section B.4 for an explanation of the pretesting process.
Survey Burden. The estimate of response time for the Survey of State Food Stamp
Directors is based upon a pretest conducted with three state food stamp directors and reviews by
staff from GAO and the Washington, DC Department of Human Services. The time to complete
the survey for the three pretest states was 45 minutes, 2.5 hours, and 4 hours, respectively. We
believe that the range in time reflects the extent and timing of state FSP modernization activities,
as those factors determine the applicable survey sections to be completed. Although some
revisions were made to the survey instrument in response to pretest findings, we believe they
would not significantly change the estimated time required to complete the survey. We have
assumed an average burden of 2.5 hours per state respondent.
The estimate of response time for the Survey of Local Food Stamp Directors is based
upon a pretest conducted with two county food stamp offices and reviews by staff from GAO
and the Washington, DC Department of Human Services. The range of time to complete the
survey was 2.5 to 4.5 hours. We believe that the range in time reflects the extent and timing of
county FSP modernization activities, as well as variations in the role of counties in state
modernization decisions. The respondent that reported needing 4.5 hours to complete the survey
indicated that a large part of that time was spent conferring with colleagues about responses, in
part to provide feedback for the pretest. Although some revisions were made to the survey
instrument in response to pretest findings, we believe they would not significantly change the

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November 13, 2007

estimated time required to complete the survey. For purposes of estimating burden, we have
assumed an average burden of 2.5 hours per local agency respondent.
The advance letter (Appendix E) to State Food Stamp Agencies asks states to identify
counties and organizations or vendors involved in significant FSP modernization activities. The
advance letter to County/Local Offices (Appendix E) requests county/local offices to identify
primary partner organizations or vendors involved in local FSP modernization activities. We
have estimated that it will take one hour for respondents to refer this request to appropriate staff
and provide contact information.
The estimate of response time for the Partner Organization Survey is based upon a pretest
conducted with three community-based organizations and reviews conducted by the GAO and
the California Association of Food Banks. The range of time to complete the survey was 25
minutes to 3 hours. We believe that the range in time reflects the variation in the extent of
partner involvement in FSP modernization activities. Although some revisions were made to the
survey instrument in response to pretest findings, we believe they would not significantly change
the estimated time required to complete the survey. For purposes of estimating burden, we have
assumed an average burden of 1.5 hours per partner organization respondent.
Case Study Burden. In each of the states and counties selected, in-depth interviews will
be conducted with state level officials, local agency administrators and staff, and partner agency
staff (section B.1 describes potential respondents). Questions will be open-ended and tailored to
job responsibilities of the individual respondents.
All case study instruments, with the exception of the focus group instruments, were
pretested during the initial phase of the project (see B.4 for more information). Four states were
visited and interviews were conducted using the semi-structured guides (State Agency, Local
Agency and Partner Discussion Guides), applicant/participant intercept interview guide, and onsite observation guide. The staff that conducted the site visits provided feedback on the
instruments on aspects such as timing, redundancy, and gaps in content, and refined the case
study instruments accordingly. The test interviews using all three discussion guides took
approximately 30 minutes to 1.5 hours and, thus, a burden estimate of 1 hour is provided for each
of these instruments. The applicant/participant intercept interview and on-site observations are
intended as short, on-the-spot data collection efforts from participants and testing of these case
study instruments indicated a burden estimate of approximately 6 minutes for each instrument.
Burden estimates for the focus groups are based on prior experience with similar data collection
instruments and respondents.

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November 13, 2007

Description
State-Level: Survey
(Appendix A—State Food
Stamp Agency Survey)
State-Level: Interview
(Appendix B-1— State Food
Stamp Agency
Administrators and Staff)
Local Level FSP: Survey
(Appendix A—Local Food
Stamp Agency Survey)
Local Level FSP: Interview
(Appendix B-2— Local Food
Stamp Office Administrators
and Staff)
Local Community Reps &
Contractors: Partner
Organization Survey
(Appendix A—Partner
Organization Survey)
Local Community Reps &
Contractors: Partner Agency
Interviews (Appendix B-3—
Partner Agency
Administrators and Staff)
Food Stamp Participants:
Focus Groups (Appendix B5— Focus Group Discussion
Guide: Guide 1 – FSP
Participants)
Focus Group Food Stamp
Program Participants and
Eligible Nonparticipants:
Information Form (Appendix
B-5— Focus Group
Participant Information
Form:
Food Stamp Program
Participants and Eligible
Nonparticipants)

No. of
Respondents
51

No. of
Responses
per
Respondent
1

Estimated
Total
Responses
51

Estimated
Hours per
Response
2.5

Total
Burden
127.5

84

1

84

1

84

150

1

150

2.5

375

252

1

252

1

252

150

1

150

1.5

225

84

1

84

1

84

168

1

168

1.34

225.1

336

1

336

.16

53.8

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November 13, 2007

Description
Food Stamp
Applicants/Participants:
Intercept Interview
(Appendix B-4—
Applicant/Participant
Intercept Interview)
Eligible Nonparticipants:
Focus Groups (Appendix B5— Focus Group Discussion
Guide: Guide 2 – Eligible
Nonparticipants )
Letters from UI to State Food
Stamp Agencies (Appendix
E—Urban Institute Survey
Advance Letter to States)
Letters from UI to
Counties/Local Offices
(Appendix E—UI Survey
Advance Letters to
Counties/Local Offices)
TOTALS

No. of
Respondents
168

No. of
Responses
per
Respondent
1

Estimated
Total
Responses
168

Estimated
Hours per
Response
.10

Total
Burden
16.8

168

1

168

1.34

225.1

51

1

51

1

51

150

1

150

1

150

1,812
responses

14.7
hours

1,869.3
Hours

1,812
respondents

12(b). Estimate of burden cost to respondents
Estimates of annualized costs to the respondents are based on an hourly wage rate for the
following four respondent categories: State-Level Government Staff; Local-Level Government
Staff; Local Community Representatives and Contractors; and Food Stamp Participants,
Applicants, and Eligible Nonparticipants. National median wage estimates are used as the
survey and case studies will be fielded in all geographic regions. The source for the wage data is
the Bureau of Labor Statistics, May 2005 National Industry-Specific Occupational Employment
and Wage Estimates, Median Hourly Wages, and the current minimum wage.

Type of Respondent
State-Level Government Staffa
(Survey and Interview)
Local-Level Government Staffb
(Survey and Interview)
Local Community Representatives and Contractorsc
(Survey and Interview)

Median
Hourly
Wage
Rate
$18.38

Total
Respondent
Costs
$4,824.75

777

$16.78

$13,038.06

309

$12.57

$3,884.13

Total
Burden
Hours
262.5

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Type of Respondent
Food Stamp Participants, Applicants, and Eligible
Nonparticipants d
(Focus Group/ Applicant/ Participant Intercept
Interview)
Total

Total
Burden
Hours
520.8

Median
Hourly
Wage
Rate
$5.15

1,869.3

Total
Respondent
Costs
$2,682.12

$24,429.06

a

NAICS 999200 – State Government
NAICS 999300 – Local Government
c
NAICS 624200 – Community Food and Housing, and Emergency and Other Relief Services
d
Minimum wage is used for this respondent category as most have low education and skill levels and approximately
80 percent are not working at this intercept point.
b

13.

Total annual cost burden to respondents or record keepers

There are no capital/start-up or ongoing operation/maintenance costs associated with this
information collection.

14.

Annualized cost to the Federal government

The total cost of this study including survey administration and site visits is
approximately $1,180,029 over a 36-month period. This amount covers the costs associated with
background research, the design of the data collection instruments, data collection activities,
analysis, and reporting. The following breaks down the cost for the study by year:
Year 1
Year 2
Year 3

15.

$288,568 (October 2006 – September 2007)
$736,111 (October 2007 – September 2008)
$155,351 (October 2008 – September 2009)

Reasons for any program changes or adjustments

This data collection plan is new and does not represent any changes in estimates of
respondent burden or cost.

16.

Tabulation and publication

The information collection and data analysis will occur in two concurrent phases after
OMB approval. The survey, which comprises the first phase of data collection, will be fielded in
early 2008 and data will be analyzed in 2008. The following shows the schedule for the survey
phase of the study:

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Field surveys

January-March 2008

Submit table shells

April 2008

Conduct survey data analysis

April-May 2008

Submit draft interim report

July 2008

Conduct briefing

August 2008

Submit revised interim report

September 2008

Submit interim report

October 2008

The case study phase of the study will occur beginning in July 2008 as follows:
Disseminate state selection letter

July 2008

Conduct site visits

September-November 2008

Submit table shells for final report

November 2008

Conduct case study data analysis

November 2008 - January 2009

Once both phases are completed by mid-January 2009, a final report will be developed
and a public use database will be created. The final report and public use database will be made
available in the second half of 2009. The final report will categorize modernization efforts
across states; compare information on outcomes, success and challenges; and discuss
crosscutting issues. The separate components of the final report will include: the stand-alone
summary, executive summary, main body of the report, and directory of key food stamp
modernization features. It is anticipated that main sections of the final report will describe key
findings from the individual case studies, promising practices, and crosscutting issues.
The schedule for their development is as follows:
Submit draft final report

March 2009

Conduct briefing

May 2009

Submit file documentation, codebook and data
files

July 2009

Submit final report

July 2009

Submit additional final report copies after FNS
clearance

August 2009

Project reports will be made available by FNS and the Urban Institute by posting them to each
organization’s web-site. The public use data files will be made available by FNS for secondary
data analyses by interested stakeholders.
Tabulation and Statistical Analysis: Survey. Data analysis in the survey phase will
provide a comprehensive and comparative description of the policies, organizational
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infrastructure, and operational procedures that states are pursuing to enhance food stamp
application, recertification, and case management. The analysis will capture state and local-level
experiences in carrying out modernization efforts and provide insights into the variations
between states and between local areas that may exist.
The analysis will focus on taking the large amounts of information collected through the
surveys and presenting it in summary formats that allow FNS and other stakeholders to quickly
grasp the range of initiatives in a state and the range of states undertaking a particular type of
initiative. We will also summarize details of the policy initiatives, such as whether they are
statewide or limited to specific counties or regions, and whether nonprofit organizations and forprofit firms are involved. Other tables will summarize the reasons given by respondents for the
adoption—or nonadoption—of a particular type of initiative, along with the intended and
perceived effects on outcomes such as participation, payment error, and administrative costs.
These results will be used to identify associations between modernization strategies and a variety
of outcomes that will be explored further in the subsequent case study and integrative analysis.
Tabulation and Statistical Analysis: Case Studies. Case study analysis will synthesize
the qualitative data collected through the 14 site visits, where interviews with multiple
informants will occur. This analysis will focus on the scale and scope, unique features,
implementation schedules, characteristics of participants, state characteristics, perceptions of
successes and challenges, and lessons learned. Analytic files from site visit data will be
developed. Tables will be developed for the case studies to identify and categorize models of
modernization and look for trends in modernization efforts across states.
At this point, analysis from both phases of the information collection will be synthesized
to produce a final report and briefing. This overall analysis involves identifying patterns and
themes and synthesizing the data to suggest models and interpretations supported by the data.
This process is the part of analysis that sharpens, sorts, focuses, discards, and organizes data in
such a way that conclusions can be drawn and verified. The analysis will integrate case study
data with relevant information from state, local, and partner surveys as well as the FNS national
databank, public use and quality control data, FNS publications, and state-specific data sources.
The qualitative information gleaned through case studies will be essential to interpreting
outcomes in 14 of the states. Interviews with program staff and other stakeholders will help us
put outcomes in the context of the goals of modernization and the demographic, economic, and
social service climate of each state. They will also help us determine which initiatives may be
showing short-run costs but have large long-run savings potential (e.g., implementing a new
eligibility database, where two eligibility systems must often run concurrently during the
transition but the new system will be more efficient when fully implemented). Or, there may be
cases where there are short-term administrative savings but significant longer-term costs may
accrue (for instance, when state staff are laid off as contractors assume eligibility functions
resulting in short-term cost savings, but significant service capacity and expertise with eligibility
determination in the longer term may be lost).
In the integrative analysis, we will pay particular attention to the criteria for identifying
promising practices and evaluating their generalizability to other states. Our highlights of

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promising practices will include those states in which more than one outcome has improved, or
where at least one outcome has improved without harming outcomes in other domains. In other
words, we would prefer to choose initiatives that have improved the efficiency and effectiveness
of the FSP without harming any of the program’s major goals. Our first preference would be to
highlight modernization initiatives where quantitative data demonstrate a significant positive
impact, and that impact is attributable to the initiative. We may also choose to highlight
initiatives that may not yet have shown a demonstrable impact, but have done no harm and show
great potential for long-run improvement, according to the stakeholders responding to our study.

17.

Approval to not display the OMB expiration date

The agency plans to display the expiration date for OMB approval on all data collection
instruments. Please see Appendices A-B.

18.

Exception to the certification statement

The agency is able to certify compliance with all provisions under Item 19 of OMB Form
83-I.

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