SUPPORTING STATEMENT – JUSTIFICATION
Explain
the circumstances that make the collection of information
necessary.
The
attached form FNS-648, WIC Local Agency Directory Report, which is
submitted for revision, is used in the administration of the Special
Supplemental Nutrition Program for Women, Infants and Children
(WIC).
Due
to the increase in the number of WIC State agencies, this revision
is an adjustment in the number of respondents from 88 to 90. The
WIC Program is authorized by section 17 of the Child Nutrition Act
(CNA) of 1966 (42 U.S.C. 1786), as amended. Section 17(a) of the
CNA explains the WIC Program's mission, as follows:
“Congress
finds that substantial numbers of pregnant, postpartum, and
breastfeeding women, infants, and young children from families with
inadequate income are at special risk with respect to their physical
and mental health by reason of inadequate nutrition or health care,
or both. It is, therefore, the purpose of the program authorized by
this section to provide, up to the authorization levels set forth in
subsection (g) of this section, supplemental foods and nutrition
education through any eligible local agency that applies for
participation in the program. The program shall serve as an adjunct
to good health care, during critical times of growth and
development, to prevent the occurrence of health problems, including
drug abuse, and improve the health status of these persons.”
The
Food and Nutrition Service (FNS) of USDA administers the WIC Program
by awarding cash grants to State agencies (generally State health
departments). The State agencies award subgrants to local agencies
(generally local health departments and nonprofit organizations) to
deliver program benefits and services to eligible participants.
This administrative structure follows section 17(c)(2) of the CNA,
which reads, “Subject to amounts appropriated to carry out
this section under subsection (g)--(A) the Secretary shall make cash
grants to State agencies for the purpose of administering the
program, and (B) any State agency approved eligible local agency
that applies to participate in or expand the program under this
section shall immediately be provided with the necessary funds to
carry out the program.”
As part of their State Plan
submission, State agencies identify the local agencies that will
provide WIC services. Local agencies authorized to furnish WIC
participants with supplemental foods, nutrition education,
breastfeeding promotion and support activities, and referrals to
related health services are subject to change. New local agencies
may be selected to operate the WIC Program, and local agencies
already in operation may be disqualified for continued operation.
Additionally, local agencies may relocate, resulting in address
changes. The procedures for WIC local agency selection, expansion,
reduction, and disqualification are explained in paragraph 246.5 of
WIC Program Regulations. WIC State agencies use the FNS-648 to
report additions and deletions of local agencies operating the WIC
Program and local agency address changes, when such changes occur.
Indicate how, by whom, and
for what purpose the information is to be used.
FNS
maintains a local agency directory that lists the names and
addresses of all WIC local agencies. The WIC local agency directory
serves as the primary source of data on the number and location of
local agencies and is published annually. It is used to refer
individuals to the nearest source of WIC Program services and to
maintain continuity of program services to migrant and other
transient participants. It is also used as a mailing list to
provide local agencies with technical assistance manuals and other
information.
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.
According
to the Government Paperwork Elimination Act (GPEA), federal agencies
are required to provide for electronic submission of information in
lieu of paper submission. FNS’s new electronic reporting
system, the Food Programs Reporting System (FPRS), allows all WIC
State agencies to directly submit FNS-648 data electronically. The
FNS-648 report contains a small amount of data and is completed on
an as-needed basis, rather than at regular intervals.
Describe
efforts to identify duplication.
This
information collection does not duplicate other reporting
requirements. State agencies only report changes to the existing
local agency listing. The frequency and amount of data reported
varies.
If
the collection of information impacts small businesses or other
small entities, describe any methods used to minimize burden.
Many
of the Indian State agencies are small organizations. FNS minimizes
their burden, as well as the burden on all other State agencies, by
requesting that State agencies only report changes to existing
data.
Describe the consequences
to Federal program or policy activities if the collection is not
conducted or is conducted less frequently.
Less
frequent collection will result in a WIC local agency directory and
mailing list that is so outdated as to impede communications and
continuity of program services to migrant and other transient
populations.
Explain
any special circumstances that would cause an information collection
to be conducted in a manner that is inconsistent with the general
information collection guidance in 5 CFR 1320.6.
This
collection is not inconsistent with 5 CFR 1320.6.
If applicable, provide a
copy and identify the date and page number of publication in the
Federal Register of the agency’s notice. Describe efforts to
consult with persons outside the agency to obtain their views on the
availability of data and frequency of collection.
Consultation with representatives of those from whom information is
to be obtained.
A
60-day Federal Register Notice announcing FNS’ intention to
extend the use of form FNS-648 was published in the Federal Register
on October 3, 2007, Volume 72, Page 56331. No comments were
received in response to this notice.
Experts were consulted outside
of FNS. The FNS-648 collects the names, addresses and telephone
numbers of WIC local agencies which is simple contact information.
The State expert work group also decided the data would be collected
as changes occurred to keep the directory up-to-date. The data
elements collected and frequency of data collection remains
unchanged. But FNS’ Food Programs Reporting System (FPRS) will
now make it easier for State agencies to report changes in local
agency contact information to the directory.
When
necessary, State and regional officials provide ongoing advice or
feedback on form FNS-648. Monthly conference calls between FNS and
the National WIC Association Funding Committee provide an excellent
opportunity for State officials to communicate regularly to discuss
any potential change to the data elements or data form based on
feedback from State staff responsible for reporting the data.
Explain
any decision to provide any payment or gift to respondents.
No
payments or gifts are provided to respondents.
Describe
any assurance of confidentiality provided to respondents.
The
Department will comply with the Privacy Act of 1974.
Provide
additional justification for any questions of a sensitive nature,
such as sexual behavior and attitudes, religious beliefs, and other
matters that are commonly considered private.
There
are no questions of a sensitive nature included in this clearance.
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.
Number
of respondents - 90 State agencies X
Number of reports
submitted per year - 1 report X
Estimated
number of hours spent per report - 0.17 hours
Total
burden hours = 15.30 hours
If this request for
approval covers more than one form, provide separate hour burden
estimates for each form.
This
request for approval does not cover more than one form.
Provide estimates of
annualized cost to respondents for the hour burden for collection
of information.
Annualized
cost to 90 respondents is estimated to be $310.50,
as
follows:
Estimated
annual salary of respondent = $42,249*
Estimated salary per
hour ($42,249/2080) = $20.31*
Total burden hours (0.17) X
salary per hour ($20.31) = $3.45 per respondent/year.
Cost per
respondent per year $3.45 X 90 respondents = $310.50.
*These
salary estimates are the Mean Annual and the Mean Hourly wage
estimates for State Government employees for calendar year 2005
obtained from the U.S. Department of Labor, Bureau of Labor
Statistics (BLS). As of the date of this submission, the 2005 data
is the latest data available from BLS for State Government employee
salaries.
Provide an estimate of the
annual cost burden to respondents or record keepers resulting from
the collection of information. Cost estimates should be split into
two components: a total capital and start-up costs.
There
are no startup or annualized maintenance costs.
Provide estimates of the
annualized cost to the Federal government.
Annualized
cost to the Federal government is estimated to be $292.69.
The
cost to the Federal government is the cost for the regional staff to
process local agency directory changes submitted by each of the 90
State agencies.
GS9, step 1 regional program analyst =
$39,795*
Salary per hour ($39,795/2080) = $19.13*
Hours
spent per report at the region (review/data entry) (0.17 hour) X
number of reports submitted to regions (90) = 15.30 total
hours/year
Total hours (15.30) X salary per hour ($19.13) =
$292.69 total regional cost.
*These salaries are the
Annual and Hourly Rates obtained from the Office of Personnel
Management Salary Table 2008-General Schedule, Effective January
2008.
Explain
the reasons for any program changes or adjustments reported in items
13 or 14 of the OMB Form 83-1.
This
revision adjusts
the number of respondents from 88 to 90 because the total number of
WIC State agencies has increased from 88 to 90. However, it does
not increase the estimated time spent per report or the total annual
burden hours. The
estimated time spent per report remains 0.17 hours. The total
annual burden hours remain 15 hours, rounded, going from 14.96 to
15.30 hours.
For
collections of information whose results will be published, outline
plans for tabulation and publication.
As
the response to item #2 above indicates, FNS compiles the data
reported by WIC State agencies on form FNS-648 into a directory of
WIC local agencies. This information is used by FNS headquarters
and regional office staffs, and by State and local agencies in
administering the WIC Program.
If
seeking approval to not display the expiration date for OMB approval
of the information collection, explain the reasons that display
would be inappropriate.
We
are seeking approval to not display the expiration date. We have
developed an electronic form to allow WIC State agencies to report
electronically through the Food Programs Reporting System (FPRS).
To display the expiration date on the electronic form would require
updating the form’s programming each time its approval is
extended. To reduce the future burden associated with such updates,
we propose not including the expiration date on the electronic form
rather than updating it.
Explain
each exception to the certification statement identified in item 19,
“Certification for Paperwork Reduction Act Submissions,”
of OMB Form 83-1.
There
are no exceptions to the certification statement on OMB Form 83-1.
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT - JUSTIFICATION |
| Author | JOAN CARROLL |
| Last Modified By | Rgreene |
| File Modified | 2008-03-27 |
| File Created | 2008-03-27 |