Supporting Statement

Supporting Statement.doc

7 CFR Part 210, National School Lunch Program

OMB: 0584-0006

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NATIONAL SCHOOL LUNCH PROGRAM

OMB CLEARANCE NUMBER 0584-0006


Debbie Hill, Program Analyst

Food and Nutrition Service, USDA

Child Nutrition Division

Program Analysis and Monitoring Branch

Special Nutrition Program

3101 Park Center Drive

Alexandria, VA 22302

PH: 703-305-2638

[email protected]






















*Note: Upon OMB’s approval of the information collection request FNS will merge the burden hours with OMB control number 0584-0550 titled School Food Safety Program Based on Hazard Analysis and Critical Control Point Principles (HACCP).


1. Circumstances making the collection of information necessary.


The Richard B. Russell National School Lunch Act (NSLA P.L. 79-396), as amended authorizes the National School Lunch Program (NSLP). Section 10 of the Child Nutrition Act (CNA) of 1966 (P.L. 89-642), as amended, requires the Secretary of Agriculture to “prescribe such regulations as the Secretary may deem necessary to carry out this Act and the Richard B. Russell National School Lunch Act (NSLA).The Department of Agriculture provides States with general and special cash assistance and donations of foods to assist schools in serving nutritious lunches to children each school day. Participating schools must serve lunches that are nutritionally adequate and to the extent practicable, ensure that participating children gain a full understanding of the relationship between proper eating and good health. The Department of Agriculture prescribes the nutritional and other programmatic requirements for those school lunches in accordance with Section 9 of the NSLP, 42 U.S.C. 1758. The reporting and recordkeeping burdens associated with administration of the NSLP by States and participating schools proposed for extension under this notice reflect both those in place since this collection was extended in 2006, and an increase made in support of implementation of the Department of Agriculture’s rule, Procurement Requirements for the National School Lunch, School Breakfast and Special Milk Programs.



2. Purpose and use of the information.


This information is required to administer and operate this program in accordance with the NSLA. The Program is administered at the State and school food authority (SFA) levels and the operations include the submission and approval of applications, execution of agreements, submission of claims, payment of claims, providing monitoring and technical assistance.

The FNS forms used to collect this data are as follows:



FNS-10, REPORT OF SCHOOL PROGRAM OPERATIONS (OMB #0584-0002, expiration 05/31/2009), which is used to collect monthly and annual data for State administered programs. The data is used by the FNS administrator, the Child Nutrition Division, and the Financial Management Divisions to analyze progress in the programs and to make monthly adjustments to State agency funding requirements


FNS-777, FINANCIAL STATUS REPORT (OMB #0584-0067, expiration 12/31/2011, formerly the SF-269) which is used to collect quarterly reports for SAE Program costs. Meal reimbursement and cash-in-lieu of commodities is reported on the SF-269.


FNS-640, COORDINATED REVIEW EFFORT (CRE) DATA REPORT which is used by states to report on an annual basis the results of comprehensive on-site administrative evaluations conducted of school food authorities and schools operating the school lunch program.



3. Use of information technology, and reduce burden.


FNS is committed to complying with the E-Government Act, 2002 to promote the use of the Internet and other information technologies to provide increased opportunities for citizen access to Government information and services, and for other purposes.

All 57 state agencies participating in the NSLP transfer their completed FNS-10 and FNS-269 forms to FNS electronically via the Food Programs Reporting System (FPRS) at https://www.FPRS.usda.gov. In addition, each state agency maintains its own website to communicate electronically with SFAs in their state. The FNS-640 form is submitted via email from each participating State agency to FNS regional offices where it is reviewed and consolidated and then emailed to headquarters.


4. Efforts to identify duplication and use of similar information.


There is no similar information data collection available. This NSLP is administered solely by


FNS.


5. Impact on small businesses or other small entities.


Information being requested or required has been held to the minimum required for the intended use. Although smaller SFA record fewer financial transactions involving the NSLP, they delivered the same program benefits and perform the same function as any other SFA. Thus, they maintain the same kinds of information on file. FNS estimates that one percent of our respondents are small entities, approximately 1,266 respondents.

6. Consequence of collecting the information less frequently.


The information is collected for the purpose of administering an ongoing program. Applications can be accepted and agreements executed at any time, although SFAs generally execute agreements at or shortly before the beginning of each school year. SFAs submit claims for reimbursement for every month they operate the NSLP because funds for NSLP are budgeted on a fiscal year basis, collecting data less frequently would not allow FNS to properly monitor program funding and program trends.

7. Special circumstances relating to guidelines in 5 CFR 1320.6.


Monthly reporting is used instead of quarterly. 7 CFR Part 210, National School Lunch Program, states that, “to be entitled to reimbursement, each school food authority shall submit to the State agency a monthly Claim for Reimbursement.”


There are no other special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.5.


8. Comments in response to the Federal Register Notice and efforts to consult outside agency.


A notice was published in the Federal Register at 73 FR 64301 on October 29, 2008. No comments were received.


FNS consults with Regional Offices regarding any proposed changes as the result of legislative, regulatory or administrative changes. Regional offices are in daily contact with state agencies which provide feedback on FNS processes and procedures for this information collection.


9. Explanation of any payment or gift to respondents.


No payment or gift was provided to respondents.



  1. Assurance of confidentiality provided to respondents.


The Department will comply with the Privacy Act of 1974.



  1. Justification for sensitive questions.


There are no questions of a sensitive nature included in this clearance package.



12. Provide estimates of the hour burden including annualized hourly cost.


One hundred and twenty-one thousand one hundred and sixty-five respondents administer or operate the NSLP at State or local which includes:

57 SAs

20,858 SFAs

101,747 Schools

122,662 Total Respondents



A.12.1 REPORTING - The number of burden hours in inventory is 1,309,918. This submission changes the number of reporting burden hours to 1,324,060, an increase of 14,142 burden hours.

(See Attachment I).


A.12.2 RECORDKEEPING - The number of burden hours in inventory is 8,173,313. This submission changes the number of burden hours for recordkeeping to 8,234,222 and increase of 60,909 burden hours. (See Attachment II)


Total Reporting Hours 1,324,060

Total Recordkeeping Hours 8,234,222

Total Part 210 Burden Hours 9,558,282


A.12.3 Annualized Cost to Respondent


To estimate public cost, we consulted the U.S. Department of Labor’s 2007 Bureau of Labor Statistics. The average hourly rate of all State and local government employees, along with private sector employees, is $17.69. We assumed that an appropriate portion of State level cost would be funded under the State Administrative Expense (SAE) Program (7 CFR Part 235; OMB No. 0584-0067, Expiration Date: 12/31/2011). During the most recent fiscal year for which we have data on SA Expenditure of both SAE and State appropriated funds, SAs funded a percent from State sources. Therefore, we computed SA compliance cost at a rate of $4.40 per hour rather than $29.02. The average hourly rate of local government employees, along with private sector employees, is $17.69. Given this, we made the following computations.


Reporting


SA Level 5,482 hours x $4.40 $24,121

SFA Level 474,078 hours x $17.69 $8,386,440

School Level 844,500 hours x $17.69 $14,939,205

TOTAL 1,324,060 $23,349,766



Recordkeeping


SA Level 81,422 hours x $4.40 $358,257


SFA Level 2,201,566 hours x $17.69 $38,945,703


School Level 5,951,234 hours x $17.69 $105,227,329


TOTAL 8,234,222 $144,531,289



13. Estimate of other total annual cost burden to respondents or record keepers.


There is no start-up or annual maintenance costs for this collection of information.



  1. Annualized cost to the Federal government.



Federal Costs.


We identified functions performed by FNS Regional Office (FNSRO) and Headquarters (HQ) staff related to the NSLP and obtained estimates of the total number of staff hours spent performing these Functions. (See Attachment III)


Using the 2009 Federal Wage Salary Tables, we estimated the salary rate is $29.00 per hour (the average hourly salary for a GS 11/12 which is the grade level of staff who performs these functions). Our computations are:

FEDERAL SALARIES

Salaries (81,996 hours @ $29.00) $2,377,884.00

10 % for

Administrative overhead $237,788.00


Federal Cost $2,615,672.00

15. Explanation of program changes or adjustments.

There is an increase of 75,050 burden hours associated with both the reporting and recordkeeping requirements at the SFA and school levels. This increase is due to an adjustment in the number of SFAs and schools participating in the NSLP. The number of SFAs increased by 148 from 20,710 to 20,858. The number of schools increased by 1,349 from 100,398 to 101,747.


16. Plans for tabulation and publication and project time schedule.


This submission does not involve the collection of information by statistical methods.


17. Reasons that display of OMB expiration date is inappropriate.

We are not seeking approval concerning the display of the expiration data


18. Exception to certification for Paperwork Reduction Act submissions.


There are no exceptions to the certification statement.

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File Typeapplication/msword
File TitleSupporting Statements
Subject7 CFR Part 210 NSLP
Authorusda fcs
Last Modified ByRgreene
File Modified2009-03-30
File Created2009-03-30

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