OMB supporting statement_FNS 292-A and B_FINALm

SUPPORTING STATEMENT

REPORT OF COMMODITY DISTRIBUTION FOR DISASTER RELIEF (FNS-292-A) AND Report of Disaster Supplemental Nutrition Assistance Program Benefit Issuance (FNS-292-A and FNS-292-B)

OMB No. 0584-0037

Mary Rose Conroy, Project Officer

Supplemental Nutrition Assistance Program

Program Development Division, Certification Policy Branch

Food and Nutrition Service, USDA

3101 Park Center Drive, Room 812

Alexandria, VA 22310

PH: 703-305-2803 FAX: 703-305-2896

[email protected]

A. JUSTIFICATION

A.1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

This is a revision of a currently approved collection. Food Distribution in disaster situations is authorized under Section 32 of the Act of August 24, 1935, as amended; Section 416 of the Food and Agriculture Act of 1949, as amended; Section 709 of the Food and Agriculture Act of 1965, as amended; Section 4(a) of the Agriculture and Consumer Protection Act of 1973, as amended; and by Sections 412 and 413 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act. Surplus foods are made available by State distributing agencies for relief purposes to victims of natural disasters such as hurricanes, floods, tornadoes, etc. Distribution to these recipients is made primarily through such organizations as the American Red Cross or the Salvation Army. These organizations use surplus foods for both central feeding operations and for distribution to families in homes cut off from normal sources of food supply. Program implementing regulations are contained in 7 CFR Part 250 and include reporting requirements for foods provided for disaster relief purposes. Form 292 A will be used in accordance with 7 CFR 250.69(f) and 7 CFR 250.70(f) by State distributing agencies to provide a summary report to the agency within 45 days following termination of the disaster assistance.

Disaster assistance through SNAP is authorized by sections 402 and 502 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 USC 5121 et seq.) and the temporary emergency provisions contained in Section 5 of the Food and Nutrition Act of 2008, and in 7 CFR Part 280 of the SNAP regulations. This program is initiated in a SNAP project area by FNS when all or part of the area has been affected by a disaster. In accordance with 7 CFR 274.4, State agencies shall keep records and report SNAP participation and issuance totals to FNS. Form 292-B will be used by State welfare departments to report to FNS the number of households and persons who were certified for the Disaster SNAP, and also to report the value of benefits issued to those households.

The Food, Conservation, and Energy Act of 2008 (Public Law 110-246), Section 4001-4002 changed the name of the Food Stamp Program to the Supplemental Nutrition Assistance Program (SNAP) on October 1, 2008, to reflect the fact that participants no longer receive stamps or coupons to make food purchases and to emphasize the nutritional aspect of the program. To comply with current law, FNS is using the new program name in this revision of information collection for OMB No. 0584-0037.

A.2. Indicate how, by whom, how frequently, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

Information collected on Form 292-A and 292-B will be used by the FNS Administrator, the Food Distribution Division, and the three SNAP divisions to monitor program activity, assess coverage provided to needy recipients, assure the validity of requested commodity reimbursements and to prepare budget requests. Data from Form 292-A and 292-B has been used in the past to report to the Secretary of Agriculture, the Federal Emergency Management Agency, the White House and Congress on FNS disaster relief efforts. For example, following the hurricanes of 2005, the collected information contributed to a report to the President entitled The Federal Response to Hurricane Katrina: Lessons Learned, Appendix B, p. 136, February 2006.

If the information were not collected, FNS would be unable to monitor the issuance of SNAP benefits and the distribution of surplus foods during disaster situations. In addition, it would not have the information to respond to requests from multiple agencies on FNS contributions to Federal disaster relief efforts.

State education and welfare agencies that administer FNS nutrition assistance programs will provide the information which is collected only once per disaster per State. The frequency of collection and the reporting procedures have not changed since the previous collection was approved. Agencies will collect information using an electronic version of Form 292-A and 292-B that can be submitted using the Food Program Reporting System (FPRS). All State agencies have the technological capacity to support electronic submissions.

A.3. 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, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also, describe any consideration of using information technology to reduce burden.

In accordance with the E-Government Act of 2002 (E-Gov), FNS has reviewed the process for collecting information via Form 292-A and 292-B and will provide electronic submission of these forms with an alternative for paper submission, if needed.

The form will be available in the Food Program Reporting System (FPRS) web-based application found at https://fprs.fns.usda. FNS anticipates 100 percent of our responses will be submitted electronically. This format allows all State Agencies to access forms quickly, report on specific disaster relief activities in detail, and submit the forms directly to FNS Regional Offices as required by FNS.

A.4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose described in item 2 above.

There is no similar information available. The information required for FNS-292-B and FNS 292-B is not currently reported to any other entity outside of FNS. Every effort has been made to avoid duplication. FNS has reviewed USDA reporting requirements, state administrative agency reporting requirements and special studies by other government and private agencies.

A.5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

FNS has determined that the requirements for this information collection do not adversely impact small businesses or other small entities. Information being requested or required has been held to the minimum required for the intended use. Circumstances limit the flexibility in modifying the reporting and recordkeeping requirements. FNS estimates that out of 55 State agencies, one percent of our respondents are considered small entities, approximately 1 State agency.

A.6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Reporting of data is done only “on occasion” after a disaster situation has occurred. However, if information collection was not collected in the period following each disaster program, FNS would be unable to monitor the issuance of SNAP benefits and the distribution of surplus foods during disaster situations and reimburse States appropriately for their disaster relief efforts. In addition, FNS would be unable to respond to White House, Congressional, and outside requests to accurately quantify disaster relief provided by FNS.

A.7. Explain any special circumstances that would cause an information collecti­on to be con­ducted in a manner:

• requiring respondents to report informa­tion to the agency more often than quarterly;

• requiring respondents to prepare a writ­ten response to a collection of infor­ma­tion in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any docu­ment;

• requiring respondents to retain re­cords, other than health, medical, governm­ent contract, grant-in-aid, or tax records for more than three years;

• in connection with a statisti­cal sur­vey, that is not de­signed to produce valid and reli­able results that can be general­ized to the uni­verse of study;

• requiring the use of a statis­tical data classi­fication that has not been re­vie­wed and approved by OMB;

• that includes a pledge of confiden­tiali­ty that is not supported by au­thority estab­lished in statute or regu­la­tion, that is not sup­ported by dis­closure and data security policies that are consistent with the pledge, or which unneces­sarily impedes shar­ing of data with other agencies for com­patible confiden­tial use; or

• requiring respondents to submit propri­etary trade secret, or other confidential information unless the agency can demon­strate that it has instituted procedures to protect the information's confidentiality to the extent permit­ted by law.

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

A.8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments.

The FNS notice was published in the Federal Register on February 9, 2011, Volume 76, Number 27, Page 7146 (included with this submission). The Department received two comments from a State agency in response to the notice. The original comments and FNS response are included with this submission.

Form 292-A and 292-B have been in use for three years. During that time, FNS national and regional offices have worked closely with State agencies in coordinating disaster response efforts and FNS has not received information from affected State agencies that necessitate a change to the data collection instrument or the frequency of collection.

A.9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.

There are no plans to provide any payments or gifts to respondents.

A.10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

FNS does not offer any assurance of confidentiality to the respondents.

A.11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

Form 292-A and 292-B contain no questions of a sensitive nature.

A.12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

The estimated total annual burden of this collection is 5500 minutes (92 hours) including a total reporting burden of 2750 minutes (46 hours) and a total recordkeeping burden of 2750 minutes (46 hours).

Reporting Burden:

Form 292-A and 292-B collect information from State agencies whenever FNS assistance is provided during disaster or emergency food relief operations. Based on past experience, FNS expects to receive an estimated 110 total responses (Form 292-A and 292-B) from 55 State agencies on an annual basis. Since data to prepare Form 292-A and B are readily available from State agency records, the reporting burden for this collection is estimated to average 25 minutes (0.42 hours) per part (292-A and 292-B) per respondent (total of 50 minutes (.84 hours) per respondent).

Description of the Collection Activity	Form Number	Number of Respondents	Frequency of Response	Estimated Total Annual Responses	Estimate of Burden Hours per response	Total Annual Reporting Hours
Commodity Distribution	292-A	55	1	55	.4175	22.96
SNAP Benefit Issuance	292-B	55	1	55	.4175	22.96
Totals	------	55	-------	110	-------	45.92

TABLE A.12.1 – Estimates of Reporting Burden

Record Keeping Burden:

The data provided on Form 292-A and 292-B is part of State agency records maintained for overall commodity food distribution and SNAP administration. Recordkeeping burden for the State agencies is estimated to be 25 minutes (.42 hours) per part (292-A and 292-B) per respondent (total of 50 minutes (.84 hours) per respondent).

TABLE A.12.2 – Estimates of Record Keeping Burden

Description of Record Keeping Activity	Form Number	Number of Record Keepers	Frequency of Response	Estimated Total Annual Responses	Annual Hours per Record Keeper	Total Annual Record Keeping Hours
Commodity Distribution	292-A	55	1	55	. 4175	22.96
SNAP Benefit Issuance	292-B	55	1	55	. 4175	22.96
Totals		55		110	--------	45.92

Annualized Cost to Respondents:

Respondents and record keepers involved in this collection will be managers at State Departments of Social Services, which corresponds to the Bureau of Labor Statistics Category 11-9151, Social and Community Service Managers. Based on the most recent Occupational Employment and Wage Estimates from May 2009, workers in this category employed by State Governments earn an hourly mean wage of $31.57.

TABLE A.12.3 – Estimates of Annual Costs to Respondents

Type of Respondents	Form Number	Number of Respondents	Frequency of Response	Average Time per Response	Hourly Wage Rage	Respondent Cost
Commodity Distribution	292-A	55	1	. 835	$31.57	$1449.85
SNAP Benefit Issuance	292-B	55	1	. 835	$31.57	$1449.85
Totals	------	55	-------	--------	--------	$2899.70

A.13. Provide estimates of the total annual cost burden to respondents or record keepers resulting from the collection of information, (do not include the cost of any hour burden shown in items 12 and 14). The cost estimates should be split into two components: (a) a total capital and start-up cost component annualized over its expected useful life; and (b) a total operation and maintenance and purchase of services component.

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

A.14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

The Federal cost has been developed by estimating the various costs involved in Form 292-A and 292-B and the electronic collection system (FPRS) to support the collection. The ongoing costs to the Federal government related to this collection are primarily employee labor costs and contractor services. Federal government employees will review and evaluate the data submitted by the State agencies. FPRS contractors will maintain the forms and the reporting system. Estimates for the average annual costs of contractor services were calculated by the contractor, based on the current FPRS contract. The estimates use FY 2011 as the base year, with a 3.5% escalator for FY 2012 and 2013, per the terms of the contract.

Estimate of Annualized Cost to the Federal Government

Employee labor for analyzing, evaluating, and summarizing information from this collection:

292-A

1 Full-time Employee @ GS-12 = $74,872 annually / 52 weeks

= $1,439.85 / 40 hours

= $36 hourly wage rage

15 minutes per response x 55 responses annually = 825 minutes / 60

= 13.75 hours annually

$36.00 x 13.75 = $495.00 annual cost

292-B

1 Full-time Employee @ GS-13 = $89,033 annually / 52 weeks

= $1,712.17 / 40 hours

= $42.80 hourly wage rage

15 minutes per response x 55 responses annually = 825 minutes / 60

= 13.75 hours annually

$42.80 x 13.75 = $588.50 annual cost

TOTAL ANNUAL EMPLOYEE LABOR COST = $1,083.50 ($495.00 + $588.50)

TOTAL 3-YEAR EMPLOYEE LABOR COST = $3,250.50 ($1,083.50 x 3)

Contractor Services:

292-A

Average Annual Projected Contractor Cost per Workload

(weighted by complexity of form, number of elements,

and number of programs using the form) = $87,808

292-B

Average Annual Projected Contractor Cost per Workload

(weighted by complexity of form, number of elements,

and number of programs using the form) = $84,430

TOTAL ANNUAL CONTRACTOR SERVICES COST = $172,238 ($87,808 + $84,430)

TOTAL 3-YEAR CONTRACTOR SERVICES COST = $516,714 ($172,238 x 3)

TOTAL ANNUAL COST TO FEDERAL GOVERNMENT = $173,321.50 ($1,083.50+$172,238)

TOTAL 3-YEAR COST TO FEDERAL GOVERNMENT = $519,964.50 ($3,250.50+$516,714)

A.15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.

This is a revision of a currently approved collection. There is a small adjustment in total estimated burden hours associated with this revision. The previously approved collection erred in estimating half a response annually per respondent, which resulted in a lower number of approved burden hours (46 hours) than was appropriate for this collection. This revision reflects a more accurate estimate of the one annual response per respondent which increased the burden to (92 hours) for State agencies in reporting and maintaining records of this information.

In addition, there is a significant adjustment in the annualized cost to the Federal Government. The previously approved collection did not include the costs associated with the FPRS contract. The contractor has provided an estimate of the annual costs for the management of the system as it relates to Form 292-A and 292-B. This collection now properly accounts for these costs.

A.16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

The information collected is published annually on the “Disaster Assistance” page of the FNS website: http://www.fns.usda.gov/disasters/disaster.htm. The information collection does not employ statistical methods.

A.17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The agency plans to print the expiration date of OMB approval on Form 292-A and 292-B.

A.18. Explain each exception to the certification statement identified in Item 19 "Certification for Paperwork Reduction Act."

There are no exceptions to the certification statement.