2 FNS380-1 SS Part A OMB 0584-0299 10-26-12 final (3)

Supporting Statement for

Paperwork Reduction Act Submission for FNS-380-1, Supplemental Nutrition Assistance Program’s Quality Control Review Schedule

OMB Number 0584-0299

Associated with Final Rule RIN 0584-AE24 Supplemental Nutrition Assistance Program: Quality Control Error Tolerance Threshold

Prepared by:

Tiffany Wilkinson

U.S. Department of Agriculture

Food and Nutrition Service

3101 Park Center Drive, Room 822

Alexandria, VA 22302

703-305-2805

[email protected]

Table of Contents

Part A- Justification

1. Explanation of Circumstances That Make Collection of Data Necessary ……………3

2. Purpose and Use of the Information ….………………………………………………3

3. Use of Information Technology to Burden Reduction ……………………………… 4

4. Efforts to Identify Duplication and Use of Similar Information ……………………..5

5. Impacts Small Businesses or Other Small Entities …………………………………..5

6. Consequences of Collecting the Information Less Frequently ………………………5

7. Special Circumstance Relating to the Guideline of 5 CFR 1320.5 …………….…….6

8. Comments in Response to the Federal Register Notice and

Efforts to Consult Outside Agency ………………………………………...6

9. Explanation of Any Payment or Gift to Respondents ………………………………..7

10. Assurance of Confidentiality Provided to Respondents ……………………………7

11. Justification for Sensitive Questions ………………………………………………8

12. Estimates of Hour Burden Including Annualized Hourly Costs …………………..9

13. Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers …11

14. Annualized Cost to Federal Government …………………………………………….12

15. Explanation for Program Changes or Adjustments ………………………………….12

16. Plans for Tabulation and Publication and Project Time Schedule …………………..13

17. Reason(s) Display of OMB Expiration Date is Inappropriate ………………………14

18. Exceptions to Certification for Paperwork Reduction Act Submission …………….14

19. Information collection related to the Customer Service Center………………………14

List of Appendices

1. FNS-380-1

2. FNS 380-1 Coding Instructions from FNS 310 HB; Pages C-5 to C-42

3. Final Rule: “Supplemental Nutrition Assistance Program: Quality Control Error Tolerance Threshold”

Background:

The proposed OMB inventory for the reporting and recordkeeping burdens associated with the FNS-380-1 is approximately 63,131 annual burden hours. This is a result of an increase in the current number of completed reviews and is also attributed to an increase in the recordkeeping burden because of a new recording requirement of all QC errors and error causing variances in QC final rule titled, "Supplemental Nutrition Assistance Program: Quality Control Error Tolerance Threshold,” Vol. 26, No. 211, Pg. 67315, which went into effect on January 3, 2012. The burden estimates were not included in the regulation when the rule was published because FNS did not have clearly defined burden estimates finalized. At this time, we developed a more accurate estimate of these burden requirements, which are reflected below. In accordance with OMB, the 60day comment period for rulemaking serves as the information collection comment period.

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 associated with the QC final rule titled, "Supplemental Nutrition Assistance Program: Quality Control Error Tolerance Threshold,” which was published on November 1, 2011 (Vol. 26, No. 211, Pg. 67315), which went into effect on January 3, 2012. State agencies are required to perform Quality Control (QC) reviews for the Supplemental Nutrition Assistance Program (SNAP). The FNS-380-1, Quality Control Review Schedule (QCRS), was developed by the Food and Nutrition Service (FNS) for State use to collect both QC data and case characteristics for SNAP and to serve as the comprehensive data entry form for SNAP QC reviews.

The legislative basis for the QC system is in Section 16 of the Food and Nutrition Act of 2008, as amended (the Act). Part 275, Subpart C, of SNAP regulations implements the legislative mandates found in Section 16. The regulatory basis for the QC reporting requirements is provided by 7 CFR 275.14(d) and 7 CFR 275.21.

The legislative basis for the recordkeeping requirements is Section 11(a) of the Act. SNAP regulations, in Section 272.1(f), specify that program records must be retained for a period of three years from the month of origin.

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:

The QCRS collects both QC and case characteristic data. The information needed to complete form FNS-380-1 is obtained from SNAP case records and State QC findings.

Data collected is used by FNS and the States to monitor and reduce errors, develop policy strategies, and analyze household characteristic data. In addition, FNS uses this data to determine sanctions and bonus payments based on error rate performance and to estimate the impact of some program changes to SNAP participation and costs by analyzing the available household characteristic data.

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 compliance with the E-Government Act, 2002 (E-Gov), FNS has reviewed the entire process for collecting and submitting QC data. However, we are not able to make the entire process electronic at this time. Part of the process allows electronic submission.

The QCRS serves as both the data summary entry form that the QC reviewer completes during each QC review and, subsequently, as the data input document for direct data entry into the National Information Technology Center (NITC). While the data is manually collected on a paper form from information extracted from a case file, it is 100 percent electronically submitted to FNS via the SNAP Quality Control Automated System, SNAPQCS, through upload or by direct data entry.

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 duplication of effort since there is no similar data available.

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. There are smaller State agencies; however, they provide the same data as larger State agencies for this collection.

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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:

Errors made in the certification of benefits would not be effectively monitored or reduced, program policy strategies could not be satisfactorily developed, sanctions and bonus payments based on error rate performance would not be assessed on a timely basis, and information and analysis based on household characteristic data would be incomplete or delayed.

Legal obstacles to reducing the frequency of this collection are contained in SNAP regulations, referenced under Question #1 of this statement.

7. Special Circumstances Relating to the Guideline of 5 CFR 1320.5:

State agencies are required to select and conduct QC reviews on a monthly, ongoing basis. The results of those reviews are required by regulations at 7 CFR 275.21 to be reported on a monthly, ongoing basis.

There are no other special circumstances that cause the information collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.5.

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.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting form, and on the data elements to be recorded, disclosed, or reported:

Notice of this collection was published in the Federal Register on January 23, 2012 (Volume 77, Number 14, Page 3228). No public comments were received for the 60 or 30 day notices.

FNS attends an annual meeting regularly with the National Association of Program Information and Performance Measurement (NAPIPM) organization and holds calls regularly with the Quality Control Technical Advisory Group (QC TAG) of this organization, an association made up of state SNAP QC Directors, to discuss various QC topics including FNS worksheet 380-1. In our discussions on the FNS 380-1, we’ve covered various areas from coding to modernization of the form; however, we have not received comments regarding the changes of this collection package.

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

No payments or gifts are made to respondents.

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

Information gathered from State agency records and interviews during the course of active case reviews are subject to the same safeguards as information obtained from households applying for SNAP benefits. Section 11(e)(8) of the Food and Nutrition Act of 2008 mandates that each State agency shall provide "safeguards which limit the use or disclosure of information obtained from applicant households to persons directly connected with the administration or enforcement of the provisions of this Act, regulations issued pursuant to this Act, Federal Assistance programs, or federally assisted State programs...". SNAP regulations at 7 CFR 272.1(c) implement this legislative mandate. The findings of active case reviews, when compiled, do not identify the recipient by name.

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:

A final rule entitled “Civil Rights Data Collection” was published on May 18, 2006 by FNS. This rule revises the racial and ethnic data collection and reporting for SNAP to comply with the 1997 data collection standards issued by the Office of Management and Budget (OMB) for civil rights data collections. All Federal programs are required to collect racial/ethnic data and information from applicants to permit effective enforcement of the Civil Rights Act. Under the changed procedures, applicants will be allowed to choose more than one race and State and local agencies will be required to report tallies for the new racial categories. This rule was effective June 19, 2006.

In accordance with this rule, QC revised item number 51 (Race) of the FNS-380-1, in 2006, to reflect the new racial/ethnic codes. These codes have been updated for our 310 Handbook for further clarification and instruction on their implementation. The FNS-310 Handbook was submitted with OMB control number 0584-0034.

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

There are 53 State agencies required to conduct QC reviews of the active cases as part of the Performance Reporting System. The number of active cases that must be selected and reviewed by each State agency during each annual review period is determined based on its size and the State's choice of sampling options. We estimate an annual active case sample of approximately 59,831 cases nationwide for a total of 1,128 responses per respondent. The number of hours per response will vary depending on the needs of each individual active sample case. We estimate that State agencies will need an average of 1.056 hours per response for reporting. The annual estimate for reporting is 63,131.90 hours.

In addition, each of the 53 State agencies are required to maintain records of the Form FNS 380-1 for the recordkeeping requirement. We estimate that the burden is .0236 hours per record for 59,831 records per year and the frequency of responses per respondent is approximately 1,128 records to keep. We estimate the annual burden for recordkeeping is 1,410.90 hours.

We estimate the total annual hour burden of the collection of information is 64,542.80 hours. This burden was arrived at by adding together the estimated reporting burden and the estimated recordkeeping burden as follows:

Table A. 12.1 Reporting Estimates of Hour Burden

Form Number	No. of Respondents	Est. No. of Responses per Respondent	Est. Total Annual Responses	No. Hours per Response	Est. Total Burden Hours
FNS-380-1	53	1,128.8867	59,831	1.056	63,131.90

Table A. 12.2 Record Keeping Burden

Form Number	No. of Record keepers	Est. No. of Records per Record keeper	Est. Total Annual Records	No. Hours per Record to be Kept	Est. Total Burden Hours
FNS-380-1	53	1,128.8867	59,831	0.0236	1,410.90

II Provide estimates of annualized costs to respondents for the hour burden for collections of information, identifying and using the appropriate wage categories

Table A. 12.3 Estimates of Annualized Cost to Respondents

Type of Respondents	Number of Active Sample Cases Per Annum	Average Time Per Response	50 % Hourly Wage Rate	Total Respondent Cost
Reporting Burden
FNS-380-1 State Agencies	59,831	1.056	$12.57	$794,191.91
Recordkeeping Burden
FNS-380-1 State Agencies	59,831	0.0236	$12.57	$17,748.99

The cost to the public is based on $25.13 per hour. The rate to State agencies after 50 percent reimbursement by FNS is $12.57. Based on these figures the total cost to respondents for the reporting and recordkeeping burdens after FNS reimbursement is $811,940.90.

To estimate public cost, FNS consulted with the U.S. Department of Labor’s May 2010 Occupational and Wage statistics – 21-1029 Community and Social Services Occupations (http://www.bls.gov/oes/current/oes211029.htm).

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.

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 annual cost to the Federal Government to collect and use the data for the FNS-380-1 is estimated at $275,391.41. This cost includes (1) the cost of printing reporting forms; (2) reviewing and approving the data, data entry and retrieval; and (3) automated system costs [includes system monitoring and salaries]. These costs are operational costs only.

Worksheet	Printing Costs	Est. Hours Reviewing & Approving	Cost per Hour	Est. Costs Reviewing & Approving	Automated System Costs (incl. Monitoring)	Est. Total Federal Costs
FNS-380-1	$2,000	2,813	$12.57	$35,359.41	$238,035	$275,394.41

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

This is a revision of a currently approved data collection associated with rulemaking. The proposed OMB inventory for the reporting and recordkeeping burdens associated with the FNS-380-1 is 64,542.80 annual burden hours. The difference between the old burden of 60,191 and the new burden of 64,542.80 is an increase of 4,351.80 hours. This difference is primarily a result of an increase in caseload where the number of completed reviews went up from 56,065 to 59,831 since our last collection revision. The increase is also attributed to an increase in the recordkeeping burden by .006 hours for each response because of a new recording requirement of all QC errors and error causing variances. This new requirement was recently published in QC final rule titled, "Supplemental Nutrition Assistance Program: Quality Control Error Tolerance Threshold,” which was published on November 1, 2011 (Vol. 26, No. 211, Pg. 67315), which went into effect on January 3, 2012.

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

Data tabulation is achieved through established computer programs.

Data included in this collection of information is gathered throughout the entirety of each annual (fiscal year) review period. The data is then published in two separate reports issued on an annual basis.

The first report is the SNAP QC Annual Report. This report presents official QC error rates, and related data for the United States, individual states, Guam, the Virgin Islands and the District of Columbia. The SNAP QC Annual Report will be published approximately one year after the end of each annual review period and is sent to each region and state electronically though our PartnerWeb application.

The second report is the Characteristics of SNAP Households. This report examines the demographic characteristics and economic circumstances of food stamp recipients and households. An advance report, featuring the highlights of the characteristic data, is published approximately one year after the end of each annual review period.

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:

FNS is seeking approval to not display the OMB expiration date on the FNS-380-1. If required to include an expiration date, the FNS-380-1 would require modification and would render the existing paper supply an economic loss each time the information collection burden was renewed. At that time the form would have to be revised and a new supply printed.

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

This information collection conforms to the requirements of 5 CFR 1320.9. There are no exceptions to the certification statement.

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