Burden Requirement Narrative

Estimate of the Information Collection Burden for the

Summer Food Service Program (OMB #0584-0280)

This document explains the calculation of the information collection burden for the Summer Food Service Program under OMB #0584-0280 as submitted for the renewal of the existing regulation. A 60-day notice was published in the Federal Register on December 19, 2012 (Volume 77, Number 244, pages 75106-75110).

REPORTING REQUIREMENTS

AFFECTED PUBLIC: STATE AGENCIES

1. Section 225.3(b) requires that each State agency must notify the Department by November 1 of each fiscal year regarding its intention to administer the Summer Food Service Program.

FNS estimates that each of the 53 State agencies will file 1 report annually for a total

of 53 responses (53 X 1=53). The estimated average number of burden hours per

response is 0.25 resulting in estimated total burden hours of 13.25 (53 X .25=13.25). The number of state agencies has increased from 52 to 53. This change results in increase of 0.25 burden hours.

2. Section 225.4(a) requires that no later than February 15^th of each year, each State

agency shall submit to FNSRO a Program Management and Administration Plan for

that fiscal year.

FNS estimates that each of the 53 State agencies will file 1 Management and

Administration Plan annually for a total of 53 responses (53 X 1=53). The estimated

average number of burden hours per response is 1 resulting in estimated total burden

hours of 53 (53 X 1= 53). The number of State Agencies has increased from 52 to 53. The average burden hours per response has decreased from 40 hours to 1 hour due to reassessment of burden in consultation with state agency staff. This change results in a reduction of 2,027 burden hours.

3. Sections 225.6(b)(2) and 225.6(b)(7) require that State agencies inform potential

sponsors of the procedure for advance and administrative cost payments. This is an

administrative burden.

4. Section 225.6(b)(2) requires that State agencies inform sponsors of the procedures for applying for start-up payments. This is an administrative burden.

5. Section 225.6(h)(2) requires that State agencies develop a standard contract for use by sponsors and food service management companies. This is an administrative burden.

6. Section 225.7(c) requires that State agencies develop and make available to sponsor food specifications, and model meal quality standards, which shall become part of all contracts between vended sponsors and food service management companies. This is an administrative burden.

7. Sections 225.7(d) and 225.7(d)(2) require that State agencies conduct program monitoring assistance for sites, to include pre-approval visits, sponsor reviews, follow up reviews, developing and implementing a monitoring system, food service management facility visits, development of forms, and corrective action when appropriate. This is an administrative burden.

8. Sections 225.7(d)(6) and 225.7(e) require that State agencies conduct inspections of food service management companies, self-preparation, and vended sponsors’ food preparation facilities. This is an administrative burden.

9. Section 225.7(f) requires that State agencies establish a financial management system to identify program costs and establish standards for recordkeeping and reporting. This is an administrative burden.

10. Section 225.8(d) (2) requires that State agencies must notify the appropriate FNSRO within 5 working days after they approve each private nonprofit organization to participate as a SFSP sponsor.

FNS estimates that each of the 53 State agencies that will file 90 (90 is the average

number of sponsors/State agency) reports annually for a total of 4,770 responses (53

X 90=4,770). The estimated average number of burden hours per response is 1

resulting in estimated total burden hours of 4,770 (4,770 X 1=4,770). The number of state agencies has increased from 52 to 53. The average number of responses per respondents increased from 74 to 90 (due to change in the number of total sponsors over the past three years and the number of burden hours per response has decreased from 8 hours to 1 hour due to reassessment of burden in consultation with state agency staff). This change results in an decrease of 26,014 burden hours.

11. Section 225.8(b) requires that each State agency shall submit to FNS a final report

(FNS-418) on the SFSP operations for each month no more than 90 days following

the last day of the month covered by the report.

FNS estimates that each of the 53 State agencies will file 3 reports annually for a total

of 477 responses (53 X 3=159). The estimated average number of burden hours per

response is 2 resulting in estimated total burden hours of 318 (159 X 2=318).

The number of State agencies has increased from 52 to 53. This change results in

an increase of 6 burden hours.

12. Section 225.8(d)(1) requires that by May 1 of each year, State agencies must submit to the FNSRO a list of potential private nonprofit organization sponsors for each site, the first day of operation, and the estimated daily attendance.

FNS estimates that there will be audits of 53 State agencies and each will file 1

(average number of potential private nonprofit sponsors/State agency) reports

annually for a total of 53 responses (53 X 1=53). The estimated average

number of burden hours per response is 1 resulting in estimated total burden hours of

53 (53 X 1=53). The number of State agencies has increased from 52 to 53.

The amount of time it takes to complete the task is reduced from 4 hours to

1 hour due to reassessment of burden in consultation with state agency staff. This change results in a decrease of 4,523 hours.

13. Section 225.9(b)(2) requires that the State agency prepare and submit a list of sponsors eligible to receive commodities and the daily number of eligible meals to be served by each sponsor not later than June 1 of each year.

FNS estimates that the 53 State agencies will each file 1 report annually for a total

of 53 responses (53 X 1=53). The estimated average number of burden hours per

response is 1 resulting in estimated total burden hours of 53 (53 X 1=53). The number of State agencies increased from 52 to 53. This change resulted in an increase of 1 hour.

14. Section 225.9(d)(4) requires that the State agency shall forward reimbursement

within 45 days of receiving valid claims.

FNS estimates that of the 53 State agencies, 270 (90 sponsors/State agency X 3

reports) reports will be filed annually for a total of 14,310 responses. The estimated

average number of burden hours per response is 0.5 resulting in an estimated total

burden hours of 7,155 (14,310 X 0.5=7,155). The number of responses for respondents increased from 222 to 270 (due to change in number of sponsors over the past three years). This change resulted in an increase in 1383 burden hours.

15. Section 225.10 requires that State agencies arrange for audits of their own operations per 7 CFR Part 3015. This is an administrative burden.

16. Section 225.12(a) requires that the State agency shall disallow any portion of a claim for reimbursement and recover any payment to a sponsor not properly payable.

FNS estimates that 53 State agencies will each file 9 (1% of the average number

of sponsors/State agency) reports annually for a total of 477 (53 X 9=477). The

estimated average number of burden hours per response is 4 resulting in an estimated

total burden hours of 1,908 (477 X 4=1,908). The respondents increased from 52 to 53. Additionally, the average burden hours per response have decreased from 8 hours to 4 hours due to reassessment of burden in consultation with state agency staff. This change results in a reduction of 1,004 burden hours.

17. Section 225.13(a) requires that State agencies establish hearing appeal procedures.

This is an administrative burden.

18. Section 225.17 requires that State agencies make available to sponsors information on procurement standards. This is an administrative burden.

19. Section 225.18(b)(2) requires that the State agency shall terminate a sponsor’s

participation in the program by written notice whenever it is determined by the State

agency that the sponsor has failed to comply.

FNS estimates that 53 State agencies will each file 5 reports (average number of

terminated sponsors per year) annually for a total of 265 (53 X 5=265). The

estimated average number of burden hours per response is 1 resulting in an estimated

total burden hours of 265 (265 X 1=265). The number of State agencies increased from 52 to 53 and average number of reports filed increased from 4 to 5. This number actually changed over the past three years. This change results in an increase of 57 hours.

20. Section 225.15(j) requires that States agencies, which plan to use or disclose information in ways not permitted, must obtain written consent from parent/guardian. This is an administrative burden.

21. Section 225.15(k) requires that State agencies enter into a written agreement with party requesting disclosure information. This is an administrative burden.

AFFECTED PUBLIC: SPONSORS

1. Sections 225.6(c) (1) require that sponsors submit written application

to State agencies for participation in the SFSP.

FNS estimates that there are 4,754 sponsors that will each file 1 report annually for a

total of 4,754 responses (4,754 X 1=4,754). The estimated average number of

burden hours per response is 3.30 resulting in estimated total burden hours of 15,688

(4,754 X 3.3=15,688). The number of sponsors increased from 3,842 to 4,754. This change results in an increase of 2,894 burden hours.

2. Section 225.6(c) (2) requires that sponsors submit site information for each site where a food service operation is proposed.

FNS estimates that there are 4,754 sponsors that will each file 1 report annually for a total of 4,754 responses (4,754 X 1=4,754). The estimated average number of burden hours per response is 1 resulting in estimated total burden hours of 4,754 (4,754 X 1= 4,754). The numbers of sponsors increased from 3,842 to 4,754 hours. This change resulted in an increase of 912 hours.

3. Section 225.6(c) (3) requires that sponsors submit a Statement of its policy for serving free meals.

FNS estimates that there are 475 sponsors that will each file 1 report annually for a total of 475 responses (475 X 1=475). The estimated average number of burden hours per response is 0.01 resulting in estimated total burden hours of 5(475 X 0.01= 5). The number of sponsors decreased from 3,842 to 475 (10% of 4,754 sponsors as this policy applies to new sponsors only. (Note that the prior estimate for this line item was an error and the amount of time it takes to complete the task reduced from 1 hour to .01 hours). This change resulted in a reduction of 3,837 hours.

4. Section 225.6(e) requires that sponsors approved for participation enter into written

agreements with State agencies to operate the program in accordance with regulatory

requirements.

FNS estimates that there are 475 sponsors (10% of the number of sponsors/State

agency) that will each file 1 report annually for a total of 475 responses (475 X 1 =

475). The estimated average number of burden hours per response is .12 resulting in

estimated total burden hours of 475 (475 X .12=58). The number of

sponsors decreased from 3,842 to 475 (10% of 4,754 as this task applies to new sponsors only. Note that prior estimate for this line item was an error). This change resulted in reduction of 415 hours.

5. Section 225.6(h) (2) (iii) requires that sponsors provide food service management

companies with a list of approved sites.

FNS estimates that approximately 1426 sponsors will contract with food service management companies and will each file 1 report annually for a total of 1426 (1426 X 1=1426). The estimated average number of burden hours per response is .5 resulting in an estimated total burden hours of 713 (1426 X .5=713). The number of sponsors decreased from 1,921 to 1,426 (note change in total number of sponsors and this task applies to less than third of sponsors). This change resulted in reduction of 248 hours.

6. Section 225.6(h) (3) requires that sponsors submit requests to State agencies for

exception to unitizing requirements for certain components of a meal.

FNS estimates that 1% of sponsors that have contracts with food service

management companies will submit 1 of these requests. Since FNS estimates that

475 sponsors hire food service management companies, 1% of that would be 47.

47 would file 1 report annually for a total of 47 (47 X 1=47). The estimated average

number of burden hours per response is .5 resulting in an estimated total burden hours

of 23.5(47 X .5=23.5). The number of sponsors for this task increased from 19 to

47 and this change resulted in an increase of 14 hours.

7. Sections 225.6(h) (5) and 225.6(h) (2) require that sponsors submit to State agencies

copies of the contracts with food service management companies, the bids received,

and the reasons why the food service management company was chosen.

FNS estimates that there is approximately 1426 food service management

Companies doing business in the SFSP and that sponsors submit 1 report annually for

a total of 1,426 annual responses (1,426 X 1 = 1,426). The estimated average number

of burden hours per response is 20 resulting in an estimated total burden hours

of 28,520 (1,426 X 20 = 28,520). The number of sponsors decreased from 1,921 to

1,426 (this requirement applies to less than third of sponsors) and this change

resulted in a decrease of 9,900 hours.

8. Section 225.15(j) requires sponsors that plan to use or disclose information in

ways not permitted by law must obtain written consent from parent/guardian. This is

an administrative burden.

9. Section 225.15(k) requires that sponsors should enter into written agreement with the

party eligibility information. This is an administrative burden.

AFFECTED CAMPS AND OTHER SITES

1. Section 225.6(c) (5) requires that camps submit copies of hearing procedures.

FNS estimates that 791 camps participate in the SFSP. Each camp will file 1 report annually for a total of 791 responses (791 X 1=791). The estimated average number of burden hours per response is .25 resulting in an estimated total burden hours of 198 (791 X .25=198). The number of camps and other sites increased from 766 to 791. This change resulted in an increase of 6.25 burden hours.

2. Section 225.15 requires that camps and others distribute free meal applications to children enrolled in SFSP. This is an administrative burden.

AFFECTED HOUSEHOLDS

1. Section 225.15(f) requires households to read instructions, complete free meal applications, and return to camps and sites.

FNS estimates that 100,589 households participate in the SFSP. Each household will

file 1 report annually for a total of 100,589 responses (100,589 X 1=100,589). The

estimated average number of burden hours per response is .5 resulting in an estimated

total burden hours of 50,295 (100,589 X .5=50,295).

2. Section 225.15(j) requires households to provide written consent for sponsors to use or disclose information.

FNS estimates that 100,589 households participate in the SFSP. Each household will file 1 report annually for a total of 100,589 responses (100,589 X 1=100,589). The estimated average number of burden hours per response is .25 resulting in an estimated total burden hours of 25,147 (100,589 X .25=25,147).

RECORDKEEPING REQUIREMENTS

AFFECTED PUBLIC: STATE AGENCIES

1. Section 225.8(a), 225.13(d) and 225.7(d) requires state agencies to maintain accurate accounting records for reviews, appeals and accounting.

FNS estimates that 53 state agencies will maintain 30 records for reviews resulting in 2067 total records (53x39). The estimated average number of burden hours per each record is 0.08 hours resulting in 163.36 hours (2067x.08). Similarly FNS estimates that 53 state agencies will each maintain 2 appeal records resulting in 106 records (53x2) and estimated average number of burden hours per each record is 0.08 resulting in 8.480 hours (106x0.08). For accounting records 53 state agencies will each maintain 90 records resulting in 4770 (53x90) and estimated average time per each record is 0.08 hours resulting in an estimated total burden hours of 381.6 (4770x0.08).

AFFECTED SPONSORS

1. Section 225.15(c), 225.15(a) and 225.9(g) requires sponsors to maintain records that justify all cost and meals claimed.

FNS estimates that 4754 sponsors will each maintain 1 record for a total of 4,754 records. The estimated average burden for each record is 0.08 hours resulting in a total of 380 burden hours (4,754x0.08).

2. Section 225.16(b) requires sponsors to maintain copies of the documentation establishing the eligibility of child receiving meals and all other meal service requirement information.

FNS estimates that 4,754 sponsors will each maintain 90 records resulting in 427,860 (4754x90) records. The estimated average burden hours for each record are 0.08 hours resulting in a total of 34,229 hours (427,860x0.08).

AFFECTED CAMPS AND OTHER SITES

1 Section 225.6(c) (5) (XII) requires that camps maintain records of hearing.

FNS estimates that 791 camps participate in the SFSP. Each camp will file 1 report annually for a total of 791 responses (791 X 1=791). The estimated average number of burden hours per response is .3 resulting in an estimated total burden hours of 237 (791 X .3=237).

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