0010 Supporting Statement FINAL4-8-13

Supporting Statement for

Paperwork Reduction Act

Submission for Performance Reporting System – Management Evaluation

OMB Number 0584-0010

Prepared by:

Jennifer McNabb

U.S. Department of Agriculture

Food and Nutrition Service

3101 Park Center Drive, Room 8-51

Alexandria, VA 22302

703-305-2142

[email protected]

Table of Contents

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…………………...……….. 4

5. Impacts Small Businesses or Other Small Entities......………………..………………….. 4

6. Consequences of Collecting the Information Less Frequently………………………….. 4

7. Special Circumstance Relating to the Guideline of 5 CFR 1320….…………………….. 5

8. Comments in Response to the Federal Register Notice and

Efforts to Consult Outside Agency…………………………………………………………... 5

9. Explanation of Any Payment or Gift to Respondents……………………………………... 5

10. Assurance of Confidentiality Provided to Respondents…….………………….………… 5

11. Justification for Sensitive Questions…….…………………………………………………. 7

12. Estimates of Hour Burden Including Annualized Hourly Costs…..……………………… 7

13. Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers...... 8

14. Annualized Cost to Federal Government………………………………………………….. 8

15. Explanation for Program Changes or Adjustments.…………..………………………..… 8

16. Plans for Tabulation and Publication and Project Time Schedule.………………..……. 8

17. Reason(s) Display of OMB Expiration Date is Inappropriate..………………..…………. 8

18. Exceptions to Certification for Paperwork Reduction Act Submission...……….....……. 9

A. Justification

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 information collection associated with Supplemental Nutrition Assistance Program (SNAP) Performance Reporting System (PRS). Section 11 of the Food and Nutrition Act (the Act) of 2008 requires that State agencies maintain records necessary to ascertain that SNAP is operating in compliance with the Act and regulations and must make these records available to the Food and Nutrition Service (FNS) for inspection.

Management Evaluation (ME) Review Schedules – Unless the State receives approval for an alternative ME review schedule, each State agency is required, under 7 CFR part 275, to submit one review schedule every one, two, or three years, depending on the project area make-up of the State.

2. Indicate how, by whom, and for what purpose the information is to be

used. Except for a new collection, indicate how the agency has actually used the information received from the current collection.

The purpose of the PRS is to ensure that each State agency and project area is operating SNAP in accordance with the Act, the regulations, and the State agency’s Plan of Operation. The System enables each State agency to monitor its administration of SNAP. It is also a tool used by FNS to evaluate State agency operations and to collect information that is necessary to develop solutions to improve the State’s administration of SNAP policy and procedures. The State agencies submit their management evaluations to FNS via e-mail or hard copy. There is no electronic format for the submissions.

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.

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. For the PRS, State agencies have the authority to use information technology that best suits the needs of their individual or unique systems of operations to comply with this information collection.

4. Describe efforts to identify duplication. Show specifically why any similar

information already available cannot be used or modified for use for the purposes described in Question 2.

There are currently no known State agencies monitoring systems in place which are designed to obtain data similar to that required for the PRS.

5. If the collection of information impacts small businesses or other small

entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

This information collection does not affect small business or other small entities. The collection is limited to what is necessary to comply with statutory requirements and to protect SNAP integrity.

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.

The purpose of this information collection is to support the Federal management evaluation review of State agency and project area administration of certification determination and benefit issuance to eligible SNAP households. The ME review process assures administrative continuity and supports continued program integrity. Regularly scheduled State agency and Federal MEs provide increased opportunity to identify discrepancies and enable problem resolution thereby increasing SNAP accountability.

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 that require information collection inconsistent with 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, required by 5 CFR 1320.8 (d), 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. Specifically address comments received on cost and hour burden.

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 format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years even if the collection of information activity is the same as in prior years. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

The 60-day notice (78 FR 2013-00823) for this submission was published on January 16, 2013. FNS did not receive any comments that were germane to the burden time, or cost for this information collection.

FNS regional offices are in constant contact with State agencies and consults with State representatives on issues including Management Evaluations. We routinely glean information on many issues including data collection from these informal consultations.

9. Explain any decision to provide any payment or gift to respondents, other

than reenumeration of contractors or grantees.

No payments or gifts to respondents are provided under this information collection.

10. Describe any assurance of confidentiality provided to respondents and

the basis for the assurance in statute, regulation, or agency policy.

Section 11 (e) (8) of the Act and implementing regulations at 7 CFR 272.1 limit the use or disclosure of information obtained from applicant households to persons directly connected with either the administration or safeguarding the integrity of SNAP. The activities covered by this action are to be used only by those directly connected with the administration of SNAP.

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.

This information collection does not ask any questions of a sensitive nature.

12. 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.

A) 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.

FNS estimates that the hour burden of the collection of information for the State agencies to be 490,832 hours. This estimated burden is based on the assumption that it takes the State agency and project areas an average of 212 hours to prepare review schedules, 4,240 hours to prepare review plans, 486,200 hours to conduct the ME reviews, which includes 180 in recordkeeping hours.

ME Review Schedules

Review schedules are required to be submitted to the appropriate FNS Regional Office no later than 60 days prior to the start of each Federal fiscal year. FNS estimates that it takes 4 hours to prepare a review schedule, and that each of the 53 State agencies would submit one review schedule per year, resulting in a total burden of 212 hours (53 State agencies x 1 schedule = 53 total annual responses x 4 hours).

ME Review Plan Development

Each State agency is required to submit a review plan annually. The number of hours required to prepare these plans is a function of the number and size of project areas in the State. Not all project areas are reviewed annually. FNS estimates that the 53 State agencies annually prepare plan reviews for approximately half of the total number of state project areas. Further FNS estimates that it takes on average approximately 80 hours to develop a comprehensive State review plan, resulting in a total of 4,240 hours (53 State agencies x 1 State review plan submitted = 53 total annual responses x 80 hours).

ME Reviews Conducted

FNS estimates that it takes an average of 340 hours to conduct a review. It is estimated that ME reviews are conducted for one-half of the total number of project areas (1,430) annually. Therefore, FNS estimates that it will take approximately 486,200 hours annually to conduct and document ME reviews (53 State agencies x 28.981132 = 1,430 x 340).

Reporting Burden Estimates:

Respondent	Estimated # of Respondents	Responses Annually per Respondent/Reviews	Total Annual Responses (Col. bxc)	Estimated Avg. # of Hours per Response	Estimated Total Hours (Col. dxe)
Reporting Burden
State and local agencies review schedule	53	1	53	4	212
State and Local review plan development	53	1	53	80	4,240
State and Local agencies conducting reviews	53	28.98	1,430	340	486,200
Total Reporting Burden	53		1,536		490,652

Recordkeeping Burden Estimates:

FNS also estimate that the time necessary for recordkeeping, that is, the time necessary to find and file a record in the conduct of an ME review, is based on 53 record keepers x approximately 30 annual hours per record keeper (1,536 hours) annually.

Respondent	Estimated # of Respondents	Responses Annually per Respondent	Total Annual Responses (Col. bxc)	Estimated Avg. # of Hours per Response	Estimated Total Hours (Col. dxe)
Recordkeeping Burden
State and local agencies	53	28.98	1,536	.1169	179.56
Total Recordkeeping Burden	53		1,536		180

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

The cost to State agencies is based on $30.80 per hour for management analyst staff in accordance with the National Compensation Survey: Occupational Wages in the United States, December 2012. This rate after 50 per cent reimbursement by FNS is $15.40. Therefore, the cost to respondents (492,188 burden hours x $15.40= $7,558,812.80).

Affected Public		Burden Hours	Cost
Reporting		490,652	$7,556,041
Recordkeeping		180	$ 2,772
TOTAL		490,832	$7,558,813

Note* Total Cost to Respondent rate for Reporting and Recordkeeping is after 50 per cent reimbursement by FNS.

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 questions 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 and/or annualized maintenance costs associated with this burden.

14. Provide estimates of annualized cost to the Federal government. 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.

All costs incurred by State agencies in the administration of the management evaluation process are reimbursed at 50 percent. The estimated annual cost to the Federal government for State agency incurred ME expense is over $11 million. The estimated expense is calculated by multiplying the total number of burden hours times $30.80 per hour and dividing by 50 percent 490,832 (490,832 x $30.80 = 15,117,625 ÷ 2 = $7,558,812.50). In addition, it took a Management Analyst GS-13 using the 2012 Federal Salary Table 20 hours to prepare this data collection, at ($42.66) hourly wage rate this cost is $853 for a total cost of $7,559,665.50.

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 existing collection. The current burden inventory is 492,222 and we are requesting 490,832 which is a decrease of 1, 390 due to adjustments. The numbers of record keepers were incorrectly reported in the previous submission.

16. For collections of information whose results are planned to be published,

outline plans for tabulation and publication.

There are no plans for statistical analyses in publications.

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.

This submission is not seeking OMB approval to not display the expiration date.

18. Explain each exception to the certification statement identified in Item 19

of the OMB 83-I" Certification for Paperwork Reduction Act."

There are no exceptions to the Certification Statement.

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