0584-0064 Extension without Revision - Supporting_Statement_03-10-13

FNS is currently undertaking an extensive review of the burden associated with the application and certification procedures for SNAP. The Agency anticipates releasing a revised Notice and submitting an Information Collection Request within 2013 to reflect the results of this research. This ICR is a request for extension without revision.

Justification

Circumstances making the collection of information necessary

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 an extension without revision of a currently approved information collection (OMB No. 0584-0064; expiration date March 31, 2013). The information collection is necessary to ensure that households applying for and participating in SNAP are eligible for assistance and that program participants receive the correct amount of assistance. The Food and Nutrition Act of 2008 (the Act), as amended, specifies national eligibility standards and imposes certain administrative requirements on State agencies in administering the program. Information must be collected from households to assure that they are eligible for the program and that they receive the correct amount of SNAP benefits. Information collected is limited to that necessary for the administration and enforcement of the SNAP Program. The Federal procedures for implementing the application and certification procedures in the Act are in Parts 271, 272, and 273 of the Title 7 of the Code of Federal Register. Part 271 contains general information and definitions, Part 272 contains requirements for participating State agencies, and Part 273 contains procedures for the certification of eligible households.

Purpose and Use of the Information

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 information collected is provided by applicant and participating households and is limited to what is necessary for the administration of SNAP as provided by the Act. In States administering SNAP, agencies obtain information from households through the initial application and recertification process as well as through reports to determine program eligibility and benefit levels. The required activities are illustrated in the following section.

REPORTING BURDEN:

Application to Participate in SNAP

Initial Application for SNAP. Section 273.2 of the SNAP regulations requires that each applicant household complete and file an application, either in paper or electronic form. The application contains detailed information about each household member, income, and resources that is necessary to determine if the applicant household is entitled to assistance and, if so, the benefit amount. This information is used by the State agencies that administer the program to determine household eligibility and benefit amounts.

Application for SNAP Recertification. Section 273.10(f) of the regulations provides that all households participating in SNAP must be assigned certification periods of a definite length. Under section 273.14(b), in order to continue participating in SNAP, ongoing households must apply for recertification prior to the end of their current certification periods. The recertification form is similar to the initial application and is completed and used in the same manner.

Periodic Reports

Monthly Report. Under section 273.21, households subject to monthly reporting are required to submit reports of their circumstances on a monthly basis. The report requests the information necessary to determine eligibility and benefits of affected households. Households subject to monthly reporting are assigned certification periods of 12-months and submit 11 monthly reports a year plus the application for recertification.

Quarterly Report. Under section 273.12 (a)(4) State agencies may require households to report changes on a quarterly basis. Currently, California is the only State that requires households to report changes in circumstances on a quarterly basis. Since households are not required to submit a separate quarterly report when they submit an application for recertification, the quarterly report is submitted 3 times a year for households in California.

Semi-annual or Simplified Report. Section 273.12(a)(5) allows State agencies to establish a simplified reporting (SR) system, under which most households are only required to report when the household’s gross monthly income exceeds 130 percent of the Federal poverty level. State agencies have the option of including most households assigned a certification period of at least 4 months in their SR systems; households assigned certification periods greater than 6 months must submit a periodic report by the sixth month. State agencies may opt to require households to submit periodic reports at intervals from every 4 months to every 6 months. SR households that are certified for longer than 6 months must submit a periodic report.

The only other mandatory reporting requirement applies to certain able-bodied adults without dependents (ABAWDs). Under Section 6(o) of the Act and section 273.24 of the SNAP regulations, ABAWDs are limited to 3 months of SNAP eligibility in a 36-month period unless they are employed an average of the 80 hours a month or participating in a qualifying work program. ABAWDs, regardless of their household’s reporting system, are required to report if their weekly work hours slip below the 20-hour average minimum.

Change Report Form. Under section 273.12(a)(1), households not subject to monthly, quarterly reporting or simplified reporting must report most changes in household circumstances within 10 days from the date that the change becomes known to the household. .

Notices

Notice of Eligibility or Denial. Section 273.10(g)(1)(i) and (ii) of the regulations apply to notices of eligibility and notices of denial. These notices are used by State agencies to advise households of the disposition of their application for initial certification or recertification. If the household is denied, the notice contains the reason(s) for the denial and advises the household of its right to appeal.

Notice of Missing or Incomplete Report. Sections 273.12(a)(4)(iii) and 273.12(a)(5)(iii)(D) relate to notice of missing or incomplete reports. This is used by State agencies to advise ongoing households when they have failed to submit the required monthly, quarterly or semiannual report altogether or, if the household submitted an incomplete report.

Notice of Missed Interview (NOMI). Sections 273.2(h)(1)(i)(D) and 273.14(b)(3)(iii) of the regulations apply to the NOMI. The NOMI is issued by State agencies to households that fail to appear for their scheduled initial or recertification interview, or in the case of households subject to telephone interviews, fail to contact the State agency or receive telephone calls initiated by the local office. The household may respond to the notice by requesting that the interview be rescheduled.

Notice of Expiration (NOE). Per the regulations in section 273.14(b)(1), State agencies are required to mail a NOE to currently participating households at least 30 days prior to the expiration of their current certification period. The NOE is usually accompanied by the Application for Recertification. The NOE advises the household that its certification period is expiring and that to continue receiving assistance; the household must file its Application for Recertification in a timely manner.

Notice of Adverse Action (NOAA). Per section 273.13(a), the NOAA is issued by State agencies to participating households whose benefits will be reduced or terminated as the result of a change in household circumstances.

Adequate Notice. Sections 273.12(a)(4)(v) and 273.13(b) of the regulations apply to adequate notices. An adequate notice is sent to households by the State agency when the household’s benefits are reduced or terminated based on information reported by the household itself. Adequate notices can also be used when mass changes occur. Mass changes are certain changes initiated by the State or Federal government that may affect the entire caseload or significant portions of the caseload.

Request for Contact (RFC). According to section 273.12(c)(3)(i) of the regulations, the RFC notice is used to contact the household when the State agency receives information regarding a potential change in a household’s eligibility or benefits and such information is not sufficient for the State agency to determine exactly how the household’s status would be affected.

Transitional Benefits Notice (TN) . According to section 273.29, State agencies that opt to provide transitional benefits must provide eligible families a TN that includes detailed and specific information about the household’s transitional benefits and rights. Because the TN and the NOE are very similar, the reporting burden associated with the TN is included in the reporting burden for the NOE. State agencies have also incurred startup costs associate with developing transitional benefits. Because these costs were a one-time only expense and have already been incurred we have not included them in this information collection.

RECORDKEEPING:

Case Records - State agencies must keep records as may be necessary to ascertain whether the program is being conducted in compliance with the Act and the regulations. The Act and Section 272.1(f) of the regulations require States to maintain such records for a period of 3 years from date of origin. States are allowed to store records using automated retrieval systems and other features that do not rely exclusively on the collection and retention of paper records.

Duplicate Participation System - Section 272.4(e) of the regulations require State agencies to search their files for duplicates in order to prevent individuals from receiving benefits in more than one household and to prevent households from receiving benefits in more than one jurisdiction within the State. The Act further requires State agencies to establish a system that will prevent an individual from receiving both SNAP benefits and cash benefits in lieu of SNAP benefits in an SSI cash-out State or under a cash-out demonstration project.

Use of Information Technology and Burden Reduction

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 E-Government Act of 2002 (E-Gov), State agencies have the authority to use the technology that best suits the needs of their individual or unique systems of operation to comply with the reporting and recordkeeping requirements contained in this submission. FNS has made every effort to provide for electronic submission as an alternative to paper submission in compliance with the E-Gov. FNS provides funding to support the development of electronic systems through Federal matching of States’ administrative costs.

All State agencies have automated their SNAP eligibility systems. States send aggregate level data on participation, benefits issued, and other basic program information to FNS using the Food Programs Reporting System (FPRS) via this website: https://fprs.fns.usda.gov. FNS does not receive client-specific data, such as applications or individual case records.

Efforts to Identify Duplication and Use of Similar Information

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.

For SNAP purposes, States are required to limit collection to information necessary to comply with the SNAP statutory requirements and to protect program integrity without imposing undue burden on respondents.

Because of the numerous Federal or State means-tested programs with variations in eligibility rules and benefit criteria, duplication of information collection and reporting may result for both States and households.

SNAP regulations permit State agencies to use multi-program forms and notices. Most States use a joint application for the Temporary Assistance to Needy Families Program (TANF) and SNAP, allowing applicants to apply for both programs with a single application form. Some States also include applications for the Medicaid program and general assistance programs with the TANF/SNAP application. While this may reduce the reporting burden for some information, if applications for too many programs are included in the same form, the forms may become too long and complicated and may deter households from applying.

Impacts Small Businesses or Other Small Entities

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.

State agencies administer SNAP at the State level and collect the necessary data to ensure correct eligibility determinations and delivery of benefit. All State agencies deliver the same program benefits and perform the same function regardless of population size. Thus, they maintain the same kinds of information on file. Of the 53 SNAP State agency respondents, none are small entities.

Consequences of Collecting the Information Less Frequently

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.

In order to certify households for SNAP, certain information collection is necessary. Changing the frequency of the information collection or reporting requirements as they relate to the application, certification, and continued eligibility of households would result in a direct violation of the Act and its implementing regulations (i.e., the Act sets the eligibility standards and allows State agencies to set certification periods for most households up to 12 months). Further, benefits could be over-issued, under-issued, or provided to ineligible households if the necessary information is not collected or actions are not taken timely.

Special Circumstances Relating to the Guideline of 5 CFR 1320.5

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.

Section 6(c) of the Act authorizes monthly reporting by households and authorizes the Secretary to prescribe such regulations as the Secretary may deem appropriate. Under section 273.21, households subject to monthly reporting are required to submit reports of their circumstances on a monthly basis.

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

Comments in Response to the Federal Register Notice and Efforts to Consult Outside Agency

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.

FNS published a notice in the Federal Register on January 25, 2013 at 78 FR 5407 soliciting comments on this information collection. No comments were received in response to this notice.

FNS National Office staff meets with staff from FNS regional offices, state offices, and public interest groups to discuss a variety of subjects related to SNAP, including the application process.

Explanation of Any Payment or Gift to Respondents

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

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

Assurance of Confidentiality Provided to Respondents

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 7 CFR 272.1(c) of the regulations limit the use or disclosure of information obtained from applicant households or contained in the case files of participating households to persons directly connected with the administration of SNAP (i.e., other Federal or federally-assisted means-tested programs; persons directly connected with the verification of immigration status of aliens; the Office of the Comptroller General of the U.S. for audit and examination authorized by any other provisions of law; local, State, or Federal law enforcement officials for the purpose of investigating an alleged violation of the Act or regulations; agencies of the Federal Government for purposes of collecting the amount of an over issuance from Federal pay; and any Federal, State or local law enforcement officer if the member is a fleeing felon or a parole violator.) The application for benefits contains personal identifying information on individuals doing business with FNS. Therefore, FNS published a Privacy Act Notice System of Records Notice (SORN) March 31, 2000, entitled USDA/FNS-10: Persons Doing Business with the Food and Nutrition Service, in the Federal Register (65 FR 17251) to specify the uses to be made of the information collected.

Justification for Sensitive Questions

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.

Section 5 of the Act specifies basic SNAP eligibility requirements, including but not limited to, those relating to income, resources, and expenses. Section 16 (e) requires State agencies to collect social security numbers as a condition of eligibility and provides that State agencies shall use such numbers in the administration of the program and State agencies shall have access to the Social Security Administration’s computerized information system for purposes of determining or verifying a household’s eligibility and benefit level.

In order to comply with the Computer Matching and Privacy Acts, FNS regulation continues to require that State-designed SNAP application forms contain a statement informing households that their social security numbers will be used in the administration of the program to check the identity of household members, prevent duplicate participation, and to facilitate making mass changes. A statement must also be included on State-designed applications informing households that the information provided will be used: In computer matching with other agencies (e.g., the Department of Health and Human Services, the Social Security Administration, and the U.S. Citizenship and Immigration Services); in program reviews and audits to ensure the household is eligible for SNAP benefits ; and in criminal or civil action or administrative claims against persons fraudulently participating in the program.

In order to comply with Civil Rights requirements, State-designed applications must contain a nondiscrimination statement and solicit racial/ethnic information from applicants. The applicant must be notified that reporting the information is voluntary, and it will not affect the household’s eligibility or benefit determination.

Estimates of Hour Burdens Including Annualized Hourly Costs

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.

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.

The estimated reporting burden for this information collection including the number of respondents, frequency of response, average time to respond and annual hour burden are shown in the attached Burden Table (Appendix A). A summary of the burden appears below.

SUMMARY OF BURDEN (OMB #0584-0064)
TOTAL NO. RESPONDENTS	14,910,993Top of Form Bottom of Form
AVERAGE NO. RESPONSES PER RESPONDENT	19.74559
TOTAL ANNUAL RESPONSES	294,426,291.75
AVERAGE HOURS PER RESPONSE	0.08456
TOTAL ANNUAL BURDEN HOURS REQUESTED	24,897,946.68
CURRENT BURDEN INVENTORY	24,897,946.68
DIFFERENCE	0

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

Annualized Costs to Respondents

SNAP information collection requirements described herein are imposed primarily on State agency eligibility workers. Standard wage rate categories used in determining annualized burden costs are based on the Bureau of Labor and Statistics (BLS) May 2011 Occupational Employment and Wages Statistics report which indicated a median wage rate of $19.74 per hour for eligibility interviewers in government programs. States would incur an annualized administrative cost of $19.74 per hour burden in the information collection. Fifty percent of the administrative costs to the State agencies are reimbursed by FNS. This results in a reimbursement value of $9.87 per burden hour. The Federal minimum wage rate of $7.25 per hour is used to calculate annualized costs for households applying for SNAP benefits.

A summary of annualized costs for the collection is shown in the table below. A detailed calculation is included in the Burden Table (Appendix A).

Respondent	Cost
State Agencies and Local Offices	$153,229,143.60
Households	$67,955,777.94
Total	$221,184,921.54

Estimate of Other Total Annual Cost Burden to Respondents or Record Keepers

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 or ongoing operation or maintenance costs associated with this information collection.

Annualized Cost to Federal Government

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.

Fifty percent of the administrative costs incurred by State agencies are reimbursed by FNS. Thus, the estimated wage rates for State agency staffs noted above have been reduced by 50% to reflect cost sharing. Costs associated with the burden imposed on SNAP applicants and recipients are not reimbursed.

Total governmental costs: = $ 306,458,287.20

State Share @ 50% = $ 153,229,143.60

Federal share @ 50% = $ 153,229,143.60

The Federal cost also includes the cost associated with the preparation of this information collection package. This includes Federal worker time at FNS for the following:

Hours Hourly Wage * Total

GS-12/3 Program Analyst 3 $38.26 $114.79

GS-14/2 Branch Chief 8 $52.09 $416.72

Planning and Regulatory Affairs Branch

Cost of Federal workers: $531.51

*Wage rages determined in accordance with the Office of Personnel Management salaries and wages information (http://www.opm.gov/oca/12tables/index.asp)

Total Cost To Federal Government $ 153,229,675.11

Explanation for Program Changes or Adjustments

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

This is an extension without revision of a currently approved information collection. The burden for 0584-0064 will remain as 24,897,947.

Plans for Tabulation and Publication and Project Time Schedule

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

There are no plans to publish statistical analyses.

Reason(s) Display of OMB Expiration Date is Inappropriate

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 display the expiration date for OMB approval of the information collection on all instruments.

Exceptions to Certification for Paperwork Reduction Act Submissions

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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File Title	_Supporting Statement for OMB No
Author	Patrick Waldron
File Modified	0000-00-00
File Created	2021-01-29