Burden Narrative

Burden narrative for the 6 cents rule 4-12-12.docx

Certification of Compliance with Meal Requirements for the National School Lunch Program Under the Healthy, Hunger-Free Kids Act of 2010 (a.k.a. "Six-Cent Rule")

Burden Narrative

OMB: 0584-0567

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Estimate of the Information Collection Burden for the

National School Lunch Program (OMB #0584-new) Certification of Compliance with Meal Requirements for the National School Lunch Program Under the Healthy, Hunger-Free Kids Act of 2010




This document explains the calculation of the information collection burden for the National School Lunch Program, OMB #0584-new (RIN 0584-AE15), to include the reporting and recordkeeping requirements contained in the interim rule “Certification of Compliance with Meal Requirements for the National School Lunch Program under the Healthy, Hunger-Free Kids Act of 2010 which is currently in clearance. This is a new collection. The “Estimate of the Collection of Information Burden” describes program changes and adjustments in detail set forth under OMB #0584-NEW and will be merged with 0584-0006 once approved by OMB.


REPORTING REQUIREMENTS



AFFECTED PUBLIC: STATE AGENCIES (SA)



  1. Section 210.7(d) (1)(iv) states that State agencies review submitted certification materials related to meal compliance and notify School Food Authorities (SFAs) of the certification determination. FNS estimates that there are 56 SAs that will each file 372 reports annually for a total of 20,832 responses (56x372=20,832). The estimated average number of burden hours per response is 2 hours resulting in estimated total burden hours of 41,664 (20,832x2=41,664).


  1. Section 210.5(d) (2) (ii) states that State agencies submit a quarterly report (format to be determined) to FNS detailing the disbursement of performance based reimbursement to SFAs. FNS estimates that there are 56 SAs that will each file 4 reports (one each quarter) annually for a total of 224 responses (56x4=224). The estimated average number of burden hours per response is 1hour resulting in estimated total burden hours of 224 hours (224x1=224).



AFFECTED PUBLIC: SCHOOL FOOD AUTHORITIES (SFA)



  1. Section 210.17 (d) (2) states that each SFA must submit certification materials to State agency to support receipt of performance based reimbursement. FNS estimates that there are 20,858 SFAs that will each file 1 report annually for a total of 20,858 responses (20,858x1 = 20,858). The estimated average number of burden hours per response is 4.5 hours resulting in estimated total burden hours of 93,861 (20,858x4.5= 93,861).


  1. Section 210.17 (d) (2) also states that each SFA must submit an annual attestation of compliance with meal pattern and nutrition requirements. FNS estimates that there are 20,858 SFAs that will each file 1 report annually for a total of 20,858 responses (20,858x1 = 20,858). The estimated average number of burden hours per response is 0.25 hours resulting in estimated total burden hours of 5,215 (20,858x0.25= 5,215).




RECORDKEEPING REQUIREMENTS



AFFECTED PUBLIC: STATE AGENCIES (SA)



No burden identified for this section.




AFFECTED PUBLIC: SCHOOL FOOD AUTHORITIES (SFA)



  1. Section 210.7(d) (2) states that the SFAs maintain certification documentation to support performance based reimbursement. FNS estimates that there are 20,858 SFAs that will each respond 2 times a year for a total of 41,716 responses (20,858x2 = 41,716). The estimated average number of burden hours per response is 0.25 hours resulting in estimated total burden hours of 10,429 (41,716x0.25= 10,429).


  1. Section 210.7(d)(2) also states that SFAs maintain documentation related to the attestation of compliance submitted to the SA as an attachment to the written agreement required in 210.9/(b). FNS estimates that there are 20,858 SFAs that will each manage records once a year for a total of 20,858 responses (20,858x1=20,858). The estimated average number of burden hours per response is 0.25 hours resulting in estimated total burden hours of 5,215 (20,858x0.25=5,215).




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