Supporting_Statement_FNS-13_01 29 2014

Form FNS-13, Annual Report of State Revenue Matching

(National School Lunch Program)

OMB CLEARANCE NUMBER 0584-0075

Yolly Smith, Program Analyst

Food and Nutrition Service, USDA

Child Nutrition Division

Program Analysis and Monitoring Branch

Special Nutrition Program

3101 Park Center Drive

Alexandria, VA 22302

PH: 703-305-2664

[email protected]

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. The information on the form
FNS-13 (expires 02/28/2014) must be collected from State agencies (SA) who participate in
the National School Lunch Program (NSLP). This form is administered directly by the Food
and Nutrition Service (FNS) Regional Offices through a web-based Federal reporting system.
Information on school program operations is collected from SAs on a yearly basis
to monitor and make adjustments to SA funding requirements. Per the regulations
(CFR 210.17), State revenues must be appropriated or used specifically by the State federal
school lunch program purposes. The amount that must be appropriated, or used generally, is
at least 30% of the funds received by the State under Section 4 of the NSLA (42 U.S.C.
1753). For this purpose, Form FNS-13, Annual Report of State Revenue Matching, is
necessary to monitor SA compliance with the revenue matching requirement
contained in Section 7 of the Richard B. Russell National School Lunch Act, amended
(Public Law 109-97).

2. Indicate how, by whom, 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.

Form FNS-13 collects information on a school year basis for the National School Lunch Program (NSLP). The information will be used by the FNS administrator, the Child Nutrition Division, and the FNS Financial Management Division to ensure compliance with State revenue matching requirements. Each State is required to match 30 percent (or a lesser percent based on per capital income) of the Section 4 funds made available to the State during the school year. These State revenues must be appropriated or otherwise made available for program purposes during the school year. FNS would not be able to monitor State compliance with this revenue matching requirement without the information collected on Form FNS-13.

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 of 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. All 57 SAs and United States territories (100 percent) submit data for the FNS-13 electronically through the Food Program Reporting System (https://fprs.fns.usda.gov) to FNS.

3. 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 in reporting of State revenue matching data. Every effort has been made to avoid duplication. FNS solely administers the State Revenue matching data and has reviewed USDA reporting requirements, SA reporting requirements, and special studies by other government and private agencies. This information is not currently reported to any other entity outside of FNS.

3. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

Information being requested or required has been held to the minimum required for the intended use. Although smaller SAs involved in this data collection effort, they delivered the same program benefits and perform the same function as any other State. Thus, they maintain the same kinds of information on file. FNS estimates that 1-3 percent of our respondents (out of 57) are small entities.

3. 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.

Federal funds must be matched with State revenues on a school year basis. Collecting information less frequently would result in the unlawful use of Federal funds. Without the information collected on Form FNS-13, FNS would not be able to monitor State compliance with this revenue matching requirement.

7. Circumstances that would cause an information collection to be conducted in a manner that is inconsistent with 5 CFR 1320.5:

• 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. The collection of information is conducted in a manner consistent 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.

A notice was published in the Federal Register on September 9, 2013 (Volume 78, Number 174, and Page 55052). No public comments were received in response to the notice published in the Federal Register.

• 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.

FNS consults with its Regional Offices any proposed changes as the result of legislative, regulatory, or administrative changes. The Regional Offices are in constant contact with SAs who provide feedback on FNS processes and procedures that may impact them. After consultation with Regional Office staff, the response time (estimated average number of hours per response) was decreased from the previously approved 80 hours to 8 hours and hence the total number of burden hours was reduced from 4,560 to 456 hours. This revision made significant program adjustment to reporting burden hours as a result of automation and the advancement of State systems technology.

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

No payment or gift will be provided to respondents.

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

This information does not require confidentiality.

8. 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.

There are no questions of a sensitive nature involved.

8. Provide estimates of the hour burden of the collection of information. The statement should include:

• 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 burned estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

Form number FNS-13 collects information from 57 SAs on an annual basis. The estimated average burden hours per SA has been determined to be 8 hours per response based on consultations with the SAs submitting reports. After consultation with Regional Office staff, the response time (estimated average number of hours per response) was decreased from the previously approved 80 hours to 8 hours and hence the total number of burden hours was reduced from 4,560 to 456 hours. Therefore, the previously OMB approved burden will be reduced from 4,560 to 456. This revision made significant program adjustment to reporting burden hours as a result of automation and the advancement of State systems technology.

# Respondents	# Responses Per Respondent	Total Annual Responses	Hours Per Response	Total Annual Burden
57	1	57	8	456

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

The estimate of respondent cost is based on the burden estimates from the Bureau of Labor Statistics May 2011 Occupational and Wage Statistics (25-0000) (http://www.bls.gov/oes/2011/may/oes_nat.htm#25-0000). The hourly mean wage (education-related occupation) for functions performed by State and local agency staff are estimated at $24.46 per staff hour.

TOTAL COST TO PUBLIC = 456 hour X $24.46 per hour = $11,154

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.

It is estimated that a GS 12/06 takes approximately 80 hours to analyze data received from SAs:

$41.85 x 80 hrs. = $3,348 (estimated annualized cost to the Federal government.)

15. Explain the reasons for any program changes or adjustments reported in Items 13 or

14 of the OMB 83-I.

This is a revision of a currently approved data collection. After consultation with Regional Office staff, the estimated average number of hours per response was decreased from the previously approved 80 hours to 8 hours as a result of automation (at the State level) and the advancement of State systems technology. Therefore, the previously OMB approved burden will be adjusted from 4,560 to 456.

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

The information collected is not published for external distribution.

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.

The agency plans to display the expiration date for OMB approval of the information collection on all instruments.

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

There are no exceptions to the certification statement.