0584-0492 Supporting Statement Revised 7-29-14

SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM

REPAYMENT DEMAND AND PROGRAM DISQUALIFICATION

OMB NUMBER: 0584-0492

Kelly Stewart, Project Officer

Supplemental Nutrition Assistance Program

Food and Nutrition Service, USDA

3101 Park Center Drive, Room 820

Alexandria, VA 22302

Phone: 703-305-2425 and Fax: 703-305-2425

[email protected]

Table of Contents

Part A Justification

A.1 Explanation of Circumstances That Make Collection of Information Necessary

A.2 How the Information Will Be Used, By Whom, and for What Purpose

A.3 Use of Improved Information Technology to Reduce Burden

A.4 Efforts to Identify and Avoid Duplication

A.5 Efforts to Minimize Burden on Small Businesses or Other Entities

A.6 Consequences of Less Frequent Data Collection

A.7 Special Circumstances Requiring Collection of Information in a Manner Inconsistent

with Section 1320.5(d)(2) of the Code of Federal Regulations

A.8 Federal Register Comments and Efforts to Consult with Persons outside the Agency

A.9 Payments to Respondents

A.10 Assurance of Confidentiality

A.11 Questions of a Sensitive Nature

A.12 Estimates of Respondent Burden

A.13 Estimates of Other Annual Costs to Respondents

A.14 Estimates of Annualized Government Costs

A.15 Changes in Hour Burden

A.16 Time Schedule, Publication, and Analysis Plans

A.17 Display of Expiration Date for OMB Approval

A.18 Exceptions of Certification Statement

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 statement supports the request for a revision of the currently approved information collection associated with initiating collection actions against households who received an overissuance in the Supplemental Nutrition Assistance Program (SNAP), issuing notifications to SNAP households regarding processes related to intentional program violations (IPV), and using disqualified recipient data to ascertain the correct penalty for IPVs, based on prior disqualifications.

Initiating Collection Action - Section 13(b) of the Food and Nutrition Act of 2008, as amended (7 U.S.C. 2022(b)), and Supplemental Nutrition Assistance Program (SNAP) regulations at 7 CFR 273.18(a)(2) require State agencies to initiate collection action against households that have been overissued benefits. To initiate collection action, State agencies must provide an affected household with written notification informing the household of the claim and demanding repayment. This process is automated in most State agencies. Note that for overissuance claims, this information collection only covers the activities associated with initiating collection. The burden associated with reporting collections and other claims management information on form FNS-209 is covered under currently approved OMB number 0584-0069, expiration date 9/30/2015. The burden associated with referring delinquent claims and receiving collections through the Treasury Offset Program is covered under currently approved OMB number 0584-0446, expiration date 4/30/2016.

Intentional Program Violation Notification - SNAP regulations at 7 CFR 273.16(a)(1) require State agencies to investigate any case of suspected fraud and, where applicable, make an intentional Program violation (IPV) determination either administratively or judicially. This activity is vital to protect and enhance the integrity of SNAP. Notifications and activities involved in the IPV process include:

• 7 CFR 273.16(e)(3) - The State agency providing written notification informing an individual suspected of committing an IPV of an impending administrative disqualification hearing or court action;

• 7 CFR 273.16(f)(2) and 273.16(h)(2) - An individual opting to accept the disqualification and waiving the right to an administrative disqualification hearing or court action by signing either a waiver to an administrative disqualification hearing or a disqualification consent agreement in cases of deferred adjudication and returning it to the State agency; and

• 7 CFR 273.16(e)(9) - Once a determination is made regarding an IPV, the State agency sending notification to the affected individual of the action taken on the administrative disqualification hearing or court decision.

Accessing, Reviewing, and Updating Disqualified Recipient Data - SNAP regulations at 7 CFR 273.16(i)(4) require State agencies to use disqualified recipient data to ascertain the correct penalty for IPVs, based on prior disqualifications. State agencies determine this by accessing and reviewing records located in the Electronic Disqualified Recipient System (eDRS). eDRS is an automated system developed by FNS that contains records of disqualifications in every State. State agencies are also responsible for updating the system, as required at 273.16(i)(2)(i), which includes reporting disqualifications in eDRS as they occur and updating eDRS when records are no longer accurate, relevant, or complete.

2. 1. 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.

Initiating Collection Action – To initiate collection action, SNAP regulations at 7 CFR 273.18(a)(2) require all 53 State agencies to provide written notification as needed to all households that were overissued SNAP benefits informing them of the claim and a demand for repayment. This process is automated in most State agencies. The notification must conform to the requirements of 7 CFR 273.18(e)(3)(iv) to include the data below:

• The amount of the claim;

• The intent to collect from all adult household members;

• The type of and reason for the claim;

• The time period associated with the claim;

• How the claim was calculated;

• A listing of payment procedures and applicable options;

• A listing of appeal and due process rights; and

• A listing of actions that may be taken if the claim is not timely paid.

Intentional Program Violations (IPV) – SNAP regulations at 7 CFR 273.16(a)(1) require State agencies to investigate any case of suspected fraud, and, where applicable, make a determination of an IPV either administratively or through the court. A State agency may determine an IPV by:

• The individual accepting the penalty by signing a waiver of right to an administrative disqualification hearing (ADH);

• The individual signing a disqualification consent agreement in cases of deferred adjudication; or

• An administrative hearing official or a court of appropriate jurisdiction determining that the individual committed the IPV.

SNAP regulations at 7 CFR 273.16(e)(3) require that State agencies provide written notification of an impending ADH to the individual suspected of committing an IPV. The notification contains an explanation of the charge against the individual, the potential penalties, and a listing of the rights and options afforded to the individual. A similar notification is sent to individuals who are being prosecuted through the court.

In some State agencies, one of the options available to the individual under 7 CFR 273.16(f)(2) is the ability for the individual to waive the right to an ADH and accept the disqualification penalty. The disqualification waiver may be included in the advance notification or provided as a separate attachment for the individual to sign and submit to avoid having the ADH. Similarly, under 7 CFR 273.16(h)(2), State agencies may establish procedures to provide the accused individual with the option to consent to a Program disqualification to avoid criminal prosecution.

Once a determination is made regarding an IPV, the State agency must send notification to the affected individual of the action taken on the ADH or court decision, as required at 7 CFR 273.16(e)(9). This includes notifying the person that he/she will be disqualified and when the disqualification will become effective.

One of the factors used by a State agency to determine the appropriate disqualification penalty to assign to an individual is whether or not the individual was found to have committed any prior IPVs. The way that State agencies determine this is by accessing and checking the Electronic Disqualified Recipient System (eDRS). eDRS is an automated system developed by FNS that contains records of disqualifications in every State. Per 7 CFR 273.16(i)(4) State agencies are responsible for checking eDRS to determine the appropriate length of each disqualification.

7 CFR 273.16(i)(2)(i) requires State agencies to update the eDRS system, which includes reporting disqualifications as they occur and removing records which are no longer accurate, relevant, or complete. States have a choice between using a batch process for correcting and resubmitting data or submitting data directly through the eDRS website. Data entry errors are identified at the point of entry and corrections can be made immediately.

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 technology. Federal agencies are to provide for electronic submission of information as an alternative to paper submission. 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. For initiating collection action, this process is automated in most State agencies. The tracking and notification process for IPVs is also automated in most State agencies. FNS makes every effort to comply with these requirements for this information collection. eDRS is an automated system developed and maintained by FNS and is made available to all 53 State agencies so that they may submit and retrieve data efficiently; 100 percent of the States submit data electronically.

4. 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.

Based on research conducted during the life cycle of this information collection, there was no other information collection that existed that would serve the Agency’s purpose. To ensure program integrity, FNS solely monitors overissuance and intentional violations of SNAP benefits. The information required for eDRS and repayment demands is not currently reported to any other entity outside of FNS. Every effort has been made to avoid duplication. FNS has reviewed USDA reporting requirements, state administrative agency reporting requirements and special studies by other government and private agencies.

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

The information required has been held to the minimum requirement for the intended use. Circumstances limit the flexibility in modifying the reporting and recordkeeping requirements to comply with statutory requirements and to protect Program integrity. There are no small businesses involved in this data collection.

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.

If FNS did not initiate overissuance collection actions, the Federal program would not be in compliance with Federal regulations. Additionally, claims collections have a direct financial impact on both State and Federal government. If these overissuances were not identified and households not notified about overissuances, both entities stand to lose an opportunity to reduce Program costs by millions of dollars. There is also a negative impact on recipients. Not adequately notifying a household of an overissuance or an impending IPV compromises the respondent’s right to due process. Further, States are responsible for assigning the appropriate penalty lengths to those found guilty of an IPV. Individuals who have committed prior IPVs are assigned longer penalty durations. States access eDRS in order to determine if any prior IPVs have been committed. States are responsible for updating the system so that it may be used for this purpose.

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 that is 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.

The 60-day notice was published in the Federal Register on March 24, 2014, Volume 79 Number 56, and Page 15936. No comments were received.

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.

Informal discussions with State agencies and advocates occur during annual conferences, such as at the United Council on Welfare Fraud (UCOWF) conference and the Public Assistance Information Reporting System (PARIS) conference. State agencies continue to indicate they generally support the initiating collection action and IPV procedures. The advocacy community also generally supports this activity as it provides households and recipients advance notice of an impending adverse action.

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.

The Privacy Act of 1974 requires that before personal identifying information (such as social security numbers) may be shared with other entities, a Privacy Act notice must first be published.  Therefore, the Food and Nutrition Service published such a System of Record Notice (SORN) on March 27, 1998 in the Federal Register Volume 63, Number 59, Page 14894, titled USDA/FNS-3 “Claims Against Food Stamp Recipients.”

The Food and Nutrition Act of 2008, Section 11(e)(8) and 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 the SNAP. The information will be kept private; the activities covered by this action are to be used by those directly connected with the administration of SNAP. Access to records is limited to those persons who process the records or conduct research in an investigation as stated in this Privacy Act notice, except as otherwise required by law.

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 question 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.

(53) State Agency reporting and recordkeeping burdens followed by (917,566) household reporting burden hours are stated in the narrative and separated out in the tables below.

State Agencies reporting burden is estimated at 141,506.314 hours and 1,095,018.000 total annual responses. The recordkeeping burden estimates for State Agencies is 33,454 and the total annual responses are estimated at 1,003,746. The household 32,873 hours and 1,030013 total annual responses are stated in the narrative and separated out in the tables below:

STATE AGENCIES REPORTING BURDEN:

• (7 CFR 273.18 (a)(2) Demand Letter for Overissuance – State agencies provide an affected household with written notification informing the overissued household of the claim and demanding repayment as required. FNS estimates the annual reporting and recordkeeping burden for State agencies (122,339 hours). This estimated burden is based on the assumption that it takes the State agency an average of 8 minutes to produce an automated demand letter, 2 minutes for State agency recordkeeping. The total number of notifications used in this estimate was based on FY 2012 data and is 917,566 per year. The annual burden on the State agency is 122,339 hours to produce the letter.

• (7 CFR 273.16(e)(3) Action taken on Hearing and Court Decision for Intentional Program Violation – State agencies must provide written notification of an impending ADH to the individual suspected of committing an IPV. A similar notification is sent to individuals who are being prosecuted through the court. We estimate, data that about 43,743 households received these notifications sent by State agencies each year. In addition, we assume that it will take the State agency an average of 8 minutes to produce a notification for a hearing or prosecution and the household about 1 minute to read the notification. The annual reporting burden associated with this activity then computed to be 5,832 hours for the State agency.

• 7 CFR 273.16(e)(9) Action Taken on Hearing or Court Decision: For IPV Findings Once a determination is made regarding an IPV, the State agency must send notification to the affected individual of the action taken on the ADH or court decision. We estimate that 53 State Agencies sends approximately 800 notifications per State Agencies to 42,437 households receive notifications sent by State agencies each year to individuals who were found to have committed an IPV. In addition, we assume that it will take a State agency an average of 10 minutes to produce a notification for a hearing or prosecution. The annual reporting is 7,073 hours for the State agency.

• 7 CFR 273.16(e)(9) Action Taken on Hearing or Court Decision: For No IPV Findings. In addition, we estimate that 53 State Agencies will send about 1,306 individuals/households notices (average of 24 per State) after their hearings that they have not committed an IPV. We estimate that this activity takes the State agency an average of 5 minutes to produce a notification for hearing or prosecution and the household about 1 minute to read the notification. The additional annual burden associated with this activity is broken out into 109 hours for the State.

• 7 CFR 273.16(i)(2)(i) Electronic Disqualified Recipient System Breakout: For eDRS Reporting. The burden associated with eDRS involves 53 State agencies updating approximately 800 eDRS records with disqualification data, correcting and resubmitting any incorrect entries, and accessing the system to determine the proper disqualification penalty for a total annual response of 42,437. We estimate that the data will take a State agency about 5 minutes to enter a disqualification into eDRS for an annual burden 3,536 hours associated with the eDRS process.

• 7 CFR 272.1(f)(3) Electronic Disqualified Recipient System Breakout: For Editing and Resubmission. In addition to entering data, 53 State agencies need to correct and resubmit disqualification data that contained an error when the data were originally entered. We estimate that eDRS initially rejects about 12 percent or 5,092 disqualifications because of missing or improperly entered data. This is approximately 96 responses per State Agencies. We also estimate that it takes about 10 minutes for the agency to correct and re-enter this data. The total annual burden associated with this activity is 849 hours.

• 7 CFR 273.16(i)(4) Electronic Disqualified Recipient System Breakout: For Penalty Checks using Mainframe. Since the disqualification period is longer if the individual is a repeat offender, the State agency needs to access eDRS each time an individual is disqualified to determine whether the individual has any prior disqualifications. Currently, State agencies use their own database (which is periodically updated with eDRS data) or connect directly to eDRS online to perform this function. We estimate 53 State Agencies will review approximately 800 records per State Agencies for estimated total annual records of 42,437 disqualifications in eDRS in FY 2012. It will take an average of 2.5 minutes to check each of the estimated disqualification records for an estimated total burden hours of 1,768 hours.

STATE AGENCIES RECORDKEEPING BURDEN:

• 7 CFR 272.1(f) Recordkeeping for initiating collection actions. The total number of notifications used in this estimate was based on FY 2012 data. The annual burden on the State agency is 30,582 burden hours for recordkeeping. This estimated burden is based on the assumption that it takes the 53 State agencies to maintain an estimated 17,312.57 records per recordkeepers. It takes an average of 2 minutes for State agency recordkeeping for a total annual notification of 917,566 burden hours per year.

• 7 CFR 272.1(f) Recordkeeping for Intentional Program Violation - This estimated burden is based on the assumption that it takes 53 State agencies to maintain an estimated number of 1,626 IPV records per State Agencies. The total number of IPV maintained is 86,180 records. Again, it takes an average of 2 minutes for State agency recordkeeping for approximately 2,872.37 burden hours.

INDIVDUAL/HOUSEHOLD REPORTING BURDEN:

• 7 CFR 273.18(a)(2) Demand Letter for Overissuance - FNS estimates the annual the reporting burden on the households to read the letter is 30,582 hours per year. This estimated burden is based on the assumption that it 917,566 respondent about 2 minutes for the household to read the letter. There is no recordkeeping burden imposed on the households.

• 7 CFR 273.16(e)(3) Action taken on Hearing and Court Decision for Intentional Program Violation – We estimate, 43,743 households received these notifications sent by State agencies each year. A notification for a hearing or prosecution and the household about 1 minute to read the notification. The annual reporting burden associated with this activity then estimated at 729 hours for the households.

• 7 CFR 273.16(i)(2) - In some State agencies, one of the options available is the ability for the accused individual to waive the right to an ADH and accept the disqualification penalty. Similarly, State agencies may establish procedures to provide the accused individual with the option to consent to a Program disqualification to avoid criminal prosecution. We are estimating that 24,961 households (18,112 Administrative Disqualification Hearing Waiver and 6,849 Disqualification Consent Agreement) will use either of these options. We are estimating that it takes a household about 2 minutes to respond to either of these options. The resulting household burden is estimated to be 832 hours per year.

• 7 CFR 273.16(i)(2) Administrative Disqualification Hearing Waiver. Approximately 18,112 individuals/households will receive a notification letter. We estimate it will take approximately 1 minute to read this notification for a total annual burden of 603 burden hours.

• 7 CFR 273.16(i)(2) Disqualification Consent Agreement. FNS estimates that out of those 18,112 households approximately 6,849 will receive a disqualification consent agreement and it too will take approximately 1 minute to read and sign for an estimated total burden hours of 228 burden hours.

• 7 CFR 273.16(e)(9) Action Taken on Hearing or Court Decision: For IPV Findings. Once a determination is made regarding an IPV, the State agency must send notification to the affected individual of the action taken on the ADH or court decision. We estimate that 42,437 households will receive and read notifications by State agencies each year to individuals who were found to have committed an IPV. We estimate that it will take households about l minute to read the notification. The annual reporting is 707 hours for the household reporting.

• 7 CFR 273.16(e)(9) Action Taken on Hearing or Court Decision: For No IPV Findings. Once a determination is made regarding an No IPV findings, the State agency must send notification to the affected individual of the action taken on the ADH or court decision. We estimate that 1,306 households will receive and read notifications by State agencies each year to individuals who were found No IPV. We estimate that it will take households about l minute to read the notification. The annual reporting is 22 hours for the household reporting.

Table A. 12.1 Reporting and Recordkeeping Burden Hour Estimates

Title	CFR Section of Regulations	Estimated # Respondents	Responses Per Respondent	Total Annual Responses (Col. DxE)	Estimated Avg. # of Hours Per Response	Estimated Total Hours (Col. FxG)	Previously Approved	Due to Program Change	Due to an Adjustment	Total Difference
STATE AGENCY
Reporting Burden
Demand Letter for Overissuance	273.18(a)(2)	53	17,312.57	917,566.00	0.13333	122,339.075	91,722.931	0.000	30,616.144	30,616.144
Notice for Hearing or Prosecution	273.16(e)(3)	53	825.34	43,743.00	0.13333	5,832.254	6,892.361	0.000	-1,060.107	-1,060.107
Action Taken on Hearing or Court Decision: For IPV Findings	273.16(e)(9)	53	800.70	42,437.00	0.16667	7,072.975	8,362.665	0.000	-1,289.690	-1,289.690
Action Taken on Hearing or Court Decision: For No IPV Findings	273.16(e)(9)	53	24.64	1,306.00	0.08333	108.829	126.328	0.000	-17.499	-17.499
Electronic Disqualified Recipient System Breakout: For eDRS Reporting	273.16(i)(2)(i)	53	800.70	42,437.00	0.08333	3,536.275	4,181.483	0.000	-645.208	-645.208
Electronic Disqualified Recipient System Breakout: For Editing and Resubmission	272.1(f)(3)	53	96.08	5,092.00	0.16667	848.684	1,003.520	0.000	-154.836	-154.836
Electronic Disqualified Recipient System Breakout: For Penalty Checks using Mainframe	273.16(i)(4)	53	800.70	42,437.00	0.04167	1,768.222	2,090.717	0.000	-322.495	-322.495
Total State Agency Reporting Burden		53	20,660.730	1,095,018.000	0.12923	141,506.314	114,380.005	0.000	27,126.309	27,126.309
Recordkeeping
Title		Estimated # Recordkeepers	Records Per Recordkeeper	Annual Records	Estimated Avg. # of Hours Per Records	Estimated Total Annual Records	Previously Approved	Due to Program Change	Due to an Adjustment	Total Difference
Recordkeeping Breakout: For initiating Collection Action	272.1(f)	53	17,312.57	917,566.00	0.03333	30,582.475	22,930.504	0.000	7,651.971	7,651.971
Recordkeeping Breakout: For IPVs	272.1(f)	53	1,626.04	86,180.00	0.03333	2,872.379	3,395.699	0.000	-523.320	-523.320
Total State Agency Recordkeeping Burden		53	18,938.606	1,003,746.000	0.03333	33,454.854	26,326.203	0.000	7,128.651	7,128.651
	CFR Section of Regulations	Estimated # Respondents	Responses Per Respondent	Total Annual Responses	Estimated Avg. # of Hours Per Response	Estimated Total Hours	Previously Approved	Due to Program Change	Due to an Adjustment	Total Difference
TOTAL STATE AGENCY BURDEN		53	39,599.321	2,098,764.000	0.08336	174,961.168	140,706.208	0.000	34,254.960	34,254.960
Title		Estimated # Respondents	Responses Per Respondent	Total Annual Responses (Col. DxE)	Estimated Avg. # of Hours Per Response	Estimated Total Hours (Col. FxG)	Previously Approved	Due to Program Change	Due to an Adjustment	Total Difference
HOUSEHOLD
Reporting Burden
Demand Letter for Overissuance	273.18(a)(2)	917,566.00	1.00	917,566.00	0.03333	30,582.475	22,930.504	0.000	7,651.971	7,651.971
Notice for Hearing or Prosecution	273.16(e)(3)	43,743.00	1.00	43,743.00	0.016667	729.065	861.532	0.000	-132.467	-132.467
Administrative Disqualification Hearing Waiver	273.16(i)(2)	18,112.00	1.00	18,112.00	0.03333	603.673	711.062	0.000	-107.389	-107.389
Disqualification Consent Agreement	273.16(i)(2)	6,849.00	1.00	6,849.00	0.03333	228.277	275.706	0.000	-47.429	-47.429
Action Taken on Hearing or Court Decision: For IPV Findings	273.16(e)(9)	42,437.00	1.00	42,437.00	0.016667	707.281	836.297	0.000	-129.016	-129.016
Action Taken on Hearing or Court Decision: For No IPV Findings	273.16(e)(9)	1,306.00	1.00	1,306.00	0.016667	21.767	25.266	0.000	-3.499	-3.499
Total Household Reporting Burden		917,566	1.12255	1,030,013.000	0.03191	32,872.537	25,640.367	0.000	7,232.170	7,232.170
SUMMARY OF BURDEN
State Agency Level		53		2,098,764.000		174,961.168	140,706.208	0.000	34,254.960	34,254.960
Household		917,566		1,030,013.000		32,872.537	25,640.367	0.000	7,232.170	7,232.170
TOTAL BURDEN THIS COLLECTION		917,619	3.40967	3,128,777.000	0.06643	207,833.705	166,346.575	0.000	41,487.130	41,487.130

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

Based on the Bureau of Labor Statistics May 2012 Occupational and Wage Statistics – 43-4061 (http://www.bls.gov/oes/current/oes434061.htm), hourly mean wage for Eligibility Interviewers, Government Programs functions performed by State and local agency staff are valued at $20.15 per staff hour. Based on the total estimated burden for State agency reporting and recordkeeping of 174,961.27 hours, the total cost is $3,525,467.54. The State share is 50% of the total cost, or $1,762,733.77.

SA Reporting and Recordkeeping for 0584-0492

1. State and local government

cost @ $20.15/per staff hour $3,525,467.54

2. Less Federal reimbursement $1,762,733.77

3. Net cost to State and local

government $1,762,733.77

Respondent Cost (SA) = $1,762,733.77

According to the Bureau of Labor Statistics, the Federal minimum wage rate is $7.25 an hour. Based on the total estimated burden hours for household reporting of 32,872.55, the total cost to households is $238,325.92.

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 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.

Annualized costs for the Federal government include 50% of total cost to State agencies and their issuance agents. Based on the total estimated burden for State agency reporting and recordkeeping of 174,961.17 hours, the total cost is $3,525,467.54. The Federal share is 50% of the total cost, or $1,762,733.77.

Federal costs for this burden also include an estimated 12 hours of work to collect and review data by a Program Analyst (GS-12, Step 1) at $35.88 an hour, and 4 hours of work by a Branch Chief (GS-14, Step 1) at $50.41 an hour, totaling $632.20. Adding in the Federal share of State costs, the total annualized cost to the Federal government is $1,763,365.97 (1,763,733.77 + 632.20 = 1,763,365.97).

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 approved collection. These adjustments are a result of an increase in overissuance collections and a decrease in IPV activity. The overall current burden inventory for this collection is 166,347 and this revision seeks to request 207,834. This revision burden estimates reflects a total increase of 41,488 burden hours reported in this information collection. The IPV- related State agency and household annual reporting and recordkeeping burden has decreased slightly from 21,486 hours to 19,167 hours to reflect the lower number of disqualifications. eDRS has allowed States to better identify and track recipients disqualified from the Program. As a result of these adjustments, the annual burden associated with the eDRS process reflects a total decrease from 7,733 hours to 6,153 hours per year. This decrease is due to the lower number of intentional Program violations. However, the overall burden inventory has increased since the last revision.

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

Aggregate data on the number of claims established and disqualification are included in the SNAP State activity report that is released on an annual basis on the United States Department of Agriculture web site.

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.

There is no form associated with this information collection; therefore, this submission is not seeking OMB approval to not display the expiration date. This information collection plans to display the OMB control number and expiration date on the database home page.

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.