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pdf2014 SUPPORTING STATEMENT
[TITLE OF DOCKET]
OMB # _0584____ - __0559__
Contents
A.1
Explanation of Circumstances That Make Collection of Data Necessary ................................... 1
Authorizing Legislation ...................................................................................................................... 1
Very Low Food Security Among Children is Acute During the Summer Months ............................ 1
Congressionally Mandated Summer EBT for Children Demonstrations ........................................... 2
Evaluation Objectives ......................................................................................................................... 4
A.2
How the Information Will Be Used, By Whom, and For What Purpose..................................... 4
Overview of the Research Design ...................................................................................................... 5
Use of the Information........................................................................................................................ 9
A.3
Uses of Improved Information Technology to Reduce Burden .................................................. 10
A.4
Efforts to Identify and Avoid Duplication.................................................................................... 11
A.5
Efforts to Minimize Burden on Small Businesses or Other Entities .......................................... 11
A.6
Consequences of Less Frequent Data Collection ......................................................................... 12
A.7
Special Circumstances Requiring Collection of Information in a Manner Inconsistent with
Section 1320.5(d)(2) of the Code of Federal Regulations ............................................................ 12
A.8
Federal Register Comments and Efforts to Consult with Persons Outside the Agency .......... 13
Consultations Outside the Agency ................................................................................................... 13
A.9
Payments to Respondents .............................................................................................................. 13
A.10 Assurances of Confidentiality ........................................................................................................ 14
Institutional Review Board ............................................................................................................... 16
A.11 Questions of a Sensitive Nature ..................................................................................................... 16
A.12 Estimates of Respondent Burden .................................................................................................. 16
A.13 Estimates of Other Annual Costs to Respondents ....................................................................... 17
A.14 Estimates of Annualized Government Costs ................................................................................ 17
A.15 Changes in Hour Burden ............................................................................................................... 19
A.16 Time Schedule, Publication, and Analysis Plans ......................................................................... 19
Study Schedule ................................................................................................................................. 19
Analysis Plan .................................................................................................................................... 20
Analysis Methods ............................................................................................................................. 20
Publication of Study Results ............................................................................................................ 21
i
A.17 Display of Expiration Date for OMB Approval ........................................................................... 21
A.18 Exceptions to Certification Statement .......................................................................................... 21
References .................................................................................................................................................. 22
ii
A.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.
Authorizing Legislation
This is a revision of a currently approved information collection. In the 2010 Agriculture Appropriations
Act (P.L. 111-80), Section 749(g), Congress authorized demonstration projects to develop and test
methods of providing access to food for low-income children in urban and rural areas during the summer
months when schools are not in regular session, as well as a rigorous independent evaluation of the
projects regarding their effectiveness. The data being collected under this submission are necessary to
meet the congressionally-mandated requirement for an independent evaluation of the Summer Electronic
Benefit Transfer for Children (SEBTC) Demonstration being conducted by FNS under this authorizing
legislation.
The first year of the SEBTC Demonstration, 2011, was a proof-of-concept (POC) period. The actual
demonstration began in 2012 and continued through 2013. The data being collected under this
submission are for the 2014 and potentially 2015-2016 years of the demonstration.
Background
Very Low Food Security Among Children During the Summer Months
Despite the existence of three USDA food programs that provide meals directly to children, many
children are not food secure and some meet the standard for Very Low Food Security (VLFS).
Furthermore, the available evidence suggests that levels of VLFS are even higher during the summer
months when most children are not in school. During the school year, most children in low-income
households (income <185 percent of the poverty level) have access to free or reduced-price meals through
the School Breakfast Program (SBP) and the National School Lunch Program (NSLP). In contrast,
1
summer access to meals through the Summer Food Service Program (SFSP) is much more limited. There
are significant geographic gaps in the availability of the SFSP—even in those communities where the
program operates, rates of participation by eligible children are well below rates of participation for the
SBP and NSLP. Gaps in coverage by the SFSP are among several factors responsible for the summer
spike in VLFS.
National data for 2008 show that 21 percent of all households with children experienced low or very low
food security, and 1.5 percent of all children experienced VLFS (Nord et al. 2009). Food insecurity is
considerably higher among the low income population; 39 percent experienced low or very low food
security (17 percent VLFS) which translates to 3.1 percent of VLFS among children. In addition, 20
percent of food insecure households obtained emergency food from a local food pantry or emergency
kitchen, suggesting that households at greatest risk of VLFS seek food assistance from multiple sources
(Nord et al. 2009). In fact, in 2009, 33 percent of families with children visiting food pantries in the
Feeding America National Network had VLFS, and another 43 percent had low food security (Mabli et al.
2010). National data from the Current Population Survey (CPS) indicate that food insecurity changes
seasonally. Households with school-age children have a higher prevalence of food insecurity in the
summer, and rates of food insecurity were greater in states with fewer SFSP and summertime NSLP
meals (Nord and Romig 2006). The summer spike in food insecurity among children is consistent with
anecdotal reports that emergency kitchens see more children accompanying adults in summer months.
Congressionally Mandated Summer EBT for Children Demonstrations
The SFSP was implemented in 1975 to reduce the risk that children in low-income households would
miss meals during the summer when they have little or no access to the NSLP and SBP. Research
suggests that an expanded SFSP could, in principle, substantially reduce, though not eliminate, the
summer spike in VLFS among children (Nord and Romig 2006). However, logistical and other practical
considerations would present barriers to such expansion. The SFSP is operated by local community-based
2
organizations in churches, recreation centers, schools, and the like. It would be challenging to find
additional program operators and locations to expand the program sufficiently to dramatically increase
access to it. Furthermore, even in those areas where substantial expansion of the SFSP would be feasible,
rates of participation by eligible children would likely remain below those for the NSLP and SBP. An
earlier evaluation of the SFSP reported various barriers to SFSP participation, including lack of
transportation, lack of publicity about the program, limited days and hours of site operations, lack of
program activities, and parents’ concerns about neighborhood safety (Gordon and Briefel 2003). In
addition, most SFPS sites operate for eight weeks or less, leaving low-income children with several weeks
in the summer with no SFSP or alternative program for meals.
In response to the high prevalence of VLFS among low-income children when school is not in session,
Congress has mandated that USDA implement demonstrations of two approaches to reducing the risk that
children will miss meals during the summer. The first of these demonstrations enhanced the existing
SFSP so that it can serve more children in the demonstration sites. The second of these demonstrations,
which is the subject of this evaluation, has used existing SNAP and WIC benefit delivery systems to
enhance the food purchasing power of households with eligible children during the summer months. More
specifically, the benefits are delivered through the electronic benefit transfer (EBT) procedures used by
the SNAP and the WIC program. This Summer EBT Benefits for Children demonstrations have
supplemented rather than replace SFSP in the demonstration sites.
In authorizing the demonstrations, Congress mandated that USDA provide for their rigorous independent
evaluation. The demonstrations and evaluation have provided and will continue to provide USDA and
Congress with comprehensive research findings that will allow policy makers to determine whether the
SEBTC methodology is a feasible and effective strategy for reducing VLFS, reducing low food security,
and improving nutrition status among children in low-income households.
3
The SEBTC benefit was provided to households of children from pre-kindergarten through 12th grade
who are certified for free and reduced-price (FRP) school meals in the demonstration school food
authorities (SFAs). The amount of the benefit in 2011 and 2012, an approximately $60 value per summer
month per eligible child in the household, is comparable to the cost of free lunches plus breakfasts under
the NSLP and SBP. Benefits—provided monthly on an EBT card and prorated for partial summer
months—were administered by grantees in the summer for the period when schools are not in session.1
FNS added a third demonstration year in 2013 to evaluate two levels of SEBTC benefits—a $60 value
versus $30 value per month per eligible child in the household. The 2014 demonstrations will provide
benefits to the same households at the same levels as were provided in 2013.
Evaluation Objectives
The 2014 evaluation of SEBTC has two broad objectives: (1) to describe the receipt and use of the
benefits and (2) to describe the implementation of the SEBTC in terms of approaches used and the
challenges and lessons learned during the demonstrations.
A.2
INDICATE HOW, BY WHOM, HOW FREQUENTLY, 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.
This section of the supporting statement provides an overview of the research design and data collection
efforts planned to meet the overall objectives of the Summer Electronic Benefits Transfer for Children
(SEBTC) Demonstration: Evaluation Findings for the Fourth Implementation Year.
1
More information on these evaluations and projects can be found on the FNS website at [http://www.fns.usda.gov/ops/summerfood-children-demonstrations].
4
Overview of the Research Design
The USDA/FNS released a Request for Application (on August 11, 2010 which closed October 29, 2010
under OMB Control Number 0584-0512, expiration date: 1/31/2016 to States that are implementing
either EBT systems for SNAP or for WIC. From among those States, USDA awarded five grants in Year
1 (school year 2010/11) for the proof-of-concept year that targeted 5,000 households. Each grantee had a
single site. 2 The second year, referred to as the “full implementation year” expanded the demonstration to
10 State agencies (grantees) and a total of 14 sites, and targeted 27,000 households for the evaluation
(school year 2011/2012). In Year 3 (school year 2012/2013), all 10 grantees provided SEBTC benefits
($60) in 2013 to all of the households who received them in 2012, if they still had eligible children. For
the evaluation component, FNS selected four of the 2012 grantees (Chickasaw Nation, Delaware,
Michigan, and Oregon) to implement the 2013 demonstration ($30 benefits vs. $60 benefits)) and
evaluation in six sites (targeting 18,000 households). The 2014 evaluation will examine 5 States that
participated in the 2013 demonstration and evaluation. This collection will not re-contact any households
that participated in prior phases of this study.
Measures
Exhibit A.1 provides an overview of the research objectives for the study, the outcome measures and the
data sources.
2
The term “grantee” refers to the State agency or group of agencies implementing the demonstration. In 2013, two of the 10
grantees are Indian Tribal Organizations (ITOs) with demonstration sites in Oklahoma. For this report, the term “State” or
grantee refers to the 10 grantees composed of eight States and two ITOs.
5
Exhibit A.1. SEBT for Children Evaluation Research Objectives, Outcomes, Subgroups for Analysis, Data Sources, and Analysis
Methods
Research Objectives
Use of Benefits by Participants
Implementation of Demonstrations
Subgroups Represented
in Analysis
Data Sources
By site
EBT transaction data
By demonstration type
(SNAP vs. WIC)
By benefit level
By site
By demonstration type
(SNAP vs. WIC)
Stakeholder (grantee or
school) interviews
Analysis Methods
Descriptive statistics presented in tables,
cross-tabs, and charts
Descriptive lists, tables, and narrative
6
Use of Benefits Analysis
In the 2011 and 2012 reports, the SEBTC evaluation described patterns of use of the $60 SEBTC benefit
for households in the treatment group. In 2013, in addition to providing similar descriptive results for
households who received the $60 SEBTC benefit and the $30 benefit, the evaluation also assessed the
differential impact of a $60 SEBTC benefit relative to a $30 benefit on SEBTC participation (i.e., any use
of the SEBTC benefit), the proportion of SEBTC that households redeemed SEBTC benefits, and the
proportion of households that exhausted all of their SEBTC benefits in at least one month. The 2014
evaluation will also provide these descriptions.
Specifically, the research questions for the analysis of SEBTC benefit use are:
1. How do the participants use their SEBTC benefits? What are their respective benefit
participation, redemption, and exhaustion rates, overall and by site? For households in WIC sites,
how do redemptions vary by food category?
2. What are the size and types of stores at which the benefits are used?
3. In WIC sites, what foods are purchased by participants with their benefits? For households in
WIC sites, what specific foods within the food categories are purchased?
4. For rates of SEBTC participation, redemption, and benefit exhaustion, do impacts vary by benefit
amount ($60 vs. $30), site, and demonstration model?
The analysis will use EBT transaction data collected from the evaluation sites. Grantees/site
administrators and EBT vendors will provide EBT data, which can be used to examine benefit issuances,
redemptions, and other transactions (such as returns and reversals) for each month of the SEBTC benefit
period. Data from the SNAP and WIC systems will provide the date, time, and total dollar value of each
purchase transaction. In addition to the purchase-level data, the WIC data will provide separate
transactions for each category of food issued and redeemed, allowing for the analysis of redemptions at
the aggregate and food category levels for the WIC-model sites.
7
The transactions for each household will be aggregated to produce net amounts for benefits issued and
redeemed for each issuance cycle, and then the monthly benefits issued and redeemed for the summer will
be summed (taking into account benefits carried over from month to month in the SNAP sites). All
outcomes are defined for the entire summer. A household is defined as having exhausted benefits if it
spent the maximum redeemable amount in one or more months in the summer. These research questions
are descriptive, and they are addressed by describing the pooled results on the levels of the key SEBTC
benefit use outcomes for the $60 SEBTC benefit group and separately for the $30 group. The analyses
will also present additional descriptive tabulations on the dollar value of benefits issued and redeemed,
and the percentage of benefits redeemed by food category in the WIC model sites. The descriptive
analysis also reports differences in the patterns of SEBTC benefit use among the evaluation sites. The
descriptive analyses do not control for observable differences among the sites.
Implementation Study
Successful implementation of the demonstrations has required the involvement and cooperation of a
number of state and local agencies and vendors in each demonstration site. Local school food authorities
(SFAs), either individually or in combination, administer the demonstration sites; however, the state WIC,
SNAP, or NSLP/SBP agencies are the formal recipients of the USDA grants for the demonstrations, with
legal responsibility for their implementation and operation. Substantial cooperation, including data
sharing, was promised by the schools and school districts served by the SFAs as well as by the state
education agency. EBT vendors for SNAP and WIC deliver the SEBTC benefits to participating
households. The evaluation will include qualitative interviews with these stakeholders (Appendix C) in
order to document the implementation processes, challenges, and lessons from the demonstrations. The
responses from these interviews will be incorporated into a training document for future SEBTC
demonstration expansion sites.
The Implementation Study will address three research questions:
8
1. Are the three different models of SEBTC: 1) WIC; 2) SNAP; and 3) SNAP hybrid
operationally feasible? If so, under what conditions?
2. How are the demonstrations implemented? What are the challenges encountered and lessons
learned?
To address these research objectives, the team will conduct qualitative interviews with State grantees and
school districts (stakeholders) to collection information on implementation and operations. This
collection will not re-contact any households that participated in prior phases of this study.
Exhibit A.2 shows the data to be collected during stakeholder interviews.
Use of the Information
The information gathered in the data collection activities described above will be used by FNS to describe
the use of benefits and implementation of the 2014 SEBTC demonstration. There is currently no other
national effort that can address the research objectives of the proposed study.
Exhibit A.2: Topics and Respondents for Qualitative Stakeholder Interviews
9
State
Topic
SNAP/WIC
Plan demonstration and prepare application
Identify eligible children and households
Obtain consent for demonstration and evaluation
Inform selected parents/caretakers
Distribute SEBTC cards
Training for schools
Training for parents
Training for/support for retailers
Other training and public information
Project organization and management
Replace cards/other participant support
Prevent/detect losses and abuse
Involve local agencies or community
organizations
Successes, challenges and solutions
Feasibility of continuing and replicating
demonstrations
Implementation and operational costs
Impact on program participation and operations
Notes:
indicates agency expected to be lead source for topic;
School
District/SFA
EBT Vendor
A.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
The study will comply with the E-Government Act of 2002 to promote the use of technology. The study
will use computer-assisted telephone interviewing (CATI) for the client survey as an efficient alternative
to conducting interviews and tracking responses on paper. Features such as programmed skip patterns on
the survey instrument will reduce respondent burden and minimize any questions asked in error. By
including programmed skip patterns, consistency and data range checks, these technologies reduce data
entry error that often necessitate callbacks to respondents to clarify the responses recorded by an
10
interviewer using pencil and paper to conduct an interview. No responses will be collected with the use
electronic submission.
A.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
The data requirements for the evaluation have been carefully reviewed to determine whether the needed
information is already available. Efforts to identify duplication included a review of FNS reporting
requirements, State administrative agency reporting requirements, and special studies by government and
private agencies. It was concluded that no existing data sources can provide data needed to answer the
study’s research questions.
A.5
IF THE COLLECTION OF INFORMATION IMPACTS SMALL BUSINESSES OR
OTHER SMALL ENTITIES, DESCRIBE ANY METHODS USED TO MINIMIZE
BURDEN
FNS has determined that the requirements for this information collection do not adversely impact small
businesses or other small entities. Information being requested or required has been held to the minimum
required for the intended use. Although smaller State agencies and SFAs will be involved in this data
collection effort, they deliver the same program benefits and perform the same function as any other State
agency and SFA. Thus, they maintain the same kinds of information on file. All grantees have agreed to
participate in the evaluation and provide the necessary data. Data requirements include interviews with
State and/or local agencies. Interviews will also be conducted with EBT vendors; however, none are small
businesses.
11
A.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.
This is a one-time data collection. The data collection for the proposed study will be conducted at two
separate points in times during 2014 (once to obtain the transaction/administrative data and another time
to conduct the qualitative interviews). If this study is not conducted, FNS will not have the data
necessary to examine how the demonstration sites implemented SEBTC and how the benefits were used
by households in 2014, which will be used to produce the required report to Congress and inform future
program decisions.
A.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.
12
There are no special circumstances. The collection of information is conducted in a manner consistent
with guidelines in 5 CFR 1320.5.
A.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.
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
An announcement was published in the Federal Register on November 15, 2013 (Federal Register
Volume 78, No. 221, Page 68810). No substantive public comments that discussed burden and time were
received.
Consultations outside the Agency
FNS has consulted with Colette Bounds, Mathematics Statistician at the National Agricultural Statistical
Service (202-720-9189), Fran Thompson, Epidemiologist at the National Cancer Institute, National
Institutes of Health (301-435-4410) and Ronette Briefel, Senior Fellow at Mathematica Policy Research
(202-484-9220).
A.9
EXPLAIN ANY DECISION TO PROVIDE ANY PAYMENT OR GIFT TO
RESPONDENTS, OTHER THAN REMUNERATION OF CONTRACTORS OR GRANTEES
No gifts or incentives will be provided to respondents in this revised data collection.
13
A.10 DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO
RESPONDENTS AND THE BASIS FOR THE ASSURANCE IN STATUTE, REGULATION, OR
AGENCY POLICY
A system of record notice (SORN) titled FNS-8 USDA/FNS Studies and Reports in the Federal
Register on April 25, 1991 Volume 56, Number 80, and is located on pages 19078-19080 discusses the
terms of protections that will be provided to respondents. Participants in this study will be subject to
assurances and safeguards as provided by the Privacy Act of 1974 (5 USC 552a), which requires the
safeguarding of individuals against invasion of privacy. The Privacy Act also provides for the privacy
treatment of records maintained by a Federal agency according to either the individual’s name or some
other identifier.
The States and sites participating in this study will be notified that the information they provide
will not be released in a form that identifies participants, except as otherwise required by law. No
identifying information will be attached to any reports or data supplied to USDA or any other researchers.
Our contractor, [Abt Associates and their partner, Mathematica Policy Research] has extensive experience
in data collection efforts requiring strict procedures for maintaining the privacy, security, and integrity of
data. The following data handling and reporting procedures will be employed to maintain the privacy of
survey participants and composite electronic files.
All project staff, both permanent and temporary, will be required to sign a confidentiality and
nondisclosure agreement (see Appendices D and E). In this agreement, staff pledges to
maintain the privacy of all information collected from the respondents and will not disclose it
to anyone other than authorized representatives of the evaluation, except as otherwise
required by law. Field data collectors are required to carry their signed pledge with them at all
times while in the field and may be required to show it to respondents. Issues of privacy are
also discussed during training sessions provided to staff working in the project.
14
While in the field, data collectors are required to store all completed forms, surveys, and
material with identifying information on it in a locked car trunk. If the data collector is in the
field for several days, forms and materials are shipped to the central office by Federal
Express, UPS or other traceable shipping service. Regular mail is not used to ship any
material containing respondent information. Field staff are also instructed to avoid making
photocopies of such material.
Once in the central office, documents containing respondent information are kept in locked
files cabinets. At the close of the study, such documents are shredded.
Data gathered from the interviews will be combined into master respondent files.
Immediately after each file is created, it will be assigned a unique identification number. Any
identifying information will be removed from the survey data and replaced with the
identification number.
In addition, the evaluation contractor has established a number of procedures to ensure the privacy and
security of electronic data in their offices during the data collection and processing period. Standard
backup procedures will be implemented for the central office computer system to protect project data
from user error or disk or other system failure. Backups and inactive files will be maintained on tape or
compact disks. The system servers will be maintained inside a secure locked area accessible only to
authorized systems personnel. Files will be accessible only by authorized personnel who have been
provided project logons and passwords. Access to any of the study files (active, backup, or inactive) on
any network multi-user system will be under the central control of the database manager. The database
manager will ensure that the appropriate network partitions used in the study are appropriately protected
(by password access, decryption, or protected or hidden directory partitioning) from access by
unauthorized users. All organizations using data on study participants will maintain security, virus, and
firewall technology to monitor for any unauthorized access attempts and any other security breaches.
15
Institutional Review Board
The contractor, Abt Associates, maintains its own Institutional Review Board (IRB), which serves as the
organization’s administrative body that conducts prospective reviews of proposed research and monitors
continuing research for the purpose of safeguarding research participants’ rights and welfare. All
research involving interactions or interventions with human subjects is within the purview of the IRB.
A.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
There are no personally sensitive questions to be asked during the qualitative interviews.
A.12 PROVIDE ESTIMATES OF THE HOUR BURDEN OF THE COLLECTION OF
INFORMATION. THE STATEMENT SHOULD:
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.
Provide estimates of annualized cost to respondents for the hour burdens for
collections of information, identifying and using appropriate wage rate categories.
Exhibit A.3 shows affected public, estimated number of respondents, estimated frequency of response,
estimated annual responses per respondent, estimated burden and estimated annualized cost of respondent
burden for the revised data collection. These estimates reflect consultations with program officials and
the Agency’s prior experience in collecting data. It has been calculated using average hourly earnings for
May 2013 obtained from the Bureau of Labor Statistics’ estimates for occupational employment wages.
Individuals and Households will not be contacted in this revised data collection request.
16
State Agency Reporting Burden
Affected Public Activities/Requirem ents
State Agencies
Primary Site Grantees –
Implementation Study
Interview s
Primary School Districts Implementation Study
Interview s
SA Grand Total
Reporting
Affected Public Activities/Requirem ents
EBT Vendors – SEBTC
Business
Transaction Data
Reporting Burden
Business
Grand Total
Reporting
Sum m ary of SA & Business Grand Totals
for Reporting
Estim ated #
Respondents
13
13
Estim ated
Responses
Annually per
Respondent
Estim ated
Total Annual
Responses
(Col. bxc)
Estim ated
Annual Tim e
per
Response
1
5
1
5.00
$ 39.10
$
195.50
1
8
1
8.00
$ 39.10
$
312.80
----
13.00
----
$
508.30
---13
Business Reporting Burden
Estim ated #
Respondents
Estim ated
Responses
Annually per
Respondent
Num ber of
Total Annual
Records
Estim ated
Tim e Per
Record
5
1
5
0.5
5
Estim ated #
Respondents
---Estim ated
Responses
Annually per
Respondent
5
Estim ated
Total Annual
Responses
---Estim ated
Annual Tim e
per
Response
----
18
18
----
Estim ated
Estimated Total Cost
Total Annual Hourly
Burden Hours Rate
(Col. dxe)
Estim ated
Estimated Total Cost
Total
Hourly
Recordkeepin Rate
g Hours
2.50
$ 39.70
$
99.25
2.50
$ 39.70
Estim ated
Total Annual Estimated
Burden Hours Hourly
Rate
$
99.25
15.50
----
Total Cost
$
607.55
A.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 annualized maintenance costs associated with this data collection for
respondents.
A.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.
Annualized Costs to Federal Government is $641,350.00. This includes the costs associated with the
contractor conducting the project and the salary of the assigned FNS project officer. The cost of the FNS
employee, Social Science Research Analyst, involved in project oversight with the study is estimated at
17
GS-13, step 1 at $43.23 per hour based on 2,080 hours per year. We anticipate this person will work 520
hours per year for 3 years for a combined total of 1560 hours. The annual cost for this FNS employee
over the course of this study is $22,480. The cost of the FNS employee, Branch Chief, involved in project
oversight with the study is estimated at GS-14, step 1 at $51.09 per hour based on 2,080 hours per year.
We anticipate this person will work 156 hours per year for 3 years for a combined total of 468 hours. The
annual cost for this FNS employee over the course of this study is $7,970. The annual cost for both of
these FNS employees over the course of this study is $91,350. Federal employee pay rates are based on
the General Schedule of the Office of Personnel Management (OPM) for 2014 for the Washington DC
locality.
This Federal Cost also includes the costs associated with the contractor conducting the project and the
salary of the assigned FNS project officer. The cost to the Federal government for the all tasks associated
with the Summer Electronic Benefits for Children (SEBTC) Demonstration is $550,000, as specified in
the 2010 Agriculture Appropriations Act (P.L. 111-80), Section 749(g). This cost includes all study
tasks, including design, pretests, sample selection, recruitment, information collection, analysis and report
writing.
18
A.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 collection of information. The current OMB burden inventory is 34,774. FNS
is requesting 15.5 burden hours for this revised information collection request. This is a decrease
of -34,758.5 burden hours as a result of program changes. In addition there is a decrease in the
estimated total annual responses. The currently approved responses for this collection are 83,672
estimated total annual responses; with this revision, we are seeking approval for estimated total
annual responses of 18. This will reflects a decrease of -83,654 total annual responses. These
decreases are primarily due to the removal of individuals and households (I/H) that will not
participate in this phase of the information collection request. There were 41,233 I/H
respondents and non-respondents included in the prior clearance; again, there will be no recontact with that affected public in this information collection request. Therefore, this is a
decrease of -41,233 I/H respondents. There are also decreases to SA/SFA, 62 participated in the
current collection and 13 will be contacted for this request. This program change reflects a
decrease of -49 SA/SFA. The other affected public Business’ also decreased. The current
number of Business that participated in the current approval was 87; this phase seeks to contact
5, a decrease of -82 Business respondents. Consequently these program changes reflect a
significant decrease in burden hours.
A.16 FOR COLLECTIONS OF INFORMATION WHOSE RESULTS ARE
PLANNED TO BE PUBLISHED, OUTLINE PLANS FOR TABULATION
AND PUBLICATION
Study Schedule
The schedule shown in Exhibit A.4 lists the expected period of performance for the data collection and
reporting. Data collection plans are designed to provide timely data for the evaluation reports, including:
19
Demonstration (2014) Reports:
Final Congressional Status report completed April 15, 2015
Final Evaluation Report completed June 15, 2015
Exhibit A.4: Schedule of Tasks and Deliverables
Task
Activity/Deliverable
Begin Date
1.0
Data Collection/Analysis Plan
5/1/2014
1.1
Revise Research Design – 2014 Update
5/1/2014
1.2
Revise 2014 Data Collection/Analysis Plan
5/1/2014
2.0
Collect Data
6/15/2014
2.1
Collect EBT transaction data*
6/15/2014
2.2
Collect Implementation Study data*
10/1/2014
3.0
Analyze Data
11/15/2014
3.1
Conduct implementation analysis
11/15/2014
3.2
Analyze EBT transaction data
10/1/2014
4.0
Reports and Briefings
2/1/2015
4.1
Draft Implementation Training Manual
2/1/2015
4.2
Final Implementation Training Manual
3/16/2015
4.3
Draft Evaluation Report on 2014 SEBT for Children
4/1/2015
Demonstrations
4.4
Final Evaluation Report on 2014 SEBT for Children
5/16/2015
Demonstrations
4.5
Annual briefing 1
5/16/2015
4.6
Annual briefing 2
6/16/2015
5.0
2014 Documentation
7/1/2015
5.1
Data files and documentation for Final Evaluation Report
7/1/2015
5.2
2014 Public Use Files
8/1/2015
*Data collection and interviews can only occur after OMB clearance has been obtained.
Deliverable
Date
End Date
5/31/2014
5/31/2014
5/31/2014
11/1/2014
9/15/2014
11/1/2014
1/28/2015
1/15/2015
1/28/2015
6/30/2015
3/15/2015
4/15/2015
5/15/2015
3/15/2015
4/15/2015
5/15/2015
6/15/2015
6/15/2015
5/30/20115
6/30/2015
8/15/2015
7/30/2015
8/15/2015
5/30/2015
6/30/2015
7/30/2015
8/15/2015
Analysis Plan
The main lines of analysis follow the broad research categories outlined in section A.1. Each of the
research questions within these categories is explicitly or implicitly associated with one or more outcome
measures to be analyzed. Our approach, including data sources for each question and the planned analyses
are summarized in Exhibit A.1, above.
Analysis Methods
Tabulations and cross-tabulations: The descriptive research questions will be addressed by tabulations
or cross-tabulations. For example, simple tabulations will be used to characterize overall SEBTC use of
benefits. Cross-tabulations will be used to examine outcomes by site characteristics and other sub-groups.
Tests of significant differences in levels of use across subgroups will be performed.
20
Publication of Study Results
The study’s findings will be represented in two reports which will undergo peer review. The projected
dates for these reports are presented in Exhibit A.4 (above).
A.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.
All data collection instruments (Appendix C) for the Food and Nutrition Service Evaluation of the
Summer Electronic Benefits for Children Demonstration Projects will display the OMB approval number
and expiration date.
A.18 EXPLAIN EACH EXCEPTION TO THE CERTIFICATION STATEMENT IDENTIFIED IN
ITEM 19 "CERTIFICATION FOR PAPERWORK REDUCTION ACT."
There are no exceptions to the Certification for Paperwork Reduction Act (5 CFR 1320.9) for this study.
21
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| File Type | application/pdf |
| File Title | Abt Single-Sided Body Template |
| Author | NicholsonJ |
| File Modified | 2014-03-28 |
| File Created | 2014-03-28 |