Appendix B: Burden Narrative

ATTACHMENT B

Estimate of the Information Collection Burden for

Supplemental Nutrition Assistance Program: Student Eligibility, Convicted Felons, Lottery and Gambling, and State Verification Provisions of the Agricultural Act of 2014

(RIN 0584-AE41)

(OMB #0584-NEW)

This document explains the calculation of the information collection burden for the Professional Standards under OMB #0584-NEW.

AFFECTED PUBLIC: SNAP STATE AGENCIES AND STATE PUBLIC AGENCY GAMING ENTITIES

REPORTING REQUIREMENTS

1. 7 CFR 272.17 requires to the maximum extent possible that each of 53 State Supplemental Nutrition Assistance Program (SNAP) agencies establish cooperative agreements once with gaming entities within the State. It is assumed for this rule-making that each State SNAP agency will establish cooperative agreements with one State public gaming entity (public gaming entity) within the State and with three private business gaming entities (private gaming entities) within the State for a total of 212 annual responses, which will take approximately 320 hours per response, for a total of 67,840 annual burden hours. It is estimated that State SNAP agency managers in the General and Operations Managers for Local Government occupation group (11-1021) in the 53 State SNAP agencies will spend a total of 67,840 hours to establish cooperative agreements with public and private gaming entities, at a rate of $45.64 per hour, for a total estimated cost of $3,096,217.60 for all respondents in the first year.

Each of the 53 public gaming entities will also incur a burden entering into cooperative agreements with their State SNAP agency, which will take approximately 320 hours per response for a total of 16,960 burden hours. It is estimated that public gaming entity managers in the General and Operations Managers for Local Government occupation group (11-1021) in the 53 public gaming entities will spend a total of 16,960 hours to establish cooperative agreements with their State SNAP agency, at a rate of $45.64 per hour, for a total estimated cost of $774,054.40 for all respondents in the first year.

2. 7 CFR 272.17 requires to the maximum extent practicable that each of 53 State SNAP agencies create a data matching system once for a total of 53 systems to match information on winners from public gaming entities and private gaming entities within the State with SNAP participation lists. It is estimated that it will take 53 State SNAP agency managers in the General and Operations Managers for Local Government occupation group (11-1021) approximately 160 hours per response, for a total of 8,480 annual burden hours, at a rate of $45.64 per hour, for a total estimated cost of $387,027.20 for all respondents in the first year.

3. It is assumed for this estimate that each of the 53 public gaming entities would have 200 individuals who win over the threshold in a given year, for a total of 10,600 annual responses. It is estimated that it will take approximately 0.08 hours for the public gaming entity staff in the Information and Record Clerks, All Other occupation group (43-4199) to identify the winner and enter the appropriate information into the matching system, for a total of 848 annual burden hours, at a rate of $18.46 per hour, for a total estimated cost of $15,654.08 for all respondents every year.

Once the matching system is in place, the monthly matches between the winner list and SNAP participation list should occur automatically and with negligible cost.

4. 7 CFR 272.17 and 273.11(r) require that each of 53 State SNAP agencies will have to identify among the responses those that are misidentified as SNAP participants because of a similar name, inaccurate reporting etc.

It is assumed for this estimate that each of 53 State SNAP agencies will positively match with one public and three private gaming entities, in their respective States, an average of 35 records per year, for a total annual response of approximately 1,855 annual SNAP participants nationally. FNS anticipates that each of 53 State SNAP agencies will receive of these 35 records approximately five total annual records with misidentified participants, for a total annual response of 265 records. It will take approximately 0.667 hours of State SNAP agency eligibility worker’s time in the Eligibility, Interviews, Government Programs occupation group (43-4061) to identify these types of misidentifications, for a total annual burden of 176.76 burden hours, at a rate of $20.41 per hour, for a total estimated cost of $3,607.57 for all respondents every year.

5. 7 CFR 272.17 and 7 CFR 273.11(r) require that each of 53 State SNAP agencies will have to follow-up with and disqualify SNAP participants discovered through the above matches to have actual substantial lottery or gambling winnings. FNS anticipates approximately 30 records annually per State SNAP agency will be households with actual substantial winnings, for approximately 1,590 total annual responses. It is estimated that it will take approximately one hour of State SNAP agency eligibility worker’s time in the Eligibility, Interviews, Government Programs occupation group (43-4061) time for this activity, for a total of approximately 1,590 annual burden hours, at a rate of $20.41 per hour, for a total estimated cost of $32,451.90 for all respondents every year.

BUSINESS FOR PROFIT PRIVATE LOTTERY AND GAMBLING ENTITIES REPORTING REQUIREMENTS

1. 7 CFR 272.17 requires to the maximum extent practicable that each of the affected private gaming entities will establish cooperative agreements once with their respective State SNAP agency. It is estimated that 159 private gaming entity managers in the General and Operations Managers, Management in Companies and Enterprises occupation group (11-1021) will take approximately 320 hours per response for a total of 50,880 annual burden hours, at a rate of $71.79 per hour, for a total estimated cost of $3,652,675.20 for all respondents in the first year.

2. It is estimated that each of the 159 private gaming entities will identify 100 individuals per year who have won over the threshold for a total of 15,900 annual responses. It is estimated it will take approximately 0.08 hours for the private gaming entity staff in the Gaming Cage Workers occupation group (43-3041) to identify the winner and enter the appropriate information into the matching system, for a total of 1,272 annual burden hours, at a rate of $13.25 per hour, for a total estimated cost of $16,854.00 for all respondents per year.

Once the matching system is in place, the monthly matches between the winner list and SNAP participation list should occur automatically and with negligible cost.

THERE ARE NO RECORDKEEPING REQUIREMENTS

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