ICR 0584-0594 366B Revision OCIO comments 1-15-16

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 request (ICR). FPRS facilitates data gathering for the reporting of data for the Special Supplemental Nutrition Program (SNAP) and the Special Nutrition Programs. FPRS is the primary collection point for program performance statistics and financial data from State agencies (SA), Indian Tribal Organizations (ITO), and U.S. Territories participating in the nutrition assistance programs. This information collection pertains to 20 FNS collections currently approved by OMB The reporting burdens for these collections will merge with FPRS once approved by OMB. Any recordkeeping burdens associated with the existing collections will remain with its approved OMB control number. Each program has multiple information collection packages and they are listed here by program:

Currently OMB approved information collection packages
OMB Control Number	Worksheet/Form number	Expiration Date
Child Nutrition Program
0584-0002	FNS-10	6/30/2017
0584-0075	FNS-13	6/30/2017
0584-0280*	FNS-418	3/31/2016
0584-0055	FNS-44	09/30/2016
0584-0067	FNS-777	5/31/2016
0348-0061	SF-425	2/28/2015
Special Nutrition Assistance Program
0584-0025	FNS-101	6/30/2017
0584-0069	FNS-209	6/30/2017
0584-0083	FNS-366A & FNS-366B	4/30/2017
0584-0081	FNS-388 & FNS-388A	3/31/2017
0584-NEW	FNS-778 & FNS-778A
0584-0339	FNS-583	6/30/2017
0584-0037	FNS-292A&B	6/30/2017
0584-0080	FNS-46	6/30/2017
0584-0542	FNS-759	8/31/2016
Food Distribution Programs
0584-0293	FNS-667, FNS-152, FNS-153, & FNS-667	6/30/2017
0584-0025	FNS-191 & FNS-101	6/30/2017
0348-0061	SF-425	2/28/2015
Special Supplemental Food Program for Women, Infants and Children (WIC)
0584-0447	FNS-683 & FNS-203	6/30/2017
0584-0541	FNS-683A	5/31/2016
0584-0431	FNS-648	6/30/2017
0584-0045	FNS-798 & FNS-798A	6/30/2017
0348-0061	SF-425	2/28/2015
Grants Management
0348-0061	SF-425	2/28/2015

*Currently at OMB under review.

Note that the FPRS system also includes form FNS-674 (OMB Control Number 0584-0532; Expiration date 3/31/18) which is an FNS User Access form, used for all FNS systems. Screenshots are included of this form, but burden for this form will remain under the existing collection as the form is not specific to FPRS.

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 planned revision is only for Section 7 CFR 272.2(e) which requires State agencies (SA) submit the Program Activity Statement, or worksheet FNS-366B to substantiate the costs the State agency expects to incur during the next fiscal year. It currently provides data on the number of SNAP applications the State agency processed, the number of fair hearings the State agency conducted, and the fraud control activities the State agency engaged. FNS uses the data to monitor State agency activity levels and performance. Using the FNS forms/worksheets, State agencies, Indian Tribal Organizations, and local agencies that enter into agreements with the Federal government use FPRS to submit data to FNS electronically. The data is gathered at various times, ranging from monthly, quarterly, annual or final submissions. The primary use for this information is regulatory compliance. The information may also be used by FNS to conduct program evaluation, planning and audits, future funding, research, and general statistics. For details on the use of each form, please see attachment “FPRS Forms Purpose.”

The proposed revisions to the FNS-366B are not in yet available in FPRS and, therefore, screenshots are not available. Only the current, unrevised form is available in FPRS. It will take our contractor 6-months to program the new form. Once the revised form is programed and available in FPRS, SNAP will provide a screenshot of the form.

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, by providing electronic submissions of information in lieu of paper whenever possible. FNS encourages its State agency partners to offer electronic submission to local agencies whenever it is feasible. FNS estimates that 100% of the State agencies will respond electronically to this data collection using Food Programs Reporting System (FPRS) at https://fprs.fns.usda.gov/Home/Reminder.aspx.

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.

There is no similar data collection available. 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. FNS solely administers the school meal programs, monitors issuance of SNAP and WIC benefits. Each nutrition assistance program has distinct reporting requirements that are collected electronically through FPRS.

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

There will be no small entities involved with 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.

FNS will be unable to meet its legislative and regulatory reporting requirements for the affected programs.

7.) Explain any special circumstance that would cause an information collection to be conducted in a manner:

Requiring respondents to report information to the agency more often than quarterly;

Current OMB Control Number	Program	Worksheet Number and Title	Reason for requiring respondents to report information to the agency more often than quarterly
0584-0002	Child Nutrition Program	FNS-10 Report of School Program Operations	Per the regulation, States shall not receive Program funds to operate for any month for which the final report is not submitted with the time limit (90 days following the last day of the month covered by the report).
0584-0078	Child Nutrition Program	FNS-44 Report of Child and Adult Care Food Program	Per the regulation, States shall not receive Program funds to operate for any month for which the final report is not submitted with the time limit (90 days following the last day of the month covered by the report).
0584-0081	Special Nutrition Assistance Program	FNS-388 State Issuance and Participation Estimates	Part 274.4(b)(4) of the Supplemental Nutrition Assistance Program (SNAP) regulations require State agencies to submit on a monthly basis. Timely State monthly issuance estimates are necessary for FNS to ensure that it remains with the appropriation and will have a direct effect upon the manner in which allotments would be reduced when necessary.
0584-0080	Special Nutrition Assistance Program	FNS-46 Issuance Reconciliation Report	Section 7(d) of the Food and Nutrition Act of 2008, as amended, (the Act) (7 U.S.C. 2016(d)) and Regulations at 7 CFR 274.4(a) and 274.4(b)(2), require State agencies to report on their SNAP benefit issuance operations not less than monthly, through a reconciliation process and to report to FNS using Form FNS-46, Issuance Reconciliation Report. This monthly report is used to account for benefits issued during a report month for each issuance reporting point, and to document the reconciliation process by which States compare the total issuance, returns, and unauthorized issuance amounts resulting in the net Federal obligation.
0584-0293	Food Distribution Program	FNS-152 Monthly Distribution of Donated Foods to Family Units	Form is collected electronically monthly to ensure efficient management of the program. Timely ordering, receipts, inventory control, and accounting of commodities and funds are necessary to ensure the programs continue to operate and the funds are spent during the appropriate time periods.
0584-0293	Food Distribution Program	FNS-153 Monthly Report of the CSFP and Quarterly Administrative Financial Status Report	Form is collected electronically monthly to ensure efficient management of the program. Timely ordering, receipts, inventory control, and accounting of commodities and funds are necessary to ensure the programs continue to operate and the funds are spent during the appropriate time periods.
0584-0045	Special Supplemental Food Program for Women, Infants and Children (WIC)	FNS-798 WIC Financial Management and Participation Report	Monthly reporting is critical for monitoring each State agency's expenditures to ensure it does not overspend its authorized grant, which would create a financial burden for the State. Costs incurred by a State agency in excess of its grant must be paid by the State.

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 support 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 other 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 60-day Notice was published in the Federal Register on July 6, 2015, page 38427, Vol. 80, No.18. Seventeen (17) comments were submitted in reference to FNS 366 B and we have summarized comments below.

Summary of comments

Sixteen State agencies and one Federal agency submitted a total of seventeen comments during the 60-day public comment period for the proposed Program Activity Statement information collection request. These comments are available for public inspection at online at www.regulations.gov. In general, comments referenced proposed changes, additions or removals of specific elements in the collection, and requested clarification of form instructions. FNS reviewed all of these comments, and summarized all responses in the following section. Nine commenters submitted comments addressing the burden and cost of this proposed revision. FNS responded directly to these comments via the method they were submitted and included them in this submission as attachments.

Frequency of Reporting

Two commenters referenced a possible change to the frequency of reporting for this collection. One commenter stated that changing the reporting requirement from annual to quarterly would increase the burden by a factor of four. The commenter stated data collection would be easier and less error prone if the form were to be submitted monthly or quarterly instead of annually.

Reporting frequency for the FNS-366B is prescribed at 7 CFR 272.2(e) and, therefore, cannot be modified with this information collection request. FNS is concurrently pursuing regulatory change for the FNS-366B reporting period in a separate rulemaking package, RIN 0584-AE36. This rulemaking contains the additional burden hours that any modification may necessitate.

Investigations

Several commenters questioned the removal of the distinction between pre- and post-certification investigations. They asked if FNS was no longer interested in pre-certification investigations and explained that a significant amount of fraud prevention activities would not be accounted for with this removal. Specifically, one commenter stated that there was no way to report investigations that did not result in a disqualification although they did result in a denial of eligibility or a reduction in benefits. Multiple commenters also suggested that the proposed addition of an element designed to capture the aforementioned reduction in benefits was confusing, impractical and difficult to report due to State system designs.

Fraud prevention through eligibility denial and reduction are essential elements of fraud control activity that FNS intends to capture with this revision. These activities were not adequately captured by distinguishing between pre- and post-certification. Often, there is little difference in the practical impact of investigations that conclude pre-certification and those that conclude shortly after certification when no disqualification is pursued. This is especially true for the large percentage of applications that receive expedited service. Furthermore, there were wide discrepancies in how State agencies defined pre-certification investigations. For these reasons, and in light of the impracticality of the proposed addition, FNS removed pre- and post-certification and replaced these options with an element that captures all investigations that lead to an eligibility denial or reduction.

The majority of commenters questioned the proposed additions of elements capturing investigation unit cost and staffing, such as primarily addressed confusion over what and who to include in the cost,, who to include in the staffing calculation, and how to prorate staff time. A few of these commenters stated that these calculations would be difficult to calculate and inconsistent between counties and States.

FNS agrees with these comments and removed the investigation cost element, and replaced the staffing element with one that captures only total investigator hours dedicated to SNAP investigations. This element more accurately captures the most critical and variable component of both cost and staffing. States should have ready access to this information as it is used to calculate investigation unit budgets and administrative cost reimbursement, though it is not currently reported to FNS. This information is essential to provide context for investigation data reported by States.

Several commenters asked for clarification of the investigation length element and suggested that FNS change the method of determining investigation end date. Specifically, some suggested that using benefit payment end-date for canceled investigations is not appropriate. One commenter stated that their State cannot track investigation length.

This information is essential for understanding the unique investigative environment in each State. FNS also believes that it is common practice for investigative units to maintain this information for internal monitoring, and that collecting and summarizing this data can be accomplished by the same methods used for the other data elements in this collection. FNS understands that the end-date methodology was unsuitable for some States, and has changed the end-date to the day the investigation was completed and/or was canceled, as determined by the investigative unit. The instructions were updated to provide additional clarification.

Two commenters requested clarification of the instructions for the open investigations element. FNS updated the instructions to address this. One commenter asked if all investigations will be reported on this form. All investigations occurring during the reporting period will be reported in either the concluded investigations or the open investigations sections. Referrals for investigation that are rejected or not yet opened will not be reported on this form.

One commenter stated that the definition of investigation provided in the form instructions needed to include local investigative unit activity to include all activity. FNS updated the instructions to reflect this.

Cost Savings

Many commenters stated that the cost savings estimate element in the proposed revision would be difficult to calculate and would be inconsistent between States. Some of these commenters stated that the allotment reduction amount and final claims resolution are often determined well after investigative activities conclude and is maintained in separate databases from the other data collected in these sections. One commenter also pointed out that individual States would only be able to report estimates and suggested that this information be estimated at the national level.

FNS agrees that States should not report estimated values for cost savings, and removed the proposed element from the collection. FNS will continue to collect the “program dollars” as it exists on the current form. This element is relabeled as “amount subject to claim”; however, the content and means of calculation have not changed.

Prosecutions and Administrative Disqualification Hearings

One commenter stated that the prosecutions section terminology was not appropriate for their State. FNS realizes that there is substantial variation in prosecutorial practices between States. For this reason, prosecutions for SNAP fraud are reported according to whether they resulted in a SNAP participant’s disqualification. Specific terminology, such as acquittal, conviction, or plea agreement, is intentionally omitted from the form to account for State variation. Also for this reason, FNS removed the “prosecutorial inaction” and “reclaimed from prosecutor” sections. States that do not pursue SNAP fraud through a prosecutorial system will report zeroes in this section.

One commenter questioned the relevance of collecting data regarding cases that have been referred for an administrative disqualification hearing but have not received a scheduled hearing date. FNS believes this element is critical for ensuring that SNAP recipients receive due process and that cases are adjudicated timely. The proposed revision included all cases awaiting scheduling; however, FNS further revised this element to include only cases awaiting scheduling for 90 or more days.

One commenter asked if rejected ADH or Prosecution referrals would be reported in the referred for ADH and the prosecution sections. FNS updated the instructions for this section to provide clarification.

Other Collection Methods and Training

Two commenters suggested using Management Evaluations (ME) and Program Access Reviews (PAR) to collect the information requested in this proposal. One commenter suggested that, by doing so, FNS could focus the collection on only poor performing States. FNS does not believe that MEs and PARs should be the sole means of collecting this information, as they are too infrequent and lack the detail needed for this data collection. FNS needs all States to report the information requested for all reporting periods. Furthermore, MEs provide an opportunity for FNS to validate the information reported in this collection and, therefore, should not be the primary method of data collection. FNS agrees that MEs and PARs provide opportunities for FNS to work with States to address data irregularity and provide targeted assistance as needed.

One commenter recommended collecting this information with multiple forms tailored to the seven different SNAP regions. FNS believes continuing to use a single form is essential for data consistency and collection efficiency.

One commenter suggested that States would benefit from additional training on the completion of this collection. FNS agrees and intends to provide opportunities for programmatic training and question and answer sessions, pending approval of this collection.

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.

On October 16, 2014, FNS published a Request for Information (RFI) in the Federal Register to obtain State and partner feedback on potential changes to the FNS-366B form. FNS received 18 responses to the RFI from 17 State agencies and 1 national organization, and the information provided in these responses played a crucial role in decision-making when drafting the revised form.

FNS also discussed the form revision with multiple State agencies at Regional, State, and national integrity conferences between 2013 and 2015.

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

No payment or gift will be offered to respondents.

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

The Department will comply with the Privacy Act of 1974. No individual or household data is collected nor maintained in this system. State Agencies are assigned codes by FNS as an identifier for States only no personal information from individuals. The data will be collected in aggregate form and respondents will not be identified individually.

A Privacy Impact Assessment was conducted in June 2007 on the FPRS (attachment) which determine FNS does not need to publish a SORN.

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.

No sensitive questions will be asked in this data collection.

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 the 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.

The requested burden hours associated with this collection and the cost to respondents, are shown in the attached burden chart. Time estimates include the time needed to look up data or copy recorded information and submit it to FNS. There is no recordkeeping burden associated with this data collection. Once these reporting burden hours have been approved by OMB, the agency will discontinue those information collections that would be considered duplicative in nature. However, there is recordkeeping involved with many of the existing FNS forms/worksheets identified in this request. Any recordkeeping burden hours will remain with those existing collections. Lastly, recordkeeping for the SF 425 will be contained in OMB Control # 0584-0512, expiration date: 1/31/2016.

The current overall burden inventory for FPRS is 103,627 burden hours and 46, 216 responses annually. This request will add 1,855 burden hours and no additional responses for an revised burden inventory of 105,482 burden hours and the responses remains unchanged with this revision.

Table A.12-1 FPRS Reporting Estimates + Revised FNS 366 B increase in time per respondent:

FPRS 0584-0594 CURRENT Annual Time Burden (Hr)	FPRS 0584-0594 FNS 366 B Annual Time Burden (Hr)	Grand Total Burden Hours	FPRS 0584-0594 CURRENT Total Annual Response	FPRS 0584-0594 FNS 366 B Total Annual Response
103,624.00	1,855.00	105,479.00	46,216	remains unchanged once annually

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 for the FNS-366B is based on the burden estimates developed in 12(A) above. Based on the Bureau of Labor Statistics May 2014 Occupational and Wage Statistics – 13-0231 (http://www.bls.gov/oes/current/oes132031.htm), hourly mean wage for budget analyst functions performed by State and local agency staff are valued at $35.55 per staff hour. Annual respondent cost prior to federal cost sharing is estimated at $65,945.

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 costs 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 the current annualized cost of the FPRS system to the Federal government is $9,222,126.51. This includes contract cost of $2,334,991 which includes overhead costs as well as the cost for computing, copying, supplies, postage, shipping, setting up the website, and other miscellaneous items.

This information collection also assumes that a total of 20 hours of Federal employee time: for labor, analyzing, evaluating, summarizing and reporting on this information collected: GS-14, step 5 Branch Chief at $57,70 per hour for a total of $1,154 and GS-13, step 5 Program Analyst at 100 hours for this of $4,883 on an annual basis. Federal employee pay rates are based on the General Schedule of the Office of Personnel Management (OPM) for 2014.)

FNS program specific staff developed the form instructions and related policies for the State agencies and will compile the resulting data to ensure compliance with regulations.

Estimated costs are provided in Table A14.1 for the expenses that would not have been incurred without this collection of information.

Table A.14 - 2 Cost to the Federal Government

Currently OMB approved information collection packages			Cost to Federal Government (Reports submitted by SA and Analyzed by HQ or Regional Staff) No ICR drafting Cost in this table
OMB Control Number	Worksheet/Form number	Expiration Date	Headquarter or Regional Staff Grade	Total Federal Cost (no ICR drafting cost for Program)
Child Nutrition Program
0584-0002	FNS-10	6/30/2017	GS-12 Step 6	$ 3,215.20
0584-0075	FNS-13	6/30/2017	GS-12 Step 6	$ 3,348.00
0584-0280	FNS-418	3/31/2016	GS-12 Step 5	$ 312,000.00
0584-0055	FNS-44	9/30/2016	GS-12 Step 5	$ 2,270,613.00
0584-0067	FNS-777	5/31/2016	GS-12 Step 5	$ 7,281.90
0348-0061	SF-425	2/28/2015	GS-12 Step 5	$ -
Special Nutrition Assistance Program
0584-0025	FNS-101	6/30/2017	GS-12 Step 5	$ 114,035.00
0584-0069	FNS-209	6/30/2017	GS-12 Step 5	$ 193,533.00
0584-0594	FNS-366A & FNS-366B	4/30/2017	GS-12 Step 5	$ 635,721.00
0584-0081	FNS-388 & FNS-388A	3/31/2017	GS-12 Step 5	$ 127,722.00
0584-0594	FNS-778 & FNS-778A	6/30/2017	GS-12 Step 5	$ 3,348.00
0584-0339	FNS-583	6/30/2017	GS-12 Step 5	$ 902.46
0584-0037	FNS-292A&B	6/30/2017	GS-12 Step 5	$ 1,733,185.00
0584-0080	FNS-46	6/30/2017	GS-12 Step 5	$ 23,185.44
0584-0542	FNS-759	8/31/2016	GS-12 Step 5	$ 25,000.00
Food Distribution Programs
0584-0293	FNS-667, FNS-152, FNS-153, & FNS-667	6/30/2017	GS-12 Step 5	$ 595,427.00
0584-0025	FNS-191 & FNS-101	6/30/2017	GS-12 Step 5	$ -
0348-0061	SF-425	6/30/2017	GS-12 Step 5	$ -
Special Supplemental Food Program for Women, Infants and Children (WIC)
0584-0447	FNS-683 & FNS-203	6/30/2017	GS-12 Step 5	$ 138,892.80
0584-0541	FNS-683A	5/31/2016	GS-12 Step 5	$ 561,000.00
0584-0431	FNS-648	6/30/2017	GS-12 Step 5	$ 1,491.21
0584-0045	FNS-798 & FNS-798A	6/30/2017	GS-12 Step 5	$16,082.50
0348-0061	SF-425	2/28/2015	GS-12 Step 5	$ -
Grants Management
0348-0061	SF-425	2/28/2015	GS-12 Step 5	$ -
Sub Total Estimated Total Annual Cost to Federal Government				$ 6,881,098.51
Estimated Total Contract Cost to Federal Government to maintain FPRS				$ 2,334,991.00
Estimated Total Draft ICR for FPRS				$ 6,037.00
Grand Total Estimates for this ICR Cost to Federal Government				$ 9,222,126.51

¹Hourly rate for GS-12/Step5 and 12/6 staff; ²Hourly rate for GS-13/Step 5 staff and 14/Step 5 Branch Chief

Criteria Used: Estimates includes Cost for Regional and Headquarter Federal Program Staff to analyze data reported on each FNS forms/worksheets by States. Includes cost for staff to develop policy guidance for forms, includes contract cost to develop and maintain FPRS website, create, print, warehouse or distribute any paper forms if applicable.

15.) Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

The current overall burden inventory for FPRS is 103,627 burden hours and 46, 216 responses annually. This request will add 557 burden hours and no additional responses for a revised burden inventory of 104,184burden hours and the responses remains unchanged with this revision.

The current burden is reported for worksheet FNS 366 B is 1,298.50 (this activity should have been reported as 950 burden hours during this last approval). The revised requested burden to use the 366 B is 1,855.00 an increase of 556.50 rounded to 557 due to program changes. Under this revision, fifty-three (53) SA’s submit 1 response annually for a total of 53 annual responses. The annual reporting burden for the form FNS–366B revision is 35 hours per respondent to complete the form. The current time per activity is reported as 24.50. This was reported in error. This is an increase of 6.57 burden hours per response from the actual time of 17.93 hours per response. The reporting burden for form FNS–366B is 1,855 hours (53SA × 1 annual report = 53 total annual responses × 35 hours per response = 1,855).

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

There are no plans to publish a compilation of the data from this information collection. Data collected will be used for internal administration of contracts.

The data is gathered at various times, ranging from monthly, quarterly, annual or final submissions. The information may also be used by FNS to conduct program evaluation, planning and audits, future funding, research, and general statistics.

The data compile is used by the FNS administrator, the Program’s Division, FNS Financial Management Division and State Agencies administering FNS Programs to ensure program integrity and compliance. This information is also used to determine eligibility to participate in these programs, ensure acceptance of responsibility in managing an effective food service program, implement systems for appropriating Program funds, and ensure compliance with all statutory and regulatory requirements.

Additionally, FNS uses the data reported on the FNS-778 worksheet to monitor the actual cost of each function against budgeted amounts approved for each State agency. FNS also uses the data to ensure that the Federal rate of reimbursement is appropriate for each function and that the State agency has met its matching requirement. FNS uses the reported data on the FNS 778A to monitor the actual benefit cost for these projects in each State agency along with participation trends. FNS also uses the data to look at both total costs and cost per case. The actual cost data (along with participation trends) helps us to estimate, budget, and set funding levels for these costs for the upcoming fiscal year.

A.16 - 1 Project Time Schedule
Activity	FPRS Time Schedule
Completed Reports in FPRS	4 months after OMB approval and quarterly thereafter
Validation	10 - 12 months after OMB approval and quarterly thereafter
Analyses	12 - 18 months after OMB approval and quarterly thereafter
Publication	No publication of reports

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.

FNS plans to display the OMB approval number and the expiration date on this information collection.

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.

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File Title	Supporting Statement for Paperwork Reduction Act Submission
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File Created	2021-01-24