SUPPORTING STATEMENT FOR
“The Loving Support Award of Excellence”
Anne Bartholomew, Chief, Nutrition Services Branch
Supplemental Food Programs Division
Food and Nutrition Service/ USDA
3101 Park Center Drive, Room 522
Alexandria, VA 22302
703-305-2116
(Fax) 703-305-2196
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A. Justification |
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1. Circumstances that make the collection of information necessary. |
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2. Purpose for which the information is to be used. |
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3. Description of any technological collection techniques. |
9 |
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4. Identification of duplication efforts. |
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5. Impacts on small businesses or other small entities. |
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6. Consequences to Federal program of policy activities. |
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7. Circumstances that would cause an information collection to be |
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conducted in a manner that is inconsistent with 5 CFR 1320.5. |
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8. Agency’s Federal Register Notice Publication. |
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9. Decisions to provide payment or gifts to respondents. |
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10. Confidentiality provided to respondents. |
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11. Justification for questions of a sensitive nature. |
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12. Hour burden of collection information estimates. |
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13. Total annual cost burden estimates to respondents or record keepers. |
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14. Annual cost estimates to the Federal government. |
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15. Explanation of any program changes or adjustments. |
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16. Plans for tabulation and publication of information collection results. |
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17. Justification of not displaying OMB expiration date. |
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18. Explanation of exceptions to the certification statement in Item 19. |
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B. Appendices - Appendix 1: Public Comments Received
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Appendix 2: Documents
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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 collection which covers the information collections of the Special Supplemental Nutrition Program for Women, Infants and Children (WIC. This information collection is based on Section 231 of the Healthy, Hunger-Free Kids Act of 2010 (HHFKA) (Public Law 111–296) which requires the U.S. Department of Agriculture (USDA) to implement a program to recognize exemplary breastfeeding support practices at WIC local agencies and clinics. This request for approval of information collection is necessary to meet a HHFKA mandate. The Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Program is authorized by the Child Nutrition Act of 1966 (42 U.S.C. 1787), as amended, and is administered by State and Local agencies in accordance with WIC Program regulations at 7 CFR Part 246. The information collection will recognize WIC agencies with exemplary breastfeeding programs and provide examples of model programs to motivate other local agencies and clinics to strengthen their breastfeeding promotion and support activities.
The WIC Program provides breastfeeding promotion and support for pregnant and postpartum mothers as a part of its mission to improve the health of the approximately 8 million Americans it serves each month. Breastfeeding is a priority in WIC and WIC mothers are strongly encouraged to breastfeed their infants unless medically contraindicated. WIC State and Local agencies, who receive Federal grant funds to operate the Program, are required by Federal WIC regulations to create policies and procedures that ensure that breastfeeding education and appropriate support are provided to assist mothers in initiating and continuing breastfeeding. The WIC Program has achieved many accomplishments in promoting, encouraging and supporting breastfeeding as the preferred feeding method for all infants. WIC breastfeeding initiatives fall under the umbrella of USDA’s national breastfeeding promotion campaign, Loving Support Makes Breastfeeding Work. The goals of the campaign are to encourage WIC participants to initiate and continue breastfeeding; increase referrals to WIC for breastfeeding support; increase general public acceptance and support of breastfeeding; and provide technical assistance to WIC State and Local agency professionals in the promotion of breastfeeding.
The WIC Program has achieved many accomplishments in promoting and supporting breastfeeding and continues to build upon these successes through its various breastfeeding efforts. Initiatives such as the changes to the WIC food packages, designed to support exclusive breastfeeding and provide additional incentives to assist mothers in making the decision to initiate and continue to breastfeed, WIC breastfeeding performance bonus awards for high performing WIC State agencies, and the updated WIC Peer Counseling curricula, are currently being implemented to provide recognition, and culturally appropriate educational resources to WIC State and Local agencies.
The HHFKA also requires the USDA to annually compile and publish breastfeeding performance measurements. The collection and publication of breastfeeding performance measurements is one of several provisions in the HHFKA that strengthens the WIC Program’s emphasis on breastfeeding promotion and support and underscores the importance of exclusive, continued breastfeeding to the health of WIC participants. This reporting requirement provides an exciting opportunity to help further the efforts of WIC State and Local agencies by highlighting agencies that demonstrate success in breastfeeding through high breastfeeding rates and by motivating other agencies to strengthen their breastfeeding promotion and support services with the goal of increasing their breastfeeding rates. The breastfeeding performance measurements will be used in the process to determine awardees for the top two level awards.
The award application period is open once annually, and has been designed to allow local WIC agencies at different stages of progress in breastfeeding promotion and support program development to apply for an award. Local agencies may submit one application per year for a self-designated level within the three award levels. Agencies may apply for a recognition award for their level of efforts and success one year, continue to develop their local programs, and then apply for a higher level award in a following year when further success is achieved.
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.
The core components of the information collection including information about local WIC agency breastfeeding peer counseling programs and community partnerships are core to WIC’s efforts to promote and support exclusive breastfeeding. The information requested will be collected from local WIC agencies dedicated to breastfeeding using the Gold Award, Gold Premier Award or Gold Elite Award applications/instructions (Attachment G-N). State Agencies will evaluate and award local WIC agencies based on their application and performance measures already collected using Title: Food Programs Reporting System (FPRS) approved under OMB Number: 0584–0594 (expiration date: 09/30/2019), Forms FNS 798 and FNS 798A. Burden for those forms are already approved and we are not requesting additional burden hours for that information collection. This information collection will continue to strengthen the breastfeeding promotion and support efforts of local WIC agencies by recognizing exemplary activities as well as provide models to assist and motivate other local WIC agencies and clinics to strengthen their breastfeeding promotion and support activities.
The information will be provided voluntarily by approximately 363 local WIC agencies applying for an award online. The data collected will be used to evaluate the components of existing breastfeeding programs in local WIC agencies, and make decisions about awardees. Decisions will be made by the State, Regional and FNS Headquarters.
Although there are three awards, the application is divided into two core components:
Baseline Gold Award application (Attachments G-J) will collect information on the following topics:
Local Agency Name, Address, Applicants Name/Title, Telephone Number and Email Address.
Prescreening Questions: Has peer counseling program been in place for at least one year and does it meet all components of the FNS Loving Support peer counseling model?
Peer Counseling Criteria: Questions 1-14: Assessment of target audience and their needs, gaps in service or resources in community. Monitor and observation of newly trained peer counselors along with adequate supervision. Process and protocols for WIC staff to refer participants to peer counselors.
Partnership: Questions 14 - 20: Focuses on working together with to provide breastfeeding support through continuum of care.
Other: Questions 21-30: Focuses on best practices for competency-based breastfeeding curriculum peer counseling staff training, continuing education, policies and procedures related to support for exclusive breastfeeding.
Gold Premier/Gold Elite Award Application (Attachments K-N) is combined with the baseline Gold Award application and will collect information on the following topics once annually. A completed Gold Award application is required before moving on to the higher Gold Premiere/Gold Elite award application:
Local Agency Name, Address, Applicants Name/Title, Telephone Number and Email Address.
Peer Counseling Criteria: Questions 1-10: Focuses on established guidelines for peer counseling training/continuing education, referral resources for peer counselors. Established processes and procedures between hospitals and WIC programs for newly delivered WIC mothers, for hospital or home visits, and social media technologies for peer counselors to communicate with client, established electronic tracking database for referrals, and recognition programs in place.
Partnerships Criteria: Questions 10-14: Focuses on Memorandum of Understanding (MOUs) with partners, new policies or procedures developed due to partnership and partner plans for sustainability.
Other Criteria: Questions 15-17: Focuses partner’s stakeholders, work-friendly breastfeeding environments, funding for staff education and certification and round the clock support for mothers who experience breastfeeding problems.
The Gold and Gold Premier/Gold Elite Evaluation Instructions and Worksheets (Attachments I, J, M, and N) will be used by State WIC Agencies who have local WIC agencies in their State who voluntarily filled out applications, to evaluate the components of existing breastfeeding programs in local WIC agencies.
Approximately, 90 State WIC Agencies, who have local WIC agencies in their State who voluntarily filled out applications, will complete the evaluation component. The information in the evaluation instructions regarding the award evaluation criteria is also in the application and application instructions to allow transparency of evaluation criteria to the applicant. The questions that make up the evaluation component that will focus on the following topics:
Prescreening criteria assessment conducted
WIC Peer Counseling implementation, protocols and operations,
Protocol to mitigate WIC breastfeeding clients concerns outside clinic hours, procedures for referrals,
Peer Counselor observation and shadowing, adequate supervision of Peer Counselors by staff with advance training,
Monitoring Peer Counselors, observation of newly trained Peer Counselors during client contact, written scope of practices for Peer Counselor,
Routine meetings to discuss case studies with Peer Counselors,
Routine client contact during pregnancy, after delivery and various postpartum periods
Partnership development
Again, the data collection efforts described above, we will use performance measure data provided by FNS using Food Programs Reporting System (FPRS) WIC Financial Management and Participation Report with Addendum approved under OMB Number: 0584–0594 (expiration date: 09/30/2019), Forms FNS 798 and FNS 798A.
FNS uses the information collected about the local WIC agency breastfeeding peer counseling program to evaluate components of existing breastfeeding programs and support within WIC local agencies and to recognize and celebrate local WIC agencies that provide exemplary breastfeeding programs and support services. This program highlights successful local agencies in order to provide models and best practices that motivate other agencies and clinics to strengthen their breastfeeding promotion and support activities. FNS assists in the development and communication of culturally appropriate educational resources to WIC State and local agencies, with the ultimate goal of increasing breastfeeding rates, especially in low breastfeeding rate areas.
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 makes every effort to comply with the E-Government Act, 2002. State, Local and Indian Tribal Organizations have the authority to use information technology that best suits the needs of their individual or unique systems of operation to comply with the information collection and individual reporting requirements contained in this submission. All local WIC agencies will submit electronic reporting to the WIC Works Resource System at [email protected]. We anticipate that 100 percent of the responses will be submitted 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.
There is no similar data collection available. The data requirements for this congressional-mandated 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.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
The information collection will not have an impact on small businesses or other small entities.
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 will be an on-going data collection. Section 231 of The Healthy, Hunger- Free Kids Act of 2010, Public Law 111-296, requires this information collection. Failure to collect this information will prevent annual data accountability on breastfeeding performance measurements. Without this information collection, FNS would not be able to assist in the development and communication of culturally appropriate educational resources to WIC State and local agencies.
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. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.5.
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.
There was one Federal Register Notice published for this information collection request. The Federal Register Notice was published on August 29, 2016 in the Federal Register (81 FR 59179). The notice requested comments on the data collection and the estimated burden of time. FNS estimated the time burden based on the maximum amount of time required for the highest level award, the Gold Elite Award. However, an applicant would not be required to answer all the questions to be eligible for the first two award levels.
No public comments were received on the estimated burden of time. A total of 3 comments were received. Two were supportive of WIC’s effort in breastfeeding promotion and practices. Zero of the 3 comments received were directly relevant to the burden of time or cost of the information collection (Attachments D-F).
The first commenter suggested an increase in funding to further support the Peer Counseling Program. The second commenter suggested adding a question to the application clarifying the peer counselors role and accountability. The third commenter suggestions were inconsequential.
FNS analyzed and considered the comments and determined that clarifying the peer counselors role and accountability was important. In response, FNS will add one question requiring a policy document to the application pertaining to peer counselor accountability. Additionally, FNS reviewed all application questions and determined that requiring a narrative and a policy document for Question 29 was redundant, and as a result, eliminated the narrative requirement.
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.
The 60-day notice published in the Federal Register allowed the public and stakeholders an opportunity to comment on this collection. FNS received feedback on clarity of instructions for the application and evaluation process from a small number of applicants and from the seven FNS regional office nutritionists throughout the application and evaluation timeframe and informally at its exhibit booth at the National WIC Association (NWA) conference, a non-profit education and advocacy voice for the WIC Program.
From the feedback received, FNS developed an expedited Gold Award Application process for past awardees with a valid Gold award that apply for a higher level award. FNS also hosted voluntary webinars to clarify the application and evaluation instructions for Local, State, and Federal staff who had additional questions after reviewing the instructions. The instructions and webinar contain the same information; the webinar is the paper instructions broken down to only a few steps per slide for staff who desire visual instructions. Staff can go view this webinar at their leisure at any point in time. Frequently Asked Questions (Attachment O) for common errors that could be remedied without additional assistance was developed from the instructions.
9. Explain any decision to provide any payments or gifts to respondents, other than remuneration of contractors or grantees.
This is a nonmonetary recognition award for Local agencies. No payments or gifts are to be provided.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
Information collection will not involve confidential information.
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
Information collection will not involve questions of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information.
Indicate the number of respondents, frequency of responses, 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.
An FNS study on WIC Breastfeeding Peer Counseling found that approximately two thirds of the local WIC agencies operate a Loving Support Program. The Loving Support Program is an FNS initiative that equips WIC programs with an implementation and management model—the Loving Support Model—that serves as a framework for designing, building, and sustaining peer counseling programs, a requirement for award eligibility.
Based on the findings of the study, of the 1834 local WIC agencies, it is estimated that approximately 1210 local WIC agencies will be eligible to apply for an award. Although the number of local agencies operating a Loving Support Program has increased, an average of 16.4% of eligible respondents have applied over the past two years. To better reflect the estimated number of respondents for subsequent years, FNS estimates that 30% (363) of eligible local agencies will respond annually. The estimated number of responses per respondent for the local agency is derived from the application process, where the local agency may only apply once per year.
The estimated number of respondents for the State agency evaluation is derived from the total number of State WIC agencies. The estimated number of responses per respondent for the State agency evaluation was derived by dividing the total number of respondents for the local agency applications, 363, by the total number of State WIC agencies, 90. The estimated number of responses per respondent for the WIC State agency is 4, as each WIC State agency will evaluate approximately 4 applications annually.
Respondent |
Estimated # Respondent |
Responses annually per Respondent |
Total Annual Responses (Col. B x C) |
Estimated Avg. # of Hours Per Response* |
Estimated Total Hours (Col. D x E) |
Reporting Burden |
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WIC Local Agency Application |
363 |
1.00 |
363.0 |
2.00 |
726.00 |
WIC State Agency Evaluation |
90 |
4.03 |
362.7 |
1.20 |
435.24 |
Total Reporting Burden |
453 |
1.60 |
725.7 |
1.60 |
1161.24 |
*Estimated average # of hours per response includes .5 hours for reviewing instructions
The total estimated annual burden is 1,161.24 hours. The estimation for time requirements are based on historical numbers of respondents from current and past WIC data collections and consultation with regional office staff. The total burden estimate includes time for reviewing instructions, gathering data needed, completing the application and evaluating the applications. The instructions and webinar contain the same information and is not an additional burden to what is already requested. There is no recordkeeping burden required for this data collection.
b. Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.
Type of Respondents |
Type of Instrument |
Average Time per Response |
Number of Respondents |
Frequency of Response |
Hourly Rate |
Total Cost ($) |
Local Agency Application |
Application |
2.0 |
363 |
1.00 |
$ 25.81* |
$18,738.06
|
State Agency Evaluation |
Evaluation |
1.2 |
90 |
4.03 |
$25.81* |
$11,233.54
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Total |
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453 |
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$29,971.6
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*Hourly rates were obtained from the U.S. Department of Labor, Bureau of Labor Statistics, May 2015 National Industry-Specific Occupational Employment and Wage Estimates. The average hourly rate of a State and Local Dietitian or Nutritionist is $25.81, as shown above.
13. Provide an estimate 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.
For the respondents there is no capital or operating and maintenance costs associated with this collection.
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.
The annual estimated cost to the Federal government (Headquarters and Regional Offices) to collect and use the data is estimated at $4,666.72. This cost includes reviewing, analyzing and approving applications, evaluations, and recommendations for recognition awards.
This information collection also assumes that approximately 133 hours of Federal employee time will be used to review and approve awards. The awards will be reviewed by Federal staff at FNS Headquarters and FNS Regional Offices at an average of base GS-11, GS-12 and GS-13 salaries, step 6, estimated at $34.99 per hour. FNS regional staff will review all award applications and recommendations for a total estimated cost of $4,242.49 annually. FNS Headquarters staff will review and approve only highest level award for a total estimated cost of $424.23 annually. See table below.
The estimated number of staff used at the FNS Regional Office for application review is derived from the total number of FNS Regional Offices. The estimated number of applications reviewed is derived from dividing the total number of local agency applications, 363, by the total number of FNS Regional Offices, 7 which is approximately 52 applications annually.
One staff member at FNS Headquarters will review and approve the highest awards. We estimate that 20 percent of the applications will be applicants for the highest level award, the only award requiring FNS Headquarters approval. The estimated number of responses per respondent for the FNS Headquarters approval is derived from multiplying the total number of local agency applications, 363, by 20 percent for a total of approximately 73 approvals annually for FNS Headquarters.
Type of Respondents |
Type of Instrument |
Number of Reviewing Staff/Offices |
Frequency of Response |
Total Annual Responses or Applications Reviewed |
Average Time per Response |
Total Staff Hours Annually |
Hourly Rate ($) |
Total Annual Cost to Government |
FNS Regional Office Application Review |
Application Review |
7 |
51.86
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362.99 |
.334 |
121.20 |
$34.99*
|
$ 4,242.25 |
FNS Headquarters Approval |
Application Approval |
1 |
72.60 |
72.60 |
.167 |
12.12 |
$34.99* |
$ 424.23 |
Total |
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8 |
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$ 4,666.72 |
* Based on an average $ 73,018 annual salary (Average of base GS 11, 12 and 13 salaries, Step 6, from the U.S. Office of Personnel Management Salary Table 2016.)
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 information collection request. The current total annual burden inventory for this collection is 1942.04. Under this revision, FNS is requesting 1161.24 hours a burden reduction of -781 burden hours. The current total number of annual responses is 1214. FNS is requesting 726 total annual responses for this revision. This reflects a decrease of -488 total annual responses. The current number of respondents participating is 697 (607 WIC Local Agencies + 90 WIC State Agencies). The estimated number of agencies anticipated in this revised data collection is 453 (363 WIC Local Agencies + 90 WIC State Agencies) this reflects a decrease of -244 WIC Local Agencies. This is due to adjustments in the number of respondents who chose to participate in the data collection. These estimates are based on historical numbers; therefore, FNS has adjusted our methodology and will not assume all eligible local WIC agencies will apply for an award.
Additionally, FNS added one question in response to public comments and eliminated the required narrative for Question 29. This program change didn’t modify the average time of response.
Another program change that will reduce the application time for Gold Awardees Applications, FNS is now allowing Local agency to skip all Gold questions 1 through 30 and only complete the Cover Page, Prescreening Questions, and Application Checklist. This reduces the amount of time spent completing the Gold Award, however, only for a small portion of applicants with a prior award will benefit from the time reduction. Therefore, the reduction of time will not be reflected in the burden table, as the burden hours are estimated for the highest level award application and evaluation. Lastly, the inclusion of the webinar is not an additional burden as the instructions and webinar contain the same information.
For collections of information whose results are planned to be published, outline plans for tabulation and publication.
There are no plans to tabulate, or publish the data. The names of the local WIC agencies that receive awards are posted on the FNS website at http://www.fns.usda.gov/wic/loving-support-award-excellence-awardees.
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 is not seeking exemption from this requirement.
Explain each exception to the certification statement identified in Item 19 "Certification for Paperwork Reduction Act."
There are no exceptions to the certification statement being requested.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Questions for Supporting Statement |
| Author | USDA |
| File Modified | 0000-00-00 |
| File Created | 2021-01-22 |