0584-0083 Supporting Statement

Supporting Statement for

Paperwork Reduction Act Submission

OMB No. 0584-0083

Forms FNS-366A and FNS-366B, Program and Budget Summary Statement

Prepared by:

Ralph Badette

U.S. Department of Agriculture

Food and Nutrition Service

3101 Park Center Drive, Room 816

Alexandria, VA 22302

703-457-7717

[email protected]

Table of Contents

Part A Justification

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

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

A.3 Use of Improved Information Technology to Reduce Burden

A.4 Efforts to Identify and Avoid Duplication

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

A.6 Consequences of Less Frequent Data Collection

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

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

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

A.9 Payments to Respondents

A.10 Assurance of Confidentiality

A.11 Questions of a Sensitive Nature

A.12 Estimates of Respondent Burden

A.13 Estimates of Other Annual Costs to Respondents

A.14 Estimates of Annualized Government Costs

A.15 Changes in Hour Burden

A.16 Time Schedule, Publication, and Analysis Plans

A.17 Display of Expiration Date for OMB Approval

A.18 Exceptions of Certification Statement

A.1 FNS 366A Screenshot

A.1.1 FNS 366A PDF for Instructional Purposes in FPRS

A.2 FNS 366B Screenshot

A.2.1 FNS 366B PDF for Instructional Purposes in FPRS

A.3 SWIM Screenshot

A.4 SF 425 Federal Financial Report Screenshot

A.4.1 SF 425 Federal Financial Report PDF for FPRS

A.5 FPRS Public Burden Statement

Terms of Clearance

The agency has successfully merged the reporting burden hours for FNS 366A Budget Projection and 366B Program Activity Statement under of the Food Programs Reporting System (FPRS) 0584-0594, Expiration Date: 06/30/2019. Additional reporting not captured on these forms and recordkeeping burdens for both forms will remain in this collection.

A. Justification

1. Indicate how, by whom, and for what purpose the information is to be used. Except for

a new collection, indicate how the agency has actually used the information received from

the current collection.

This is a revision of a currently approved collection to remove any reporting burden for FNS 366A and 366B. All other reporting outside these forms and any recordkeeping will remain in this collection.

Primarily, this information collection package consists of four major components of State agency reporting: (1) a budget projection statement, (2) a program activity report, (3) State plans of operation updates, and (4) other plans and submissions such as advance planning documents for information systems and for electronic benefit transfer (EBT) systems.

Budget Projection Statement, Program Activity Report, and State Plan of Operation Updates

Under section 16 of the Food & Nutrition Act of 2008 (the Act), 7 U.S.C. 2025, the Secretary is authorized to pay each State agency an amount equal to 50 percent of all administrative costs involved in each State agency’s operation of the Supplemental Nutrition Assistance Program (SNAP). Under corresponding SNAP regulations at 7 CFR 272.2(c), State agencies are required to submit to FNS for approval a Budget Projection Statement and maintain Form FNS-366A, which includes projections of the total Federal costs for major areas of program operations. The budget projection allows FNS to estimate funding needs so we can fund the State administrative costs for the fiscal year, and a Program Activity Statement (Form FNS-366B), which provides a summary of SNAP operations during the preceding fiscal year. The activity report and maintenance of this form is required annually to substantiate the costs the State agency expects to incur during the next fiscal year. It provides data on the number of applications processed, number of fair hearings and fraud control activity. FNS uses the data to monitor State agency activity levels and performance.

In accordance with section 11(d) of the Act, 7 U.S.C. 2020, State agencies are also required to submit a Plan of Operation specifying the manner in which SNAP will be conducted within the State in every political subdivision. Section 11(e) of the Act provides that the State plan of operation shall provide for State agency verification of household eligibility prior to certification, completion of certification within 30 days of the filing of the application, fair hearings, submission of reports as required by the Secretary, and other provisions as may be required by regulations. Section 16(a) of the Act authorizes 50 percent Federal reimbursement for State agency costs to administer the program. Part 272.2(a) of SNAP regulations requires that State agencies plan and budget program operations and establish objectives for the next year. The basic components of the State Plan of Operation are the Federal/State Agreement, the Budget Projection Statement, and the Program Activity Statement (272.2(a)(2)). Under Part 272.2(c), the State agency shall submit to FNS for approval a Budget Projection Statement (which projects total Federal administrative costs for the upcoming fiscal year) and a Program Activity Statement (which provides program activity data for the preceding fiscal year). In addition, certain attachments to the plan as specified in subparagraphs (c) and (d) are to be submitted and maintained. As specified in subparagraph (f), State agencies only have to provide FNS with changes to these attachments as they occur. Consequently, these attachments are considered State plan updates. FNS developed and launched an electronic workflow system, SNAP Workflow Information Management (SWIM), to streamline FNS waiver processing procedure. Current procedures require that in order for FNS to approve a SNAP waiver request, the State agency must submit the SNAP Waiver Request Form via the SWIM application. The online version of the request form does not modify the currently approved burden hours in any way, but changes the method of collection for this information and how this data is maintained.

Advance Planning Documents for Information Systems

Under Section 11(o) of the Act, Volume 79, No. 1 published in the Federal Register on January 2, 2014 (Volume 79, No. 1, Page 6, Titled: RIN 0584-AD99: Automated Data Processing and Information Retrieval System Requirements: System Testing) each State agency is required to develop and submit plans for the use of automated data processing (ADP) and information retrieval systems to administer SNAP. We estimate that up to 53 State agencies may submit on an average of four (4) APD. Section 16(a) of the Act authorizes partial Federal reimbursement of State costs for State ADP systems that the Secretary determines will assist meeting the requirements of the Act, meets conditions prescribed by the Secretary, are likely to provide more efficient and effective administration of the program, and are compatible with certain other Federally-funded systems. Under 7 CFR 277.18(c)(1) of SNAP regulations, State agencies must obtain prior written approval from FNS when it plans to acquire ADP equipment with a total acquisition cost of $5 million or more in Federal and State funds. The State agency must submit and maintain Advance Planning Document (APD) prior to acquiring planning services and an Implementation APD prior to acquiring ADP equipment or services.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for

a new collection, indicate how the agency has actually used the information received from

the current collection.

Budget Projection: Under FPRS OMB Control No.: 0584-0594, Expiration Date: 06/30/2019, State agencies are required to submit to FNS for approval a Budget Projection Statement, Form FNS-366A, which includes projections of the total Federal costs for major areas of program operations. The budget projection allows FNS to estimate funding needs so we can fund the State administrative costs for the fiscal year. However, recordkeeping requirements for these forms remain in this collection OMB Control Number OMB control number 0584-0083.

Program Activity Statement: Again, under FPRS OMB Control No.: 0584-0594, Expiration Date: 06/30/2019, State agencies are required to submit to FNS a Program Activity Statement, Form FNS-366B, providing a summary of program activity for the State agency's operations during its preceding fiscal year. The activity report is required annually to substantiate the costs the State agency expects to incur during the next fiscal year. Recordkeeping requirements for these forms remain in this collection OMB Control Number OMB control number 0584-0083. It provides data on the number of applications processed, number of fair hearings and fraud control activity. FNS uses the data to monitor State agency activity levels and performance.

State Plan of Operation Updates & Waiver Requests:

State agencies submit the operations planning documents to the appropriate regional office for approval. This information explains how States are operating the program for monitoring purposes and allows FNS to know which States have implemented which activities and options for data and cost analysis purposes. State agencies administering SNAP may also submit formal written requests, SNAP waiver requests, to obtain approval from FNS to deviate from a specific program rule or regulation SNAP waiver requests fall into two broad categories based on statutory or regulatory authority.

1. Demonstration Waivers: Section 17(b) of the Act, 7 U.S.C. 2026(b), the Secretary may waive certain requirements of the Act to test program changes that might increase the efficiency of SNAP and improve the delivery of SNAP benefits to eligible households. Waivers of provisions of the Act are referred to as demonstration waivers.

2. Administrative Waivers: The FNS Administrator may authorize waivers to deviate from specific regulatory program requirements per 7 CFR 272.3(c) and 273.21(a). Waivers of the regulations are referred to as, administrative waivers and are the most common waiver requested by States and approved by FNS.

Under current procedures, State agencies may request SNAP waivers by submitting formal written requests to FNS Regional SNAP Directors. FNS is currently developing SWIM, an online database and workflow system to streamline waiver processing that will be re-deployed at the end FY 2017, which will allow State agencies to submit waiver requests electronically.

Advance Planning Documents: Under 7 CFR 277.18(c)(1) the Advance Planning Documents (APD) for State automated data processing and information systems are useful to FNS because they explain how the system will work and help explain the estimated cost of the system. The testing plan itself does not require approval. However, under 7 CFR 277.18(c)(1)it must be submitted via e-mail so that FNS can make a sound determination as to the validity of the test results and the State’s decision to proceed to pilot, which does require FNS concurrence. The information allows FNS to determine whether the system meets the statutory criteria for approval for Federal reimbursement.

Financial Reporting: FNS requires State agencies to report expenditures for administrative costs and cash-out benefit costs using SF-425 (burden estimates cleared under SF-425 Federal Financial Report 4040-0014), OMB Control No.: 4040-0014; Expiration date: 1/31/2019) in conjunction with the FNS 366-A which requests Federal funding. A copy is maintained for 3 years.

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 makes every effort to comply with E-Government Act, 2002 (E-Gov) and to provide for alternative submission of information collections.

Currently, States submit electronic FNS-366A, FNS-366B, and SF-425 reports via the Food Programs Reporting System (FPRS) at https://fprs.fns.usda.gov/Home/Reminder.aspx. Because budgets come in before and for the upcoming fiscal year while program activity reports come in after the completed fiscal year, the time frames for the two reports in this submission are different by necessity. In fiscal year (FY) 2012, 100% of these responses on the forms mention above were submitted electronically.

In 2014, FNS developed and launched an electronic workflow system, SNAP Workflow Information Management (SWIM), to streamline FNS waiver processing; the current waiver request form will be transposed to an online waiver request form. Since SWIM was deploy, there has been to program concerns, FNS is revamping the system and it will be redeployed at the end of FY 2017; in the meanwhile, the States are submitting waivers via a waiver request to the FNS Regional SNAP Directors. FNS will submit screenshot of the system with the OMB control number and expiration date format. FNS estimates that 100% of waiver requests will be submitted via SWIM once the full release of the tool is made available at the end of FY 2017.

Currently, States submit the request for administrative review of ADPs via electronic mail. This request is an official memorandum, signed and provided by the requestor in portable document format (PDF). In fiscal year (FY) 2012, 100% of these plans were submitted via email.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Question 2.

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 monitors State performance to ensure that the program is being efficiently and economically operated.

The FNS-366A, which includes projections of the total Federal costs for major areas of program operations, is submitted prior to the start of the fiscal year and is necessary as part of the budget approval process. State agencies report actual cost data to FNS after the fact; actual cost data is not duplicative of the data collected on the FNS-366A.

In order to eliminate duplication on APDs, FNS works closely with the Department of Health and Human Services on integrated systems affecting both Departments. The State agency submits the same documentation to each Department concurrently. Coordination of decisions and responses to State requests for approval are executed between the two Departments routinely.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

Information being requested or required has been held to the minimum required for the intended use. Although two smaller State, Local, or Tribal Government Agencies are involved in this data collection effort, they delivered the same program benefits and perform the same function as any other State Agencies. Thus, they maintain the same kinds of information on file. There are no other 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.

This is an ongoing information collection. Form FNS-366A is submitted annually by August 15 for the upcoming fiscal year and Form FNS-366B is submitted no later than 45 days after the end of each State agency's fiscal year. Less frequent reporting would disrupt budget planning and delay appropriation distributions. State Plans of Operation are a one-time effort with updates provided as necessary.

The frequency of the APD requirement is at the discretion of respondents and their need to apply for Federal Financial Participation for the cost of their ADP equipment and services acquisition. These documents allow FNS to determine whether the system meets the statutory criteria for approval for Federal reimbursement. Without these documents FNS would not be able to verify and ensure State integrity or compliance with statutory criteria.

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

• requiring respondents to report information to the agency more often than

quarterly;

• requiring respondents to prepare a written response to a collection of information in

fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to

protect the information's confidentiality to the extent permitted by law.

There are no special circumstances that require the information to be collected in a manner that is inconsistent with 5 CFR 1320.5.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

November 14, 2016 FNS published in the Federal Register a 60-day notice 81 FR 79411 regarding this information collection. Comments were solicited on this information collection as part of the comment period of the notice. FNS received no 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 format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or

those who must compile records should occur at least once every 3 years even if the

collection of information activity is the same as in prior years. There may be circumstances

that may preclude consultation in a specific situation. These circumstances should be

explained.

Consultation with users of the FNS-366A, FNS-366B, and State Plan of Operations has been a continuous process over the years through informal conversations and with publication of our 60dayFRN. Consultations on the new SWIM system were conducted on the following dates:

• May 13, 2013 - SWIM Overview for SNAP Midwest Regional Office Director and Managers

• May 20, 2013 - SWIM Overview Webinar for SNAP National Office and Regional Office Staff

• May 29, 2013 - SWIM Overview Webinar for SNAP National Office and Regional Office Staff

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

FNS has no plans to provide payments or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the

assurance in statute, regulation, or agency policy.

Agency complies with the Privacy Act of 1974.

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 sensitive questions included in this submission.

12. Provide estimates of the hour burden of the collection of information. Indicate the

number of respondents, frequency of response, annual hour burden, and an explanation of

how the burden was estimated.

A) Indicate the number of respondents, frequency of response, annual hour burden, and

an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

The total number of respondents and affected public is 53 State, Local and Tribal Government Agencies who are estimated to respond 15.9433 times per agency annually for estimated total annual responses 845. The estimated reporting time per response per State Agency is 1.32489 for a total estimated annual reporting burden hours of 1,119.54 for reporting and recordkeeping. See the table below for a breakdown in estimates.

The burden consists of six major reporting components. It covers (1) the FNS-366A, (2) the FNS-366B, (3) the State Plan of Operation updates submitted as attachments (Waivers) to the FNS-366B, (4) other Advance Planning Documents (APD) and update submissions and SF 425. The estimated total annual burden for this collection is 2,866 hours. We are not requesting these reporting burden hours (for FNS 366A, FNS 366B nor SF 425) since these are already approved under the FPRS information collection request.

However, there are other reporting burden 1087.99 and 31.77 recordkeeping burden hours for a grand total of 1,119.54 burden hours we are requesting under this collection. The calculation of the burden for each of these components is described below:

Reporting cleared under 0584-0594 FPRS:

FNS-366A. Fifty-three (53) State Agencies (SA) submit 1 response annually for a total of 53 annual responses. The annual burden for the FNS-366A is 685 hours. Form FNS-366A provides an estimate of the funding needed to operate the program. The reporting burden is estimated to be 12.92 hours annually per respondent (53SA x 1 annual report= 53 total annual responses x 12.92 hours per response = 685). ROCIS would not allow for rounding in the time per response.

FNS-366B. Fifty-three (53) SA submit 1 response annually for a total of 53 annual responses. The annual reporting burden for the FNS-366B report is 17.93 hours per respondent to complete the form. The reporting burden for the FNS-366B alone is 950.29 hours (53SA x 1 annual report= 53 total annual responses x 17.93 hours per reponse= 950.29).

SF 425 - Financial Reporting.  FNS requires State agencies to report expenditures for administrative costs and cash-out benefit costs using SF-425 in conjunction with the FNS 366-A which requests Federal funding.  FNS estimates that 53 State agencies will submit 1 report quarterly, the total annual responses is 212 and the estimated burden per response is 1.50 hours for a total reporting burden of 318 hours annually.  These burden hours are currently cleared under SF-425 Federal Financial Report 4040-0014), OMB Control No.: 4040-0014; Expiration date: 1/31/2019).

Reporting remained in 0584-0083:

Plan of Operation Updates & SNAP Waiver Request. Fifty-three (53) SA submits 1 response annually for a total of 53 annual responses. The reporting burden for submission of updates to State Plans of Operation is 6.58 hours per respondent, resulting in estimated burden hours of 348.99 (53 x 6.5847 = 348.99). The SNAP Waiver Request Form is included as part of the total reporting burden for State Plan of Operation Updates. Approximately 53 SA will submit 3.94336 SNAP Waiver Requests annually for a total of 208.99 rounded up to 209 responses (53 x 3.94336 = 209). The estimated average number of burden hours per submission is 1 hour resulting in estimated total burden hours of 208 rounded to 209. The total reporting burden for the State Plan of Operation updates is 557.81 hours (348.99 + 209= 557.99).

Other Plans and Submissions. We estimate that up to 53 State agencies may submit on an average of four (4) APD, plan, or update submission for a total of 212 annual responses at an average estimate of 2.5 hours per respondent. The reporting burden is 530 hours. This burden has increased since the prior revision. This was reporting annually at 132.50 and this increase of 397.50 is due to program changes due to rulemaking which increase the frequency from once annually to a quarterly report.

Table A. 12.1 Reporting Estimates of Hour Burden in 0083

AFFECTED PUBLIC	FORMS	NUMBER OF RESPONDENTS	FREQUENCY OF RESPONSE	TOTAL ANNUAL RESPONSES	TIME PER RESPONSE (HRS)	ANNUAL REPORTING BURDEN HOURS
State Agencies	Plan of Operation Updates	53	1	53	6.58	348.99
	Plan of Operation Updates (SWIM) Waivers request after re-deployment	53	3.94336	209	1	209
	Other APD	53	4	212	2.5	530
	Plan or Update
0584-0083 Reporting Total Burden Estimates		53.00	8.9433	474	3.36	1,087.99

Recordkeeping for 0584-0083:

FNS-366A. There is a total number of 53 recordkeepers for each activity. Each State agency submits 1 response annually for a total of 53 annual responses. A copy is maintained for 3 years. It takes approximately 0.05 minutes to maintain each record. Total annual recordkeeping burden for FNS-366A is estimated at 2.65 hours annually per recordkeeper.

FNS-366B. Each State agency submits 1 response annually for a total of 53 annual responses; each record takes approximately 0.05 minutes to maintain. The annual recordkeeping burden for FNS-366B is estimated annually at 2.65 hours per recordkeeper.

Plan of Operation Updates & SNAP Waiver Request.

Each State agency submits 1 response annually for a total of 53 annual responses; each record takes approximately 0.07 minutes to maintain. The annual recordkeeping burden for updates to State Plans of Operation as attachments to the FNS-366B is 3.15 hours per record-keeper. Also, 53 States who will submit SNAP Waivers, there is no recordkeeping burden for the use of the SNAP Waiver Request Form associated with SNAP waiver requests.

Other Plans and Submissions. FNS estimated that up to 53 State agencies may submit an average of 4 APD, Plan, or Update submissions and approximately 212 records at an average estimate of 0.11 minutes per record keeper for an estimated total of 23.32 recordkeeping burden for this activity hours.

Financial Reporting.  The annual recordkeeping burden for financial reporting is estimated at 4,353 hours for 53 recordkeepers at approximately 212 records per State Agencies submitted quarterly. A copy is maintained for 3 years. (The current recordkeeping burden estimates for the SF-425 and cost associated to the respondents fare currently approved under [SF-425 Federal Financial Report 4040-0014), OMB Control No.: 4040-0014; Expiration date: 1/31/2019), and the estimates are no longer included as part of this FNS collection, FNS submitted a Request for Common Forms (RFC) associated with OMB Control Numbers: 0584-0512, Expiration Date: 03/2019 and 0584-0594, Expiration Date: 06/2019 .

Table A. 12.2 Record Keeping Burden

AFFECTED PUBLIC	(b) Form Number or activity	(c ) No. Recordkeepers	(d) No. Records Per Respondent	(e) Est. Total Annual Records (cxd)	(f) Hours Per Recordkeeper	(g) Total Burden (exf)
	FNS-366A	53	1	53	0.05	2.65
	FNS-366B	53	1	53	0.05	2.65
	Plan of Operations	53	1	53	0.07	3.15
	Other APD Plan or Update	53	4	212	0.11	23.32
0584-0083 Recordkeeping Total Burden Estimates		53	1.75	371	0.07	31.77

*No recordkeeping burden for the use of the SNAP Waiver Request Form

Table A. 12.3 Reporting and Record Keeping Burden Summary

AFFECTED PUBLIC	FORMS OR ACTIVITIES	NUMBER OF RESPONDENTS	ANNUAL FREQUENCY OF RESPONSE	TOTAL ANNUAL RESPONSES	TIME PER RESPONSE (HRS)	ANNUAL REPORTING BURDEN HOURS
State Agencies Reporting	FNS 366 A & B recordkeeping only	53	2	106	0.05	5.30
	Plan of Operation	53	2	106	3.32	351.92
	Updates Plan of Operation Updates (Waivers)	53	3.94336	209	1	209
	Other APD Plan or Update	53	8	424	1.305	553.32
GRAND Total Reporting and Recordkeeping Burden Estimates		53	15.9433	845	1.32489	1,119.54

B) 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 is based on the burden estimates developed in 12(a) above. Based on the Bureau of Labor Statistics May 2015 Occupational and Wage Statistics – 13-2031 (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 $36.13 per staff hour. Annual respondent cost is estimated at $40,456.98.

Table A. 12.3 Reporting and Recordkeeping Annualized Cost to Respondents

TYPE OF RESPONDENTS	TYPE OF SURVEY INSTRUMENTS	REPORTING AND RECORDKEEPING BURDEN	HOURLY WAGE RATE	RESPONDENT COST – PRIOR TO FEDERAL COST SHARING
State Agency	FNS 366 A & B recordkeeping only	5.30	$36.13	$191.50
	Plan of Operation	351.92	$36.13	$12,714.86
	Plan of Operation Updates (SWIM)	209	$36.13	$7,551.17
	Other APD Plan or Update	553.32	$36.13	$19,999.45
Total		1,119.54	$36.13	$40,456.98

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 questions 12 and 14). The cost estimates should be split into two components: (a)

a total capital and start-up cost component annualized over its expected useful life; and (b)

a total operation and maintenance and purchase of services component.

There are no capital, start-up and/or annualized maintenance costs associated with this burden.

14. Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

Table A. 14.1 Annualized Costs to Government

ACTIVITY	HOURS REVIEWING AND MONITORING	COST PER HOUR	COSTS REVIEWING AND	AUTMOATED SYSTEM COSTS	FEDERAL SHARE OF STATE COSTS	TOTAL FEDERAL COSTS
			MONITORING
Plan of Operation	348.99	$38.25	$13,349	$0	$9,103	$26,928
Other APD Plan or Update	530	$38.25	$20,273	$0	$9,503.50	$107,339
Total	878.99	$76.50	$33,622	0	$18,606.50	$134,267

The annual cost to the Federal Government using the 2016 Federal Salary Wage Table for two Management Analysts, GS 12, Step 5 to collect and use the data is estimated at $38.25 an hour. In addition to the wage data the annualized cost to the Federal Government also includes (1) reviewing, approving, and tracking State administrative budgets and disbursing funds; (2) reviewing and approving State plans and automated system project planning documents; (3) data entry and retrieval; (4) automated system costs; and (5) the Federal share of State agencies' burden costs to report the data. Total cost to the Federal Government is $134,267.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or

14 of the OMB Form 83-1.

This is a revision of a currently approved collection. FNS is requesting 1,119.54 burden hours and the total annual response are 845. The revised burden estimates have decreased from 2,754 to 1,119.54 burden hours, for an overall reduction of -1,634.46 (rounded up to -1,635) burden hours for reporting. The current total annual responses are 919 and the request total for this revision is 845. There is also a decrease of -74 responses per respondent.

The decreases are due to program changes where -1,635 burden hours were merged to the FPRS collection for reporting of the FNS 366A (-684.71 burden hours rounded to -685) and FNS 366B (-950.29 burden hours).

The decreases are due to program changes, -26 hours was removed for the one-time only survey for FNS 366 B review of intentional program violation (IPV) study conducted in 2014. “FNS Headquarters reached out to 8 FNS Regional Offices to gain insight on SNAP Recipient Trafficking Data Survey, and we determined there was year-to-year improvement in State recipient trafficking outcomes.

Another program change was due to rulemaking for Other Plans and Submissions. The burden for this activity is 132.50 and we are requesting 530 burden hours for this activity with the revision, an increase of 397.50 is due to program changes due to rulemaking published in the Federal Register, January 2, 2014 (Volume 79, No. 1, Page 6, Titled: RIN 0584-AD99: Automated Data Processing and Information Retrieval System Requirements: System Testing) which reduced the frequency from five (5) reporting annually to a quarterly (4) report which reflects a total annual responses from 265 to 212 an decrease of -53 responses required by the respondent for this specific activity, note although there is an decrease, this did not cause an overall increase for the data collection.

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

for tabulation and publication.

This data is included in the annual SNAP State Activity Report that is produced for and used by FNS for analysis and evaluation purposes. The report also published on the USDA FNS website at http://www.fns.usda.gov/pd/snapmain.htm. The report is usually published in the first quarter of the calendar year.

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.

The agency plans to display the expiration date for OMB approval of the information collection on all instruments.

18. Explain each exception to the certification statement identified in Item 19 of the OMB

83-I" Certification for Paperwork Reduction Act."

There are no exceptions to the certification statement.