OMB 0584-0034 FNS 245 Supporting Statement Part A Renewal Final PRAO 10-23-17_

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; we are documenting the renewal of the collection and the reduction in negative cases. State agencies are required to perform Quality Control (QC) reviews for the Supplemental Nutrition Assistance Program (SNAP). The FNS-245 (Case and Procedural Case Action Review Schedule) Appendix 1, is for State use to collect QC data and information on the status of case and procedural reviews. There are instructions for completing the form FNS-245 and can be found in the Food and Nutrition Service (FNS) Handbook 310, which is provided in this information collection request.

New QC procedures for Negative cases went into effect for the 2012 QC review year. Recently, SNAP determined the form associated with the reporting of these cases should retain the word, “Negative”, as the regulatory reference will not be updated. As such, instead of being the “Case and Procedural Case Action Review Schedule”, the form’s name will better reflect its regulatory reference as the “Negative Case Action Review Schedule.”

The legislative basis for the QC system is Section 16 of the Food and Nutrition Act of 2008, as amended, hereafter referred to as “the Act”. Part 275, Subpart C, of SNAP regulations implements the legislative mandates found in the Act. The regulatory basis for the QC reporting requirements is provided by 7 CFR 275.14(d) and 7 CFR 275.21.

The legislative basis for the recordkeeping requirements is – Section 11(a) of the Act. SNAP regulations, in Section 272.1(f), specify that program records are to be retained for a period of three years from the date of fiscal or administrative closure.

A2. Purpose and Use of the Information.

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.

The FNS-245 form serves as the data collection form for Case and Procedural case action reviews. Case and Procedural cases include the name, address and telephone number of applicants who were a part of the denial, termination or suspension process of benefits. The form consists of four sections and is used to record data in Case and Procedural case action reviews only. The first section, Case Management Information, is designed for State-related management tool use. The second section, Identifying Information, provides space for information about the household. The third section, Analysis of Review Activity, is for coding compliance with notice requirements. The fourth section, Description of Variances, provides for the detailed coding of each distinct variance identified in the review and the recorded reasons for the agency’s action. All information will be previously provided by the household through a SNAP application or through the interview process with an State eligibility worker. The State agency will use the extant collected data to input into the worksheet.

A3. Use of information technology and burden reduction.

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.

In compliance with the E-Government Act, 2002 (E-Gov), FNS has reviewed the QC review and sampling process. We have made every effort to streamline and automate the process.

The FNS-245 serves as both the data summary entry form that the QC reviewer completes during each case and procedural case action review and, subsequently as the data input document for direct data entry into the SNAP Quality Control System (SNAPQCS). Therefore, while data is manually collected by State Agencies, it is electronically submitted via a virtual network connection to a web-based database for tabulation and analysis.

A4. Efforts to identify duplication.

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.

There is no duplication of effort since there is no similar data available. FNS solely monitors the Quality Control reviews for SNAP to ensure program integrity.

A5. Impacts on small businesses or other small entities.

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.

FNS has determined that the requirements for this information collection do not adversely impact small businesses or other small entities. There are smaller State agencies; however they provide the same data as larger State agencies for this collection.

A6. Consequences of collecting the information less frequently.

Describe the consequence to Federal program or policy activities if the collection is not conducted, or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

This is a mandatory on-going data collection. FNS would not be able to effectively monitor invalid denials, terminations or suspensions; nor would we be able to identify related policy improvements without information obtained through the negative case review.

Legal obstacles to reducing the frequency of this collection are contained in SNAP regulations at 7 CFR 275.14(d) and 7 CFR 275.21.

A7. Special circumstances relating to the Guidelines of 5 CFR 1320.5.

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;

State agencies are required to select, conduct, and report on QC reviews on a monthly, ongoing basis.

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;
SNAP regulations in 7 CFR 272.1(f) specify that program records are to be retained for a period of three years from the date of fiscal or administrative closure. The date of an administrative closure could cause the case to be kept more than three years after the initial case review.
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 other special circumstances.

A8. Comments to the Federal Register Notice and efforts for consultation.

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.

Notice of this collection was published in the Federal Register on June 01, 2017 (Volume 82, Number 104, Page 25227). We 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.

FNS attends an annual meeting with the National Association of Program Information and Performance Measurement (NAPIPM) organization and holds calls regularly with the Quality Control Technical Advisory Group (QC TAG) of this organization, an association made up of State SNAP QC Directors, to discuss various QC topics including FNS worksheets.

A9. Explain any decisions to provide any payment or gift to respondents.

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

No payments or gifts are made to respondents.

A10. Assurances of confidentiality provided to respondents.

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

Information gathered from State agency records and information gathered in interviews during negative case action reviews (recorded on the FNS-245) are subject to the same privacy safeguards as information obtained from households applying for SNAP benefits. Section 11(e)(8) of the Act mandates that each State agency shall provide "safeguards which limit the use or disclosure of information obtained from applicant households to persons directly connected with the administration or enforcement of the provisions of this Act, regulations issued pursuant to this Act, Federal Assistance programs, or federally assisted State programs...". Section 272.1(c) of SNAP regulations implements this legislative mandate. The findings of negative case reviews, when compiled, do not identify the recipient by name. Please see: USDA/FNS System of Record Notice (SORNs) “Food Stamp Program Inquiries and Complaints” referenced in the Federal Register.

A11. Justification for any questions of a sensitive nature.

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 questions of a sensitive nature on the FNS 245.

A12. Estimates of the hour burden of the collection of information.

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.

There are 53 state agencies required to conduct QC reviews of the negative cases as part of the Performance Reporting System. State agencies complete the FNS-245 for each negative case in their QC sample. The overall reporting and recordkeeping burden associated with the completion of the FNS-245 has decreased from approximately 121,784.16 hours to 115,514.39 hours. The 6,269.29 hour decrease in the total burden is largely a result of the decrease in total SNAP negative case selections from 41,085 cases in FY 2010 to 38,970 (rounded up) cases in FY 2015.

In addition, each of the 53 state agencies are required to maintain records of the Form

FNS-245 for the recordkeeping requirement. FNS estimates 735.28 total annual records will be maintained by each state agency for a combined total annual records of 38,969.84. We estimate the burden is 0.0236 hours per record. This record keeping burden totals approximately 919.688 hours per year to maintain the 38,969.84 records.

We estimate the total annual reporting and recordkeeping burden for the FNS-245 to be 115,514.39 hours. The above burdens were arrived at by adding together the estimated reporting burden and the estimated recordkeeping burden.

Type of Respondents	Number of Respondents	Estimated Number of Negative Sample Cases Per Annum	Estimated Total Responses annually per Respondent	Estiamted Average Time Per Response (Hrs)	Estimated Total Respondent Burden (Hrs)
FNS -245 State Agencies Reporters	53	735.28	38,969.84	2.9406	114,594. 71
FNS -245 State Agencies Record Keepers	53	735.28	38,969,84	0.0236	919.688
	53	1,470.56	77, 939. 68	0.148209	115,514.39

B. Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

The cost to the public is based on $28.56 per hour. The rate to State agencies after 50 percent reimbursement by FNS is $14.28. Based on these figures the estimated total cost to respondents for the reporting and recordkeeping burdens after FNS reimbursement is $1,649,545. 40.

To estimate public cost, FNS consulted with the U.S. Department of Labor, Bureau of Labor

Statistics’ May 2016 data. Please see https://www.bls.gov/oes/current/oes211029.htm.

Type of Respondents

Total Burden Hours

Hourly
Wage
Rate

Total

Respondent
Cost

FNS -245

State Agencies

115,514.39

14.28

$1,649,545. 40

A13. Estimates of other total annual cost burden.

Provide estimates of the total annual cost burden to respondents or recordkeepers 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 costs for this collection by respondents or recordkeepers.

A14. Provide estimates of annualized cost to the Federal government.

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.

The annual cost to the Federal Government to collect and use the data for the FNS-245 is estimated at $2,660,620.48. This cost includes (1) the cost of printing reporting forms; (2) reviewing and approving the data, data entry and retrieval; (3) automated system costs [includes system monitoring and salaries]; and (4) the Federal government’s share of State Agency’s reimbursable operating costs for SNAP. These are operational costs only.

Required Reviewers Reviewing/Approving	Total Responses per annum	Hours per response	Regional office GS 11/2 2017 Hourly Salary	Cost
Regional Offices	8,805	2.9406	27.39	$709,181.41

Worksheet

Printing Costs

Federal Salary Costs from Reviewing/
Approving cases

Federal Share of State Agency’s reimbursable costs

Automated System Costs
(incl. Monitoring)

Estimated Total

Federal
Cost

FNS -245

$2,000

$709,181.41

$1,649,545.40

$299,893.67

$2,660,620.48

A15. Explanation of program changes or adjustments.

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

This is a revision of a currently approved information collection. The total negative case selection decreased from 41,085 cases in FY 2010 to 38,970 cases in FY 2015. This caused an adjustment in the overall burden from 121,784 hours in FY 2010 to 115,514.87 hours in FY 2015; a 6,269.13 hour decrease in overall burden.

A16. Plans for tabulation, and publication and project time schedule.

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

Data tabulation is achieved through established computer programs. Data included in this collection of information is gathered throughout each annual (fiscal year) review period. The data is then published in the SNAP QC Annual Report. This report presents official QC error rates, and related data for the United States, individual states, Guam, the Virgin Islands and the District of Columbia. The SNAP QC Annual Report will be published approximately one year after the end of each annual review period and is sent to each region and state electronically though FNS’ PartnerWeb application.

A17. Displaying the OMB Approval Expiration Date.

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 will be displaying the expiration date on the new form.

A18. Exceptions to the certification statement identified in Item 19.

Explain each exception to the certification statement identified in Item 19 of the OMB 83-I" Certification for Paperwork Reduction Act."

This information collection conforms to the requirements of 5 CFR 1320.9. There are no exceptions to the certification statement.

File Type	application/vnd.openxmlformats-officedocument.wordprocessingml.document
File Title	Supporting Statement for OMB No
Author	USDA
File Modified	0000-00-00
File Created	2021-01-22