Final Draft FNS-543 USDA National Hunger Clearinghouse Database Form - Clean3 EGA edits 9-12-18

USDA NATIONAL HUNGER CLEARINGHOUSE DATABASE FORM

OMB No.: 0584-0474

Project Manager: Celeste Perkins

Office: Office of Policy Support

Address: 3101 Park Center Drive, Suite 1014, Alexandria, VA 22302

Email: [email protected]

Phone Number: 703-305-2012

CONTENTS

Chapter Page

A. JUSTIFICATION

1. Circumstances That Make This Information Collection

Necessary 5

2. How, by Whom, How Frequently, and for What Purpose

Information Is to Be Used 6

3. Use of Information Technology 7

4. Efforts to Identify Duplication 8

5. Methods to Minimize Burden on Small Businesses or Other

Small Entities 8

6. Consequences If Information Is Not Collected or Is Collected Less

Frequently; Technical or Legal Obstacles to Reducing the Burden 9

7. Special Circumstances Requiring Specific Collection

Methods 10

8. Public Input into the Information Collection Prior to Submission

to OMB

a. Comments on FITS’ Federal Register Notice in Compliance

with 5 CFR 1302.8 (d) 11

b. Consult with Persons Outside the Agency 11

c. Circumstances that Preclude Consultation with

Respondents at Least Once Every 3 Years 11

9. Decisions to Provide Any Payment or Gift to Respondents,

Other Than Remuneration of Contractors or Grantees 12

10. Assurances of Confidentiality to Respondents 12

11. Additional Justification for Any Questions of a Sensitive Nature 12

12. Estimates of the Hour Burden of the Information Collection 12

a. Number of Respondents, Frequency of Response, Annual 12

Hour Burden, How Burden Was Estimated

b. Hour Burden Estimates for Additional Forms 13

c. Annualized Cost Estimates of Hour Burden Estimates 13

13. Total Annual Cost Burden Estimates to Respondents 13

14. Total Annual Cost Burden Estimates to the Federal

Government 15

15. Reasons for Any Program Changes or Adjustments Reported

in Items 13 and 14 15

16. Plans for Tabulation, Statistical Analysis, and

Publication

a. Publications 16

b. Time Schedule 1 6

17. Displaying Expiration Date of OMB Approval on Database

Form 16

18. Exceptions to the Certification Statement of Compliance

with 5 CFR 1320.6 17

APPENDIX A1: LEGAL AUTHORITY

APPENDIX A2: USDA NATIONAL HUNGER CLEARINGHOUSE DATABASE FORM FNS-543

APPENDIX A3: SCREENSHOT OF USDA NATIONAL HUNGER CLEARINGHOUSE DATABASE FORM FNS-543

APPENDIX B1: PUBLIC COMMENT B1 TO 60-DAY NOTICE

APPENDIX B2: PUBLIC COMMENT B2 TO 60-DAY NOTICE

A. Justification

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. Section 26 of the National School Lunch Act, which was added to the Act by Section 123 of P.L. 102-446 on November 2, 1994 (Legal Authority - Appendix A1), mandates that FNS enter into a contract with a non-governmental organization to establish and maintain a clearinghouse to provide information to non-governmental groups located throughout the United States that assist low-income individuals or communities regarding food assistance, self-help activities to aid individuals in becoming self-reliant, and other activities that empower low-income individuals or communities to improve the lives of low-income individuals and reduce reliance on Federal, State, or local government agencies for food or other assistance.

The USDA National Hunger Clearinghouse collects, develops, and distributes information and resources to help build the capacity of emergency food providers to address the immediate needs of struggling families and individuals while promoting self-reliance and access to healthy food. The Clearinghouse includes the USDA National Hunger Hotline, (1-866-3 HUNGRY or 1-866-348-6479, and 1-877-8-HAMBRE or 1-877-842-6273), and a USDA texting service (97779) which refers people in need anywhere in the U.S. to food pantries, soup kitchens, government programs and model grassroots organizations.

FNS began data collection activities for the National Hunger Clearinghouse in May 1996. The USDA National Hunger Clearinghouse Database Form (FNS-543, Appendix A2) and the electronic web database (screenshot Appendix A3) are sent to businesses-for profit organizations and not-for-profit institutions that assist low-income individual or communities. The organizations submit data annually about the type of services they provide and their respective target markets. The information submitted via form FNS-543 is maintained in the USDA National Hunger Clearinghouse Database. The information is used by FNS to fight hunger and improve nutrition by increasing participation in the FNS nutrition programs through the development, coordination, and evaluation of strategic initiatives, partnerships, and outreach activities. This database enables FNS to get food and self-help resources to those who need it most. Information is collected annually and maintained by the USDA National Hunger Clearinghouse contractor.

In this revision, we are not seeking approval for Summer Meal Sites form FNS-543A. Since the last OMB approval, FNS has removed the instrument from this collection request and the National Hunger Clearinghouse and that collection for Summer Meal Site (FNS-543 A) will be submitted separately by another FNS division. Thus, FNS is renewing this data collection for National Hunger Clearinghouse (FNS-543) in order to continue collecting information mandated by Congress.

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.

The information collected voluntarily on the FNS-543 provides a resource for groups that assist low-income individuals or communities regarding nutrition assistance programs or other assistance. Using the FNS-543 form, business-for-profit or not-for-profit organizations will submit this form once to provide important information such as operation hours, phone numbers, contact names, target population, types of services provided to the community, the organizations’ service locations, children services provided, whether the organization provides counseling or educational or job training services, health care assistance, homeless or housing services and any food assistance or government program assistance which will enable service groups to improve assistance to the target audience. The information is submitted to FNS almost exclusively through an electronic online form however paper copies of the form can be submitted via email or mail as well.

The information is used by FNS to fight hunger and improve nutrition by increasing participation in the FNS nutrition programs through the development, coordination, and evaluation of strategic initiatives, partnerships, and outreach activities. This database enables FNS to get food and self-help resources to those who need it most.

The information is additionally used by policy officials at the Office of the Under Secretary for Food and Nutrition Services at USDA. Other interested parties may include nutrition or health education professionals, state or local government health officials, nutrition councils, public interest advocates, private foundations and corporate officials.

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.

In compliance with the E-Government Act of 2002, FNS has reviewed this information collection in an effort to make electronic collection available to respondents. The USDA National Hunger Clearinghouse uses computer and telecommunications technologies, when feasible, to connect to the targeted audience. The information is available free of charge through a toll-free telephone line (1-866-3HUNGRY or 1-877-8HAMBRE), texting service (97779), and via the internet at https://www.hungerfreeamerica.org/about/our-work/usda-national-hunger-hotline.

Organizations may electronically submit their information via email or mail to the FNS contractor to be included in the Clearinghouse database located at https://nhc.fns.usda.gov/nhc/submit.

Based on 2018 data, FNS estimates that approximately 95% of our respondents submitted data for the FNS-543 electronically and 5% submitted via email or mail to our contractors.

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.

The data requirements for this data collection have been carefully reviewed to determine whether the needed information is already available. Although there are similar data collections, those do not meet the needs of this congressionally-mandated clearinghouse. FNS is mandated to enter into a contract with a non-governmental organization to establish and maintain a clearinghouse. The FNS managed data collection is necessary to meet our needs.

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

The burden for this information collection is minimal and participation is voluntary.

Information being requested or required has been held to the minimum required for the intended use. The respondent categories related to business-for and not-for-profit are considered small businesses or other small entities. Community-based organizations (Food Banks) engage in community outreach activities.

The sizes of the organizations vary, ranging from large national groups to small volunteer-run grassroots organizations. FNS estimates out of 600 respondents (using FNS-543) approximately 50 percent are considered small business or entities.

The FNS-543 is easily read online at https://nhc.fns.usda.gov/nhc/submit. The information is readily available to the respondents and they can start and stop at their leisure when visiting the website. There have been efforts to incorporate multiple response methods by making submission of the FNS-543 available in paper and electronically online.

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 data collection. If this data is not collected or is collected less frequently, FNS would not be in compliance with the congressional mandate or have the ability to aid low-income individuals or communities to become more self-reliant and empowered, improve the lives of low-income individual and reduce reliance on the Federal, State, or local governmental agencies for food or other assistance. The database provides valuable information to groups that assist low-income individuals or communities regarding nutrition assistance programs or other assistance. The Clearinghouse database is the only readily available source of current information on effective program models, surplus and emergency food distribution networks, and USDA food programs and policies.

In order to maintain the database, updated program, site physical locations, mail and email contact information must be collected from organizations contained in the database once each year.

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.

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 Federal Register Notice announcing the 60-day notice was published on May 30, 2018 (Volume 83, FR 24718). In response to this notice FNS received two comments (Appendix B1 and B2), which were not germane to the time or cost of this information collection; therefore, FNS did not provide a response.

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 External and Governmental Affairs Division, within the Office of Policy Support, met internally and externally with other FNS program offices and partner organizations to discuss the fields on form FNS-543. The decision was made to decrease the number of required fields on the form. External and Governmental Affairs Division also distributed the public notice to partner organizations within their distribution list requesting comment and received no response directly or through the public comment process.

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

No payments or gifts will be provided 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.

10. 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.

This information collection does not involve questions of a sensitive nature.

10. 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 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 table below shows the yearly estimated burden for the 600 respondents included in this data collection for FNS-543 displayed for the affected public (600 business-for and not-for-profit) and respondent and instrument types totaled for the entire data collection. The overall burden for this collection is 50 burden hours and 600 responses. The total annual estimated burden for the FNS-543 is 50 burden hours for reporting hours. The total estimated annual responses for this FNS-543 collection is 600 responses. There is no recordkeeping burden imposed on the respondents in this data collection.

The calculation of the burden for FNS-543 is described below:

• FNS-543. Six hundred (600) businesses submit 1 response annually for a total of 600 annual responses. The annual reporting burden for the FNS-543 report is 0.0833 per respondent to complete the form is 5 minutes (0.0833 hours) (600 business x 1 annual report= 600 total annual responses x 5 minutes (0.0833 hours) per response = 49.98 burden hours rounded up to 50).

• BUSINESS REPORTING BURDEN FOR FNS-543

Estimated Number of Respondents: 600

Estimated Number of Responses per Respondent: 1

Estimated Total Annual Responses: 600

Estimated Time per Response: 5 minutes (0.0833 hours)

Estimated Total Annual Burden on Respondents: 49.98 hours rounded up to 50 hours

TABLE. BUSINESS ESTIMATED ANNUAL REPORTING HOUR BURDEN

FNS-543 (Business Agency Reporting Burden)
Affected public	Respondent Type	Estimated # Respondent	Responses annually per Respondent	Total Annual Responses	Estimated Avg. # of Hours Per Response	Estimated Total Hours
Business	Food Banks	300	1	300	0.0833	24.99
	Business and Other For Profit	100	1	100	0.0833	8.33
	Not For Profit	200	1	200	0.0833	16.66
	Total Reporting Burden	600		600		49.98

The estimated total cost to respondents for the entire collection is $1,076.06. Community and social service specialists (business-for or not-for-profit) at community food, housing and emergency relief organizations are the most likely to complete the FNS-543 at food banks, businesses and other for profit and not for profit organizations. They have a mean hourly wage of $21.53 according to the Bureau of Labor Statistics (http://www.bls.gov/oes/current/oes211099.htm), thus the annual respondent cost for this affected public is estimated at $1,076.06.

10. 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 operational/maintenance cost associated with this information collection.

10. 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 total estimated cost to the Federal Government for this information collection is $302,337.10.

The annual hours worked on preparing this data collection and the hours worked to monitor the clearinghouse is approximately 40% of an employee’s time. For the purpose of this annualized cost estimate, the Program Analyst at a GS-13 Step 1 for the Washington, D.C. locality area using the Federal GS Pay Scale published in 2018, which has an annual salary of $96,970; additionally, the Branch Chief at a GS-14 Step 1 will spend approximately 10 hours drafting, editing and reviewing this data collection at a hourly wage rate of $54.91 which is a total of $549.10. An estimated $10,000 is spent annually in staff time from other miscellaneous employees that contribute their time to the Clearinghouse. An estimated $3,000.00 is spent annually on travel costs to conduct site visits to the Clearinghouse contractor and the contract has an annual cost of $250,000. The calculations for the estimated cost are = $96,970* 40% + $549.10 + $10,000 + $3,000 + $250,000 = $302,337.10.

10. 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. The current OMB burden inventory for the FNS-543 is 160 burden hours and 655 total annual responses. FNS is requesting 50 burden hours and 600 total annual responses for this revision.

FNS plans to remove the burden for FNS-543 A, which reflects a decrease of -60 burden hours and a decrease of -55 total annual responses. This program change is due to the removal of FNS-543 A which reflects a decreased number of expected respondents, total annual responses and burden estimates.

There is also a -50 burden hours adjustment which reflects a decrease due to erroneous burden estimates calculated in ROCIS.

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

There are no plans to publish results.

10. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

We are not seeking approval concerning the display of the expiration date.

10. 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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