SUPPORTING STATEMENT - PART A for
OMB Control Number 0584-NEW
Final Rule: Supplemental Nutrition Assistance Program: Student Eligibility, Convicted Felons, Lottery and Gambling, and State Verification Provisions of the Agricultural Act of 2014
(RIN 0584-AE41)
Mary Rose Conroy
Chief, Program Design Branch
Supplemental Nutrition Assistance Program
USDA, Food and Nutrition Service
3101 Park Center Drive
Alexandria, Virginia 22302
Table of Contents
A1. Circumstances that make the collection of information necessary. 3
A2. Purpose and Use of the Information. 4
A3. Use of information technology and burden reduction. 4
A4. Efforts to identify duplication. 5
A5. Impacts on small businesses or other small entities. 6
A6. Consequences of collecting the information less frequently. 6
A7. Special circumstances relating to the Guidelines of 5 CFR 1320.5. 7
A8. Comments to the Federal Register Notice and efforts for consultation. 7
A9. Explain any decisions to provide any payment or gift to respondents. 8
A10. Assurances of confidentiality provided to respondents. 10
A11. Justification for any questions of a sensitive nature. 10
A12. Estimates of the hour burden of the collection of information. 10
A13. Estimates of other total annual cost burden. 22
A14. Provide estimates of annualized cost to the Federal government. 23
A15. Explanation of program changes or adjustments. 23
A16. Plans for tabulation, and publication and project time schedule. 23
A17. Displaying the OMB Approval Expiration Date. 24
A18. Exceptions to the certification statement identified in Item 19. 24
Appendices
Appendix A: Final Rule
Appendix A1: Technical Correction to Final Rule
Appendix B: Burden Narrative
Appendix B.1.: Excel Table Burden Estimates
Appendix C: Legal Authority Cooperative Agreements Section 2009 of the Agricultural Act of 2014
Appendix D: Proposed Rule Comment from Faith-Based Organization (see page 2: Efficiency and Costs)
Appendix E: Proposed Rule Comment from Texas Health and Human Services Commission
Appendix F: Proposed Rule Comment from Florida Department of Children and Families
Appendix G: Proposed Rule Comment from Washington Department of Social and Health Services
Appendix H: Proposed Rule Comment from New York Office of Temporary and Disability Assistance
Appendix I: Proposed Rule Comment from Shannon Hewitt
Appendix J: Proposed Rule Comment from Kansas Department of Children and Families
Appendix K: Proposed Rule Comment from Center on Budget and Policy Priorities
Appendix L: Proposed Rule Volume 81 FR Page 86614
Appendix M: Proposed Rule Extended Comment Period Volume 82 FR Page 12184
Appendix N: System of Record Notice USDA/FNS-5 Information on Persons Disqualified from Supplemental Nutrition Assistance Program
A1. 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 new information collection request associated with final rulemaking titled Supplemental Nutrition Assistance Program: Student Eligibility, Convicted Felons, Lottery and Gambling, and State Verification Provisions of the Agricultural Act of 2014 (RIN 0584-AE41). Section 4009 of the Agricultural Act of 2014 (the Act) makes SNAP participants with substantial lottery and gambling winnings ineligible for SNAP benefits. Section 4009 of the Act also provides that State SNAP agencies are required to the maximum extent practicable to establish cooperative agreements with gaming entities within the State to identify SNAP recipients with substantial winnings. USDA is implementing Section 4009 through final rulemaking.
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.
State SNAP agencies are required, to the maximum extent practicable, establish cooperative agreements with gaming entities within the State to identify SNAP recipients with substantial winnings. Gaming entities (both State public agency and private business gaming entities) that enter into the cooperative agreements will share information with the State SNAP agency on individuals within their gaming establishment who win amounts equal to or greater than the maximum allowable resource limit for all elderly and disabled SNAP households, as defined in 7 CFR 273.8(b)(1).
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.
FNS is committed to compliance with the E-Government Act of 2002. FNS anticipates 99% of these responses will be submitted electronically to State agencies. The State SNAP agencies may use their information technologies to collect this information where feasible to ease administration and reduce burden. FNS anticipates that cooperative agreements between State SNAP agencies and State public agency and private business gaming entities will most likely involve the creation of an electronic data matching system to identify SNAP participants with substantial winnings. Currently, States utilize electronic data matching systems to collect information to verify legal alien status, prisoner verification, and deceased matches. Additionally, many States use electronic systems to intercept gaming winnings of individuals who are delinquent on child support payments.
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.
FNS has reviewed USDA reporting requirements, State administrative agency reporting requirements, and special studies by other government and private agencies. The Food and Nutrition Act of 2008, as amended, requires FNS to evaluate the financial resources of households to ensure they are below the statutory threshold. USDA is solely establishing what is considered substantial lottery and gambling winnings for SNAP participants. This rulemaking creates an additional eligibility requirement for SNAP households regarding substantial lottery and gambling winnings.
Every effort has been made to avoid duplication. Many States conduct similar information collections for the purpose of collecting past due child support payments for non-custodial parents. These States intercept lottery and gambling winnings of individuals that owe back-child support. States are encouraged to utilize existing data matching systems that collect information from State public agency and private business gaming entities, such as the child support matching systems. However, existing collections differ from this collection in purpose and threshold amounts that trigger the process. This collection requires the States to identify SNAP participants with substantial lottery and gambling winnings equal to or greater than the maximum allowable resource limit for all elderly and disabled SNAP households, as defined in 7 CFR 273.8(b)(1). In addition, the gaming entities will not be required to act on matches in the data system, which differs from the gaming entity’s responsibility in the collection of overdue child support payments.
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 private business gaming entities. Information being requested or required has been held to the minimum required for the intended use. Although smaller private business gaming entities may be involved in this data collection effort, they have to meet the same requirements for cooperative agreements as all other gaming entities based on this rulemaking. FNS estimates that one percent of private business gaming entity respondents will be small entities, approximately 1-2 respondents.
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 an ongoing mandatory data collection. In the cooperative agreements established with State public agency and private business gaming entities, State SNAP agencies are expected to describe the frequency of information collection. FNS is directing State SNAP agencies through final rulemaking to collect this information as frequently as is practicable. Failure to conduct this information collection is considered to be a violation of Section 4009 of the Agricultural Act of 2014, which requires that cooperative agreements with gaming entities for data collection be established to the maximum extent practicable. Collecting this information with less frequency than that established by the terms of the State SNAP agencies’ cooperative agreements with gaming entities could allow an ineligible person to remain on SNAP, in violation of Section 4009 of the Agricultural Act of 2014, which makes SNAP recipients with substantial winnings ineligible for SNAP benefits.
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;
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.
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.
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.
On December 1, 2016, the Department published the proposed rule (in the Federal Register Volume 81 Page 86614 Number 231) and solicited comments for 60 days, ending January 30, 2017. Another notice was published in the Federal Register Volume 82, Page 12184, Number 39. The comment period was reopened on March 1, 2017 to extend the public comment for 30 days, ending on March 31, 2017. The Department received 29 comments. Overall, the comments received were supportive of the proposed rule. Accordingly, the Department largely adopted the proposed rule as a final rule, with some modifications to the regulatory language in response to comments.
The Department received 11 comments regarding the $25,000 threshold for substantial lottery and gambling winnings in the proposed rule. Based on the comments received, the Department has decided to align the definition of substantial lottery and gambling winnings with the statutory resource limit for all elderly/disabled households in the final rule. This change follows the statutory intent to limit receipt of SNAP to low-income households with limited resources. In the final rule substantial lottery or gambling winnings are defined as a cash prize won in single hand equal to or greater than the resource limit for elderly/disabled households as defined in 7 CFR 273.8(b)(1) before taxes or other amounts are withheld. All households certified to receive SNAP benefits will be subject to this threshold regardless of whether they contain an elderly or disabled member. This change will impact the burden associated with this information collection.
Additionally, the Department received six comments, included in the appendices, regarding the requirement for State agencies to establish cooperative agreements with gambling and lottery entities within the State. One comment noted that the data match required by this rule is critical and reduces burden. Four of the six comments suggested that the requirement to establish cooperative agreements is burdensome and problematic for State agencies, and two of these comments noted that this will increase State costs. One comment questioned whether private entities would be compensated for costs associated with establishing cooperative agreements and suggested that the costs included in the proposed information collection appeared to be minimal.
The Department understands the concerns expressed about establishing agreements with gaming entities; however, the Agricultural Act of 2014 directs States to establish agreements with gaming entities to determine whether SNAP recipients have received substantial lottery or gambling winnings. The Department believes that the ability of States to establish agreements to the maximum extent practicable, as provided in Section 4009, alleviates the burden on State agencies and provides needed flexibility in establishing agreements with a reasonable number of gaming entities within the State. Additionally, the Department may not reimburse private gaming entities for its business costs. See comments received from the 60dayFRN in Appendix D-K.
Additionally, FNS published another notice June 21, 2019 in the Federal Register Volume 84; Page 29029; Number 120 (Appendix A-1 included with this ICR package). This document makes a technical correction to add the burden on SNAP individuals/households to report lottery or gambling winnings to State SNAP agencies to the burden which was not discussed in the Paperwork Reduction Act sections of the Proposed or Final Rule. The details estimates for both respondent groups are based on a prior estimate in OMB Control Number: 0584-0064, Expiration Date: 07/31/2020 where individual and household SNAP participates application times are reported and maintained. It is estimated that a total of 27,500 participants, or 550 SNAP participants per State, will spend a total of 4,593 hours at a rate of .167 hours per response to report their substantial winnings to the State SNAP agency at a rate of $7.25 per hour for a total estimated cost of $33,296 for all respondents annually. FNS is seeking to make this adjustment to include those burden estimates.
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 payment or gift will be provided 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.
The Department complies with the Privacy Act of 1974. Additionally, a system of record notice (SORN) titled FNS-5 USDA/FNS Information on Persons Disqualified from Supplemental Nutrition Assistance Program in the Federal Register on December 10, 2010, Volume 75, Number 247, and is located on pages 81205 - 81209 discusses the terms of protections that will be provided to respondents. Participants will be subject to safeguards as provided by the Privacy Act of 1974 (5 USC 552a), which requires the safeguarding of individuals against invasion of privacy. The Privacy Act also provides for the private treatment of records maintained by a Federal agency according to either the individual’s name or some other identifier.
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 included in this information collection.
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.
In the proposed rule’s information collection burden, the Department assumed that all 53 State agencies would establish cooperative agreements despite large variation in gaming activities among States. The final rule’s information collection estimates are based on 50 of the 53 State agencies implementing this provision to establish cooperative agreements. The Department assumes that at least three of the 53 State agencies do not have gambling or lottery in the State. These three State agencies would not be subject to this information collection because the rule does not require States to establish agreements with gaming entities outside of the State. All State agencies, including these three State agencies, are required to act when a household self-reports substantial lottery or gambling winnings, or the State learns of a household’s winnings. Nevertheless, the Department does not anticipate that these States will experience an increased burden for action on this information, as it is estimated that States without gaming entities will have significantly fewer households that receive substantial winnings. Therefore, the estimates in this final information collection are based on 50 State agencies establishing cooperative agreements in accordance with the final rule.
First Year Burden Hours
The affected public for this collection is 50 of the 53 State SNAP agencies, 50 State public agency gaming entities, and 200 private business gaming entities. It is estimated that 50 of the 53 State SNAP agencies will establish cooperative agreements once with five State public agency and private business gaming entities within the State for a total of 250 annual responses, which will take approximately 320 hours per response for a total of 80,000 annual burden hours. This one time activity includes time for the State SNAP agency to reach out to the State public agency gaming entities and private business gaming entities in the State, negotiate terms for sharing identifying information of winners, establish secure connections for sharing information, and to complete all necessary reviews of agreements by legal counsel and State leadership. Each of the 50 State public agency gaming entities will also incur a burden entering into cooperative agreements with their State SNAP agency, which will take approximately 320 hours per response for a total of 16,000 burden hours. This one time activity includes time for the State public agency gaming entity to negotiate terms for sharing identifying information of winners, establish secure connections for sharing information, and to complete all necessary reviews of agreements by legal counsel and State public agency gaming entity leadership. It is estimated that each of 200 affected private business gaming entities will establish cooperative agreements once with their respective State SNAP agency, which will take approximately 320 hours per response for a total of 64,000 annual burden hours. Our estimate assumes 50 of the 53 State SNAP agencies receiving SNAP funding will implement this rule despite large variations in gaming activities from State to State.
It is estimated that 50 of the 53 State SNAP agencies will create a data matching system once to match information on winners from State public agency gaming entities and private business gaming entities within the State with SNAP participation lists, which will take approximately 4,160 hours per response for a total of 208,000 annual burden hours. All State SNAP agencies currently make use of other computerized data matching systems (e.g. SAVE for immigration verification), so costs assume States will re-program existing systems.
Ongoing Yearly Costs
Once the matching system is in place, for every year thereafter, the State public agency and private business gaming entities will have to enter information into the system for every individual who wins over the threshold for winnings. There is no national database of how many people win large amounts of money in State lotteries or through other gaming activities. For this estimate, it is assumed that each of the 50 State public agency gaming entities would have 6,000 individuals who win over the threshold in a given year for a total of 300,000 annual responses. It will take approximately 0.08 hours for the State public agency gaming entity to identify the winner and enter the appropriate information into the matching system for a total of 24,000 annual burden hours per year. In addition, it is estimated that each of the 200 private business gaming entities will identify 6,000 individuals/households per year who have won over the threshold for a total of 1,200,000 annual responses. It will take approximately 0.08 hours for the private business gaming agency to identify the winner and enter the appropriate information into the matching system for a total of 96,000 annual burden hours per year.
Once the matching system is in place, for every year thereafter, the matches between the winner list and SNAP participation list should occur automatically and with negligible cost. For this estimate, it is assumed that 50 of the 53 State SNAP agencies will positively match with the five State public agency and private business gaming entities in their respective States an average of 460 records per year for a total annual response of approximately 23,000 SNAP participants nationally. Each of 50 State SNAP agencies will have to identify among the responses above those that are misidentified as SNAP participants because of a similar name, inaccurate reporting, etc. FNS anticipates that each of 50 State SNAP agencies will receive approximately 260 total annual records with misidentified participants for a total annual response of 13,000 records. It will take approximately 0.667 hours to identify these types of misidentifications for a total annual burden of 8,671 burden hours. Additionally, each of the 50 State SNAP agencies will have to follow-up with and disqualify SNAP participants discovered through the above matches to have actual substantial lottery or gambling winnings. FNS anticipates approximately 460 records annually per State SNAP agency will be households with actual substantial winnings and it will take approximately 1 hour of the State SNAP agency’s time for this activity for a total of approximately 23,000 annual burden hours.
Due to the change in the final rule, lowering the threshold for substantial lottery and gambling winnings to the $3,500 resource limit for elderly or disabled households as defined in 7 CFR 273.8(b)(1), the Department anticipates that State agencies will need to reevaluate significantly more households than estimated in the proposed information collection. This will increase the estimated cost and burden for States.
While the number of individuals reported to States is estimated to be 6,000, the Department assumes only a portion of the population, approximately 550 households per State, will have substantial winnings that will required to be reported. For the estimate of individual/household burden, it is assumed that each of the 27,500 households would have to report substantial winnings. It will take approximately 10 minutes or .167 hours to report changes as defined in 7 CFR 273.12(a)(2) for a total annual burden of 4,593 burden hours. FNS utilized the estimate of .167 hours to report a change based on a prior estimate in IC 0584-0064 on how long it takes a household to complete a simplified periodic report.
There is no recordkeeping burden required for this information collection request.
Reg. Section |
Respondent Type |
Description of Activity |
Estimated Number of Respondents |
Estimated Annual Report or Record Filed |
Estimated Total Annual Responses |
Estimated Number of Burden Hours Per Response |
Estimated Total Burden Hours |
Hourly Wage Rate* |
Estimated Cost to Respondents |
7 CFR 273.11(r) |
SNAP Individuals/ Households |
**Report lottery or gambling winnings to State SNAP Agency |
27,500 |
1 |
27,500 |
0.167 |
4,593 |
$7.25 |
$33,296 |
SNAP Individual/Household Subtotal Reporting |
27,500 |
1 |
27,500 |
|
4,593 |
|
$33,296 |
||
7 CFR 272.17 (a & b) |
State SNAP Agency Managers |
**Establish cooperative agreements with State public agency and private business gaming entities |
50 |
5 |
250 |
320 |
80,000 |
$59.35 |
$4,748,000 |
7 CFR 272.17 (c) |
State Public Agency Gaming Entity Managers |
**Establish cooperative agreements with State SNAP agency |
50 |
1 |
50 |
320 |
16,000 |
$59.35 |
$949,600 |
7 CFR 272.17 (c) |
State SNAP IT Staff |
**Create a data matching system with State public agency and private business gaming entities |
50 |
1 |
50 |
4,160 |
208,000 |
$53.74 |
$11,177,920 |
7 CFR 272.17 and 7 CFR 273.11(r) |
State SNAP Agency Eligibility Worker |
Eligibility worker follow-up - misidentified winners |
50 |
260 |
13,000 |
0.667 |
8,671 |
$21.45 |
$185,993 |
7 CFR 272.17 and 7 CFR 273.11(r) |
State SNAP Agency Eligibility Worker |
Eligibility worker follow-up - true winners |
50 |
460 |
23,000 |
1 |
23,000 |
$21.45 |
$493,350 |
7 CFR 272.17 and 7 CFR 273.11 (r) |
State SNAP Agency Eligibility Worker |
Eligibility worker work new applications (churn). |
50 |
411 |
20,550 |
1 |
20,550 |
$21.45 |
$440,798 |
7 CFR 272.17 (c) |
State Public Agency Gaming Entity Staff Member |
Input data into data matching system for use by State SNAP agency |
50 |
6,000 |
300,000 |
0.08 |
24,000 |
$19.56 |
$469,440 |
7 CFR 272.17 (c) |
State SNAP IT Staff |
Maintain a data matching system with State public agency and private business gaming entities |
50 |
1 |
50 |
320 |
16,000 |
$53.74 |
$859,840 |
State Agency Subtotal Reporting
|
50 |
6728 |
336400 |
|
375,671 |
|
$18,884,143 |
||
7 CFR 272.17 (a) - (b) |
Private Business Gaming Entity Managers |
**Establish cooperative agreements with State SNAP agency |
200 |
1 |
200 |
320 |
64,000 |
$40.12 |
$2,567,680 |
7 CFR 272.17 (c) |
Private Business Gaming Entity Staff Member |
Input data into data matching system for use by State SNAP agency |
200 |
6,000 |
1,200,000 |
0.08 |
96,000 |
$13.57 |
$1,302,720 |
Business Subtotal Reporting
|
200 |
6,001 |
1,200,200 |
- |
160,000 |
- |
$3,870,400 |
||
Individual, States and Business Reporting Grand Total Burden Estimates |
27,750 |
13,141 |
1,584,650 |
- |
560,814 |
- |
$23,228,636 |
||
*Based on the Bureau of Labor Statistics May 2017 Occupational and Wage Statistics. The salaries of State SNAP agency managers and public gaming entity managers are considered to be “General and Operations Managers (11-1021).” The salaries of private gaming entity managers are considered to be “Gaming Managers (11-9071).” The salaries of State SNAP IT Staff are considered to be “Software Developers, Systems Software (15-1133).”
The salaries of the eligibility workers are considered to be “Eligibility Interviewers, Government Programs (43-4061).” The salaries of public gaming entity staff member are considered to be “Information and Record Clerks, All Other (43-4199).” The salaries of private gaming entity staff member are considered to be “Gaming Cage Workers (43-3041).” (http://www.bls.gov/oes/home.htm)
** These are only first year costs and are next expected to re-occur annually.
B. Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.
The annual total cost is $30,894,085.98 including fully loaded wages ($23,228,636 total annual cost x 0.33 = $7,665,449.90 + $23,228,636) is for all of the identified occupation groups identified below.
The estimate of respondent cost is based on the burden estimates and utilizes the Department of Labor, Bureau of Labor Statistic, May 2017 National Occupational and Wage Statistics, Occupational Groups (11-1021), (11-9071), (43-4061), (43-4199), and (43-3041).
It is estimated that State SNAP agency mangers in the General and Operations Managers for Local Government occupation group (11-1021) in 50 of the 53 State SNAP agencies will spend a total of 80,000 hours to establish cooperative agreements with State public agency and private business gaming entities at a rate of $59.35 per hour for a total estimated cost of $ 4,748,000
for all respondents in the first year.
It is estimated that State public agency gaming entity managers in the General and Operations Managers for Local Government occupation group (11-1021) in 50 of the 53 State SNAP agencies will spend a total of 16,000 hours to establish cooperative agreements with State SNAP agencies at a rate of $59.35 per hour for a total estimated cost of $949,000 for all respondents in the first year.
It is estimated that private gaming entity managers in the General and Operations Managers, Management in Companies and Enterprises occupation group (11-1021) in the 200 private business gaming entities will spend a total of 64,000 hours to establish cooperative agreements with State SNAP agencies at a rate of $40.12 per hour for a total estimated cost of $2,567,680 for all respondents in the first year.
It is estimated that State SNAP agency IT staff in the Software Developers, Systems Software occupation group (15-1133) in 50 of the 53 State SNAP agencies will spend a total of 16,000 hours to maintain data matching systems with State public agency and private business gaming entities at a rate of $53.74 per hour for a total estimated cost of $859,840 for all respondents in the first year.
It is estimated that State SNAP agency eligibility workers in the Eligibility, Interviews, Government Programs occupation group (43-4061) in 50 of the 53 State SNAP agencies will spend a total of 20,550 hours to re-evaluate lottery or gambling winners who lose eligibility for SNAP according to normal program rules if they again decide to apply for SNAP benefits at a rate of $21.45 per hour for a total estimated cost of $440,798 for all respondents annually.
It is estimated that State SNAP agency IT staff in the Software Developers, Systems Software occupation group (15-1133) in 50 of the 53 State SNAP agencies will spend a total of 4,160 hours to establish data matching systems with State public agency and private business gaming entities at a rate of $53.74 per hour for a total estimated cost of $11,117,920 for all respondents in the first year.
It is estimated that State SNAP agency eligibility workers in the Eligibility, Interviews, Government Programs occupation group (43-4061) in 50 of the 53 State SNAP agencies will spend a total of 8,671 hours to review matches for misidentified winners at a rate of $21.45 per hour for a total estimated cost of $185,993 for all respondents annually.
It is estimated that State SNAP agency eligibility workers in the Eligibility, Interviews, Government Programs occupation group (43-4061) in 50 of the 53 State SNAP agencies will spend a total of 23,000 hours to follow-up with and disqualify correctly matched winners at a rate of $21.45 per hour for a total estimated cost of $493,350 for all respondents annually.
It is estimated that State public agency gaming entity staff in the Information and Record Clerks, All Other occupation group (43-4199) in the 50 State public agency gaming entities will spend a total of 24,000 hours to enter appropriate information into the data matching system with the State SNAP agency at a rate of $19.56 per hour for a total estimated cost of $469,440 for all respondents annually.
It is estimated that private business gaming entity staff in the Gaming Cage Workers occupation group (43-3041) in the 200 private business gaming entities will spend a total of 96,000 hours to enter appropriate information into the data matching system with the State SNAP agency at a rate of $13.57 per hour for a total estimated cost of $1,302,720 for all respondents annually.
It is estimated that a total of 27,500 participants, or 550 SNAP participants per State, will spend a total of 4,593 hours at a rate of .167 hours per response to report their substantial winnings to the State SNAP agency at a rate of $7.25 per hour for a total estimated cost of $33,296 for all respondents annually.
A13. Estimates of other total annual cost burden.
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 additional capital/start up or ongoing operation/maintenance costs associated with this information collection.
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
total Federal annualized cost is $4,283,695.13 including fully loaded
wages ($3,220,823.41 total annual cost x 0.33 =$1,062,871.72 +
$3,220,823.41) State SNAP agencies’ allowable SNAP
administrative costs are eligible for 50 percent Federal
reimbursement. The Federal government’s estimated total
annual cost is 50 percent of the State agency SNAP cost to create
cooperative agreements and establish data matching systems,
as well as 50 percent of the ongoing yearly costs to manage the data
matches, for a total of $9,442,071 over three years. In addition, the
cost to the Federal government to create this data collection was 20
staff hours for a GS 12 (Step 5) at a rate of $42.08/hour for a total
of $841.60.
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 new information collection request as a result of program changes and will add 1,584,650 responses and 560,814 hours of burden to OMB’s inventory. Out of those estimates 27,500 total annual responses and 4,593 burden hours accounts for the 27,500 SNAP participants who will be subject to requirements covered under this Final Rule.
FNS published a technical correction to Final Rule AE41 to add the burden on SNAP individuals/households participants to report lottery or gambling winnings to State SNAP agencies to the burden details below based on a prior estimate in OMB Control Number: 0584-0064, Expiration Date: 07/31/202 where the burden hours for SNAP Participants are reported and maintained.
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.
This collection does not employ statistical methods and there are no plans to publish the results of this collection for statistical analyses.
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.
The agency plans to display the expiration date for OMB approval of the information collection on all instruments.
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."
The agency is able to certify compliance with all provisions under Item 19 of OMB Form 83-I.
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