SUPPORTING STATEMENT
for the
TECHNICAL ASSISTANCE FOR SPECIALTY CROPS PROGRAM
(0551–0038)
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.
The Technical Assistance for Specialty Crops program was authorized by Section 3205 of the Farm Security and Rural Investment Act of 2002 (Pub. L. 107–171), as amended, which became effective on May 13, 2002. Program regulations appear at 7 CFR part 1487. Section 3205 provides that the Secretary of Agriculture shall establish a program to address unique barriers that prohibit or threaten the export of U.S. specialty crops. The program was reauthorized by the Agriculture Improvement Act of 2018 (section 3201), which became effective on December 20, 2018.
2. Indicate how, by whom 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 Foreign Agricultural Service (FAS) will administer the program for the Commodity Credit Corporation (CCC). Data collected will be used by FAS marketing specialists and program managers for fund allocation, program management, planning, and evaluation. Participants will be required to keep documents for 5 years after completing a project.
Proposals: Through the proposal, prospective applicants submit data about their organizations so that FAS can determine the extent to which applicants satisfy the criteria upon which allocations are based. The proposal must include: organizational information, including a description of the organization’s experience in technical assistance projects; project information; a market assessment, including a brief description of the specific export barrier to be addressed by the project; and export information, including performance measures for three years, beginning with the year that the project would begin, which will be used to measure the effectiveness of the project.
Project Agreements: The project agreement is a binding instrument and creates a legal obligation on the part of CCC to make funds available to the Participant. The agreement creates a cooperative relationship between CCC and the Participant with each side contributing resources to support achievement of mutual goals. Because the agreement binds the United States Government, it is a proper basis for obligating funds and establishing the basis for this program.
Evaluation: FAS requires Participants, in their applications, to submit performance measures to: (1) monitor performance of technical assistance projects, (2) evaluate the benefits and effects of these projects, and (3) document the experience gained from these activities for use in the design and implementation of future projects. Based on this information, FAS program managers are also better able to determine what changes are needed in future programs to improve program performance.
Reimbursement Claims: The project agreement and corresponding amendments provide the authorities and limitations for Participants to make expenditures. The Participant is responsible for instituting a financial management and accounting system that ensures accurate, current, and complete disclosure of all financial transactions for each approved activity. All expenditures incurred must be proper, reasonable, and in accordance with FAS regulations. The Participant is responsible for submitting claims to FAS requesting reimbursement for incurred costs as outlined in the application.
Office Management Records: Other reporting and recordkeeping requirements, e.g. travel reports, are required as a means of ensuring that U.S. Government resources are disbursed as judiciously as possible. FAS requires the same control of Participant spending of taxpayer funds as the U.S. Government requires of its own employees. For example, FAS asks Participants traveling on U.S. Government funds to follow provisions of the Federal Travel Regulations.
Other Reports and Record Keeping Requirements: Other reports and records are required to ensure the proper and judicious use of Government resources. Participants must submit reports of findings whenever CCC resources are used for travel or research purposes. Auditable supporting documentation is required for all expenses reimbursed with CCC resources. These might include, but not necessarily be limited to: canceled checks, invoices, samples of produced materials, etc. As a rule, such requirements conform to generally accepted Government standards.
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.
FAS requires only the bare minimum in data collection and submission from the industry. For example, Participants are urged to use standard accounting and auditing procedures consistent with their own needs rather than government–directed accounting systems. The few activity codes established by FAS for use by Participants are used to answer congressional inquiries in very sensitive program areas such as travel, administrative costs, and evaluation.
FAS has implemented an electronic data transfer system using a web–based interface whereby reimbursement claims can be sent automatically from Participant computer systems to FAS, resulting in a major reduction in one of the largest paperwork requirements in the system. FAS has also implemented a computer financial management and information system to streamline data collection requirements, improve program accountability, and ease administrative burden on the Participants.
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 Item 2 above.
The data required of Participants is submitted in accordance with contract specifications and cannot be obtained from any other source other than the Participants. Program Participants are commodity organizations who develop proposals specifically for each project. Most of the data developed and presented to FAS is developed in–house by technical experts on their staffs.
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83–1), describe any methods used to minimize burden.
This program places information collection requirements on Participants, who generally include U.S. government agencies, State government agencies, non–profit trade associations, universities, agricultural cooperatives, and private companies. Thus, the information collection requirements imposed by this program do not require any significant actions on the part of small businesses.
Of the fifty (50) of respondents, the agency estimates (2%) are small businesses.
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.
Proposals are only submitted when an applicant would like to receive funding for a project. No other data is collected unless the proposal is approved. Less frequent collection is not possible without complete elimination of the data collection requirements.
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 or government contract, grant–in–aid, or tax records for more than three years;
* in connection with a survey that is not designed to produce valid and reliable results that can be generalized to the universe of the 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 collection of information inconsistent with 5 CFR 1320, Section 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.
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 periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
Notice of the request for comments on the extension of the currently approved information collection for the TASC program was published in the Federal Register (Vol. 83, No. 247) on December 27, 2018. A copy of the notice is attached.
FAS received comments from Terry Humfeld at the Cranberry Institute, Chris Zanobini at the California Cherry Board, John Keeling at the National Potato Council, and Ann George at the U.S. Hop Industry Plant Protection Committee. Their comments are summarized below.
General comments: Overall, the public comments were positive and indicated support for the program and cited its value to the specialty crops industry.
Comment: Two submitters expressed their desire to work with USDA to streamline and improve future application and reporting requirements to encourage additional program participation and maintain strong transparency and oversight of the TASC program.
Response: The 2018 Farm Bill requires FAS to solicit input from eligible organizations on improvements to streamline and facilitate the provision of assistance under the program, and FAS will work with industry stakeholders, including those that submitted comments on this notice, to solicit ideas and feedback on possible improvements to the program.
On March 26, 2019, FAS consulted via email with the following individuals on the appropriateness of the estimated information burden for the program. The comments and responses are noted as follows:
1) Ken Melban, California Avocado Commission, [email protected]: Reported a very positive experience with the TASC reporting requirements and said he did not find them to be overburdensome or complicated. Also noted the good help he received from FAS.
2) Amy Burdett, Potatoes USA, [email protected]: Reported the estimated time to prepare and submit a TASC application to be 4.5 hours, plus an estimated reporting and recordkeeping burden of 10.5 hours × number of years of grant.
FAS Response: This estimate is in line with FAS’s burden estimate of 32 total hours per grant.
3) Katherine Bedard, Wine Institute, [email protected]: Reported an estimated reporting and recordkeeping burden of 158 hours per grant.
FAS Response: This estimate is higher than FAS’s burden estimate of 32 total hours per grant. FAS will review its burden estimate and will solicit input from the respondent on improvements to streamline and facilitate the provision of assistance under the program.
4) Matt Lantz, Bryant Christie, Inc., [email protected]: Reported that a TASC application normally takes a few days to put it together, although addressing additional issues and questions once the application is submitted adds to the time. Noted that this burden is in line with other USDA programs that have similar requirements, but is a significant undertaking and can discourage potential applicants. Suggested bundling questions or simply having a call for clarification to lessen some of the back and forth. Appreciates the change from quarterly to annual reporting, which has helped a lot. There can be some time devoted to questions on the annual reporting, so again bundling those or perhaps doing a call could save some time. Also appreciates the recent change whereby the next year’s funds can be released once the annual report is filed. Suggested providing early training for those unfamiliar with the USDA systems, requirements, and audits to help them understand what is required and head off potential audit findings down the road.
FAS Response: The 2018 Farm Bill requires FAS to solicit input from eligible organizations on improvements to streamline and facilitate the provision of assistance under the program, and FAS will work with this respondent to explore his ideas and feedback on possible improvements to the program.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
The agency does not provide any payment or gift to respondents, other than remuneration of contractors or grantees.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation or agency policy.
Participants will be aware that information collected relating to this program is generally open for public inspection, but the agency may withhold information which could cause substantial competitive harm to the submitter under exemption 4 of the Freedom of Information Act (FOIA), 5 U.S.C. 552(b)(4). It is also the agency’s policy, prior to responding to an FOIA request, to obtain and consider the views of the submitter of the information if the information submitted is not readily identifiable as privileged or business confidential. If the agency disagrees with the views presented by the submitter, it will give the submitter sufficient time, prior to release of the information, to pursue legal action to prevent the release.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and 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 involved in this information collection.
12. 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. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
* 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 83–1.
* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contraction out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.
The current annual burden estimate of 1,600 hours is based on separate estimates of five distinct areas of data collection: Proposals, project agreements with FAS, evaluations, reimbursement claims, and office management records. The estimates used to determine the burden on the public are explained as follows:
a) Proposals. Proposals include separate assessments, projections, goals, etc., all of which make up a comprehensive proposal. The current estimate for one Participant to complete a proposal is 20 hours.
b) Project Agreements. The project agreement is a binding instrument and creates a legal obligation on the part of CCC to make funds available to the Participant. Participants will take approximately 2 hours to review the proposed contracts prepared by FAS, clear them with their lawyers, and return them to FAS.
c) Evaluations. Participants are required to evaluate the effectiveness of their programs to: (1) monitor performance of technical assistance projects, (2) evaluate the benefits and effects of these projects, and (3) document the experience gained from these activities for use in the design and implementation of future projects. Establishing good performance measures enables Participants to perform meaningful evaluations. Based on these evaluations, Participants and FAS program managers are better able to determine what changes are needed to improve program performance and designing future programs. Evaluations are expected to take 6 hours to prepare.
Reimbursement Claims. Participants submit claims to FAS whenever they feel their costs are of sufficient size to justify a claim for reimbursement. The reimbursement billing cycle varies by Participant depending on the level of activities and size of program. Participants are required to maintain receipts for all costs incurred for which reimbursement from project funds will be requested. The estimate of 2 hours per billing includes all incidental office costs and procedures necessary to prepare and support each claim. Participants are required to maintain appropriate records for three calendar years after termination of the project agreement or five calendar years following the end of the year in which the transaction evidenced by the record took place, whichever is less.
Office Management Records. Participants are required to keep good office records available for audit. These records include such things as travel reports and receipts for all disbursements. Maintaining office records should require 2 hours.
The estimated total cost to all combined respondents for reporting and recordkeeping is $107,500, which includes fringe benefit costs and is based on the following:
NUMBER OF TOTAL AV HOURS TOTAL COST COST TO
DESCRIPTION RESPONDENTS FREQ RESPONSE PER RESP HOURS PER HOUR PUBLIC
A) Proposals 50 1 50 20 1000 $70 $70,000
B) Project Agreements 50 1 50 2 100 $80 $8,000
C) Evaluation 50 1 50 6 300 $70 $21,000
D) Reimbursement Claims 50 1 50 2 100 $45 $4,500
E) Office Management Records 50 1 50 2 100 $40 $4,000
TOTAL 50 1,600 $107,500
13. Provide an estimate 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 Items 12 and 14).
* The cost estimate should be split into two components: (a) a capital and start–up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of the methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start–up costs include among other items, preparations for collection information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.
* If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60–day pre–OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
* Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or
(4) as part of customary and usual business or private practices.
There are no capital/start–up or ongoing operation/maintenance costs associated with this information collection.
14. Provide estimates of annualized cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
The estimated annual costs to the Federal Government, including fringe benefit costs, for all submissions found in the guidelines are as follows:
ITEM ORG GRADE RATE HOURS COST
A) Proposals POD 13 $45 20 $900
CPD 13 $45 320 $14,400
B) Project Agreements POD 13 $45 40 $1,800
CPD 13 $45 80 $3,600
C) Evaluation POD 13 $45 20 $900
CPD 13 $45 160 $7,200
D) Administrative Procedures POD 13 $45 100 $4,500
TOTAL $33,300
Note: POD refers to the Programs Operations Division of FAS. This office is responsible for administrative operation of the TASC program. CPD refers to the Commodity Program Division of FAS, which is responsible for review of application and evaluation content and day to day contact with program participants.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83–I.
There is no change from the last approval.
16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
The agency has no plans to publish any documents.
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 is not seeking approval to not display the OMB Control Number and Expiration Date.
18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83–1.
There are no exceptions.
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