Change Justification Memo

United States

Department of

Agriculture

Food and

Nutrition

Service

3101 Park

Center Drive

Alexandria, VA

22302-1500

TO: James Crowe, OMB Desk Officer

Office of Information and Regulatory Affairs

Office of Management and Budget

THROUGH: Ruth Brown, Desk Officer

United States Department of Agriculture

Office of Chief Information Office

FROM: Rachelle Ragland Greene rg

FNS Information Collection Officer, Planning & Regulatory Affairs

Food and Nutrition Service

SUBJECT: Justification for site changes and decreased burden through OMB Control

No: 0584-0645: An Assessment of Mandatory Supplemental Nutrition Assistance Program (SNAP) Employment and Training (E&T) Programs

Through this memorandum, we are requesting approval to modify the sites of the qualitative data collection for the Assessment of SNAP Mandatory E&T Programs, which was approved under the Information Collection Request (ICR), OMB Control No. 0584-0645; Expiration Date: 2/28/2022. The original data collection was approved for visits to 6 States, with visits to 2 local SNAP offices and 3 E&T providers in each State (in total, 12 local SNAP offices and 18 E&T providers). However, due to recruitment challenges, only 3 States will be participating in the study. To ensure the data collection is broad enough to adequately answer the research questions and study objectives, we are planning to shift the location of some of the approved local visits to the participating States, so that data collection occurs in 3 local SNAP offices in each State (9 total) and 5 E&T providers in each State (15 total). As shown in the tables below, these changes would decrease the total burden estimate from 393 hours to 346.2 hours.

Although the overall burden hours will decrease, more activity will occur in each of the 3 participating States. Rather than visit 2 local SNAP offices per State (12 total), we intend to visit 3 per State (9 total). This will decrease the total burden on local offices from 146.6 hours to 110.5 hours, but it will increase the burden on local offices in the 3 study States from 24.4 hours per State to 36.8 hours per State. Additionally, rather than visit 3 E&T providers (one for-profit, one non-profit, and one State provider) in 6 States, we intend to visit 5 providers (one for-profit, two non-profits, and two State providers) in the 3 study States. Overall, this will decrease the total burden hours for E&T providers from 121.5 to 110.8 hours, but it will increase the burden on E&T providers per State from 20.3 to 36.9 hours.

If you have any questions regarding this request, please contact Rachelle Ragland-Greene, FNS Information Collection Officer for the Food and Nutrition Service, Planning & Regulatory Affairs Office at (703) 305-2586.

	Approved	Proposed
Visits to States	6 States	3 States
Visits to local SNAP offices	2 local offices per State (12 total)	3 local SNAP offices per State (9 total)
SNAP staff interviews	36 total (3 interviews per local office)	27 total (3 interviews per local office)
Visits to E&T providers	3 providers per State (18 total)	5 providers per State (15 total)
E&T staff interviews	54 total (3 interviews per provider)	45 total (3 interviews per provider)

Table 1. Approved activities and proposed activities

	Approved	Proposed
SNAP staff interviews	146.6 burden hours	110.5 burden hours
E&T staff interviews	121.5 burden hours	110.8 burden hours
Individuals & Households	30.0 burden hours	30.0 burden hours
All other activities	94.9 burden hours	94.9 burden hours
TOTAL	393 burden hours	346.2 burden hours

Table 2. Approved burden hours and proposed burden hours

1