Attachment A - Burden Table

Attachment A

ESTIMATE OF THE INFORMATION COLLECTION BURDEN (ICB) FOR THE

SENIORS FARMERS’ MARKET NUTRITION PROGRAM (SFMNP), OMB #0584-0541

This document explains the calculation of the Information Collection Burden (ICB) for the Seniors Farmers’ Market Nutrition Program (SFMNP) under OMB #0584-0541, expiration date of 10/31/2019. The below narrative describes revisions made to the currently approved burden for reporting and recordkeeping requirements, and reflects program adjustments. There were no program changes under this burden revision. The resulting calculations are highlighted in bold and are also reflected in the attached spreadsheet.

Please note: Burden hours associated with the Annual Financial and Program Data Report, FNS-683A is not calculated, and will no longer be calculated, under the SFMNP burden, OMB #0584-0541, expiration date of 10/31/2019. Burden hours associated with the Annual Financial and Program Data Report, FNS-683A are now being calculated under the burden associated with the Food Programs Reporting System (FPRS), OMB #0584-0594, (currently under revision, expiration date of 10/31/2019).

All regulatory citations refer to 7 Code of Federal Regulations (CFR) Part 249 of the federal SFMNP regulations.

REPORTING BURDEN ESTIMATES

AFFECTED PUBLIC: STATE AND LOCAL AGENCIES

(INCLUDING U.S. TERRITORIES AND INDIAN TRIBAL ORGANIZATIONS)

1. Section 249.3(d) requires each nonprofit entity or local government agency interested in being authorized as a local agency in the SFMNP to submit an application to the State agency (SA). Currently, there are 53 SFMNP State agencies. The Food and Nutrition Service (FNS) estimates an average of 20 local agencies per participating SFMNP State agency; therefore, FNS estimates that there are 1,060 SFMNP local agencies. The average local agency agreement is for two years and FNS projects that each year, half of all local agencies (530) will submit applications. FNS further estimates that each application will require two burden hours to complete.

FNS estimates 1,060 total annual burden hours for completing local agency applications. 53 State agencies x 20 local agencies= 1,060 local agencies x .5 local agency agreements per year = 530 total annual responses x 2 burden hours per application= 1060 total annual burden hours. This represents a slight increase of 20 burden hours due to the number of State agencies increasing from 52 to 53. This increase is due to a program adjustment.

2. Section 249.4 requires each State Agency to annually submit a State Plan of Operations to FNS describing how the SA intends to implement, operate, and administer the SFMNP. There are 53 SFMNP State agencies, and FNS estimates that each State agency will spend 40 burden hours developing the State Plan of Operations.

FNS estimates 2,120 total annual burden hours for each State agency to develop and submit a State Plan of Operations to FNS. 53 State agencies x 40 burden hours= 2,120 total annual burden hours. This represents an increase of 40 burden hours due to the increase in the number of SFMNP State agencies from 52 to 53. This increase is due to a program adjustment.

3. Section 249.6(a)(3) requires that pertinent certification data (i.e. categorical eligibility, income eligibility, etc.) be collected from potential SFMNP recipients and recorded on a form provided by the State agency. Likewise, SAs are required to notify potential recipients of their rights and responsibilities; including, notification of disqualification. There are approximately 840,000 SFMNP recipients who received benefits in Fiscal Year (FY) 2018, the last FY for which data is available. SFMNP recipients are generally certified once per year, at the beginning of the Program period. FNS estimates that the collection of certification data will require 15 minutes (0.25 burden hours) of the State agency’s time, per recipient.

FNS estimates 210,000 total annual burden hours for the certification of SFMNP recipients. 840,000 recipients/53 State agencies= 15,849 recipient certifications per SA x 53 State agencies= 840,000 total annual responses x .25 hours per response= 210,000 total annual burden hours. This represents an increase of 10,000 burden hours due to an increase in the number of recipients from 800,000 to 840,000. This increase is due to a program adjustment.

4. Section 249.10(b) sets forth State agency responsibilities regarding the authorization of farmers, farmers’ markets, roadside stands and CSA programs in the SFMNP. Each farmer, farmers’ market, roadside stand and CSA program interested in being authorized in the SFMNP is required to submit an application to the State agency. Currently, there are 25,848 authorized farmers, farmers’ markets, roadside stands, and CSA programs in the SFMNP (based on FY 2018 data, the last FY for which data is available). The average farmer, farmers’ market, roadside stand, and CSA program agreement is for two years. FNS projects that each year half of all farmers, farmers’ markets, roadside stands, and CSA programs (12,924) will submit applications. FNS estimates that it takes 15 minutes (0.25 burden hours) for the State agency to review each farmer, farmers’ market, roadside stand and CSA program application.

FNS estimates 3,231 total annual burden hours for State agencies to review each farmer, farmers’ market, roadside stand, and CSA program application. 12,924 total annual responses x .25 burden hours= 3,231 total annual burden hours. This represents a decrease in 391 burden hours due to a miscalculation in the number of farmers, farmers’ markets, roadside stands, and CSA programs under the last burden revision.

5. Section 249.10(e) requires each SFMNP State agency to monitor at least 10 percent of authorized farmers, farmers’ markets, roadside stands, and CSA programs, annually. Each SFMNP State agency must document findings and observations for all on-site monitoring visits. Currently, there are 25,848 authorized farmers, farmers’ markets, roadside stands, and CSA programs in the SFMNP (based on FY 2018 data, the last FY for which data is available). FNS estimates that it takes 1.5 hours to monitor each authorized farmers, farmers’ market, roadside stand, and CSA program.

FNS estimates 3,877 total annual burden hours for monitoring of at least 10 percent of authorized farmers, farmers’ markets, roadside stands, and CSA programs. 53 State agencies x ((25,848 authorized farmers, farmers’ markets, roadside stands, and CSA programs outlets/53 State agencies) x .10 percent of authorized farmers, farmers’ markets, roadside stands, and CSA programs)= 2,585 total annual responses, rounded up. 2,585 total annual responses x 1.5 hours per response= 3,877 total annual burden hours, rounded down. This represents an increase of 3,334 burden hours, rounded down, due to a miscalculation in the number of farmers, farmers’ markets, roadside stands, and CSA programs under the last burden revision.

6. Section 249.10(f) requires that the State agency control and provide accountability for the receipt and issuance of SFMNP coupons, including the secure transportation and storage of unissued coupons. In addition, the State agency is responsible for designing and implementing a coupon management system that will detect errors in the accountability and issuance of SFMNP coupons. FNS estimates it takes 5 burden hours per year for each State agency to conduct oversight of their coupon management system.

FNS estimates 265 total annual burden hours for the oversight of the State agencies coupon management system. 53 State agencies x 5 burden hours= 265 total annual burden hours. This represents an increase of 5 burden hours due to the increase in the number of SFMNP State agencies from 52 to 53. This increase is due to a program adjustment.

7. Section 249.10(h) requires each State agency to identify the disposition of all SFMNP coupons once a year as validly redeemed, lost or stolen, expired, or not matching issuance records. In addition, the State agency is responsible for designing and implementing a system to disclose the status of all SFMNP coupons, and must describe this system in the State Plan of Operations. FNS estimates that it takes 3 burden hours per year for each State agency to audit and monitor the disposition of all SFMNP coupons.

FNS estimates 159 total annual burden hours to audit and monitor the disposition of all SFMNP coupons. 53 State agencies x 3 burden hours= 159 total annual burden hours. This represents an increase of 3 burden hours from the last burden revision due to an increase in the number of State agencies from 52 to 53. This increase is due to a program adjustment.

8. Section 249.11 requires each State agency to maintain a financial management system; including, an accounting for all property and other assets and all SFMNP funds received and expended each fiscal year. FNS estimates that it takes 10 burden hours per State agency to carry out this requirement.

FNS estimates 530 total annual burden hours to maintain and report on State agency financial management. 53 State agencies x 10 burden hours= 530 total annual burden hours. This represents an increase of 10 burden hours from the last burden revision due to an increase in the number of State agencies from 52 to 53. This increase is due to a program adjustment.

9. Section 249.12 A State agency must obtain prior approval in accordance with 2 CFR part 200, subpart E, and USDA implementing regulations 2 CFR parts 400 and 415 before charging to the SFMNP any capital expenditures and other cost items in the administration and operation of the SFMNP. FNS estimates that no more than 5 State agencies will submit requests to FNS for prior approval for capital expenditures and cost items in the administration and operation of the SFMNP each year. FNS further estimates that each request will require 40 hours for the State agency to develop and submit.

FNS estimates 200 total annual burden hours for State agencies to develop and submit a request for prior approval for capital expenditures and other cost items in the administration and operation of the SFMNP. 5 State agency requests x 40 burden hours= 200 total annual burden hours. This represents a decreases of 600 burden hours from the last burden revision due to a recalculation of the estimated time it would take for a State agency to complete a request for prior approval for capital expenditures, and other cost items in the administration and operation of the SFMNP.

10. Section 249.17(b)(2) requires each State agency to develop a corrective action plan for deficiencies found in a management evaluation, including timeframes to address the deficiencies and preventative action. Out of the 53 participating SFMNP State agencies, it is estimated that 8 State agencies (roughly 15% of State agencies) will be required to submit corrective action plans for deficiencies, annually. FNS estimates that each corrective action plan will take approximately 10 hours to develop.

FNS estimates 80 total annual burden hours for the development of State agency corrective action plans. 8 State agencies x 10 burden hours= 80 total annual burden hours. This represents a slight increase in burden hours from the last burden revision based on the estimated number of management evaluations scheduled each year.

11. Section 249.18(b) requires the State agency to develop and submit a corrective action plan to FNS addressing the findings of USDA’s Office of the Inspector General (OIG), State or local agency audits. It is estimated that of the 53 participating State agencies, one will have audit findings requiring a corrective action plan. FNS estimates that each corrective action plan will require 15 hours to develop and submit, annually.

FNS estimates 15 total annual burden hours in the development of a corrective action plan. 1 State agency x 15 burden hours= 15 total annual burden hours. There is no change in the number of burden hours associated with this revision based on a reasonable estimate of the number of OIG audits likely to occur.

12. Section 249.23(b) sets forth the financial and recipient reporting requirements for SFMNP State agencies. The information to be provided through these yearly reports includes, but is not limited to: (1) the number and type of recipients served with Federal SFMNP funds; (2) the value of coupons issued and/or eligible foods ordered under CSA programs; (3) the value of coupons redeemed and/or eligible foods provided to recipients under CSA programs; and (4) the number of authorized outlets by type (i.e. farmers, farmers’ markets, roadside stands, and CSA programs). Reporting and recordkeeping is conducted through the Annual Financial and Program Data Report, FNS-683A. FNS estimates that it will take each State agency approximately 40 hours to assemble the necessary information for these reports.

Burden hours associated with the Annual Financial and Program Data Report, FNS-683A is not calculated, and will no longer be calculated, under the SFMNP burden, OMB #0584-0541. Burden hours associated with the Annual Financial and Program Data Report, FNS-683A are now being calculated under the burden associated with the Food Programs Reporting System (FPRS), OMB #0584-0594, currently under revision, expiration date 10/31/2019.

AFFECTED PUBLIC: INDIVIDUALS AND HOUSEHOLDS

(APPLICANTS FOR PROGRAM BENEFITS)

1. Section 249.6 requires that pertinent certification data (i.e. categorical eligibility, income eligibility, etc.) be collected from potential SFMNP recipients and recorded on a form provided by the State agency. There are approximately 840,000 SFMNP recipients who received benefits in Fiscal Year (FY) 2018, the last FY for which data is available. SFMNP recipients are generally certified once per year, at the beginning of the Program period. FNS estimates that potential participants will spend approximately 1 minute (0.167 burden hours) completing the application for benefits.

FNS estimates 14,028 total annual burden hours for SFMNP recipients to complete their application for benefits. 840,000 recipients x 1 application completed per year x .0167 hours= 14,028 total annual burden hours. This represents an increase of 668 burden hours from the last burden revision due to an increase in the number of program recipients from approximately 800,000 to 840,000. This increase is due to a program adjustment.

AFFECTED PUBLIC: AUTHORIZED FARMERS, FARMERS’ MARKETS, ROADSIDE STANDS, AND COMMUNITY SUPPORTED AGRICULTURE (CSA) PROGRAMS

1. Section 249.10(b) Each farmer, farmers’ market, roadside stand and CSA program interested in being authorized in the SFMNP is required to submit an application to the State agency. Currently, there are 25,848 authorized farmers, farmers’ markets, roadside stands, and CSA programs in the SFMNP (based on FY 2018 data, the last FY for which data is available). The average farmer, farmers’ market, roadside stand, and CSA program agreement is for two years. FNS projects that each year half of all farmers, farmers’ markets, roadside stands, and CSA programs (12,924) will submit applications. FNS estimates that it will take farmers, farmers’ markets, roadside stands, and CSA programs five minutes (.08 burden hours) to complete their application.

FNS estimates 1,034 total annual burden hours for farmers, farmers’ markets, roadside stands, and CSA programs to complete their application. 12,924 farmers, farmers’ markets, roadside stands, and CSA programs x .08 burden hours= 1,034 total annual burden hours. This represents an increase in 744 burden hours due to a miscalculation in the number of farmers, farmers’ markets, roadside stands, and CSA programs under the last burden revision. This increase is due to a program adjustment.

RECORDKEEPING REQUIREMENTS

AFFECTED PUBLIC: STATE AND LOCAL AGENCIES

(INCLUDING U.S. TERRITORIES AND INDIAN TRIBAL ORGANIZATIONS)

1. Section 249.9 requires each State agency to integrate nutrition education into SFMNP operations, and may satisfy nutrition education requirements through coordination with other agencies within the State. Each State agency is required to maintain records on the delivery of nutrition education to, and participation of SFMNP recipients. FNS estimates that it will take State agencies 15 minutes (.25 burden hours) to document nutrition education activities per SFMNP recipient, per year.

FNS estimates 210,000 total annual burden hours for recordkeeping pertaining to nutrition education. 840,000 program recipients x .25 burden hours= 210,000 total annual burden hours the documentation of nutrition education for 840,000 program recipients by 53 State agencies. This represents a slight increase of 10,000 burden hours from the last burden revision due to an increase in the number of program recipients from 800,000 to 840,000. This increase is due to a program adjustment.

2. Section 249.10(b) each State agency shall ensure that all participating farmers, farmers' markets, roadside stands, and CSA programs enter into written agreements with the State agency for authorization and participation in the SFMNP. Each State agency is required to maintain records of farmer, farmers’ market, roadside stand, and/or CSA program agreements. FNS estimates that it will take each State agency two burden hours to maintain these records, annually.

FNS estimates 106 total annual burden hours for recordkeeping associated with maintaining farmer, farmers’ market, roadside stand, and CSA program agreements. 53 State agencies x 2 burden hours= 106 total annual burden hours. This represents a slight increase in 2 burden hours due to the increase in the number of SFMNP State agencies. This increase is due to a program adjustment.

3. Section 249.10(e) requires each SFMNP State agency to monitor at least 10 percent of authorized farmers, farmers’ markets, roadside stands, and CSA programs, annually. Each State agency is required to maintain records of findings and observations for all on-site monitoring visits of farmers, farmers’ market, roadside stands, and CSA programs. FNS estimates that it will take each State agency two burden hours to maintain these records, annually.

FNS estimates 106 total annual burden hours for recordkeeping associated with maintaining records of findings and observations for all on-site monitoring visits of farmers, farmers’ market, roadside stands, and CSA programs. 53 State agencies x 2 burden hours= 106 total annual burden hours. This represents a slight increase in 2 burden hours due to the increase in the number of SFMNP State agencies. This increase is due to a program adjustment.

4. Section 249.11(c) requires each State agency to maintain a financial management system; including, an accounting for all property and other assets, and all SFMNP funds received and expended each fiscal year. Each State agency is required to maintain records regarding the financial management of SFMNP program administration. FNS estimates that it will take each State agency two burden hours to maintain these records, annually.

FNS estimates 106 total annual burden hours for recordkeeping associated with the financial management of SFMNP program administration. 53 State agencies x 2 burden hours= 106 total annual burden hours. This represents a slight increase in 2 burden hours due to the increase in the number of SFMNP State agencies. This increase is due to a program adjustment.

5. Section 249.16(a) requires the State agency to provide a hearing procedure whereby program applicants/recipients, local agencies, and farmers, farmers’ markets, roadside stands, and CSA programs adversely affected by certain actions of the State agency may appeal such actions. Each State agency is required to maintain records of all hearings that are requested and conducted, including their outcomes. FNS estimates that it will take each State agency one burden hour to maintain these records, annually.

FNS estimates 53 total annual burden hours for recordkeeping associated with fair hearings. 53 State agencies x 1 burden hour= 53 total annual burden hours. This represents a slight increase in 1 burden hour due to the increase in the number of SFMNP State agencies. This increase is due to a program adjustment.

6. Section 249.23(a) requires each State agency to maintain full and complete records concerning all SFMNP operations. Such records must include, but are not limited to: information pertaining to certification, financial operations, SFMNP coupon issuance and redemption, agreements, invoices, delivery receipts, equipment purchases and inventory, nutrition education, and civil rights procedures. FNS estimates that it will take each State agency 40 burden hours to maintain these records, annually.

FNS estimates 2,120 total annual burden hours for recordkeeping associated with maintaining full and complete records of SFMNP operations. 53 State agencies x 40 burden hour= 2,120 total annual burden hours. This represents an increase in 40 burden hours due to the increase in the number of SFMNP State agencies. This increase is due to a program adjustment.