Attachment I Emergency ICR Justification Memo (P-EBT Schools)

United States
Departm ent of
Agriculture
Food and
Nutrition
Service
1320 Braddock
Alexandria, VA
22314

December 11, 2020
MEMORANDUM
TO:

Jordan Cohen
Desk Officer
Office of Information and Regulatory Affairs, OMB

THRU:

Maureen Lydon
Chief of the Planning and Regulatory Affairs Office (PRAO)
Food and Nutrition Service
Ruth Brown
Office of the Chief Information Officer
United States Department of Agriculture

FROM:

Pamilyn Miller
Administrator

SUBJECT: Emergency Approval of New Information Collection for Pandemic EBT
(Schools)
SNAP seeks emergency OMB approval of activities associated with administering PEBT. While FNS sought a previous emergency information collection (IC) for P-EBT
under the Families First Coronavirus Response Act (FFCRA) (OMB Control Number
0584-0652, expiration October 31, 2020), we did not prepare a full information
collection for these activities; the Agency did not know whether we would receive an
extension for P-EBT, and if so, under what authority we would receive that extension,
in a reasonable time to submit an Information Collection Request (ICR) to OMB prior
to expiration of the emergency collection. Therefore, we are requesting this
emergency IC while we prepare the full ICR for OMB review. The Food and Nutrition
Service (FNS) cannot reasonably comply with the normal clearance procedures under
the Paperwork Reduction Act (PRA) because complying would delay the agency’s
ability to provide emergency nutrition assistance to families and children impacted by
COVID-19. As such, we request expedited approval of this information collection.
Digitally signed by Maureen
Lydon
Date: 2020.12.11 16:00:48 -05'00'

___________________________
Maureen Lydon, Chief of PRAO

PAMILYN MILLER

Digitally signed by PAMILYN
MILLER
Date: 2020.12.18 18:18:12
-05'00'

__________________________
Pamilyn Miller, Administrator

AN EQUAL OPPORTUNITY EMPLOYER