Supporting Statement for OMB Clearance for the School Meals Operations Study: State Agency COVID-19 Child Nutrition Waivers Evaluation
Part A
Revision to OMB # 0584-0607, Child Nutrition Program Operations Study II (CN-OPS-II)
Social Science Research Analyst
Office of Policy Support
Food and Nutrition Service
United States Department of Agriculture
1320 Braddock Place
Alexandria, Virginia 22314
Phone: 703-305-2105
Email: [email protected]
TABLE OF CONTENTS
Introduction 1
A1. Circumstances Making the Collection of Information Necessary 2
A2. Purpose and Use of the Information 4
A3. Use of Information Technology and Burden Reduction 9
A4. Efforts to Identify Duplication and Use of Similar Information 10
A5. Impacts Small Businesses or Other Small Entities 11
A6. Consequences of Collecting the Information Less Frequently 11
A7. Special Circumstances Relating to the Guideline of 1320.5(D)(2) 12
A8. Comments in Response to the Federal Register Notice and Efforts to Consult with Persons Outside the Agency 12
A9. Explanation of Any Payments or Gifts to Respondents 15
A10. Assurances of Confidentiality Provided to Respondents 16
A11. Justification for Sensitive Questions 17
A12. Estimates of Hour Burden Including Annualized Hourly Costs 17
A13. Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers 20
A14. Annualized Cost to the Federal Government 20
A15. Explanation for Program Changes or Adjustments 21
A16. Plans for Tabulations and Publication and Project Time Schedule 22
A17. Display of Expiration Date for OMB Approval 22
A18. Exception to the Certification Statement Identified in Item 19.0 of Form OMB 83-1 23
TABLES
A.1. Overview of Data Collection Activities……………………………………………………………………..…6
APPENDICES
A Research Questions
B Section 2202 of the Families First Coronavirus Response Act
C.1 State Child Nutrition Director Survey 2020-2021
C.2 Screenshots of Programmed State CN Director Survey 2020-2021
D.1 FNS-10 Administrative Data Request
D.2 FNS-418 Administrative Data Request
D.3 FNS-44 Administrative Data Request
E.1 Study Support Email from FNS Regional Office to State Agencies
E.2 State Agency Child Nutrition Director Advance Email
E.3 Study Brochure
E.4 State Agency Invitation Email
E.6 Reminder Call Script
E.7 State Agency Last Chance Post Card
F.1 Public Comment 1
F.2 Public Comment 2
F.3 Public Comment 3
F.4 Public Comment 4
F.5 FNS Response to Public Comment 1
F.6 FNS Response to Public Comment 2
F.7 FNS Response to Public Comment 3
G.1 National Agricultural Statistics Service Comments
G.2 FNS Response to National Agricultural Statistics Service Comments
H Confidentiality Pledge
This information collection request is for a revision of the approved collection for the Child Nutrition Program Operations Study II (OMB Control No. 0584-0607, expiration date: 08/31/2022), which collects data annually from a nationally representative sample of School Food Authority (SFA) directors and a census of State Child Nutrition (CN) directors using online surveys. This study is modular in nature, whereby some topics are included each year while others can be added or removed as FNS priorities change. The previous OMB approval covered data collection for school year (SY) 2018-19. Because the data collection topics and research questions change each year and FNS is seeking to reduce burden on local entities by collecting additional administrative data from State Agencies (SAs), FNS again sought public comment for SY 2020-2021 (as described in Part A, Question 8). Thus, this request is to update and prioritize data collection topics for the SY 2020-2021 data collection and to include an administrative data collection component at the State level that will enable FNS to obtain the necessary information while reducing the burden of the survey component on both States and SFAs.
While FNS had originally intended to conduct online surveys with both States and SFAs on a variety of policy-relevant topics in SY 2020-2021 as we have done in previous years with this study series, in the spring of 2020 FNS’s information needs and data collection plan shifted due to the COVID-19 pandemic and the ensuing changes to school foodservice operations. As a result, and in response to public comments (summarized in Part A, Question 8 and provided in full in Appendices F.1-F.4), for the SY 2020-2021 data collection we are removing the SFA survey and will focus the SA data collection components (online survey and administrative data collection) on capturing the congressionally mandated data on the COVID-19 CN waivers, including use of the waivers and how waivers improved services to children from March to September 2020. FNS is also changing the name of the study series from Child Nutrition Program Operations Study II (CN-OPS II) to School Meals Operations (SMO) Study to better reflect the specific programs on which the study ordinarily collects data. Similarly to the CN-OPS II series, which collected data annually from SY 2015-2016 to SY 2018-2019, the SMO Study anticipates annual data collections from SY 2020-2021 through SY 2023-2024. Because the survey topics change each year as FNS policy and program needs change, FNS will seek OMB approval for future data collections in the SMO study series separately; the current information collection request only covers data collection for SY 2020-2021.
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 U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS) is responsible for the administration of the CN programs—including the National School Lunch Program (NSLP), the School Breakfast Program (SBP), the Summer Food Service Program (SFSP), the Child and Adult Care Food Program (CACFP), and others—at the federal level. To inform current and future policy decisions and effectively oversee these programs, FNS requires information on how these programs are operating. Although FNS oversees these programs, State Agencies (SAs) administer them through agreements with school food authorities (SFAs) and other local entities that implement the programs at the local level.
This information collection request is for a revision to the currently approved Child Nutrition Program Operations Study II (CN-OPS II, OMB Number 0584-0607, expiration date 08/31/2022). This collection, the School Meals Operations (SMO) Study, is necessary to provide up-to-date information about CN program operations. The annual data collected from this study allows FNS to describe and assess program operations, provide input for legislation and regulations on the CN programs, and develop pertinent technical assistance (TA) and training for program staff at the State and local levels. This information is necessary for FNS to understand how recent and proposed legislation, regulations, policies, and initiatives change CN program operations.
For the SY 2020-2021 data collection, FNS has repurposed the SMO Study to facilitate the timely collection of data to meet the statutory reporting requirements for 21 COVID-19-related nationwide waivers (listed in Appendix A) approved by FNS pursuant to section 2202 of the Families First Coronavirus Response Act (FFCRA) (Pub. L. 116-127) (Appendix B). For this data collection year, the study will help SAs to fulfill their statutory reporting requirements by focusing on the use of COVID-19-related nationwide waivers and the administration of CN Programs that operated under nationwide waiver authority during the period from March 2020 through September 2020. The waivers affected requirements for the NSLP, SBP, NSLP Seamless Summer Option (SSO), SFSP, and CACFP.
While working on this information collection request, FNS determined that the following OMB control numbers 0584-0280, 7 CFR Part 225 Summer Food Service Program, expiration date 12/31/2022; 0584-0012, School Breakfast Program, expiration date 4/30/2022; and 0584-0006 7 CFR Part 210 National School Lunch Program, expiration date 7/31/2023 do not contain a basis for the approval of the COVID-19 Child Nutrition waiver requests as the agency originally thought when OMB# 0584-0654 FNS Information Collection Needs due to COVID-19 was drafted and submitted to OMB for review. To resolve this issue, FNS plans to submit a “non-substantive” change request to incorporate these waiver requests into OMB control number 0584-0654, and thereby obtain OMB approval for them.
The study’s research questions (Appendix A) correspond to the statutory SA reporting requirements for the COVID-19 CN waivers. Section 2202(d) of the FFCRA requires any SA that elects to use a CN nationwide waiver to submit a report, not later than 1 year after electing to use the waiver that, at a minimum, summarizes the use of such waiver and describes how the waiver resulted in improved services to Program participants. The modified SMO Study will work as a streamlined data collection aimed to satisfy the congressionally mandated reporting requirements from State agencies on the 21 COVID-19 nationwide waivers. These requirements include:
1. a summary of the use of each waiver by the SA and local program operators, and
2. a description of whether each waiver resulted in improved services to children.
Three of the waivers have additional reporting requirements. SAs must report:
for the Area Eligibility SFSP/SSO waiver, how new meal sites were selected to serve children who were previously eligible or newly eligible for program benefits due to the economic impacts of COVID-19;
for the Nationwide Parent/Guardian Pick-up waiver, plans taken to ensure that meals were distributed only to parents or guardians of eligible children and that duplicate meals were not distributed to any child; and
for the Nationwide Meal Pattern waiver, information on when and where this waiver was in effect and for what food components.
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.
Previous information collected through the CN-OPS II series has been used to describe and assess program operations, provide input for legislation and regulations on the CN programs, and develop pertinent technical assistance and training for program staff at the State and SFA levels. The information collected through the current collection (the SMO Study) will be used to fulfill congressionally mandated data requirements on the use and impact of the COVID-19 CN waivers approved by FNS under the FFCRA. The data will allow FNS to assess meal service levels to determine coverage within and across States, look for patterns and trends across site types, and assess how the waivers improved services to children since, in the absence of these waivers, meal service may not have been possible. Additionally, the information will inform FNS’s planning, policy, and guidance related to state and local meal service operations during future emergency situations and unanticipated school closures. This collection will also satisfy States’ congressionally-mandated reporting requirements for the waivers listed in Appendix A.
The information will be collected from the 67 SAs that oversee the National School Lunch and School Breakfast Programs, the Summer Food Service Program, and the Child and Adult Care Food Program in the 50 States, District of Columbia, Guam, Puerto Rico, and U.S. Virgin Islands.1 Participation in this collection is mandatory, as responses will be used to satisfy States’ statutory reporting requirements for 21 nationwide CN COVID-19 waivers under the FFCRA.
This study series has historically only collected data via surveys of States and SFAs. However, in order to reduce burden on SFAs, FNS added a state-level administrative data collection component to SMO to collect administrative data at the state level that could be used to address some of the questions normally asked in the SFA survey. Originally, the administrative data collection component was intended to collect only disaggregated NSLP/SBP meal claims data via the FNS-10 Administrative Data Request (Appendix D.1). For this reason, only the FNS-10 Administrative Data Request instrument was pretested, as described in Part B, Question 4. However, because FNS’s information needs and data collection plan for this study shifted due to the COVID-19 pandemic and the ensuing changes to school foodservice operations, FNS also added the FNS-418 and FNS-44 Administrative Data Requests (Appendices D.2 and D.3) to collect disaggregated meal claims data on SFSP and CACFP at the state level as well, as these programs were used during the COVID-19 school closures to provide meals to children that would normally have received meals through NSLP/SBP. These additions also required FNS to increase the SA sample size from 55 to 67 to include directors of State agencies that oversee SFSP and CACFP as well as NSLP/SBP. Further, in response to the pandemic, FNS cancelled the SFA survey. With these changes, which are further described in Part A Question 15, there are approximately 2,181 fewer respondents and 2,900 fewer responses in the SY 2020-2021 SMO data collection than were previously approved in the study and the burden has significantly decreased as all instruments and burden associated with the SFA survey have been removed.
The SMO Study will be comprised of two parts: 1) a web-based State Child Nutrition Director Survey (Appendix C.1/C.2) and 2) an administrative data collection (Appendices D.1 – D.3). The survey portion of the study will consist of questions and response options relevant to the implementation of the nationwide waivers, while the administrative data collection portion of the study will request disaggregated administrative data from SAs that local program operators regularly report to SAs for forms FNS-10 Report of School Program Operations, FNS-418 Report of the Summer Food Service Program for Children, and FNS-44 Report of the Child and Adult Care Food Program (jointly approved under OMB control number 0584-0594, Food Programs Reporting System (FPRS), expiration date 07/31/2023), but that are not otherwise reported to FNS in disaggregated form.
Table A‑1. Overview of Data Collection Activities
Instrument |
Respondents |
Method of Collection |
Length |
Purpose |
Frequency |
State Child Nutrition Director Survey (Appendix C.1/C.2) |
67 State agency directors |
Web survey |
3 hours |
To describe State-level policies, practices, and needs related to CN programs. |
Once |
FNS-10
Administrative Data Request |
55 State agency directors that oversee NSLP/SBP |
Secure electronic transfer |
6 hours |
To provide meal claims data at the school or SFA level for the NSLP and SBP |
Once |
FNS-418 Administrative Data Request |
53 State agency directors that oversee SFSP |
Secure electronic transfer |
4 hours |
To provide meal claims data at the site or sponsor level for the SFSP |
Once |
FNS-44 Administrative Data Request |
55 State agency directors that oversee CACFP |
Secure electronic transfer |
6 hours |
To provide meal claims data at the institution or outlet level for the CACFP |
Once |
To encourage SAs to cooperate with information requests, all FNS Regional Offices will send the Study Support Email from FNS Regional Office to State Agencies (Appendix E.1) to alert the State CN directors in their region about their important role in the SMO study. All State CN directors will then be sent the State Agency Child Nutrition Director Advance Email (Appendix E.2) and Brochure (Appendix E.3) that explain the purpose of the study and describe study activities.
To request the administrative data, the study team will provide State CN directors with the list of data elements that are being requested from the FNS-10, FNS-418, and FNS-44 Administrative Data Request forms Appendices D.1-D.3 and schedule and conduct phone calls using the Telephone Meeting Agenda (Appendix D.4). Using the FNS-10 Administrative Data Request (Appendix D.1), the study team will request disaggregated FNS-10 data from the most recent full fiscal year of final data that will be available at the time of data collection (fiscal year 2020), which includes the months that correspond with the onset of the COVID-19 pandemic. It is expected that SAs will have these data either at the SFA or school level. In addition, using the FNS-418 Administrative Data Request (Appendix D.2) and the FNS-44 Administrative Data Request (Appendix D.3), the study will request disaggregated data from the FNS-418 and FNS-44 for March through September 2020 (the fiscal year 2020 COVID-19 waiver period). Similar to the FNS-10 data, it is expected that SAs will be able to provide these data disaggregated either by sponsor or institution, or by site or outlet. For each administrative data collection instrument, the study team will initially request school-, site-, or outlet-level data from SAs. If a SA does not have these data available, the team will request SFA-, sponsor-, or institution-level data from that SA. While the FNS-10, FNS-418, and FNS-44 Administrative Data Request instruments in Appendices D.1 – D.3 include requests at both levels (school/site/outlet and SFA/sponsor/institution), each SA will only receive the request at the level at which they indicate during the initial telephone meeting they are able to provide the data. The FNS-10, FNS-418, and FNS-44 Administrative Data Request instruments will link each data element to the corresponding item number on the FNS-10, FNS-418, and FNS-44 forms. The FNS-10, FNS-418, and FNS-44 variables assist in addressing the research questions related to use and impact of the COVID-19 CN waivers as they provide data on continuation of meal service during the onset of the COVID-19 pandemic.
In addition, the study team will distribute the web-based State Child Nutrition Director Survey 2020-2021 (Appendix C.1/C.2), which gathers information on the statutory reporting requirements for the COVID-19 CN waivers, including specific information about the use and impact of each waiver that cannot be answered using the administrative data. All State CN directors will be sent the State Agency Invitation Email (Appendix E.4) requesting that they complete the survey and providing instructions on how to access it. Reminder Emails (Appendix E.5) will be sent every 2-3 weeks to remind CN directors to complete their surveys. FNS expects each State to receive 2 reminder emails. If the web survey is not completed within 7 weeks after the initial questionnaire is received, trained interviewers will begin calling CN directors to remind them to complete their survey using the Reminder Call Script (Appendix E.6). Toward the end of the field period, all SA non-respondents will be mailed the State Agency Last Chance Post Card (Appendix E.7). The data collection period for the State Child Nutrition Director Survey 2020-2021 will span 10 weeks. FNS anticipates that all 67 SAs will ultimately respond.
This information request is for a web-based SA survey and FNS-10, FNS-418, and FNS-44 administrative data, which will be collected once during school year (SY) 2020–2021.
As in most FNS data collection efforts, data files and documentation will be prepared for restricted-use files (for researchers who agree to specific restrictions). While no local program operators will be identifiable in the reports or data, some analyses may identify specific States in the final dissemination products, which will be made publicly available in the research section of the USDA FNS website, http://www.fns.usda.gov/ops/research-and-analysis.
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 complying with the E-Government Act of 2002, to promote the use of technology. The team will administer a web survey to SAs using the Confirmit web survey platform. Online surveys enable efficient survey participation: survey effort can be shared among multiple respondents (if the CN Directors choose to ask other staff to complete the survey); and programming limits questions to relevant respondents and will constrain data ranges, keeping responses within a certain length and simplifying data cleaning. Web surveys also allow respondents to complete and submit data securely using unique, password-protected logins. Based on CN-OPS II experience conducting web surveys, the study team expects that all 67 State respondents will complete the survey on-line.
The FNS-10, FNS-418, and FNS-44 Administrative Data Requests will also be collected electronically using a secure transfer site. To encourage high response rates, the study team will inform SAs that they may submit these data in whatever form is most convenient for them given the variety of systems and databases used by States nationwide. Accepting these data electronically also enables the study team to adhere to proper social distancing protocols, as requested by public commenters. The study team estimates that out of a total of 714 responses for this study, 230 (32.21%) will be collected electronically.
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 made every effort to avoid duplication. FNS has reviewed USDA reporting requirements, State administrative agency reporting requirements, and special studies by other government and private agencies. The new approach used by this study, of requesting disaggregated FNS-10, FNS-418, and FNS-44 data, is intended specifically to reduce duplicative reporting. These data are not currently collected on any FNS administrative forms at the SFA, school, sponsor, site, institution, or outlet levels; however, SFAs, sponsors, and institutions regularly report these data to their States. States aggregate these data to report State-level meal claims information to FNS through the FNS-10, FNS-418, and FNS-44. Data of this type have been collected under previous studies but not within the framework or timeline of the current research questions, which address the statutory SA reporting requirements for the FNS-provided COVID-19 CN waivers from March through September 2020.
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.
Information being requested or required has been held to the minimum required for the intended use. No small entities are involved in this data collection effort.
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 revision to the School Meals Operation Study is a mandatory data collection that is required by statute. The CN programs operate in each State and Territory and represent an annual investment of more than $20 billion of Federal funds. To manage these programs effectively and to comply with statutory and regulatory requirements, FNS must collect and analyze data regarding program operations at the State and local levels. FNS also has many one-time information needs including those to address current policy issues associated with these programs that cannot be answered with current program data. For SY 2020-2021, this includes congressionally mandated information on the use and impacts of the COVID-19 CN waivers. This information will be collected only one time and respondents will only be asked to answer once in SY 2020-2021 in order to satisfy their statutory reporting requirements on the waivers listed in Appendix A. Collecting these data less frequently would make it harder for States to meet their statutory reporting requirements under the FFCRA and would not allow FNS to properly monitor program funding, statutory and regulatory compliance, and program trends, thus delaying the discussion, formulation, and implementation of suitable program policies, training, and technical assistance.
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.
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.
A notice of this study was published in the Federal Register on May 13, 2020, Volume 85, Number 93, pages 28602-28605. The public comment period ended on July 13, 2020. Four comments were received requesting that FNS work to minimize the burden on school district personnel, collect information related to program operations and administrative procedures used during the pandemic, examine the impacts of the COVID-19 CN waivers, and ensure that data collection adheres to social distancing protocols. FNS responded, noting that in response to the pandemic and to reduce burden on local program operators, data collection with SFA directors has been cancelled for school year 2020-2021, the instruments have been revised to focus on States’ reporting requirements under the FFCRA and to learn about the impacts of the COVID-19 waivers on school meal operations and children, and all State-level communications and data collection will be done electronically (email and web) or by phone (Reminder Call, Appendix E.6).
Additionally, the School Nutrition Association (SNA) recommended that FNS include a review of administrative procedures implemented at the federal and state levels and convene a commission to evaluate the processes and practices used during the pandemic to develop a national playbook on school meal service operations in emergency situations (Appendix F.1). In our response (Appendix F.5), FNS noted that, while convening a commission and developing a national playbook are outside the scope of the study, the SMO study will survey State CN Agency directors regarding the processes, practices, and flexibilities that State and local program operators used to provide meals to children during the pandemic, as well as the challenges they experienced. Findings will inform future CN Program policies and procedures.
In Appendix F.2, The Academy shared SNA’s suggestion to collect information to inform future emergency preparedness and also noted that the burden estimate included in the Federal Register Notice was too low. In response, following the decisions to cancel the SFA Director Survey for SY 2020-2021 and expand the State CN Agency Director survey and administrative data collection, FNS revised the burden estimate to more accurately reflect the burden on respondents. The burden associated with the state-level instruments was increased and the burden associated with the SFA Director Survey was removed.
Further, The Academy suggested that FNS include questions that capture the impact of school closures on districts as well as information on unpaid meal debt. Similarly, another commenter (Appendix F.4) suggested that the study should collect information on food, nutrition, hunger or food scarcity concerns among students due to the pandemic. The state-level data collection will include questions about the financial and operational impacts of the pandemic on program operators and the methods used to provide meals to children during the school closures. However, because the SMO study was repurposed for SY 2020-2021 to focus on meeting States’ reporting requirements under the FFCRA and learning about the impacts of the COVID-19 CN waivers on school meal operations and children, FNS is not able to include survey questions on unpaid meal debt this school year. FNS will consider including questions on unpaid meals in future data collections. Likewise, because the study will be conducted at the state level, it is beyond the scope of the study to collect information on student-level hunger and nutrition but FNS will consider these topics for future student-level collections.
Public comments are listed in Appendices F.1-F.4 and FNS responses are listed in Appendices F.5-F.7. One of the commenters did not provide contact information so FNS was only able to directly respond to 3 of the 4 public comments received.
In addition to soliciting public comment, FNS consulted with Douglas Kilburg from the National Agricultural Statistics Service (NASS) for expert consultation on the study design and methodology. National Agricultural Statistics Service Comments are listed in Appendix G.1, and the FNS Response to National Agricultural Statistics Service Comments is available in Appendix G.2. In addition to the pretest participants, three school nutrition experts and three individuals from State CN agencies were consulted about the burden, clarity of instructions, and content of this study. With their permission, their names and contact information are listed in Table 8.1. Overall, the reviewers found the data collection materials to be clear. However, they agreed that grouping schools into categories of elementary, middle and high school would be difficult based on how their data systems are set up. In response, the study team revised the administrative data request to ask for grade range rather than school level.
Table 8.1. Expert Consultant List
Name |
Title |
Affiliation |
Phone |
Year of consultation |
Julie Boettger |
School Nutrition Consultant |
Former School Food Authority Director |
219-671-0744 |
2019 |
Mary Jo Tuckwell |
School Nutrition Consultant |
Former School Food Authority Director |
715-559-8466 |
2019 |
Andrea Denning |
School Nutrition Consultant |
Former Child Nutrition Director, Ohio Department of Education |
614-774-5360 |
2020 |
Wendy Barkley |
Assistant Director of Child Nutrition Services |
Washington Office of Superintendent of Public Instruction, Child Nutrition Services |
360-725-0433 |
2020 |
Therese A. Dandeneau |
Education Consultant |
Connecticut State Department of Education, School Nutrition Programs |
860-807-2079 |
2020 |
Kim Loveland |
Child Nutrition Programs Coordinator – NSLP |
Utah State Board of Education |
801-538-7684 |
2020 |
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
Respondents will not receive any incentive payments or gifts.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
The study team complies with the Privacy Act of 1974. No confidential information is associated with this collection of information. FNS published a system of record notice (SORN) titled FNS-8 USDA/FNS Studies and Reports in the Federal Register (volume 56, pp. 19078–19080) on April 25, 1991. This notice discusses the terms of protections that will be provided to respondents.
To be responsive to FNS requirements regarding respondent protections, research staff will sign the Confidentiality Pledge (Appendix H) and participate in annual security awareness training. Access to the data will be limited to members of the study team working directly on the study or with oversight responsibilities, except as otherwise required by law.
The study team will ensure that data are secure by providing a secure transfer site for administrative data from States and storing all study data in a restricted access project directory on a password-protected local area network. SAs will be assured that the information they provide will not be released in a way that compromises privacy or data security. The web survey will be developed in Confirmit, a computer-assisted survey software package developed by the company of the same name, and all data will be stored securely within this system. Through Confirmit, unique user credentials (ID and Password) are created for each survey participant. Each participant will be assigned to a copy of the instrument. Access to the instrument is provided via a URL sent to the participant’s email account. The URL will contain an embedded hashed ID and Password for the participant. When the participant clicks on the URL, they will be automatically directed to the website and authenticated into the instrument. All data captured through Confirmit, will be stored in a study-specific folder that is encrypted with AES 256-bit encryption on the Confirmit server. All access to this data is controlled by Active Directory groups on Mathematica’s Domain Network. Each study team member must have valid credentials to access the Confirmit data stored in restricted access folders. While none are expected, any hard-copy documents submitted will be physically secured in locked storage cabinets and shredded at the close of the study.
While the survey requests contact information to allow the study team to follow up with respondents to clarify responses, personally identifiable information (PII) will not be used to retrieve survey records or data. Neither the survey nor the other data collection materials in this collection require a Privacy Act Statement. Contact information will be stored with the other study data in a restricted access project directory on a password-protected local area network and will not be shared outside the study team.
The FNS Privacy Officer reviewed this ICR for privacy compliance on December 16, 2020 and had no privacy concerns.
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.
This information collection does not include any questions of a sensitive nature.
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.
This is a revision of a currently approved collection. With this submission, there are 67 respondents, 714 responses, and 1,173 burden hours. The average number of responses per respondent is 10.66. Table 12.1, Estimated Annualized Burden (Appendix I), shows the estimates of the respondent burden for the proposed data collection, including the number of respondents, frequency of response, average time to respond, and annual hour burden. These estimates reflect consultations with program officials, outside consultants, affected stakeholders, and prior experience in collecting similar data.
The estimates of annualized costs to State governments are based on the burden estimates and utilize the U.S. Department of Labor, Bureau of Labor Statistics, May 2019 National Occupational and Wage Statistics for Occupational Groups 999200: State Government (https://www.bls.gov/oes/current/naics4_999200.htm). Annualized costs are based on the mean hourly wage. The estimated annualized cost for State government, which includes State CN directors (Occupation Code 11-9030, Education Administrators), is $53,524.38 ($45.63/hr. x 1,173.01 hours). Including an additional $17,663.05 to account for a fully loaded wage rate ($53,524.38 x 0.33), the estimated annualized total cost to respondents associated with this collection is $71,187.43.
Table 12.1 Estimated Annualized Burden
|
|
|
|
|
Responsive |
Non-Responsive |
All |
||||||||||
State / Local Government |
Type of respondents |
Type of survey instruments |
Appendix |
Sample Size |
Number of respondents |
Frequency of response |
Total Annual responses |
Hours per response |
Annual burden (hours) |
Number
of |
Frequency of response |
Total Annual responses |
Hours per response |
Annual burden (hours) |
Total Annual hour burden |
Hourly Wage Rate |
Total annualized cost of respondent burden |
State CN Directors |
Survey and administrative data pre-test and debrief |
N/A |
3 |
3 |
1 |
3 |
4 |
12 |
0 |
0 |
0 |
0 |
0 |
12.00 |
$ 45.63 |
$ 547.56 |
|
Study Support Email from FNS Regional Office to State Agencies |
E.1 |
67 |
67 |
1 |
67 |
0.0501 |
3.3567 |
0 |
0 |
0 |
0 |
0 |
3.36 |
$ 45.63 |
$ 153.17 |
||
State Agency Child Nutrition Director Advance Email |
E.2 |
67 |
67 |
1 |
67 |
0.0501 |
3.3567 |
0 |
0 |
0 |
0 |
0 |
3.36 |
$ 45.63 |
$ 153.17 |
||
Telephone Meeting Agenda |
D.5 |
67 |
67 |
1 |
67 |
1.0 |
67 |
0 |
0 |
0 |
0 |
0 |
67.00 |
$ 45.63 |
$ 3,057.21 |
||
FNS-10 Administrative Data Request |
D.1 |
55 |
55 |
1 |
55 |
6.0 |
330 |
0 |
0 |
0 |
0 |
0 |
330.00 |
$ 45.63 |
$ 15,057.90 |
||
FNS-418 Administrative Data Request |
D.2 |
53 |
53 |
1 |
53 |
4.0 |
212 |
0 |
0 |
0 |
0 |
0 |
212.00 |
$ 45.63 |
$ 9,673.56 |
||
FNS-44 Administrative Data Request |
D.3 |
55 |
55 |
1 |
55 |
6.0 |
330 |
0 |
0 |
0 |
0 |
0 |
330.00 |
$ 45.63 |
$ 15,057.90 |
||
State Child Nutrition Director Survey 2020-2021 |
C.1/C.2 |
67 |
67 |
1 |
67 |
3.0 |
201 |
0 |
0 |
0 |
0 |
0 |
201.00 |
$ 45.63 |
$ 9,171.63 |
||
Study Brochure |
E.3 |
67 |
67 |
1 |
67 |
0.0501 |
3.3567 |
0 |
0 |
0 |
0 |
0 |
3.36 |
$ 45.63 |
$ 153.17 |
||
State Agency Invitation Email |
E.4 |
67 |
67 |
1 |
67 |
0.0501 |
3.3567 |
0 |
0 |
0 |
0 |
0 |
3.36 |
$ 45.63 |
$ 153.17 |
||
Reminder Email |
E.5 |
67 |
67 |
2 |
134 |
0.0501 |
6.7134 |
0 |
0 |
0 |
0 |
0 |
6.71 |
$ 45.63 |
$ 306.33 |
||
Reminder Call Script |
E.6 |
8 |
8 |
1 |
8 |
0.0835 |
0.668 |
0 |
0 |
0 |
0 |
0 |
0.67 |
$ 45.63 |
$ 30.48 |
||
State Agency Last Chance Post Card |
E.7 |
4 |
4 |
1 |
4 |
0.0501 |
0.200 |
0 |
0 |
0 |
0 |
0 |
0.20 |
$ 45.63 |
$ 9.14 |
||
TOTAL |
|
|
67 |
67 |
10.66 |
714 |
1.643 |
1,173.01 |
0 |
0 |
0 |
0.000 |
0.00 |
1,173.01 |
|
$53,524.38 |
|
|
.33% to Account for Fully Loaded Wage Rate |
|
|
|
|
|
|
|
|
|
|
|
$17,663.05 |
||||
|
TOTAL REPORTING BURDEN (Fully Loaded) |
|
|
|
|
|
|
|
|
|
|
|
$71,187.43 |
||||
|
Notes: |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
In total, 67 State agencies are included in this collection. In some states, different agencies oversee different Child Nutrition Programs (NSLP/SBP, SFSP, CACFP) so the number of state agencies in the sample is larger than the number of states and territories included. State level pretest respondents are included in the overall State sample of 67 so are not considered unique respondents for the purpose of calculating total sample size or total number of respondents. |
||||||||||||||||
Provide estimates 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 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 capital/start-up or ongoing operation/maintenance costs associated with this information collection.
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 annualized cost to the Federal government is $805,314.44. The largest cost to the Federal Government is to pay a contractor $1,941,369 over a period of 30 months (September 2019 to March 2022) to conduct the study and deliver data files and reports. This represents an average annualized cost of $776,547.60 including labor and other direct and indirect costs. The annualized cost of this information collection also assumes a total of 400 hours annually of Federal employee time: for a GS-12, Step 6 at $48.26 per hour for a total of $19,304. In addition, we assume 40 hours annually for the Branch Chief, at GS-14, Step 1, at $58.13 per hour for a total annual cost of $2,325.20. Adding in $7,137.64 to account for fully loaded wages ($21,629.20 x 0.33), total Federal employee costs per year are thus estimated at $28,766.84. Federal employee pay rates are based on the General Schedule of the Office of Personnel Management (OPM) for 2020 for the Washington, DC locality.2
Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.
This is a revision of the approved collection for the CN-OPS-II (OMB Control No. 0584-0607, expiration date: 08/31/2022). This information collection is currently approved with 4,073 burden hours and 12,337 responses. FNS has repurposed this study in order to collect the data needed to meet the statutory reporting requirements for the 21 COVID-19-related nationwide waivers set forth in the Families First Coronavirus Response Act (FFCRA) (Pub. L. 116-127). As a result of this revision, FNS estimates that the reporting burden for the SMO SY 2020-2021 collection will decrease by 2,900 hours and 11,623 responses due to program changes resulting from the FFCRA, including removal of the SFA Director survey (and all recruitment instruments associated with it) for school year 2020-2021. Other program changes include an expansion of respondents for the State CN Director survey to include the 12 State directors of SFSP and CACFP in addition to the 55 NSLP and SBP directors to which the survey has been limited in previous collections, as well as the addition of the new administrative data collection component that will be conducted with all 67 State CN Directors.
With these changes, FNS estimates a change in State CN director sample size for the pretest (from 4 to 3) and web survey/administrative data collection (from 55 to 67), and in SFA director sample size for the pretest (from 5 to 0) and web survey (from 2,188 to 0). The hours per response for the pretest and survey completion are estimated to increase by 1 hour each for State CN directors because there are more survey questions that need to be answered in order to satisfy the statutory reporting requirements for the nationwide CN COVID-19 waivers than have historically been included in this collection. The hours per response for the new administrative data collection components (Appendices D.1, D.2, and D.3) are estimated to total 16 hours for SAs. With this revision, FNS estimates that this information collection will have 1,173 burden hours and 714 responses.
For collections of information whose results are planned to be published, outline plans for tabulation and publication.
Study schedule. The planned schedule for the activities in the study is as follows:
Table 16.1 Data collection schedule
Recruitment of States and SFAs |
1 week post OMB approval |
Data Collection (Administrative data collection and Survey) |
March 2021 – June 2021, or 2 weeks post OMB approval |
Prepare data files |
5 months post OMB approval |
Analyze data |
8 months post OMB approval |
Publication |
13 months post OMB approval |
The analysis will address the statutory reporting requirements for the COVID-19 CN waivers during the relevant fiscal year 2020 months (March-September 2020). The primary mode of analysis will be descriptive, including univariate statistics (means, medians, and frequencies) and cross tabulations. Analyses will be at the State, SFA, school, sponsor, site, institution and outlet levels, if administrative data at the school, site, and outlet levels are available from SAs. Survey analyses will be at the SA and waiver levels.
FNS will share study findings through potential products such as a summary of findings, data visualizations, or a study briefing. Final dissemination products will be available to the public on the FNS research website.
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.
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.
1 In some States, FNS Child Nutrition Programs are administered by multiple agencies. Across the States and Territories included in the collection, there are 55 SAs that administer the NSLP and/or SBP, 53 SAs that administer the SFSP and 55 SAs that administer the CACFP. Thus, the number of SAs asked to complete the administrative data requests for the disaggregated FNS-10 (NSLP/SBP), FNS-418 (SFSP) and FNS-44 (CACFP) data will range from 53-55. There are a total of 67 unique SAs included in the collection.
2 Office of Personnel Management. (2020). Salary table 2020-GS. Retrieved from https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2020/DCB_h.pdf
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | PART A OMB SMO |
| Author | MATHEMATICA |
| File Modified | 0000-00-00 |
| File Created | 2021-01-28 |