Attachment B Burden Narrative

Attachment A

Estimate of the Information Collection Burden for OMB #0584-0660

Pandemic EBT

This document explains the calculation of the information collection burden for the information collection titled Pandemic Electronic Benefit Transfer. A 60-Day Notice concerning this revision was published in the Federal Register on May 11, 2021 (Volume 86, Number 89, pages 25837-25839). The Emergency Information Collection for Pandemic EBT accounted for the burden associated with administering the schools component of P-EBT. Revisions to the schools component burden estimates as well as the new burden estimates for the child care and summer components will be addressed in this updated estimate. Bolded text refers to revisions to burden hour or new burden hours.

REPORTING REQUIREMENTS

AFFECTED PUBLIC: STATE AGENCIES (SA)

1. Pandemic EBT requires State agencies to submit a plan for USDA approval describing how they will determine eligibility, determine benefit amounts, issue benefits, and provide customer service during school year 2020-2021. State were encouraged to submit a single plan covering both the schools and the child care component.

FNS estimates that 53 State agencies will submit 1 report annually for a total of 53 responses (1 x 53 = 53). The estimated average burden per response is 1 hour for a total estimated burden of 53 hours (53 x 1 = 53). There is no change in burden.

2. Pandemic EBT requires State agencies to submit a plan for USDA approval describing how they will determine eligibility, determine benefit amounts, issue benefits, and provide customer service for the summer months. State were encouraged to submit a single plan covering both the schools and the child care component.

FNS estimates that 53 SAs will submit 1 report annually for a total of 53 responses (53 x 1 = 53). The estimated average burden per response is 1 hour for a total estimated burden of 53 hours (53 x 1 = 53).

3. Pandemic EBT requires State agencies to ensure correct eligibility determinations and determine benefit amounts

FNS estimates that 53 State agencies will report 163,396 responses each once for an estimated total of 8,660,000 responses (53 x 163,396 = 8,660,000). The estimated average burden per response is 1 hour for a total estimated burden of 8,660,000 hours (8,660,000 x 1). This adjustment is due to an anticipated increase in the number of participating children resulting in an increase in burden of 8,245,000 hours.

4. Pandemic EBT requires State agencies to provide monthly reports via the FNS-292B (Disaster Relief) to the FNS Regional Office, regarding the number of eligible children receiving P-EBT benefits, number of households receiving such benefits, and the total value of the benefits

FNS estimates that 53 State agencies will submit 12 responses annually for a total of 636 responses (53x 12 = 636). The estimated average burden per response is 1 hour for a total estimated burden of 636 hours (636 x 1 = 636). There is no change in burden.

5. Pandemic EBT requires State agencies to submit administrative costs plans using the FNS-366A (Program and Budget Summary Statement: Budget Projection) in order to receive reimbursement for administrative costs.

FNS estimates that 53 State agencies will submit 1 response annually for a total of 53 responses (53 x 1 = 53). The estimated average burden per response is 16 hours for a total burden of 848 hours (53 x 16 =848 ). This adjustment is due to an anticipated increase in the amount of time to complete reporting due to the extension of P-EBT to children in child care resulting in an increase in burden of 318 hours.

6. P-EBT requires States agencies to report administrative expenses quarterly to USDA using a P-EBT specific instance of the SF-425 (Federal Financial Report).

FNS estimates that 53 state agencies will submit 4 responses annually for a total of 212 responses (53x 4 = 212). The estimated average burden per response is 1 hour for a total burden of 212 hours (212x 1 = 212).

7. P-EBT requires States agencies to report on summer P-EBT issuances regarding the number of eligible children receiving P-EBT benefits, number of households receiving such benefits, and the total value of the benefits

FNS estimates that 53 state agencies will submit 1 report annually for a total of 53 responses (1 x 53 = 53). The estimated average burden per response is 30 minutes (.5 hours) for a total estimated burden of 27 hours (53 x .5 = 27).

AFFECTED PUBLIC: SCHOOLS

1. Pandemic EBT required schools to provide student eligibility data to state agencies in order for students to receive P-EBT benefits during school year 2020-2021.

FNS estimates that 94,767 schools will submit 4 responses annually for a total of 379,068 responses (94,767x 4 = 379,068). The estimated average burden per response is 20 hours for a total burden of 7,581,360 hours (94,767x 20 =7,581,360).

2. Pandemic EBT required schools to provide student eligibility data to state agencies in order for students to receive P-EBT benefits during summer 2021.

FNS estimates that 94,767 schools will submit 1 response annually for a total of 94,767 responses (94,767x 1 = 94,767). The estimated average burden per response is 1 hour for a total burden of 94,767 hours (94,767x 1 =94,767).

3. Pandemic EBT requires schools to submit their administrative costs to their State agency in order to receive reimbursement.

FNS estimates that 94,767 schools will submit 1 response annually for a total of 94,767 responses (94,767 x 1 = 94,767). The estimated average burden per response is 1 hour for a total burden of 94,767 hours (94,767 x 1 = 94,767).

AFFECTED PUBLIC: HOUSEHOLD LEVEL

1. Pandemic EBT required households who newly became eligible to receive free or reduced price meals to submit an application for free or reduced price meal benefits.

FNS estimates that 581,000 households that will submit 1 record annually for a total of 581,000 responses (581,000x 1 = 581,000). The estimated average burden per response is 10 minutes (0.1666 hours) for a total burden of 96,833 hours (581,000 x 0.1666 = 96,833). This adjustment is due to an anticipated decrease in the number of households submitting applications resulting in a decrease in burden of 179,833 hours.

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