Emergency Information Collection for Supply Chain Disruptions Oct 15 2021

ace

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

October 15, 2021
MEMORANDUM
TO:

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

THRU:

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

FROM:

Cindy Long
CYNTHIA
Administrator
LONG
Food and Nutrition Service

Digitally signed by
CYNTHIA LONG
Date: 2021.10.18 15:48:14
-04'00'

SUBJECT: Emergency Approval of New Survey on
School Food Supply Chain Disruptions
The Food and Nutrition Service (FNS) of the United States Department of
Agriculture (USDA) is requesting emergency approval under the Paperwork
Reduction Act (PRA) to conduct a survey of School Food Authorities to collect
information on school food supply chain challenges. The information will be used to
assess the impacts of COVID-19-related supply chain disruptions on the Child
Nutrition (CN) Programs. Attachment 1 is the proposed survey.
Throughout the pandemic, school nutrition professionals have met extraordinary
challenges to ensure every child can get the food they need to learn, grow, and thrive.
But circumstances in local communities remain unpredictable, and supply chains for
food and labor have been stressed and at times disrupted. USDA is committed to
working together with state agencies, school food authorities (SFAs), the food
industry, and other stakeholders to communicate school food supply chain challenges
and to identify solutions.

This survey will assist USDA’s Food and Nutrition Service (FNS) and its partners to
enhance the toolbox for school nutrition professionals working hard to make sure
students have reliable access to healthy meals. Information gained through survey
responses will build on the insight that USDA needs to support school districts during
this difficult time with tailored resources, tools and flexibility needed to serve students
healthy and nutritious meals. FNS is asking all SFAs that participate in the Child
Nutrition Programs to complete this survey. The supporting statement and burden
estimates are included in Attachment 2.
Background on Responsibilities and Authority
FNS is responsible for the administration of the CN programs—including the National
School Lunch Program (NSLP), the School Breakfast Program (SBP), NSLP Seamless
Summer Option (SSO), 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, SAs administer them through agreements with SFAs and other local
entities that implement the programs at the local level.
This collection is authorized under Section 28(a)(1) of the Richard B. Russell National
School Lunch Act (NSLA), which authorizes the USDA Secretary to conduct annual
national performance assessments of the school meal programs and requires States and
local entities participating in the programs to cooperate with program research and
evaluations (XX). Furthermore, Section 305 of the 2010 Healthy Hunger-Free Kids
Act (HHFKA) amended Section 28 of the Richard B. Russell National School Lunch
Act (NSLA) by adding the following:
‘‘(c) COOPERATION WITH PROGRAM RESEARCH AND
EVALUATION.—States, State educational agencies, local educational
agencies, schools, institutions, facilities, and contractors participating in
programs authorized under this Act and the Child Nutrition Act of 1966 (42
U.S.C. 1771 et seq.) shall cooperate with officials and contractors acting on
behalf of the Secretary, in the conduct of evaluations and studies under those
Acts.’’
Rationale for Emergency Collection
OMB has established regulations for the emergency processing of information
collection requests (ICRs) at 5 CFR 1320.13. OMB can authorize Emergency
Clearance for an information collection, for up to 6 months.
FNS can attest that this collection of information is:






Needed sooner than OMB clearance can be granted under normal procedures;
FNS needs the survey results by November 30th in order to be able to act on the
information in a timely fashion given the dynamic situation of supply chain
disruptions.
Essential to the mission of the agency to continue to provide emergency food
assistance and quantify the scope of the supply chain disruption challenges;
and
Essential to obtain the data in a timely manner. The use of normal clearance
procedures would disrupt the collection. Complying with the normal clearance
procedures would delay the agency’s ability to provide emergency nutrition
assistance to families and children who continue to be impacted by COVID-19.
This survey will assist USDA’s Food and Nutrition Service and its partners to
enhance the toolbox for school nutrition professionals working hard to make
sure students have reliable access to healthy meals. Information gained through
survey responses will quantify and describe the current challenges school
districts are facing to facilitate USDA’s support for the school districts in
successfully serving students healthy and nutritious school meals. Waiting
three or more months to obtain normal clearance would negatively impact the
timely and targeted delivery of this support.

FNS appreciates your consideration of this request.

Digitally signed by MAUREEN
LYDON
Date: 2021.10.15 14:46:11 -04'00'

Maureen Lydon, Chief
PRAO, Food and Nutrition Service

Cindy Long, Administrator
Food and Nutrition Service

Attachment 1 - Survey
Attachment 2 - Supporting Statement A and Burden
Attachment 3 - Form 83-I
Appendices