Appendix C Burden Narrative for 0584-0012, 7 CFR Part 220 School Breakfast Program

Appendix C – Burden Narrative for 0584-0012 7 CFR Part 220 School Breakfast Program

Estimate of the Information Collection Burden for 7 CFR Part 220

School Breakfast Program (OMB #0584-0012)

This document explains the calculation of the information collection burden for 7 CFR Part 220 School Breakfast Program, OMB #0584-0012, as submitted for the revision of the existing and approved collection. A notice was published in the Federal Register on February 25, 2022, at Vol. 87, No. 38, page 10767.

REPORTING REQUIREMENTS

AFFECTED PUBLIC: STATE AGENCIES

1. Section 220.5 states that funds to be paid to any State for the School Breakfast Program (SBP) shall be made available by means of Letters of Credit issued by FNS in favor of the State agency (SA). The SA shall: (a) obtain funds needed for reimbursement to School Food Authorities (SFAs) through presentation by designated State officials of a payment Voucher on Letter of Credit in accordance with procedures prescribed by FNS and approved by the U.S. Treasury Department; (b) submit requests for funds only at such times and in such amounts, as will permit prompt payment of claims or authorized advances; and (c) use the funds received from such requests without delay for the purpose for which drawn. The SA submits requests for funds to pay SBP claims.

FNS estimates that 56 SAs will each file 36 reports annually for a total of 2,016 responses (56 X 36 = 2,016). The estimated average number of burden hours per response is 15 minutes (0.25 hours) resulting in estimated total burden hours of 504 (2,016 X .25 = 504). There is no change in burden.

2. Section 220.15(b) states that each SA shall provide FNS and OIG the opportunity to conduct management evaluations and audits, respectively, and make available its records upon request by FNS or OIG.

FNS estimates that 19 SAs will receive a ME and will each file 1 report annually for a total of 19 responses (19 X 1 = 19). The estimated average number of burden hours per response is 3 hours resulting in estimated total burden 57 hours (19 X 3 = 57). There is no change in burden.

AFFECTED PUBLIC: SCHOOL FOOD AUTHORITY LEVEL

1. Section 220.7(a) states that the SFA shall make written application to the SA, or FNSRO where applicable, for any school which desires to operate the SBP, if such school did not participate in the Program in the prior fiscal year.

FNS estimates that 168 SFAs will each file 1 report annually for a total of 168 responses (168 X 1 = 168). The estimated average number of burden hours per response is 15 minutes (0.25 hours) resulting in estimated total burden 42 hours (168 X 0.25 = 42). There is no change in burden.

2. Section 220.11(a) states that, to be entitled to reimbursement, each SFA shall submit to the SA, or FNSRO where applicable, a monthly Claim for Reimbursement.

FNS estimates that 17,117 SFAs will each file 10 reports annually for a total of 171,170 responses (17,117 X 10 = 171,170). The estimated average number of burden hours per response is 1 hour resulting in estimated total burden hours of 171,170 (171,170 X 1 = 171,170). This burden is reduced by 21,230 hours, from 192,400 to 171,170 hours, as an adjustment due to the use of more up to date SBP participation data available for fiscal year 2020.

3. Section 220.11(b) states that Claims not postmarked and/or submitted within 60 days shall not be paid with Program funds unless FNS grants an exception.

FNS estimates that 117 SFAs will each file 1 report annually for a total of 117 responses (117 X 1 = 117). The estimated average number of burden hours per response is 45 minutes (0.75 hours) resulting in estimated total burden of 87.75 hours (117 X .75 = 87.75). This burden is reduced by 65.25 hours, from 153 hours to 87.75 hours, as an adjustment due to the use of more up to date SBP participation data available for fiscal year 2020.

4. Section 220.15(c) states that audits at the SFA level shall be conducted in accordance with Office of Management and Budget regulations and the Department’s implementing regulations. SFAs will provide records for the audits.

FNS estimates that 86 SFAs will each file 1 report annually for a total of 86 responses (86 X 1 = 86). The estimated average number of burden hours per response is 2 hours resulting in estimated total burden hours of 172 (86 X 2 = 172). This burden slightly increased by 8 hours, from 164 hours to 172 hours, as an adjustment due to the percentage of SFAs that respond to audits.

AFFECTED PUBLIC: SCHOOL/SITE LEVEL

1. Section 220.11(b) states Claims for Reimbursement shall include data in sufficient detail to justify the reimbursement claimed. Schools submit breakfast counts served by category to the SFA.

FNS estimates that there are 88,527 schools that will each file 10 reports annually for a total of 885,270 responses (88,527 X 10 = 885,270). The estimated average number of burden hours per response is 3 minutes (0.05 hours) resulting in estimated total burden of 44,263.50 hours (885,270 X 0.05 = 44,263.5). This burden is being decreased by 1,223 hours, from 45,486 hours to 44,263.5 hours, as an adjustment, due to more accurate SBP participation data representing a decrease in the total number of eligible sites participating in the program.

RECORDKEEPING REQUIREMENTS

AFFECTED PUBLIC: STATE AGENCIES

1. Section 220.12(a) states that SAs shall establish such rules or regulations as are necessary to control the sale of foods in competition with breakfasts served under the Program. Such rules or regulations shall prohibit the sale of foods of minimal nutritional value in the food service areas during the breakfast periods.

FNS estimates that there are 56 SAs that will each file 1 report annually for a total of 56 responses (56 X 1 = 56). The estimated average number of burden hours per response is 1 hour resulting in estimated total burden of 56 hours (56 X 1= 56). There is no change in burden.

2. Section 220.13(b)(1) states that each SA shall maintain Program records as necessary to support the reimbursement payments made to SFAs and reports submitted to FNS.

To support reimbursement payments, FNS estimates that 56 SAs will each maintain 36 records annually for a total of 2,016 responses (56 X 36 = 2,016). The estimated average number of burden hours per response is 5 minutes (0.083 hours) resulting in estimated total burden hours of 167 (2,016 X 0.083 = 167). There is no change in burden.

3. Section 220.13(c) states that each SA shall promptly investigate complaints received or irregularities noted in connection with the operation of either program, and shall take appropriate action to correct any irregularities. State agencies shall maintain on file evidence of such investigations and actions.

FNS estimates that there are 56 SAs that will each file 1 report annually for a total of 56 responses (56 X 1 = 56). The estimated average number of burden hours per response is 2 hours resulting in estimated total burden hours of 112 (56 X 2 = 112). There is no change in burden.

4. Section 220.14(d) states that each SA shall maintain records pertaining to claims against SFAs.

FNS estimates that 56 SAs will each file 12 reports annually for a total of 672 responses (56 X 12 = 672). The estimated average number of burden hours per response is 15 minutes (0.25 hours) resulting in estimated total burden of 168 hours (672 X 0.25 = 168). There is no change in burden.

AFFECTED PUBLIC: SCHOOL FOOD AUTHORITIES

1. Section 220.11(b) states that Claims for Reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the SA to provide the Reports of School Program Operations. SFAs maintain Program records to support the claims.

FNS estimates that 17,117 SFAs will each maintain 10 reports annually for a total of 171,170 responses (17,117 X 10 = 171,170). The estimated average number of burden hours per response is 5 minutes (0.083 hours) resulting in estimated total burden hours of 14,207.11 (171,170 X 0.083 = 14,207.11). This burden is being reduced by 1,762.09 hours, from 15,969.2 hours to 14,207.11 hours, as an adjustment due to recent SBP participation data representing a smaller number of participating SFAs.

AFFECTED PUBLIC: SCHOOLS

1. Section 220.8(a)(3) and 220.9(a) state that schools must keep production and menu records for the breakfasts they produce. Schools must maintain records of the latest nutritional analysis of the school menus conducted by the SA. Production and menu records must be maintained.

FNS estimates that 88,527 schools will each file 180 reports annually for a total of 15,934,860 responses (88,527 X 180 = 15,934,860). The estimated average number of burden hours per response is 7 minutes (0.12 hours) resulting in estimated total burden hours of 1,912,183.20 (15,934,860 X 0.12 = 1,912,183.20). This burden is being decreased by 52,812 hours, from 1,964,995.20 hours to 1,912,183.20, as an adjustment due to a decrease in the number of schools currently participating in the SBP.

2. Section 220.11(b) states Claims for Reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the SA to provide the Reports of School Program Operations. Schools record breakfasts by category at point of service.

FNS estimates that 88,527 schools will each file 180 reports annually for a total of 15,934,860 responses (88,527 X 180 =15,934,860). The estimated average number of burden hours per response is 6 minutes (0.1 hours) resulting in estimated total burden of 1,593,486 hours (15,934,860 X 0.1 = 1,593,486). This burden is being decreased by 44,010 hours, from 1,637,496 hours to 1,593,486 hours, as an adjustment due to the use of more accurate school participation data used from fiscal year 2020 to update this information collection.

Changes made:

Decrease in schools/sites participating in the SBP from 90,972 to 88,527.

Decreased SFAs from 19,240 to 17,117.

4