Attachment A - Burden Chart for OMB Control Number 0584-0280 7 CFR Part 225 - Summer Food Service Program (SFSP)

Attachment A Burden Chart for OMB Control #0584-0280 revised w monitoring requirements.xlsx

7 CFR Part 225, Summer Food Service Program

Attachment A - Burden Chart for OMB Control Number 0584-0280 7 CFR Part 225 - Summer Food Service Program (SFSP)

OMB: 0584-0280

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Overview

Reporting
RecordKeeping
Public Disclosure
Burden Summary
Notes


Sheet 1: Reporting

Attachment A: Burden Chart for OMB Control Number 0584-0280 7 CFR Part 225 - Summer Food Service Program (SFSP)









Reporting





A B C = (A*B) D E= (C*D) F



G =E-F

Program Rule CFR Citation Title Form Number Estimated # Respondents Responses per Respondents Total Annual Records Estimated Avg. # of Hours Per Response Estimated Total Hours Current OMB Approved Burden Hrs Previous Burden in Use Without Approval Due to Authorizing Statute Due to Program Adjustment Due to Program Change Total Difference Justification
State/Local/Tribal Governments

SFSP 225.3(b) SAs, by November 1 of each fiscal year, notify USDA if it intends to administer the Summer Food Service Program. The agreement shall contain an assurance that the State agency will comply with policy, instructions, guidance, and handbooks issued by FNS .
53 1 53 Hoang, Thoa K. - FNS PRAO instructed CNP to consider reading and reviewing handbooks, policy guidance, and instructions as reporting burden. Therefore, CNP is estimating that on average, Sas will spend 3 hours per month reviewing materials, totally 36 hours annually 36 1908.00 1,908.00 0
0.00
0

SFSP 225.4(a) SAs, by Feb. 15 of each year, submit to FNSRO a Program Management and Administration Plan for that fiscal year.
53 1 53 1 53 53 0

0 0

SFSP 225.8(d)(1) SAs submit to FNSRO a list of names and addresses of potential private nonprofit organizations and for each site, the address, first day of operation, and estimated daily attendance by May 1 each year.
53 1 53 1 Hoang, Thoa K. - FNS: SAs sibmit one report and time is adjusted in consultation with SA staff. 53 53 0

0 0

SFSP 225.8(d)(2) SAs, within 5 days of approval of sponsors, must notify FNSROs of sponsors, approved sites, locations, and days of operation and estimated daily attendance.
53 Hoang, Thoa K. - FNS: Total number of sponsors operating the program/number of state agencies 5,524/53= 104 104 5,512 1 5512 5,512 0
0 0 0

SFSP 225.9(b)(2) SAs prepare and submit a list sponsors eligible to receive commodities and daily number of eligible means to be served by each sponsor by June 1.
53 bkowtha: one report per SA 1 53 1 53 53 0

0 0

SFSP 225.9(d)(4) SAs forward reimbursements for valid claims.
53 bkowtha: average number of sponsors [(5,524/53=104) x 3] reports =312 312 16,536 0.5 Hoang, Thoa K. - FNS: increase due to increase in number of sponsors. 8268 8,268 0
0 0 0

SFSP 225.12(a) SAs establish claims against sponsors and recover payment not properly payable.
53 bkowtha: 10% of average number sponsors 10 530 4 2120 2,120 0
0 0 0

SFSP 225.18(b)(2) SAs notify terminated sponsors in writing.
53 Hoang, Thoa K. - FNS: based on CACFP statistics, about 5% of average sponsors [(5,524/53=104) x .05=5.2] FNS is rounding down to 5 5 265 1 265 265 0

0 0

SFSP 225.7(d)(2) The State agency must review sponsors and sites to ensure compliance with Program regulations. Per policy guidance, State agencies must validate 100% of claims for sponsors under review.
53 Hoang, Thoa K. - FNS: On average, this is how many applications FNS estimate State agencies have to review 467.24 24,764 0.08 2055.39 2,055.39 0.00

0.00 0.00

SFSP Delehanty, Emily - FNS: Updated citation 225.6(c)(1), 225.6(c)(4), 225.14(a), 225.14(c) Sponsors submit written application to SAs for participation in SFSP. The sponsor must demonstrates financial and administrative capability for Program operations and accepts final financial and administrative responsibility for total Program operations at all sites at which it proposes to conduct a food service. In order to do so, sponsors must comply with policy, instructions, guidance, and handbooks issued by FNS .
3,314 1 3314 Delehanty, Emily - FNS: changed due to including 225.6(c)(4) requirements. PRAO instructed CNP to include review of policy, handbooks, and instructions as burden. Therefore, CNP estiamte that on average, sponsors will spend 3 hours per month reviewing guidance from FNS, totally 36 hours annually, on top of the 3.4 hours for submitting a written application to participate in SFSP to their SA. 39.5 130903.00 130,903.00 0 0 0 0 0

SFSP Delehanty, Emily - FNS: Updated citation 225.6(c)(2) New sponsors, new sites, and, as determined by the State agency, sponsors and sites which have experienced significent operational problems, must submit site information for each site where a food service operation is proposed.
640 1 640 1 640 640 0 0 0 0 0

SFSP 225.6(c)(3) Experienced sponsors and experienced sites must submit site information for each site where a food service operation is proposed.
2,675 1 2675 1 2675.00 2675 0 0 0 0 0

SFSP 225.6(e), 225.14(c)(7) Sponsors approved for participation in SFSP enter into written agreements with SAs to operate program in accordance with regulatory requirements.
332 1 332 0.123 40.84 40.84 0
0
0

SFSP 225.6(h)(2)(iii) Sponsors provide FSMC with a list of approved sites, along with the approved level for the number of meals which may be claimed for reimbursement for each site.
1,157 1 1,157 0.5 578.50 578.50 0
0
0

SFSP 225.6(h)(3) Sponsors submit requests to SAs for exception to unitizing requirement for certain components of a meal.
11.57 1 11.57 0.5 5.79 5.79 0
0
0

SFSP Delehanty, Emily - FNS: change in citation. ( How do we calculate this from the total number of meals vended? -TH) 225.6(h)(5), 225.6(h)(2) Sponsors submit to SAs copies of contracts with FSMC, bids received, and reason for selection on FSMC chosen.
1,157 1 1157 20 23140 23,140 0
0
0

SFSP 225.15(d)(2) Sponsors must visit each of their sites at least once during the first week of operation under the Program.
3,314 9 29,826 0.50 14,913 0 14,913 0
14,913 14,913

SFSP 225.15(d)(3) Sponsors must review food service operations for all sites at least once during the first 4 weeks of Program operations, and thereafter maintain a reasonable level of monitoring.
3,314 9 29,826 2 59,652 0 59,652 0
59,652 59,652

SFSP 225.16(a) Within two weeks of receiving notification of their approval, sponsors shall submit to the State agency a copy of their letter advising the appropriate health department of their intention to provide a food service during a specific period at specific sites.
3,314 1 3314 0.25 828.50 828.50 0
0
0

State/Local/Tribal Governments Total
3367 36 120,071 2.11 253,664 179,099 74,565.00 0 0 74,565.00 74,565.00

Businessess (Non-profit Institutions and Camps)

SFSP Delehanty, Emily - FNS: Updated citation 225.6(c)(1), 225.6(c)(4), 225.14(a), 225.14(c) Sponsors submit written application to SAs for participation in SFSP. The sponsor must demonstrates financial and administrative capability for Program operations and accepts final financial and administrative responsibility for total Program operations at all sites at which it proposes to conduct a food service. In order to do so, sponsors must comply with policy, instructions, guidance, and handbooks issued by FNS .
Hoang, Thoa K. - FNS: Number of sponsors in the NDB 2018 SFSP public use report (1/9/19) 2,210 1 2,210 Delehanty, Emily - FNS: changed due to including 225.6(c)(4) requirements. PRAO instructed CNP to include review of policy, handbooks, and instructions as burden. Therefore, CNP estiamte that on average, sponsors will spend 3 hours per month reviewing guidance from FNS, totally 36 hours annually, on top of the 3.4 hours for submitting a written application to participate in SFSP to their SA. 39.5 87,295.00 87,295.00 0
0.00 0 0.00

SFSP Delehanty, Emily - FNS: Updated citation 225.6(c)(2) New sponsors, new sites, and, as determined by the State agency, sponsors and sites which have experienced significent operational problems, must submit site information for each site where a food service operation is proposed.
Hoang, Thoa K. - FNS: 2018 close out data from the regions showed that around 80.69%. (100-80.69= 19.31) 19.31% x the number of sponsors 426 1 426 1 426 426 0
0 0 0

SFSP 225.6(c)(3) Experienced sponsors and experienced sites must submit site information for each site where a food service operation is proposed.
1,783 1 1,783 1 1,783 1,783 0
0 0 0

SFSP 225.6(e), 225.14(c)(7) Sponsors approved for participation in SFSP enter into written agreements with SAs to operate program in accordance with regulatory requirements.
bkowtha: 10% of sponsors 221 1 221 0.12 27 27 0
0 0 0 HHFKA requires permanent agreements deleting the annual submission
SFSP 225.6(h)(2)(iii) Sponsors provide FSMC with a list of approved sites, along with the approved level for the number of meals which may be claimed for reimbursement for each site.
Hoang, Thoa K. - FNS: Based on the characteristic study from 2015, 34.93% of sponsors contract with an FSMC. (Number of sponsors multiply by 34.93%) 772 1 772 0.5 386 386 0
0 0 0

SFSP 225.6(h)(3) Sponsors submit requests to SAs for exception to unitizing requirement for certain components of a meal.
Hoang, Thoa K. - FNS: 34.93% of sponsors (5,524) would have contracts with FSMC. 1% of these sponsors would sbmit a special request 7.72 1 7.72 0.5 3.86 3.86 0
0 0 0

SFSP Delehanty, Emily - FNS: change in citation. ( How do we calculate this from the total number of meals vended? -TH) 225.6(h)(5), 225.6(h)(2) Sponsors submit to SAs copies of contracts with FSMC, bids received, and reason for selection on FSMC chosen.
Hoang, Thoa K. - FNS: Based on the characteristic study from 2015, 34.93% of sponsors contract with an FSMC. (Number of sponsors multiply by 34.93%) 772 1 772 20 15,440 15,440 0
0 0 0

SFSP 225.15(d)(2) Sponsors must visit each of their sites at least once during the first week of operation under the Program.
2,210 9 19,890 0.50 9,945 0 9,945 0
9,945 9,945

SFSP 225.15(d)(3) Sponsors must review food service operations for all sites at least once during the first 4 weeks of Program operations, and thereafter maintain a reasonable level of monitoring.
2,210 9 19,890 2 39,780 0 39,780 0
39,780 39,780

SFSP 225.16(a) Within two weeks of receiving notification of their approval, sponsors shall submit to the State agency a copy of their letter advising the appropriate health department of their intention to provide a food service during a specific period at specific sites.
2,210 1 2,210 0.25 552.50 552.50 0
0 0 0

SFSP 225.6(c)(5) Camps submit copy of hearing procedures.
Hoang, Thoa K. - FNS: This number is based on the SNAR081-R1 Analysis Data. NDB FY2018 Thru 7/2018. The number of residential camps as of July 2018. 333 1 333 0.25 83.25 83.25 0
0 0.00 0.00

Businessess (Non-profit Institutions and Camps) Totals
2,210 22 48,515 3.21 155,721.79 105,996.79 49,725.00 0 0 0.00 49,725.00

Households

SFSP 225.15(f) Households read instructions, complete free meal and return to camps and sites.
Hoang, Thoa K. - FNS: This number is the ADA for residential camps. This was choosen because camps have to determine eligibility of children attending the camps. So a suggestion is to use the ADA of residential camps. 58,365 1 58,365 0.50 29,182.50 29,182.50 0
0 0 0

SFSP 225.15(j) Households provide written consent for sponsors to use or disclose information.
58,365 1 58,365 0.25 14,591.25 14,591.25 0
0 0 0

Household Totals
58,365 2 116,730 0.38 43,773.75 43,773.75 0.00 0 0 0 0.00



Total Reporting Burden
63,942 4.46 285,316.01 1.59 453,159.55 328,869.55 124,290 0 0 74,565 124,290





















Program Rule Estimated # Respondents Responses per Respondents Number of Responses Estimated Avg. # of Hours Per Response Estimated Total Hours Current OMB Approved Burden Hrs Previous Burden in Use Without Approval Due to Authorizing Statute Due to Program Adjustment Due to Program Change Total Difference




SLT burden 3,367 36 120,071.29 2.113 253,664.01 179,099.01 74,565.00 - 0 74,565 74,565.0




Business burden 2,210 22 48,514.72 3.2 155,721.79 105,996.79 49,725.00 - - - 49,725.0




Household burden 58,365 2 116,730 0.4 43,773.75 43,773.8 - - - - -




Total 63,942 4.46 285,316 1.59 #REF! #REF! 124,290.00 0 0 74,565 #REF!






































































Sheet 2: RecordKeeping

Recordkeeping




A B C = (A*B) D E= (C*D) F



G =E-F
Program Rule CFR Citation Title Form Number Estimated # Recordkeepers Records Per Recordkeeper Total Annual Records Estimated Avg. # of Hours Per Record Estimated Total Hours Current OMB Approved Burden Hrs Previous Burden in Use Without Approval Due to Authorizing Statute Due to an adjustment Due to program change Total Difference
State/Local/Tribal Governments
SFSP Delehanty, Emily - FNS: change in citation 225.8 (a), 225.7(d)(5), 225.13(d) SAs maintain complete and accurate accounting records appeals for three years.













1. Reviews
53 Kowtha, Bramaramba - FNS: average number of reveiws conducted by each SA per requirements. This is a general estimate. 39 2067 0.08 165.36 165.36 0 0 0 0 0
2. Appeals
53 Kowtha, Bramaramba - FNS: avg number 2 106 0.08 8.48 8.48 0 0 0 0 0
3. Accounting
53 bkowtha: 5524/53=104 104 5512 0.08 440.96 440.96 0 0 0 0 0
SFSP 225.15 (c), 225.15 (a), 225.15(g) Sponsors must maintain records which justify all costs and meals claimed.
3,314 1 3,314 0.08 265.12 265.12 0 0 0 0 0
State/Local/Tribal Governments Total
3,367 3 10,999 0.08 880 879.92 0.00 0 0.00 0 0.00
Businessess (Non-profit Institutions and camps)
SFSP 225.15 (c), 225.15 (a), 225.15(g) Sponsors must maintain records which justify all costs and meals claimed.
bkowtha: This number is based on the SNAR081-R1 Analysis Data. NDB FY2018 Thru 7/2018. The number of residential camps as of July 2018. 2,210 1 2,210 0.08 176.80 176.80 0 - 0.00 0 0.00
SFSP 225.16(b)(1) Camps and sponsors must maintain copies of the documentation establishing the eligibility of child receiving meals and all other meal service requirement information.
Hoang, Thoa K. - FNS: from the characteristic study, FNS knows that 38% of sponsors are closed enrolled or camps. Only camps or closed enrolled sponsors would collect eligiblity information. 5,524 was multiply by 38% to determine this number 840 Kowtha, Bramaramba - FNS: 5524/53=104 104 87,360 0.08 6,988.80 6,988.80 0 - - - 0.00
SFSP 225.6(c)(5)(xii) Camps must maintain a written record of hearing for 3 years.
333 1 333 0.30 99.90 99.90 -
0
0.00
Businessess (Non-profit Institutions and Camps) Totals
2,210 40.7 89,903 0.08 7,265.50 7,265.50 0 0 0 0 0


Total Recordkeeping Burden
5,577 18.09 100,902 0.08 8,145.42 8,145.42 0 0 0 0 0



















Program Rule Estimated # Recordkeepers Records Per Recordkeeper Total Annual Records Estimated Avg. # of Hours Per Record Estimated Total Hours Current OMB Approved Burden Hrs Previous Burden in Use Without Approval Due to Authorizing Statute Due to an adjustment Due to program change Total Difference



SLT burden 3,367 3 10,999 0.08 879.92 879.92 0 0 0.00 0 0.00



Business burden 2,210 40.68 89,903 0.08 7,265.50 7,265.50 -
-
-



Total 5,577 18.09 100,902 0.08 8,145.42 8,145.42 0 0 0.00 0 0

Sheet 3: Public Disclosure

Public Disclosure




A B C = (A*B) D E= (C*D) F



G =E-F
Program Rule CFR Citation Title Form Number Estimated # Respondents Disclosures Per Respondent Total Annual Disclosures Estimated Avg. # of Hours Per Disclosure Estimated Total Hours Current OMB Approved Burden Hrs Previous Burden in Use Without Approval Due to Authorizing Statute Due to an adjustment Due to a program change Total Difference
State/Local/Tribal Governments
SFSP 225.15(e) Per policy guidance, State agency can issue a media release on behalf of the sponsor.
53 1 53 0.25 13.00 13.00 0 0 0 0 0
SFSP 225.15(e) Each sponsor shall annually announce in the media serving the area from which it draws its attendance the availability of free meals
3,314 1 3,314 0.25 828.00 828.00 0 0 0 0 0
State/Local/Tribal Governments Totals
3,367 1 3,367 0.25 841.00 841.00 0 0 0 0 0
Businessess (Non-profit Institutions and Camps)
SFSP 225.15(e) Each sponsor shall annually announce in the media serving the area from which it draws its attendance the availability of free meals
2,210 1 2,210 0.25 553.00 553.00 0 0 0 0 0
Businessess (Non-profit Institutions and Camps) Totals
2,210 1 2,210 0.25 553.00 553.00 0 0 0 0 0


Total Public Disclosure Burden
5,577 1 5,577 0.25 1,394.00 1394.00 0 0 0 0 0


















Program Rule Estimated # Respondents Disclosures Per Respondent Total Annual Disclosures Estimated Avg. # of Hours Per Disclosure Estimated Total Hours Current OMB Approved Burden Hrs Previous Burden in Use Without Approval Due to Authorizing Statute Due to an adjustment Due to a program change Total Difference



SLT burden 3,367 1 3,367 0.25 841.00 841.00 0 0 0 0 -



Business burden 2,210 1 2,210 0.25 553.00 553.00 - - - - -



Total 5,577 1.00 5,577 0.25 1,394.00 1,394.00 0 0 0 0 0









































































1

Sheet 4: Burden Summary

ICR #0584-0280, 7 CFR Part 225, Summer Food Service Program (SFSP) - Summary























Estimated # Respondents Responses Per Respondent Total Annual Responses (Col. BxC) Estimated Avg. # of Hours Per Response Estimated Total Hours (Col. DxE)








Recordkeeping













State/Local/Tribal Government 3,367 3 10,999 0.08 880








Businessess 2,210 40.7 89,903 0.08 7,266








Total Recordkeeping Total 5,577 18.09 100,902 0.08 8,145.42








Reporting













State/Local/Tribal Government 3,367 36 120,071 2.11 253,664.01








Businessess 2,210 22 48,515 3.21 155,721.79








Households 58,365 2 116,730 0.38 43,774








Total Reporting Total 63,942 4.46 285,316 1.59 453,159.55








Public Disclosure













State/Local/Tribal Government 3,367 1 3,367 0.25 841.00








Businessess 2,210 1 2,210 0.25 553.00








Total Public Disclosure Total 5,577 1 5,577 0.25 1,394.00








TOTAL BURDEN FOR SFSP 63,942 6.13 391,795 1.181 462,698.97

































































































































Sheet 5: Notes

Date User Initials Comments









































































































































































































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