Emergency Memo SFA Survey II

ace

United States
Department of
Agriculture

September 15, 2022
MEMORANDUM

Food and
Nutrition
Service

TO:

Laurel Havas
Desk Officer for FNS
Office of Information and Regulatory Affairs, OMB

1320 Braddock
Alexandria, VA
22314

THRU:

Maureen Lydon
Branch 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
Administrator
Food and Nutrition Service

SUBJECT: Emergency Approval of SFA Survey II 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 the continued impacts of COVID-19-related supply chain disruptions
on the Child Nutrition (CN) Programs, as well as emerging challenges related to the
transition back to standard school nutrition program operations. The proposed survey
is provided in Appendix B.
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 these challenges and to identify
solutions.
This is the second survey issued to SFAs that will assist FNS and its partners to
enhance the toolbox for school nutrition professionals working hard to make sure
students have reliable access to healthy meals. Whereas the first SFA survey focused
on challenges and mitigation strategies related to procuring specific food or non-food
items during the 2021-2022 school year, this survey focuses on food costs, labor costs,
and vendor issues that continue to disrupt school food service in the 2022-2023 school
year, as well as changes in student participation related to the return to standard
operations.

The survey has a maximum of 31 questions and is estimated to take approximately 20
minutes to complete per respondent. As a result, the total proposed time burden is
8,840.79 burden hours. FNS is asking all SFAs that participate in the Child Nutrition
Programs to complete this survey.
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. 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 15th to be able to act on the
information in a timely fashion given the dynamic situation of supply chain
disruptions, a national issue. It’s reasonable to add that this involves an
unanticipated event. FNS could not predict school food authorities facing labor
shortages and suppliers exiting the school foods market going into SY 20222023, and the ramifications of the pandemic lasting this long.
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•

Essential to the mission of the agency to quantify the scope of continuing
supply chain disruption challenges and take that into account, as appropriate, in
emergency food assistance; and

•

Essential to obtain the data in a timely manner. The use of normal clearance
procedures would certainly disrupt timely collection of information. 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 challenges school districts are
facing related to school food vendors, costs, and labor to facilitate USDA’s
support for the school districts in successfully serving students healthy and
nutritious school meals. Waiting months to obtain normal clearance would
negatively impact the timely collection of information, and targeted delivery of
this support, which is a primary reason for gathering this information.

FNS appreciates your consideration of this information.
Digitally signed by MAUREEN
LYDON
___________________________
Date: 2022.09.16 14:48:56 -04'00'

Maureen Lydon, Branch Chief
PRAO, Food and Nutrition Service
Digitally signed by
CYNTHIA
CYNTHIA LONG
Date: 2022.09.16
LONG
__________________________
16:14:46 -04'00'

Cindy Long, Administrator
Food and Nutrition Service

Appendices
Appendix A. Section 28 of the Richard B. Russell National School Lunch Act and Section 305 of
the Healthy, Hunger-Free Kids Act of 2010
Appendix B. SFA Survey II on School Food Supply Chain Disruption
Appendix C. Survey Support Email
Appendix D. Reminder Email
Appendix E. Thank You Email
Appendix F. Pretest
Appendix G. Burden Table

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