Attachment CC Burden Chart - All Programs

Attachment CC- Burden Chart for All Programs Due to the Final Rule Changes Final.xlsx

Child Nutrition Program Integrity

Attachment CC Burden Chart - All Programs

OMB: 0584-0610

Document [xlsx]
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Overview

Reporting
RecordKeeping
PublicNotification
60 day Summ
Burden Summary
Notes


Sheet 1: Reporting

Attachment CC Burden Chart - All Programs










Reporting
Program Rule CFR Citation Title Estimated # Respondents Responses per Respondents Total Annual Records Estimated Avg. # of Hours Per Response Estimated Total Hours Current OMB Approved Burden Hrs Due to Program Change Total Difference Notes:
State and Local Government Level
State Agency

226.4(j) SAs may submit plan to FNS for additional audit funding. Hoang, Thoa K. - FNS: FNS took the last 5 year data of state agencies that requested additional audit funds and averaged them to estimate that there are 8 state agencies that will each file 8 1 8 4 32 0 32.00 32

226.6(k)(11)(iii) SA to submit, for FNS review, information supporting a request for a reduction in the State’s liability, a reconsideration of the State’s liability, or an exception to the 60-day deadline, for exceptional circumstances. 5 1 5 4 20 0 20.00 20

226.6 (b)(4)(ii) State agency must consult with FNS prior to any taking action to terminate for convenience. 56 1 56 0.50 28 0 28.00 28

226.6(m)(6) Hoang, Thoa K. - FNS: based on certain criteria, some institutions will be reviewed more frequently. SAs to conduct reviews every two years for sponsoring organizations with less than 100 facilities and conduct activities other than the CACFP or are at risk of having serious management problems. 56 20 1120 Roth, Laura - FNS: Adjsuted from the proposed rule ICR to account for the time it takes to select a sample to review 4.00 4480 0 4480.00 4480

226.7(b)(1) Have procedures in place for annually reviewing at least one month of the sponsoring organization’s bank account activity against other associated records to verify that the transactions meet program requirements. 56 1 56 1.00 56 0 56.00 56

226.7(b)(1)(ii) State agency must have procedures for annually reviewing a sponsoring organization’s actual expenditures of CACFP funds and the amount of meal reimbursement funds retained from unaffiliated centers. Roth, Laura - FNS: FNS assumes that each SA has at least 1 unaffilated center under a SO in the State 56 1 56 Roth, Laura - FNS: Adjusted from the proposed rule ICR to account for the time it takes to determine the sample to review. 1.00 56 0 56.00 56

226.25(j) State agencies must notify SFAs of fines and submit a copy of the notice to FNS. 56 0.09 5.04 3.00 15.12 0 15.12 15

226.6(b)(2) SAs must review annual certification of an institution’s eligibility to continue participating in CACFP (replaces the renewal application process). 56 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Number based on currently approved ICR of number renewing. 390 21,840 0.334 7,295 10,920 -3625.44 -3625

226.6(m)(3)(ix) The State agency is required to assess the timing of each sponsoring organization’s reviews of day care homes and sponsored centers. 56 Otey, Jennifer - FNS: Based on the number of sponsors in the curretly approved ICR - 3257 government and 18601 businesses. 390 21,840 0.167 3,640 0 3640.00 3640

226.6(p) The SA must develop/revise and provide a sponsoring organization agreement between sponsor and facilities, which must have standard provisions. 56 1 56 6.00 336 0 336.00 336

226.12(a) SAs must multiply the appropriate administrative reimbursement rate by the number of day care homes submitting claims for reimbursement during the month, to determine the amount of payment that sponsoring organizations will receive. 56 11 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: 540+83 = 623 (number of sponsors of daycare homes, in current ICR). 623 0.167 104 0 103.83 104

226.7(g)(2) State agency must review the budget and supporting documentation prior to approval, for sponsoring organizations of day care homes seeking to carry over administrative funds. 56 11 623 1.00 623 0 623.00 623

226.7(j) State agency must establish procedures to recover administrative funds from sponsoring organizations of day care homes that are not properly payable under FNS Instruction 796-2, administrative funds that are in excess of the 10 percent maximum carryover amount, and carryover amounts that are not expended or obligated by the end of the fiscal year following the fiscal year in which they were received. 56 1 56 2.00 112 0 112.00 112

225.6 (i) State agency must consult with FNS prior to taking any action to terminate for convenience. 53.00 1.00 53.00 0.50 26.50 0.00 26.50 26.50

225.18(k) State agencies must notify SFAs of fines and submit a copy of the notice to FNS. 53.00 0.09 4.77 3.00 14.31 0.00 14.31 14.31

210.18(i)(3) SA notifies SFAs in writing of review findings, corrective actions, deadlines, and potential fiscal action with grounds and right to appeal. 56 Gaddie, Wesley - FNS: # of SFAs for every 5 years divided by the # of SAs 68 3,808 8.00 30,464 50624 -20160.00 -20160

210.5(d)(3) SAs submit an annual report to FNS detailing the disbursement of performance-based reimbursement to SFAs (in FPRS). 56 1 56 0.25 14 56 -42.00 -42

210.18(c)(2) SAs with a review cycle longer than 3-years submit a plan to FNS describing the criteria that it will use to identify high-risk SFAs for targeted follow-up reviews. 56 1 56 8.00 448 0 448.00 448

210.21(h) State agencies must complete procurement training requirements annually. 56 1 56 1.00 56 0 56.00 56

210.26(b)(4) SAs must notify SFAs of fine and specific violations or actions that constituted the fine, and of appeal rights and procedures; submit a copy of the notice to FNS. 56 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: We estimate that 5 of 56 SAs may have fines of SFAs. 0.09 5.04 3.00 15.12 0 15.12 15


State Agency Level Total 56.00 899.69 50,382.85 0.95 47,834.44 61,600.00 -13,766 -13,766
Local Governments
Sponsoring Organizations/School Food Authority/Local Education Agency Level

226.7(b)(1) Sponsoring organizations have to annually provide State agencies with bank account activity against other associated records to verify that the transactions meet program requirements. 3,257 1 3,257 0.25 814 0 814 814

226.7(b)(1)(i) Sponsoring organizations must provide State agency with actual expenditures of CACFP funds and the amount of meal reimbursement funds retained from unaffiliated centers to support the sponsoring organization’s administrative costs. Roth, Laura - FNS: This number is based on the number of large, local govt SO of sponsored centers that have unaffliated centers. 32 Roth, Laura - FNS: The SO will provide the SA 1 record for all of it's unaffiliated centers. 1 32 1 32 0 32 32

226.6(b) Each participating institution must submit annual updates to continue its participation (annual certification of information, updated licensing information, and a budget). [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: This is the number of government institutions from the most recently approved CACFP ICR. 3257 1 3,257 0.33 1,088 1629 -541 -541

226.6(p), 226.17(e),(f), 226.17a(f), 226.19(d), and 226.19a(d) Sponsoring organizations must enter into permanent agreements with their unaffiliated centers. 32 10 320 0.50 160 0 160 160

226.6(f)(1)(iv) Sponsoring organizations of day care homes seeking to carry over administrative funds must submit an amended budget, to include an estimate of requested administrative fund carryover amounts and a description of proposed purpose for which those funds would be obligated or expended. 83 1 83 1.00 83 0 83 83

226.25 SFAs may appeal the State agency's determination of fines. SFAs must submit to the State agency any pertinent information, explanation, or evidence addressing the Program violations identified by the State agency. 5 1 5 8.00 40 0 40 40

226.23(e)(1)(vii) If a tier II day care home elects to assist in collecting and transmitting the applications to the sponsoring organization, sponsoring organizations must establish procedures to ensure the provider does not review or alter the application 83 1 83 1.00 83 0 83 83

225.18(k) SFAs may appeal State agency's determination of fines. SFAs must submit to the State agency any pertinent information, explanation, or evidence addressing the Program violations identified by the State agency. Any SFA seeking to appeal the State agency determination must follow State agency appeal procedures.  5.00 1.00 5.00 8.00 40.00 - 40.00 40.00

210.15(a)(3) & 210.18(j)(2) SFA submits to the SA a written response to reviews documenting corrective action for Program deficiencies. Mack, Meghan - FNS: Number of SFAs/ 5years 3,804 1 3,804 8.00 30,430 50,720 -20,290 -20,290

210.21(h) SFAs must complete procurement training requirements annually. 19,019 1 19,019 1.25 23,774 0 23,774 23,774

210.26(b)(5) SFAs may appeal SA's determination of violations and fines. SFAs must submit to the State agency any pertinent information, explanation, or evidence addressing the Program violations identified by the SA. Any SFA seeking to appeal the SA determination must follow SA appeal procedures. 5 1 5 8.00 40 0 40 40


Local Level Total 19,019 1.571 29,870 1.89 56,584 52,349 4,236 4,236
Business Level (Institutions)

226.7(b)(1)(i) Sponsoring organizations have to annually provide State agencies with bank account activity against other associated records to verify that the transactions meet program requirements. 18,601 1 18601 0.25 4650 0 4650 4650

226.7(b) Sponsoring organizations must provide State agency with actual expenditures of CACFP funds and the amount of meal reimbursement funds retained from unaffiliated centers to support the sponsoring organization’s administrative costs. 1,030 1 1030 1 1030 0 1030 1030

226.6(b) Each participating institution must submit annual updates to continue its participation (annual certification of information, updated licensing information, and a budget). 18,601 1 18601 0.33 6213 9301 -3088 -3088

226.6(p), 226.17(e),(f), 226.17a(f), 226.19(d), and 226.19a(d) Sponsoring organizations must enter into permanent agreements with their unaffiliated centers. 1,030 10 10300 0.5 5150 0 5150 5150

226.23(e)(1)(vii) If a tier II day care home elects to assist in collecting and transmitting the applications to the sponsoring organization, sponsoring organizations must establish procedures to ensure the provider does not review or alter the application 540 1 540 1 540 0 540 540

226.6(f)(1)(iv) Sponsoring organizations of day care homes seeking to carry over administrative funds must submit an amended budget, to include an estimate of requested administrative fund carryover amounts and a description of proposed purpose for which those funds would be obligated or expended. 540 1 540 1 540 0 540 540
Total Burden for Businesses (Institutions) 18,601 2.667 49,612 0.37 18,123 9,301 8,822 8,822
Business Level (Facilities)

226.18(b)(12) Tier II day care homes may assist in collecting meal benefit forms from households and transmitting the forms to the sponsoring organization on the household’s behalf. [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Based on current approved ICR. 9,321 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Per currently approved ICR, 10.37% of homes are tier II; using logic of 10.37% of households being in tier II, 10.37% x 528,479 total daycare home ADA (per NDB, KD11 - Child and Adult Care Food Program -- Child Care Homes and Centers) = 54,804 potentially completing meal benefit forms in tier II homes. 5.88 54804 0.08 4,576
4576 4576
Total Burden for Businesses (Facilities) 9,321 5.880 54,804 0.08 4,576 0 4,576 4,576
School Level














School Level Total - 0.000 - 0.00 - - - -


Total Reporting Burden 46,997 3.93 184,669 0.69 127,118 123,250 3,868 3,868

Sheet 2: RecordKeeping

Recordkeeping



A B C = (A*B) D E= (C*D) F
G =E-F
Program Rule CFR Citation Title Estimated # Record-keepers Records Per Recordkeeper Total Annual Records Estimated Avg. # of Hours Per Record Estimated Total Hours Current OMB Approved Burden Hrs Due to Program Change - Rule Total Difference Notes:
State Agency Level

210.18(h)(2)(iv) SA maintains documentation of LEA/SFA compliance with nutrition standards for competitive foods. 56 68 3,808 0.25 952 1,582 -630 -630

210.20(b)(6) & 210.18(o)(f)(k,l,m) & 210.23(c) SA maintains records of all reviews and audits (including Program violations, corrective action, fiscal action and withholding of payments). 56 Total SFAs / SAs divided by 5 for every five years. 68 3,808 8.00 30,472 50,638 -20,166 -20,166

210.20(b)(7) & 210.19(c) & 210.18(o) SA maintains documentation of fiscal action taken to disallow improper claims submitted by SFAs, as determined through claims processing, reviews, and USDA audits. 56 Total SFAs / SAs divided by 5 for every three years. 68 3,808 0.50 1,904 3,164 -1,260 -1,260

210.18 (c-h) SA completes and maintains documentation used to conduct Administrative Review. 56 Mack, Meghan - FNS: Total SFAs / SAs divided by 5 for every 5 years 68 3,808 0.50 1,904 3,173 -1,269 -1,269

210.18 (c) SA completes and maintains documentation used to conduct targeted Follow Up Administrative Review. 56 Mack, Meghan - FNS: 1/3 of SFAs reviewed each year/ state 23 1,288 Mack, Meghan - FNS: 1/3 of the time it takes to do a regular AR. 16.00 20,608 0 20,608 20,608

210.15(b)(8) State agencies must maintain records to document compliance with the procurement training requirements. 56 1 56 0.25 14 0 14 14

210.26(b) State agencies must maintain records to related fines and specific violations 56 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: FNS estimates that 5 SA will need to maintain records related to fines. 0.09 5.04 0.25 1.26 0 1.26 1.26

226.4(j) SAs to maintain a plan for additional audit funds. 8 1 8 0.5 4 0 4 4

226.6(m)(6) Maintain records for reviewing Sponsoring organizations with less than 100 facilities and conduct activities other than the CACFP, or are at risk of having serious management problems every two years 56 20 1120 2 2240 0 2240 2240


State Agency Level Total 56 316 17,709 3.28 58,099 58,557 -458 -458
School Food Authority/Local Education Agency Level

210.21(h) School food authorities must maintain document compliance with the procurement training requirements. 19,019 1 19,019 0.25 4,755 0 4,755 4,755


School Food Authority Level Total 19,019 1 19,019 0.25 4,755 0 4,755 4,755
School Level



0 0 0 0 0 0 - -


School Level Total 0 - - - 0 0


Total Recordkeeping Burden 19,075 1.93 36,728 1.71 62,854 58,557 4,297 4,297

Sheet 3: PublicNotification

Public Notification




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 Due to Authorizing Statute Due to Program Change - Final Rule Due to an Adjustment Total Difference Highlighted cells indicate a change due to the Final Rule


Gaddie, Wesley - FNS: Exisitng Burden modified by rulemaking
210.18(m)(1) SA must post a summary of the most recent administrative review results of SFAs on the SA website and make a copy available upon request.
50 states + DC + Guam + Puerto Rico + Virgin Islands + add'l SAs in AR & OK = 56 56 Mack, Meghan - FNS: Number of SFAs/sate/ divied by 5. 68 3,808 0.25 952.0 1,582.0
-630
-630


State Agency Level Total
56 68.00 3808 0.25 952 1582 0 -630 0 -630






0 0 0 0 0 0 0 0 0 0


Local Educational Agency / School Food Authority Level Total
0 0.00 0 0.00 0 0 0 0 0 0



















School Level Total
- - -
- - - 0 - 0


Total Public Notification Burden
56 68.00 3,808 0.25 952 1,582 0 -630 0 -630

Sheet 4: 60 day Summ





SUMMARY OF BURDEN RECORDKEEPING & REPORTING

TOTAL NO. RESPONDENTS 46,997

AVERAGE NO. RESPONSES PER RESPONDENT 4.792

TOTAL ANNUAL RESPONSES 225,205

AVERAGE HOURS PER RESPONSE 0.847780259164822

TOTAL BURDEN HOURS 190,924

CURRENT OMB INVENTORY 0
This is the Current OMB Approved Burden Hrs column 'J'
DIFFERENCE (NEW BURDEN REQUESTED) 190,924
CHANGE DUE TO ADJUSTMENT 0 There are no adjustments.
CHANGE DUE TO PROGRAM CHANGE 190,924


Sheet 5: Burden Summary

ICR #0584-0655, Child Nutrition Integrity Final Rule






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




State Agency Level 56 316 17,709 3.28 58,099
School Food Authority Level 19,019 1 19,019 0.2500 4,755
School Level - - -
Recordkeeping Total 19,075 1.93 36,728 1.71 62,854
Reporting




State Agency Level 56 899.69 50,382.85 0.95 47,834.44
Sponsors 19,019 1.57 29,869.80 1.89 56,584
Institutions 18,601 2.67 49,612.00 0.37 18,123
Facilities 9,321 5.88 54,804 0.08 4,576
School Level - - - - -
Reporting Total 46,997 3.93 184,669 0.69 127,118
Public Notification




State Agency Level 56 68 3,808 0.25 952
Local Educational Agency Level - - - - -
School Level - - - -
Public Notification Total 56 68 3,808 0.2500000 952
TOTAL BURDEN [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Manually entered based on charts in PRA section. Otherwise, here, this chart double counts some entities. 46,997 4.79 225,205 0.85 190,924

Sheet 6: Notes

Date User Initials Comments
































































































































































































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