Attachment B Burden Table

Attachment B

Estimate of the Information Collection Burden for OMB #0584-0660

Pandemic EBT

This document explains the calculation of the information collection burden for the information collection titled Pandemic Electronic Benefit Transfer. A 60-Day Notice concerning this revision was published in the Federal Register on September 28, 2023 (Volume 88, Number 187 pages 66796-66797). Due to the expiration of the COVID-19 Public Health Emergency declaration on May 11, 2023, which deemed FY 2023 the last year that States and territories could receive approval for P-EBT implementation, this revision of the currently approved information collection pertains only to limited elements of the collection to facilitate the orderly wind-down and close-out of the P-EBT program.

Revisions to the burden estimates for households, schools/school districts and State agencies will be addressed in this updated estimate. Bolded text refers to revisions to burden hour or new burden hours.

REPORTING REQUIREMENTS

AFFECTED PUBLIC: STATE AGENCIES (SA)

1. The Pandemic EBT program required State agencies to submit a plan for USDA approval describing how they will determine eligibility, determine benefit amounts, issue benefits, and provide customer service during school year and the proceeding summer period. States were encouraged to submit a single plan covering both the schools and the child care component. However, all States and territories submitted their plans prior to September 30, 2023; therefore, there are no burden hours for submission of State plans for the school year or summer. This is a decrease in burden of 106 hours.

2. Pandemic EBT requires State agencies to ensure correct eligibility determinations and determine benefit amounts.

All State agencies will have conducted eligibility determinations and benefit amounts prior to November 30, 2023. Therefore, there are no longer burden hours for eligibility determinations or determining benefit amounts. This is a decrease in burden of 2,165,000 hours.

3. Pandemic EBT requires State agencies to provide monthly reports via the FNS-292B (Disaster Relief) to the FNS Regional Office, regarding the number of eligible children receiving P-EBT benefits, number of households receiving such benefits, and the total value of the benefits

FNS estimates that 50 State agencies will submit 12 responses annually for a total of 600 responses (50x 12 = 600). The estimated average burden per response is 1 hour for a total estimated burden of 600 hours (600 x 1 = 600). There is a reduction in burden of 36 hours, as there are now only 50 States that could potentially issue benefits in FY 24.

4. Pandemic EBT requires State agencies to submit administrative costs plans using the FNS-366A (Program and Budget Summary Statement: Budget Projection) in order to receive reimbursement for administrative costs.

All State agencies were required to submit administrative cost plans using the FNS 366A by September 30, 2023. These administrative cost plans include costs for wind-down and closeout of the P-EBT program in FY 2024. Therefore, there are no longer burden hours for development and submission of these administrative cost plans. This is a decrease in burden of 636 hours.

5. P-EBT requires States agencies to report administrative expenses quarterly to USDA using a P-EBT specific instance of the SF-425 (Federal Financial Report).

FNS estimates that 50 state agencies will submit 4 responses annually for a total of 212 responses (50 x 4 = 200). The estimated average burden per response is 1 hour for a total burden of 200 hours (200 x 1 = 200). This is a decrease in burden of 12 hours.

6. P-EBT requires States agencies to report estimates of summer P-EBT issuances regarding the number of eligible children receiving P-EBT benefits, number of households receiving such benefits, and the total value of the benefits

All State agencies will have submitted this information prior to November 30, 2023. Therefore, there are no longer burden hours for reporting of this information. This is a decrease in burden of 27 hours.

AFFECTED PUBLIC: SCHOOLS

1. Pandemic EBT required schools to provide student eligibility data to state agencies in order for students to receive P-EBT benefits during school year 2022-2023.

All State agencies will have submitted this information prior to November 30, 2023. Therefore, there are no longer burden hours for reporting of this information. This is a decrease in burden of 568,602 hours.

2. Pandemic EBT required schools/school districts to provide student eligibility data to state agencies in order for students to receive P-EBT benefits during summer 2023.

FNS estimates that 287 school districts in one State will submit 1 response annually for a total of 287 responses (287x 1 = 287). The estimated average burden per response is 1 hour for a total burden of 287 hours (287x 1 =287). This is a decrease in burden of 47,240.5 hours.

3. Pandemic EBT requires schools/school districts to submit their administrative costs to their State agency in order to receive reimbursement.

FNS estimates that 287 school districts will submit 1 response annually for a total of 287 responses 287 x 1 = 287). The estimated average burden per response is 1 hour for a total burden of 287 hours (287 x 1 = 287). This is a decrease in burden of 94,623 hours.

AFFECTED PUBLIC: HOUSEHOLD LEVEL

1. Pandemic EBT required households who newly became eligible to receive free or reduced price meals to submit an application for free or reduced price meal benefits.

FNS estimates that up to 114,000 households that will submit 1 record annually for a total of 114,000 responses (114,000x 1 = 114,000). The estimated average burden per response is 10 minutes (0.1666 hours) for a total burden of 19,000 hours (114,000 x 0.1666 = 19,000). This adjustment is due to an anticipated decrease in the number of households submitting applications resulting in a decrease in burden of 77,833 hours.

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