| Attachment A. Burden Chart for OMB Control Number 0584-0280, Final Rule, Child Nutrition Programs: Meal Patterns Consistent with the 2020-2025 Dietary Guidelines for Americans |
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| Reporting |
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A |
B |
C = (A*B) |
D |
E= (C*D) |
F |
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G =E-F |
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| 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 |
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| State/Local/Tribal Governments |
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| 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 . |
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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 |
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0.00 |
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0 |
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| SFSP |
225.4(a) |
SAs, by Feb. 15 of each year, submit to FNSRO a Program Management and Administration Plan for that fiscal year. |
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53 |
1 |
53 |
1 |
53 |
53 |
0 |
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0 |
0 |
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| 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. |
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53 |
1 |
53 |
1 |
Hoang, Thoa K. - FNS:
SAs sibmit one report and time is adjusted in consultation with SA staff.
53 |
53 |
0 |
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0 |
0 |
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| 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. |
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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 |
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0 |
0 |
0 |
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| 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. |
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53 |
bkowtha:
one report per SA
1 |
53 |
1 |
53 |
53 |
0 |
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0 |
0 |
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| SFSP |
225.9(d)(4) |
SAs forward reimbursements for valid claims. |
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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 |
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0 |
0 |
0 |
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| SFSP |
225.12(a) |
SAs establish claims against sponsors and recover payment not properly payable. |
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53 |
bkowtha:
10% of average number sponsors
10 |
530 |
4 |
2120 |
2,120 |
0 |
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0 |
0 |
0 |
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| SFSP |
225.18(b)(2) |
SAs notify terminated sponsors in writing. |
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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 |
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0 |
0 |
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| 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. |
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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 |
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0.00 |
0.00 |
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| 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 . |
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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 |
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| 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. |
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640 |
1 |
640 |
1 |
640 |
640 |
0 |
0 |
0 |
0 |
0 |
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| SFSP |
225.6(c)(3) |
Experienced sponsors and experienced sites must submit site information for each site where a food service operation is proposed. |
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2,675 |
1 |
2675 |
1 |
2675.00 |
2675 |
0 |
0 |
0 |
0 |
0 |
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| 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. |
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332 |
1 |
332 |
0.123 |
40.84 |
40.84 |
0 |
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0 |
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0 |
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| 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. |
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1,157 |
1 |
1,157 |
0.5 |
578.50 |
578.50 |
0 |
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0 |
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0 |
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| SFSP |
225.6(h)(3) |
Sponsors submit requests to SAs for exception to unitizing requirement for certain components of a meal. |
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11.57 |
1 |
11.57 |
0.5 |
5.79 |
5.79 |
0 |
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0 |
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0 |
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| 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. |
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1,157 |
1 |
1157 |
20 |
23140 |
23,140 |
0 |
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0 |
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0 |
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| SFSP |
225.15(d)(2) |
Sponsors must visit each of their sites at least once during the first week of operation under the Program. |
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3,314 |
9 |
29,826 |
0.50 |
14,913 |
14,913 |
0 |
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0 |
0 |
0 |
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| 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. |
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3,314 |
9 |
29,826 |
2 |
59,652 |
59,652 |
0 |
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0 |
0 |
0 |
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| 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. |
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3,314 |
1 |
3314 |
0.25 |
828.50 |
828.50 |
0 |
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0 |
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0 |
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| State/Local/Tribal Governments Total |
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3367 |
36 |
120,071 |
2.11 |
253,664 |
253,664 |
0.00 |
0 |
0 |
0.00 |
0.00 |
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| Businessess (Non-profit Institutions and Camps) |
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| 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 . |
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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 |
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0.00 |
0 |
0.00 |
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| 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. |
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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 |
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0 |
0 |
0 |
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| SFSP |
225.6(c)(3) |
Experienced sponsors and experienced sites must submit site information for each site where a food service operation is proposed. |
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1,783 |
1 |
1,783 |
1 |
1,783 |
1,783 |
0 |
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0 |
0 |
0 |
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| 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. |
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bkowtha:
10% of sponsors
221 |
1 |
221 |
0.12 |
27 |
27 |
0 |
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0 |
0 |
0 |
HHFKA requires permanent agreements deleting the annual submission |
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| 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. |
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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 |
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0 |
0 |
0 |
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| SFSP |
225.6(h)(3) |
Sponsors submit requests to SAs for exception to unitizing requirement for certain components of a meal. |
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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 |
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0 |
0 |
0 |
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| 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. |
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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 |
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0 |
0 |
0 |
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| SFSP |
225.15(d)(2) |
Sponsors must visit each of their sites at least once during the first week of operation under the Program. |
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2,210 |
9 |
19,890 |
0.50 |
9,945 |
9,945 |
0 |
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0 |
0 |
0 |
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| 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. |
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2,210 |
9 |
19,890 |
2 |
39,780 |
39,780 |
0 |
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0 |
0 |
0 |
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| 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. |
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2,210 |
1 |
2,210 |
0.25 |
552.50 |
552.50 |
0 |
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0 |
0 |
0 |
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| SFSP |
225.6(c)(5) |
Camps submit copy of hearing procedures. |
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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 |
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0 |
0.00 |
0.00 |
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| Businessess (Non-profit Institutions and Camps) Totals |
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2,210 |
22 |
48,515 |
3.21 |
155,721.79 |
155,721.79 |
0.00 |
0 |
0 |
0.00 |
0.00 |
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| Households |
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| SFSP |
225.15(f) |
Households read instructions, complete free meal and return to camps and sites. |
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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 |
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0 |
0 |
0 |
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| SFSP |
225.15(j) |
Households provide written consent for sponsors to use or disclose information. |
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58,365 |
1 |
58,365 |
0.25 |
14,591.25 |
14,591.25 |
0 |
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0 |
0 |
0 |
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| Household Totals |
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58,365 |
2 |
116,730 |
0.38 |
43,773.75 |
43,773.75 |
0.00 |
0 |
0 |
0 |
0.00 |
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Total Reporting Burden |
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63,942 |
4.46 |
285,316.01 |
1.59 |
453,159.55 |
453,159.55 |
0 |
0 |
0 |
0 |
0 |
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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 |
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SLT burden |
3,367 |
36 |
120,071.29 |
2.113 |
253,664.01 |
253,664.01 |
- |
- |
0 |
0 |
- |
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Business burden |
2,210 |
22 |
48,514.72 |
3.2 |
155,721.79 |
155,721.79 |
- |
- |
- |
- |
- |
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Household burden |
58,365 |
2 |
116,730 |
0.4 |
43,773.75 |
43,773.8 |
- |
- |
- |
- |
- |
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Total |
63,942 |
4.46 |
285,316 |
1.59 |
#REF! |
#REF! |
0.00 |
0 |
0 |
0 |
#REF! |
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| Recordkeeping |
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A |
B |
C = (A*B) |
D |
E= (C*D) |
F |
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G =E-F |
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| 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 |
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| State/Local/Tribal Governments |
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| 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. |
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1. Reviews |
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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 |
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| 2. Appeals |
|
53 |
Kowtha, Bramaramba - FNS:
avg number
2 |
106 |
0.08 |
8.48 |
8.48 |
0 |
0 |
0 |
0 |
0 |
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| 3. Accounting |
|
53 |
bkowtha:
5524/53=104
104 |
5512 |
0.08 |
440.96 |
440.96 |
0 |
0 |
0 |
0 |
0 |
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| SFSP |
225.15 (c), 225.15 (a), 225.15(g) |
Sponsors must maintain records which justify all costs and meals claimed. |
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3,314 |
1 |
3,314 |
0.08 |
265.12 |
265.12 |
0 |
0 |
0 |
0 |
0 |
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| State/Local/Tribal Governments Total |
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3,367 |
3 |
10,999 |
0.08 |
880 |
879.92 |
0.00 |
0 |
0.00 |
0 |
0.00 |
|
| Businessess (Non-profit Institutions and camps) |
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| SFSP |
225.15 (c), 225.15 (a), 225.15(g) |
Sponsors must maintain records which justify all costs and meals claimed. |
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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 |
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| 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. |
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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 |
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| SFSP |
225.6(c)(5)(xii) |
Camps must maintain a written record of hearing for 3 years. |
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333 |
1 |
333 |
0.30 |
99.90 |
99.90 |
- |
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0 |
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0.00 |
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| Menu Planning Option for SFSP |
225.16(f)(3) |
Summer Food Service Program Sponsors maintain documentation demonstrating that service sites qualify for the menu planning option to serve vegetables to meet the grains requirement by serving primarily American Indian and Alaska Native children. |
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20 |
1 |
20 |
1.25 |
25.00 |
- |
- |
- |
0 |
25 |
25.00 |
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| Businessess (Non-profit Institutions and Camps) Totals |
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2,210 |
40.7 |
89,923 |
0.08 |
7,290.50 |
7,265.50 |
0 |
0 |
0 |
25 |
25 |
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Total Recordkeeping Burden |
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5,577 |
18.10 |
100,922 |
0.08 |
8,170.42 |
8,145.42 |
0 |
0 |
0 |
25 |
25 |
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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 |
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SLT burden |
3,367 |
3 |
10,999 |
0.08 |
879.92 |
879.92 |
0 |
0 |
0.00 |
0 |
0.00 |
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Business burden |
2,210 |
40.69 |
89,923 |
0.08 |
7,290.50 |
7,265.50 |
- |
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- |
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25.0 |
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Total |
5,577 |
18.10 |
100,922 |
0.08 |
8,170.42 |
8,145.42 |
0 |
0 |
0.00 |
0 |
25 |
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