Reply to Public Comment from Vulgamore Family Farm - 06-13-2024

United States Department of Agriculture
National Agricultural Statistics Service

June 10, 2024

VFF Management Team
Vulgamore Family Farms
Western Kansas
Dear VFF Management Team:
Thank you for your letter pertaining to the National Agricultural Statistics Service’ (NASS)
intention to renew the surveys in the Agricultural Labor Information Collection Request (ICR).
Your support of the Agricultural Labor Survey is appreciated. Your submitted letter included
some recommendations for the upcoming Agricultural Labor Surveys and use of the summarized
data from the survey, which will be addressed here.
At the conclusion of each survey, NASS evaluates its performance to identify potential
improvements. The evaluation includes agency experts on agricultural labor and survey
methodology with cognitive testing of potential significant changes. The current instruction to
report wages on the questionnaire “Gross wages are the total amount paid to workers before
taxes and other deductions. INCLUDE the worker’s share of social security and unemployment
insurance, but EXCLUDE the employer’s share. INCLUDE in-kind payments (e.g., agricultural
product like a side of beef, bushels of grain, etc.) provided in lieu of wages for work done. Inkind payments do NOT INCLUDE benefits such as housing, meals or insurance.” was the result
of the evaluation. NASS offers assistance for respondents on completing the survey by calling 1888-424-7828 between the hours of 7 A.M. to 4 P.M. ET.
NASS is transparent in our methodologies for data collection and estimation of the farm labor
data. The Farm Labor Methodology and Quality Measures documents response rates along with
information how the surveys are conducted. The Farm Labor Methodology and Quality
Measures documents and questionnaires used can be found at this link on NASS’ public website:
https://www.nass.usda.gov/Publications/Methodology_and_Data_Quality/Farm_Labor/index.php
One goal of any change to the Agricultural Labor Survey is to minimize respondent burden while
keeping to the purpose of the survey as mentioned in the “Farm Labor Methodology and Quality
Measures”.
The Agricultural Labor Survey is conducted at a level consistent with appropriated funds from
the US Congress. DOL partially funded the NASS farm labor program until FY2021.
Additional funding would be required for the collection and summarization of additional
information.
USDA is an equal opportunity provider and employer.

Hopefully, this answers your questions about how data are collected and summarized for the
Agricultural Labor Survey.
The Farm Labor Methodology and Quality Measures and other documents pertaining to the
Agricultural Labor Survey along with a proposed questionnaire and other comments NASS
received will be made available later this summer for a 30-day public comment period. A
Federal Register Notice (FRN) for OMB Control Number 0535-0109 will be published when
that happens; the FRN will include instructions on how to review and comment further on the
survey before official action is taken by the Office of Management and Budget (OMB).
As a reminder, the U.S. Department of Labor is responsible for all policy and implementation of
the Adverse Effect Wage Rate (AEWR). Federal Register Notices on AEWR provide a
Department of Labor contact for more information about AEWR. Federal Register Notices may
provide the public an opportunity to comment on proposed methodology changes for setting the
AEWR.
We will keep you informed of any other modifications through Federal Register Notices.
Sincerely,

LANCE
HONIG

Digitally signed by
LANCE HONIG
Date: 2024.06.13
10:27:19 -04'00'

Lance Honig
Chair, Agricultural Statistics Board
U.S. Department of Agriculture
National Agricultural Statistics Service