Attachment I. Burden Chart Showing Impact of FInal Rule, CNP: CEP - Increasing Options for Schools, after Merge into OMB Control Number 0584-0026

---

Overview

Reporting
RecordKeeping
PublicNotification
Burden Summary

---

Sheet 1: Reporting

Attachment I. Burden Chart Showing Impact of Final Rule, Child Nutrition Programs: Community Eligibility Provision - Increasing Options for Schools After Merge into OMB Control Number 0584-0026 – 7 CFR Part 245 Determining Eligibility for Free and Reduced Price Meals and Free Milk in Schools
Reporting
				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	Total Difference
State Agency (SA) Level
Meals and Milk Eligibility	245.6(h)(2)(i)	SAs and LEAs that plan to use or disclose information about children eligible for free or reduced price meals and/or free milk in ways not specified in this section must obtain written consent from the child's parent or guardian prior to the use or disclosure.		54	1	54	0.25	14	14	0
Meals and Milk Eligibility	245.6(j)	SAs enter into written agreement with the agency receiving children's free and reduced price meal and/or free milk eligibility information.		54	1	54	0.25	14	14	0
Community Eligibility	245.9(f)(6)	State agency to notify LEAs of their community eligibility status as applicable		55	252	13,862.0	0.050	694	437	257
F/R Eligibility	245.12(g)	SAs notify FNS when there is a change in the State’s TANF Program that would no longer make households automatically eligible for free meals.		54	1	54	0.10	5	5	0
F/R Eligibility	245.12(h)(4)	SAs submit to FNS upon request, the number of schools on Provision 1, Provision 2 or Provision 3 and extensions.		35	1	35	1.50	53	53	0
CIP	245.13(e)	SAs that fail to meet the direct certification benchmark must develop and submit a Continuous Improvement Plan within 90 days of notification.		16	1	16	3.00	48	48	0
Free Milk Eligibility	215.13a(b)	Each State agency, or FNSRO shall provide such institutions with a prototype free milk policy statement and a copy of the State's family-size income standards for determining eligibility for free meals and milk.		52	1	52	0.20	10	10	0
	245.6a (h) 245.11(b)(2) 245.11(c)(3) 245.11(i)	SA reporting burden for electronic reports accounted for in the Food Program Reporting System (FPRS) ICR #0584-0594.	FNS-742, FNS-874
		State Agency Level Total		55	256.85	14127	0.0593	838	581	257
Local Educational Agency (LEA) / School Food Authority Level (SFA)
F/R Eligibility	245.6(c)(6)(i)	LEAs notify households of approval of meal benefit applications.		14,869	219.00000	3,256,311	0.02	54,380	56,290	-1,910
Free Milk Eligibility	245.6(c)(6)(i)	LEAs must notify the household of the children's eligibility in the Special Milk Program after approving their application.		446	8.54	3,808	0.02	64	64	0
Direct Certification	245.6(c)(6)(ii)	LEAs must notify households in writing that children are eligible for free meals based on direct certification and that no application is required.		14,869	332.0000	4,936,508	0.02	82,440	85,099	-2,660
Free Milk Eligibility	245.6(c)(6)(ii)	LEAs must notify households in writing that children are eligible for free milk based on direct certification and that no application is required.		446	20.04	8,938	0.02	149	149	0
F/R Eligibility	245.6 (c)(7)	LEAs provide written notice to each household of denied free or reduced price benefits.		14,869	11.56000	171,886	0.02	2,870	2,963	-92
Free Milk Eligibility	245.6 (c)(7)	LEAs provide written notice to each household of denied free milk benefits		446	0.42691	190	0.02	3	3	0
Meals and Milk Eligibility	245.6(j)	LEAs must have a written agreement with an agency to disclose children's free and reduced price meals and/or free milk eligibility information.		19,371	1	19,371	0.500	9,686	9,686	0
F/R Eligibility	245.6a (f)	LEAs notify households of selection for verification.		14,869	6.50	96,649	0.25	24,162	25,092	-930
F/R Eligibility	245.6a (j)	LEAs must provide households that failed to confirm eligibility with 10 days notice for receiving a reduction or termination of free or reduced price meal benefits.		14,869	2.65000	39,403	0.10	3,948	4,079	-131
Free Milk Eligibility	245.6a (j)	LEAs must provide households that failed to confirm eligibility with 10 days notice for receiving a reduction or termination of free milk benefits.		446	0.047085	21	0.10	2	2	0
F/R Eligibility	245.9 (f)	SFAs with schools under Provisions 1, 2, or 3 must identify those schools in its free and reduced price policy statement and certify their eligibility for the first year of operation.		472	0.25	118	0.25	30	30	0
Community Eligibility	245.9(f)(4)(i)	LEAs submit to State agency documentation of acceptable identified student percentage of LEA/school electing the provision		971	1	971	0.25	243	125	118
Community Eligibility	245.9(f)(5)	LEA to submit to the State agency for publication a list of eligible and potentially eligible schools and their eligibility status; unless otherwise exempted by State agency		13,860	1	13,860	0.08	1,157	729	[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 number rounding differently than in the PRA leads to +1 difference 428
Community Eligibility	245.9(g)	LEAs to amend free and reduced policy statement and certify that schools meet eligibility criteria		971	1	971	0.1	97	50	47
F/R Eligibility	245.9 (h)	SFAs with schools under Provision 2 or Provision 3 submit to FNS upon request all data and documentation used in granting extensions.		472	0.25	118	0.25	30	30	0
F/R Eligibility	245.10 (a)	LEAs submit to SA for approval a free and reduced price policy statement.		18,925	0.25	4,731.25	0.08	395	395	0
Free Milk Eligibility	215.7(d)	Each school food authority approved to participate in the SMP shall enter into a written agreement with the State agency or FNSRO, as applicable, that may be amended as necessary.		446	0.20	89.20	0.50	45	45	0
Free Milk Eligibility	215.13a(c)	Institutions electing to provide free milk shall annually submit a written free milk policy statement for determining free milk eligibility of children under their jurisdiction.		446	1.00	446.00	0.25	112	112	0
		Local Educational Agency / School Food Authority Level Total		19,371	441.597	8,554,389	0.0210	179,812	184,941	-5,129
School Level
Free Milk Eligibility	245.6(a)(1)	Households complete application form for participation in the Special Milk Program.		3,808	1.00	3,808	0.12	445	445	0
F/R Eligibility	245.6 (a)(1)	Households complete application form for free or reduced price meal benefits.		3,439,137	1	3,439,137	0.12	402,035	414,770	-12,735
F/R Eligibility	245.6a (a)(7)(i)	Households assemble written evidence for verification of eligibility for free and reduced price meals and send to LEA.		97,287	1	97,287	0.50	48,644	50,185	-1,542
Free Milk Eligibility	215.13a(g)(2)(iv)	Households respond to requests for verification of eligibility in the Special Milk Program.		114	1	114	0.50	57	57	0
F/R Eligibility	245.6a (a)(7)(ii)	Households cooperate with collateral contacts for verification of eligibility.		1,004	1	1,004	0.10	101	101	0
		Household Level Total		3,442,945	1.03	3,541,350	0.1274	451,281	465,558	-14,277
		Total Reporting Burden		3,462,371	3.50	12,109,867	0.05	631,932	651,080	-19,149

---

Sheet 2: RecordKeeping

Recordkeeping
				A	B	C = (A*B)	D	E= (C*D)	F	G =E-F
Program Rule	CFR Citation	Title	Form Number	Estimated # Record-keepers	Records Per Recordkeeper	Total Annual Records	Estimated Avg. # of Hours Per Record	Estimated Total Hours	Current OMB Approved Burden Hrs	Total Difference
State Agency Level
Direct Certification	245.6(b)(1)(iv)	SA must maintain agreements with the SA conducting eligibility determinations for SNAP.		55	1	55	0.10	6	6	0
Community eligibility	245.9(f)(4)(ii)	State Agency to review and confirm LEAs eligibility to participate in provision		54	9.26	971	0.0835	81	41.75	39
F/R Eligibility	245.12(h)(4)	SA maintains annual October data on number of schools on Provisions 1, 2, or 3 and extensions granted.		35	1	35	1.50	52.50	53	0
F/R Eligibility	245.12(i)	SA maintains annual verification data collected from SFAs (for FNS-742).		54	1	54	0.20	10.53	11	0
CIP	7 CFR 245.13(g)	State agencies that fail to meet the direct certification benchmark must maintain a Continuous Improvement Plan.		16	1	16	0.50	8	8	0
		State Agency Level Total		55	20.56	1,131	0.13936	158	119	39
Local Educational Agency / School Food Authority Level
F/R Eligibility	245.6(e)	LEAs must maintain documentation substantiating eligibility determinations for 3 years after the end of the fiscal year.		14,869	1	14,869	0.08	1,241.6	1,281	-39
Free Milk Eligibility	215.7(7)	Upon request, make all records pertaining to its milk program available to the State agency and to FNS; such records shall be retained for a period of three years after the end of the fiscal year to which they pertain.		446	1	446	2.50	1,115.0	1,115	0
Community eligibility	245.9(h)(3)	LEA to maintain documentation related to methodology used to calculate the identified student percentage and determine eligibility		971	1	971	0.90	876	451	425
		Local Educational Agency / School Food Authority Level Total		15,315	1.06	16,286	0.19847	3,232	2,847	385
		School Level Total		-		-	-	-	-	0
		Total Recordkeeping Burden		15,370	1.13	17,417	0.195	3,390	2,966	424

---

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	Existing Requirements in Use without OMB approval	Due to an Adjustment	Total Difference
State Agency Level
F/R Eligibility	245.3(a) & 245.12(a)(2)	Each SA shall by July 1 announce family-size income standards to be used by LEAs in making eligibility determinations for free or reduced price meals and for free milk.		54	1	54	0.10	5.4	5.4				0
Community Eligibility	245.9(f)(7)	State agency to make publically available the names of LEAs and schools receiving notifications		55	1	55	0.167	9.19	9.19	0.00	0.00	0	0
		State Agency Level Total		55	1.98	109	0.13	14.60	14.59	0	(0)	0	0.01
Local Educational Agency / School Food Authority Level
F/R Eligibility	245.5 & 245.9 & 245.3(b)	LEAs publicly announce criteria for determining eligibility of children for free and reduced price meals (or free milk) or participation in Provision 1, 2, or 3 in an annual media release.		18,925	1	18,925	0.25	4,731.25	4,731			0	0
F/R Eligibility	245.7(a)(2)(i)	LEAs publicly announce method to make an oral or written request for a hearing.		18,925	1	18,925	0.10	1,896	1,896.0			0.0	0.00
Free Milk Eligibility	215.13a(e)	LEAs with schools offering free milk available under the Special Milk Program shall annually make a public announcement.		446	1	446	0.25	111.5	111.5				0.0
		Local Educational Agency / School Food Authority Level Total		19,371	1.98	38,296	0.176	6,739.04	6,738.8	0	0	0	0.00
		Total Public Notification Burden		19,426	1.98	38,405	0.176	6753.63	6,753.34	0	(0)	0	0.01

---

Sheet 4: Burden Summary

ICR #0584-0026, 7 CFR Part 245, Free and Reduced Price Eligibility - Summary
	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	55	20.56	1,131	0.139	158
Local Educational Agency Level	15,315	1.06	16,286	0.198	3,232
Recordkeeping Total	15,370	1.13	17,417	0.195	3,390
Reporting
State Agency Level	55	256.85	14,127	0.06	838
Local Educational Agency Level	19,371	441.597	8,554,389	0.021	179,812
Household Level	3,442,945	1.03	3,541,350	0.13	451,281
Reporting Total	3,462,371	3.50	12,109,867	0.05	631,932
Public Notification
State Agency Level	55	2	109	0.13	15
Local Educational Agency Level	19,371	2	38,296	0.176	6,739.04
Public Notification Total	19,426	1.98	38,405	0.176	6,754
TOTAL BURDEN	3,462,371	3.514	12,165,689	0.053	642,075
SLT Subtotal	19,426	443.958526201997	8,624,338	0.022122682196885	190,793
I/H Subtotal	3,442,945	1.0285817054876	3,541,350	0.127432043010804	451,281
Total	3,462,371	3.51368717274954	12,165,689	0.052777529889786	642,075
	Responses	Hours
Currently Approved Burden	12,550,211	660,799
Requested	12,165,689	642,075
Difference	-384,522	-18,724