SUPPORTING STATEMENT - PART A for
OMB Control Number 0584-0401:
FOOD DELIVERY PORTAL (FDP) Data Collection
Lisa Hodgkins
Program Analyst
Policy Division
WIC Vendor & Technology Branch
USDA, Food and Nutrition Service
1320 Braddock Place
Alexandria, Virginia 22314
703-305-2646
Table of Contents
A1. Circumstances that make the collection of information necessary. 3
A2. Purpose and Use of the Information. 3
A3. Use of information technology and burden reduction. 5
A4. Efforts to identify duplication. 7
A5. Impacts on small businesses or other small entities. 8
A6. Consequences of collecting the information less frequently. 7
A7. Special circumstances relating to the Guidelines of 5 CFR 1320.5. 9
A8. Comments to the Federal Register Notice and efforts for consultation. 9
A9. Explain any decisions to provide any payment or gift to respondents. 13
A10. Assurances of confidentiality provided to respondents. 13
A11. Justification for any questions of a sensitive nature. 16
A12. Estimates of the hour burden of the collection of information. 16
A13. Estimates of other total annual cost burden. 21
A14. Provide estimates of annualized cost to the Federal government. 21
A15. Explanation of program changes or adjustments. 23
A16. Plans for tabulation, and publication and project time schedule. 26
A17. Displaying the OMB Approval Expiration Date. 26
A18. Exceptions to the certification statement identified in Item 19. 27
Appendices
Appendix A: CNA_1966_12-13-10
Appendix B: 7 CFR 246 Citations
Appendix C: FDP State Agency File Upload Templates v1.8 10042023
Appendix D: FDP File Upload Instructions v1.2 04042020
Appendix E: FDP Screenshots
Appendix F: Salesforce_ Authorization to Operate (ATO)_11-20-23
Appendix G: 2023 Salesforce Submitted PIA and PTA
Appendix I: FDP FRN IL comment
Appendix J: FDP FRN WY comment
Appendix K: FDP FRN RB comment
Appendix L: FDP FRN MN comment
Appendix M: FDP FRN WI comment
Appendix N: FDP FRN MI comment
Appendix O: FDP FRN MD comment
Appendix P: FDP FRN NWA comment
Appendix Q: FDP FRN ITCA comment
Appendix R: FDP FNS WI 2 comment
Appendix S: FDP FRN AZ comment
Appendix T: FDP FRN LA comment
Appendix U: FDP FRN TX comment
Appendix V: FDP FRN Otoe-Missouria comment
Appendix W: FDP Header Files Collection 10022023
Appendix X: FDP-User-Manual-v1.8-Final 03-18-2024
Appendix Y: Food Delivery Portal (FDP) Burden Chart
Appendix Z: FNS-866 -FDP ICR
Appendix 1: FDP FRN MD comment response
Appendix 2: FDP FRN NWA comment response
Appendix 3 Otoe Food Delivery Portal Federal Register Notice 89 FR 14622 response.msg
Appendix 4 TX Food Delivery Portal Federal Register Notice 89 FR 14622 response.msg
Appendix 5 AZ Food Delivery Portal Federal Register Notice 89 FR 14622.msg
Appendix 6 WI 2 Food Delivery Portal Federal Register Notice 89 FR 14622.msg
Appendix 7 ITCA Food Delivery Portal Federal Register Notice 89 FR 14622.msg
Appendix 8 MI Food Delivery Portal Federal Register Notice 89 FR 14622.msg
Appendix 9 WI Food Delivery Portal Federal Register Notice 89 FR 14622.msg
Appendix 10 MN Food Delivery Portal Federal Register Notice 89 FR 14622.msg
Appendix 11 IL Food Delivery Portal Federal Register Notice 89 FR 14622.msg
Appendix 12 RB Food Delivery Portal Federal Register Notice 89 FR 14622.msg
Appendix 13 WY Food Delivery Portal Federal Register Notice 89 FR 14622.msg
Appendix 14 LA Food Delivery Portal Federal Register Notice 89 FR 14622.msg
Appendix 15 WIC Food Delivery Portal Information Collection Request invitation to comment.msg
Appendix 16 86 FR 55803 FDP SORN
Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
This is a revision of a currently approved Food Delivery Portal (FDP) Data Collection. The FDP data is collected from the Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Program State agencies.
The WIC Program was created and is funded under the Child Nutrition Act of 1966 (Appendix A). The regulations at 7 CFR 246.12(j)(5) require WIC State agencies to report annually on their vendor monitoring efforts (Appendix B). The data is used primarily at the Regional and National FNS level as an oversight tool and to provide Congress, the Office of the Inspector General, senior program managers, as well as the public, assurances that program funds are being spent appropriately and every reasonable effort is being made by State agencies to prevent, detect, and eliminate fraud, waste and abuse.
Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate how the agency has actually used the information received from the current collection.
The current collection gathers data from WIC State agencies. Per 7 CFR 246.12(j)(5), WIC State agencies are required to annually report “a summary of the results of its vendor monitoring containing information stipulated by FNS.” (Appendix B). FNS requires that all WIC State agencies use the federally provided web-based tool to submit the annual report of the information documented in their WIC State agency records.
For each authorized vendor, WIC State agencies report on vendor training, redemptions, routine monitoring, compliance investigation, observed violations, claims and sanctions for applicable vendors. For each annual report, WIC State agencies will review their previous year’s information and may choose to update only the data needed for the reporting year.
FNS uses the data for Federal oversight of the WIC Program and to ensure compliance with WIC Program regulations. Specifically, FNS uses the data in FDP to ensure that WIC State agencies are providing appropriate vendor training, consistently monitoring vendors for compliance with Program rules, conducting the required ratio of compliance investigations, and are applying the correct sanctions for any patterns of violations identified. FNS works with State agencies to address any discrepancies or anomalies in the data. Final WIC State agency data is aggregated by FNS at the national level, to generate nationwide reports and trend analysis. Additionally, FNS uses this data to provide information on WIC State agency vendor management and vendor compliance to stakeholders, including Congress, USDA’s Office of the Inspector General (OIG), outside auditors, researchers, and the public.
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
In compliance with the E-Government Act of 2002, all data is collected electronically through a federal web-based system. Out of the estimated 541 responses for this information collection, FNS estimates that one hundred percent (100%) will be collected electronically.
Since fiscal year 2005, WIC State agencies have used USDA-provided applications (The Integrity Profile and the Food Delivery Portal) to electronically submit their vendor management data. In fiscal year 2022, FNS began using the Food Delivery Portal (FDP) to align with current security protocols, compliance guidance, increase data storage, ensure cost effectiveness, and provide data-driven reporting. FDP uses the private WIC Gateway (WICGateway.usda.gov) web site to provide access to FDP. The FDP URL is not available to the public and requires an approved USDA trusted customer login for WIC State agency users.
FDP’s platform offers WIC State agencies flexibility in data reporting cycles and additional data reports and analytic tools. The data WIC State agencies provide in their annual submission is extracted from their WIC State agencies’ management information systems (MIS) or vendor documentation records. FDP users can choose to provide manual updates to fields in the screens or provide a batch file upload of vendor information. FDP does not need the full vendor record recreated each year, which streamlines the reporting process. FNS estimates approximately 96.93% of all vendors authorized by the WIC Program are also authorized by Supplemental Nutrition Assistance Program (SNAP), so FDP shares data with SNAP’s Store Tracking and Redemption System (STARS), included in OMB Control No. 0584-0008, SNAP - Store Applications, Expiration Date: 04/30/2027. FDP imports data records from STARS which provides data for WIC State agencies. FNS is researching future enhancements that could integrate State agency MIS with FDP, which could significantly reduce the burden associated with data preparation.
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in
Question 2.
Although there are some data elements in FDP that provides similar information to other data collections, there is no direct duplication. FNS has reviewed USDA reporting requirements. FNS is the sole Federal agency that monitors WIC State agencies’ vendor compliance efforts. FDP is the only system of record for this information.
If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.
FNS has determined that there are no small businesses or other small entities included or impacted by this information collection. All respondents are employees of WIC State agencies. Out of the 89 State agency respondents for this information collection, FNS estimates that none of them will be small entities.
Describe the consequence to Federal program or policy activities if the collection is not conducted, or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
This is an annual ongoing, mandatory information collection request required by regulation. If this collection is not conducted, FNS could not ensure the integrity of the program and this would hinder FNS’ ability to provide Federal oversight to WIC State agencies in their process to prevent, detect, and eliminate fraud, waste, and abuse. Information on each vendor record is collected only once in a fiscal year. Reducing the frequency of collection would result in slower and less frequent identification of deficiencies, and effective corrective actions. WIC State agency vendor management and compliance activities are reported to stakeholders, Congress, USDA’s Office of the Inspector General (OIG), outside auditors, researchers, and the public.
Explain any special circumstances that would cause an information collection to be conducted in a manner:
Requiring respondents to report information to the agency more often than quarterly;
Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
Requiring respondents to submit more than an original and two copies of any document;
Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;
In connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;
Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
That includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
Requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
There are no special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.5.
If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
The 60-day Federal Register Notice announcing FNS’ intention to revise the OMB approved collection 0584-0401 was published in the Federal Register on February 28, 2024, at 89 FR 14622. The public comment period ended on April 29,2024. FNS provided an invitation to comment to 3 outside agencies, The National WIC Association [email protected], The Center on Budget and Policy Priorities [email protected]; and The National Indigenous and Native American WIC Coalition [email protected]. FNS has received 14 comments from public commenters including one comment from the National WIC Association through the Federal eRulemaking Portal at https://www.regulations.gov.The majority of commenters came from State agencies with the one comment from the National WIC Association.
All comments have been publicly posted and reviewed by the agency. Summaries of the comments are listed below, and the comments are attached in the Appendices I-W.
The Federal Register Notice posting requested feedback from the public on the collection in the areas of proper performance and practical utility, methodology and estimate in the calculation of the burden, enhancing the quality and clarity of the burden and ways to minimize the burden. The sections from the notice are listed below along with the summary of the comments received. The full comments are also attached as appendices. The agency has reviewed all of the comments and has adjusted the burden table to reflect the feedback provided. The agency will continue to make changes to FDP based on feedback from State agencies through the ongoing application development and enhancement processes to lessen the burden and ensure increased the efficiency of the Food Delivery Portal.
FRN Comment Section a: Whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility;
Commenters reported:
FDP is not used by State agencies for State agency functions, but for compliance with national WIC regulations regarding reporting annual program data on vendor monitoring. State agencies use their Management Information Systems for their State agency vendor functions.
State agencies report the volume and type of information requested in FDP is excessive.
The agency has reviewed the comments for this section of the Federal Register Notice 86 FR 14622 and recognizes that FDP primarily serves as a tool to confirm State agencies’ compliance with WIC regulations, and not as a tool for State agencies in their daily vendor management functions. The agency also acknowledges the request for data includes optional fields that State agencies may find excessive; however, all required fields are necessary to ensure State agency compliance with WIC regulations, or to maintain the relationships between data elements within the application.
FRN Comment Section b: The accuracy of the agency's estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions that were used;
Regarding the accuracy of the agency’s estimate of the burden, commenters reported:
The time needed to prepare, upload, and correct data for FDP ranged from 10 hours to 80 hours, higher than what the burden estimated.
The process of addressing file errors was time-consuming, but this activity was not addressed in the burden table.
Template changes require extra time for state staff and MIS Contractors, but MIS Modernization should reduce the burden in the future.
There are more required data fields in FDP than in the previous system, The Integrity Profile (TIP). The burden is also higher in FDP than in TIP.
System timeouts and other system limitations (e.g., the amount of data that can be uploaded into FDP at one time) have increased the burden for State agencies.
The agency has reviewed the comments and agrees to minimize the template changes, review possible solutions to template errors and adjust the burden table. In response to commenters that reported the time needed to upload and manually enter data is higher than what the burden estimates, the agency clarifies that the burden table’s estimates for the manual entry of a record, manual update of existing record, and data upload do not include any time to prepare the data and only expresses the time it takes to enter data into the spreadsheet for upload or into the FDP system once the data has been fully prepared without need for correction. Data preparation for FDP is measured by the “Data Preparation for this ICR”.
Commenters expressed that the burden for data preparation is significantly larger than stated in the proposed burden table due to differences in MIS outputs and reporting requirements for FDP. Based upon the range of burden hours presented in the comments we have increased the burden estimate of data preparation from 10 hours to 30 hours.
After reviewing comments regarding the burden needed to correct upload templates, the agency acknowledges that the proposed burden table didn’t factor in the time needed to address errors in the upload process. A new section has been added to burden table to reflect this burden, including an estimate of 10 hours for error corrections for the data upload.
Some commenters stated that FDP requires more data fields than the previous system, TIP. This is due to the change in data design between the previous and the current applications. TIP could not report multiple trainings or investigations on an annual basis, nor could it identify the monthly redemption information needed to compare WIC and SNAP data over the same partial year period. FDP allows State agencies to report with more accuracy the full scope of their vendor monitoring activities.
The agency acknowledges that the FDP system encountered unexpected issues with processing large uploads of data that increased the burden for State agencies. This issue has since been investigated and resolved for the FY 2023 data reporting cycle. The agency will continue to investigate system-level issues that may cause unnecessary burden on State agency users.
FRN Comment Section c: Ways to enhance the quality, utility, and clarity of the information to be collected;
To enhance the quality, utility, and clarity of the information to be collected, commenters reported:
Improve error messages to clearly identify the issue or improve the file upload process to allow for more flexibility with formatting
Improve documentation and better describe data for specific fields
Continue to build useful, filterable reports that include data from multiple State agencies
Improve agency response time to help desk requests, and provide more frequent real-time updates and technical assistance
Work with state vendor managers and staff to best meet State agencies needs in FDP
Continue to provide training as improvements and features are built or modified in FDP
Commenters provided information for improvements and changes to the collection which will be considered by the agency. The agency will continue to use State agency feedback to enhance the Food Delivery Portal to improve the uploads and data entry processes.
FRN Comment Section d: Ways to minimize the burden of the collection of information on those who are to respond, including use of appropriate automated, electronic, mechanical, or other technological collection techniques or other forms of information technology;
To minimize the burden, commenters reported:
Improve file uploads to allow for formatting issues like spacing and case sensitivity or allow State agency users to address errors without re-uploading files
Stabilize the process of data collection before changing data submission requirements
Combine and improve templates to reduce the number of uploads
Additional funding is needed to hire and train staff and to modify State agencies’ MIS to meet FDP requirements
Reduce the required data fields and reduce redundancy between State plan, cost containment reports, and FDP file submission
Provide more frequent updates when changes are made to FDP reporting requirements
Use an Application Programming Interface to connect with external data systems
Comments were received which provided feedback to minimize the burden of the collection. The agency has reviewed the recommendations and will consider the improvements to the file upload and manual entry process, documentation, and timely technical assistance.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years even if the collection of information activity is the same as in prior years. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
Consultation with WIC State agencies is done on at least an annual basis during vendor management and vendor staff and stakeholder meetings to gather feedback on reporting issues and provide State agencies an opportunity to share ideas for reporting improvements. Regional offices are asked regularly to share feedback from State agencies regarding concerns or requests related to data collection and reporting. Three external entities were also invited to comment on the FRN: The National WIC Association, The Center for Budget and Policy Priorities and the National Indigenous and Native American WIC Coalition. Additionally, all users can submit questions and comments through the WIC FDP help desk and all emails are addressed on an on-going basis.
All comments received from WIC State agencies and external entities are evaluated and considered for system design changes and improvements. State agency feedback has been received through the FRN, the FDP helpdesk, Office hours training and other avenues. System changes based on WIC State agency feedback have included additional SNAP Store Tracking and Redemption System (STARS) information available through FDP, additional and improved reports and accessible screen functionalities, additional training with uploading State agency data, and enhanced error messages to clarify needed changes.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payments or gifts are provided to respondents.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
The Department will comply with the Privacy Act of 1974, and the WIC confidentiality requirements in §246.26(e) (Appendix B). The regulation restricts the release of the vendor information to only those persons directly connected with the administration or enforcement of the WIC Program or SNAP who the State agency determines have a need to know the information for purposes of these programs, or with the administration or enforcement of any Federal or State law or local law or ordinance.
The privacy risks associated with FDP are centered on the unauthorized disclosure of personally identifiable information (PII) hosted on the platform. While the FDP does not include a form that requires a Privacy Act Statement, as indicated in the associated Privacy Threshold Analysis, and Privacy Impact Analysis (Appendix G), and the Authorization to Operate (ATO) (Appendix F), a Privacy Act Statement is included for the FDP on the WIC Gateway homepage.
The 60-Day Notice published in the Federal Register on February 28, 2024, was reviewed by the FNS Privacy Officer on January 9, 2024. There were no specific comments or concerns cited by the FNS Privacy Officer for FDP. FNS published a new System of Records Notice (SORN Appendix 17) entitled USDA/FNS-12, Food Delivery Portal (FDP) in the Federal Register on October 7, 2021 (86 FR 55803). The SORN was published for this ICR when FDP replaced The Integrity Profile (TIP) to house State agency vendor management data for the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC). FDP maintains records of activities conducted, authorized by legislation pursuant to FNS’ mission and responsibilities.
7 CFR § 246.12 is the specific legal authority that defines the collection of information. This collection requests personally identifiable information on vendors (i.e. stores) registered with the WIC State agencies and the USDA SNAP Program. FDP may collect for any record the FNS Authorization Number, business owner name, and business owner email (i.e. these are all optional fields for a given record). This is the information provided to the WIC State agency and FNS on the vendor or retailer application and/or agreement forms/contract.
FDP will provide a unique FNS WIC ID for each vendor record created by a WIC State agency. This number tracks the vendor information within a WIC State agency and could be used to uniquely identify the record.
FDP utilizes the Shield Platform Encryption for Salesforce to mitigate the threat to unauthorized disclosure of PII. With Shield Platform Encryption, the System Administrator can encrypt a variety of widely used standard fields, along with some custom fields, and many kinds of files. Shield Platform Encryption also supports user accounts, cases, search, approval processes, and other key FDP features.
In addition, records in FDP are secured according to applicable rules and policies, including automated systems security and access policies. FDP is hosted in a secure server environment that uses a firewall to prevent interference or access from outside intruders. When accessing FDP, Secure Socket Layer (SSL) technology protects the user’s information by using both server authentication and data encryption. From a physical security standpoint, the servers that host FDP are stored in a remote data center with strict physical access control procedures in place to prevent unauthorized access.
User access to FDP is limited to those individuals who have a need to know the information for the performance of their official duties and who have appropriate clearances or permissions, using USDA trusted customer login and least role privileges. All FDP users must have either an authorized USDA employee network account or be registered as a WIC State agency user with a USDA trusted customer login. The USDA has a System of Record Notice (SORN) for eAuthentication entitled “USDA/OCIO-2 eAuthentication Service” which was published in the Federal Register on March 14, 2012 (77 FR 15024). The requirement and burden for creating the new USDA trusted customer login is approved under OMB Control No. 0503-0014 USDA eAuthentication Service Customer Registration, Expiration: 09/30/2026.
Users need to file an FNS-674 form with the STARS Confidentiality Agreement addendum and have an active Login.gov account to add FDP as a system for their account. The FNS-674 and the burden associated with it is approved under OMB Control No. 0584-0532 The FNS User Access Request Form Data Collection, Expiration: 08/31/2027. The FDP user’s efforts in creating both an USDA trusted customer login account and filling in the FNS-674 form and STARS Confidentiality Agreement addendum are included in the estimates of 30 hours for the data preparation. The FDP user’s efforts in creating both an USDA trusted customer login account and filling in the FNS-674 form and STARS Confidentiality Agreement addendum are included in the estimates of 30 hours for the data preparation. Login.gov collects user identifying information to validate identity is collected pursuant to 6 USC § 1523 (b)(1)(A)-(E), the E-Government Act of 2002 (Pub. L. 107–347, 44 U.S.C. 3501 note), 40 USC § 501, 40 USC § 502, and OMB M-19-17.
All federal contractors are required under their development contract to agree to all USDA security monitoring and training, perform activities to actively monitor system security, prevent security incidents, respond to security incidents, and remediate security vulnerabilities within the platform. This ensures they prevent the disclosure of PII fields (FNS Authorization Number, business owner name, business owner email, and FNS WIC ID), any other system data, and any technical information regarding the system architecture.
Provide additional justification for any questions of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
There are no questions of a sensitive nature included in this clearance. Any PII or sensitive information is secured as detailed in question A10 above.
Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.
A. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.
This is a revision of a currently approved collection. With this revision, FNS estimates that this collection will have 356 respondents, 541 responses, and 3,576 burden hours.
The number of WIC State agency respondents for this information collection is 89. This includes the 89 WIC State agencies from the 50 geographic State agencies, 33 State agencies operated by Indian Tribal Organizations, the District of Columbia, Puerto Rico, Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, and the Virgin Islands. The total number of respondents reflects the number of respondents for all instruments described in the burden table (i.e., the manual updating of the new and existing records, for the data uploads, data preparation, State agency system feedback and error corrections for data uploads). In the burden chart (Appendix Z), the manually updated records are counted separately, while the data uploads are counted as a single response. This results in a total 356 respondents across all the instruments in the collection.
FNS has estimated the burden hours using data from fiscal year 2022, and comments provided by users or stakeholders. We have divided the burden hours out by data submission method and existing or new records; and we have included line items for data preparation, error corrections for data uploads and WIC State agency feedback. The final burden estimates are rounded up to the nearest one hundredth. The overall total hours requested for this revision are 3,576; which is an overall increase of 2,386.5 hours from the currently approved 1,189 burden hours. Table 12.1 and the Excel Burden Chart (Appendix Z) details the burden estimates for this information collection as described below. The burden increase is based on the feedback from State agencies resulting in the increase in hours and the addition of a row for error corrections for data uploads. The prior estimate was developed with agency internal testing prior to deployment of FDP to the State agencies. The agency has made system changes to FDP based on State agency feedback to create more efficient data uploads, provide clear error messages, and to minimize data preparation. The agency also provides ongoing technical assistance and training on a variety of topics to provide relevant information to assist in reducing the burden on State agencies.
Manual entry of a new record:
WIC State agencies may choose to manually add new vendor records to FDP. WIC State agencies using this option must complete all data fields for new vendors authorized during the fiscal year which will take 11 minutes (0.191 hours) per record. The number of manual entry respondents is 23 WIC State agencies. In FY 2022, we had 4 records manually entered for new vendors. FNS estimates that the ratio of approximately 0.17 new records are reported per WIC State agency, per year. The total burden hours for FY 2022 show approximately 0.76 hours total (4 records x 0.191 hours). This is the same work as described in the previously approved collection; however, it has been given its own line item in the burden table for clarity.
Manual update existing record:
WIC State agencies may choose to manually update vendor records in FDP. FDP stores information for vendors from the previous year’s submission making existing vendor entries quicker. WIC State agencies using this option must update redemption data, monitoring activities, compliance investigations, sanctions, and administrative reviews on existing vendors which will take 4 minutes (0.068 hours) for vendors authorized during the fiscal year. The number of manual entry respondents is 23 WIC State agencies. In FY 2022, we had 227 records manually updated and reported. FNS estimates that the ratio of approximately 9.87 records are reported per WIC State agency, per year. This results in a burden of 15.4 hours (227 records x 0.068 hours).
Data Upload:
WIC State agencies can enter information into FDP using the data upload process. WIC State agencies have the option of entering their data into FDP as a batch upload of csv or xml file(s) in the system with all vendor data. FDP stores information for vendors previously submitted. For existing records, the collection does not require all data fields for all data records in the upload file. Instead, the WIC State agency only needs to fill in the minimally required fields, and any fields that have changed during the fiscal year. The WIC State agency has the option of filling in fields manually or the information can be imported from their WIC State agency MIS reports, whichever is more efficient. WIC State agencies have the option of submitting necessary template(s) once, or in multiple batches; whichever is most efficient for their needs. WIC State agencies using this option must 1) update redemption data, monitoring activities, compliance investigations, sanctions, and administrative reviews on existing vendors and 2) to complete all data fields for new vendors, authorized during the fiscal year. FNS estimates out of 89 WIC State agencies, 66 of them will upload their data. FNS estimates that it will take an average of 6 minutes (0.104 hours) for a WIC State agency to upload its vendor data once the data has been fully prepared, with respondents with small to medium data sets taking up to a minute to upload data and respondents with large data sets taking up to 60 minutes to upload data. The total hours estimated is 6.9 hours (0.104 hours per upload x 66 WIC State agencies). The file upload process has been changed since the previously approved collection. The gathering of the data work will remain the same, but the screens and template files needed are new. This is listed on its own line item in the burden table for clarity.
Data Preparation for this ICR:
The time varies for the WIC State agencies to prepare their vendor data for submission because some WIC State agencies’ MIS automatically generate the data each fiscal year while others must compile the data from multiple sources. FNS estimates that data preparation takes an average of 30 hours. FNS estimates that it will take a total of 2,670 hours to prepare the vendor data for submission (89 State agencies x 30 hours per submission).
WIC State agency (SA) System Feedback:
For the system feedback, FNS estimates the amount of time each WIC State agency might spend reviewing and responding on at least an annual basis to FNS requests for feedback on FDP’s performance and features. FNS estimates that this feedback would be around 2.5 hours per WIC State agency, for a total of 222.5 hours.
Error corrections for data uploads:
When WIC State agencies choose to enter information into FDP using the data upload process. If their information does not meet the requirements for FDP, they will receive an error report that describes what changes need to be made in order to satisfy the FDP data requirements. Based on State agency comments, we have added this instrument to the FDP burden table. FNS estimates out of 89 WIC State agencies, 66 will upload their data and may need to correct errors in their data uploads. FNS estimates that it will take an average of 10 hours for a WIC State agency to correct its data uploads. The total hours estimated is 660 hours (10 hours per upload x 66 WIC State agencies). Based on State agency comments, we have added this instrument to the FDP burden table. This is listed on its own line item in the burden table for clarity.
Other:
There is no recordkeeping burden related to retaining this information.
Table 12.1 Estimates of Burden Hours
Respondent Category |
Type of respondents (optional) |
Instruments |
Form |
Number of respondents |
Frequency of response |
Total Annual responses |
Hours per response |
Annual burden (hours) |
State Government |
State Program Staff |
Manual entry of a new record |
FDP |
23 |
0.17 |
4 |
0.191 |
0.76 |
State Government |
State Program Staff |
Manual update existing record |
FDP |
23 |
9.87 |
227 |
0.068 |
15.4 |
State Government |
State Program Staff |
Data Upload |
FDP |
66 |
1 |
66 |
0.104 |
6.9 |
State Government |
State Program Staff |
Data Preparation for this ICR |
|
89 |
1 |
89 |
30.0 |
2,670.0 |
State Government |
State Program Staff |
SA System Feedback |
|
89 |
1 |
89 |
2.5 |
222.5 |
State Government |
State Program Staff |
Error corrections for data uploads
|
FDP |
66 |
1 |
66 |
10 |
660 |
|
TOTAL |
|
|
356 |
1.52 |
541 |
6.61 |
3,576 |
4B. Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.
The estimated annual respondent cost for this information collection, including the fully-loaded costs, is $198,206.43. The mean hourly wage rate for all State employees is $41.68 per hour, obtained from the U.S. Department of Labor, Bureau of Labor Statistics (BLS), which is in, 'Social and Community Service Managers’, Occupation Code 11-9151 (https://www.bls.gov/oes/current/oes119151.htm#nat). As of the date of this submission, this is the latest data available from BLS for State Government employee salaries.
The national total burden hours (3,576) multiplied by the mean hourly wage ($41.68) resulted in a base salary estimate of $149,027.39. This base salary amount was adjusted for fully-loaded rates (multiply by 0.33), provides an adjustment to our burden total, for a total cost of $198,206.43 ($149,027.39 total burden hours + $49,179.04 adjustment to make fully loaded ($149,027.39 x 0.33). See attached burden table for full explanation of hours and wage information.
In summary, the total burden hours for this collection has increased by 2,387 hours. The increase is based on updates made in response to State agency comments and include an increase in the burden for data preparation, and the addition of the burden for error corrections for data uploads. There has been a reduction in other parts of the burden: State agencies need less time to manually enter new records into FDP, fewer State agencies with a high number of FDEs chose manual entry for their data submission in FY 2022 and therefore saw a reduction in burden, and there was an overall reduction in FDEs participating with the WIC Program which reduced the burden for State agencies. The cost of this burden collection is higher by $106,068.88 due to the increase in the number of State agencies hours for data preparation, error correction and the $5.55 increase in the hourly basic wage rates for State government staff as provided by the U.S. Bureau Of Labor Statistics. In response to the increase, the agency has already been making FDP system changes based on State agency feedback to create more efficient data uploads, provide clear error messages, and to minimize data preparation. The agency also provides ongoing technical assistance and training on a variety of topics to provide relevant information to assist in reducing the burden on State agencies.
Provide estimates of the total annual cost burden to respondents or recordkeepers resulting from the collection of information, (do not include the cost of any hour burden shown in questions 12 and 14). The cost estimates should be split into two components: (a) a total capital and start-up cost component annualized over its expected useful life; and (b) a total operation and maintenance and purchase of services component.
There are no capital/start-up or ongoing operation/maintenance costs associated with this information collection.
Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.
The cost to the Federal government includes contractor costs to update the data collection system and provide technical assistance to State agencies. These contractor costs are approximately $6,290,254.60 over 5 years (base + 4 option years) of the contract for an annualized cost of $1,258,050.92 ($6,290,254.60 / 5 years) per year (this is based on the FY 2021 contract). The cost to the Federal government also includes the cost of FNS Regional Office staff to review the data submitted by each of the 89 State agencies and the cost of an FNS Headquarters staff members to work with Regional Offices and State agencies to ensure that vendor data is submitted and validated, as appropriate and to analyze the data and to prepare a public facing report. Total staff hours result in an annual cost of $130,568. The annual cost after adjustment for fully-loaded rates (multiply by 0.33), provides a total cost of $173,655 ($130,568 x 0.33). The amounts used for the salaries are the annual and hourly rates obtained from the Office of Personnel Management Salary Table 2023-General Schedule, Effective January 2024 (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2024/general-schedule) The GS-12 Step 5 rate provided for the 7 regional staff is from the General Schedule Base Pay table. The average of current salaries for the HQ Program Analysts is provided based on the General Schedule Base pay table.
(1) 7 Regional Program Analysts
GS-12 Step 5 Base Rate $84,365
Hourly Salary $40.42
Hours Reviewing Data 40
7 Regions x 7
Total Hours 280
Total Cost $11,317.60
(2) 1 .5 Headquarters Program Analysts
GS-12 & 13 average salary $110,252.00
Average Hourly Salary $53.00
Total Hours 2,250
Total Cost $119,250
Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.
This is a revision of a currently approved collection. The currently approved information collection burden is 1,189 total burden hours and 707 total annual responses. In this revision, we are requesting 3,576 total burden hours and 541 total annual responses which is an increase of 2,387 total burden hours and a decrease of 166 total annual responses. The change in the total burden hours is due to both program changes (with a decrease of 29.6 hours) and adjustments (with an increase of 2,416 hours), which results in the total burden hour increase of 2,387 hours.
The burden hour and response estimates were impacted by a combination of factors including a higher but more accurate estimate of the time State agencies need for data preparation, the addition of the burden instrument for error corrections for data uploads, a decreased time needed to manually enter new record into FDP, fewer State agencies with a high number of vendors chose manual entry in FY 2022, and potential reduction in businesses participating with WIC.
One public facing report summarizing the data will be created for each fiscal year in order to provide transparency on WIC vendor compliance activities nationwide. This information is provided upon request to interested parties. The Food Delivery Portal enhances FNS’ ability to create this report more efficiently.
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
The agency plans to display the expiration date for OMB approval of the information collection on all data collection instruments.
Explain each exception to the certification statement identified in Item 19 of the OMB 83-I" Certification for Paperwork Reduction Act."
There are no exceptions to the certification statement on OMB Form 83-I.
File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
File Title | Supporting Statement for OMB No |
Author | USDA |
File Modified | 0000-00-00 |
File Created | 2024-12-04 |