Public Comments

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Draft Collective Comment to USDA Food and Nutrition Service (FNS)
Agency Information Collection Activities: Renewing Burden Number 0584-0293
Submitted on behalf of participating School District Child Nutrition Program Directors
To Whom It May Concern:
Thank you for the opportunity to provide comments regarding the renewal of OMB
Control Number 0584-0293 and the associated reporting and administrative
requirements impacting child nutrition programs.
We conducted a survey of school district Child Nutrition Program Directors and staff to
better understand how current USDA/FNS reporting requirements affect local program
operations. The feedback gathered reflects the experiences of districts of varying
enrollment sizes and operational capacities.
Overall, respondents expressed appreciation for the importance of accountability and
program oversight; however, there was significant concern regarding the increasing
administrative burden associated with reporting, compliance, inventory tracking, and
audit preparation.
Key Findings from Survey Participants
1. Reporting and Administrative Burden Continue to Increase
Most respondents indicated that reporting requirements have increased over the past
several years. Many directors reported spending multiple hours each week on
USDA/FNS-related reporting and compliance activities, with several districts reporting
more than 20 hours per week dedicated to administrative tasks.
Respondents consistently noted that increasing paperwork and compliance
responsibilities reduce the time available for:
•

Meal service operations

•

Menu planning

•

Staff supervision and training

•

Student-focused program improvements

•

Procurement and financial management

2. Duplicate Data Entry and Lack of System Integration Are Major Challenges

A significant concern among respondents was the need to enter the same information
into multiple systems, including district systems, state reporting systems, inventory
platforms, and USDA systems.
Most respondents reported that their systems either do not integrate or only partially
integrate with state or federal systems. This creates:
•

Duplicate work

•

Increased risk of errors

•

Additional staff time requirements

•

Challenges meeting deadlines

Participants strongly encouraged USDA/FNS to explore unified or interoperable
reporting systems that reduce repetitive manual entry.
3. Audit Preparation and Compliance Requirements Create Significant Stress
The most commonly identified administrative burden was audit preparation and
compliance documentation.
Directors expressed concern that increasingly complex requirements, combined with
limited staffing, create operational strain and increase the risk of noncompliance
findings.
Several respondents specifically noted that:
•

Guidance can be difficult to interpret

•

Requirements are not always consistent across agencies

•

Additional operational examples and practical training would be beneficial

4. Staffing Limitations Affect Program Capacity
Many school nutrition departments operate with limited administrative staff. Smaller
districts, in particular, noted that directors often manage multiple responsibilities without
dedicated office or compliance support.
Respondents emphasized that additional reporting requirements disproportionately
affect small and rural districts with limited staffing capacity.
5. USDA Foods and Inventory Tracking Requirements Are Time-Consuming
Participants identified USDA Foods ordering, reconciliation, inventory management, and
compliance tracking as particularly burdensome.
Several respondents requested:

•

Simplified inventory reporting

•

Clearer guidance regarding compliance expectations

•

More user-friendly USDA systems and platforms

•

Improved functionality and training related to WBSCM and related systems

Recommendations
Based on survey responses, participating school nutrition professionals respectfully
recommend that USDA/FNS consider the following actions:
1. Simplify reporting requirements and eliminate unnecessary duplication.
2. Improve integration between district, state, and federal reporting systems.
3. Provide clearer and more consistent guidance documents.
4. Expand practical training opportunities with real-world operational examples and
question-and-answer sessions.
5. Review reporting frequency and identify opportunities to reduce administrative
workload.
6. Consider the staffing realities of small and rural districts when implementing
reporting requirements.
7. Improve usability and functionality of USDA reporting and inventory systems.
Closing
School nutrition professionals remain committed to accountability, compliance, and
responsible stewardship of federal resources. However, administrative processes
should support, not hinder, the core mission of feeding students.
We appreciate USDA/FNS seeking stakeholder feedback and respectfully request that
the agency consider the operational realities faced by local Child Nutrition Programs
when renewing and implementing reporting requirements.
Thank you for your consideration.