Supporting Statement A

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SUPPORTING STATEMENT - PART A for
OMB Control Number 0584-0293:  
Food Distribution Programs
Agency Information Collection Activities: Renewing Burden Number 0584-0293 

Polly Fairfield
Branch Chief
Food Distribution Programs 
USDA Food and Nutrition Administration
1320 Braddock Place 
Alexandria, VA 22314 


Table of Contents
A1. Circumstances that make the collection of information necessary.	5
A2. Purpose and Use of the Information.	7
A3.  Use of information technology and burden reduction.	15
A4.  Efforts to identify duplication.	18
A5.  Impacts on small businesses or other small entities.	19
A6.  Consequences of collecting the information less frequently.	19
A7.  Special circumstances relating to the Guidelines of 5 CFR 1320.5.	20
A8.  Comments to the Federal Register Notice and efforts for consultation.	22
A9.  Explain any decisions to provide any payment or gift to respondents.	26
A10.  Assurances of confidentiality provided to respondents.	26
A11.  Justification for any questions of a sensitive nature.	27
A12.  Estimates of the hour burden of the collection of information.	28
A13.  Estimates of other total annual cost burden.	35
A14.  Provide estimates of annualized cost to the Federal government.	36
A15.  Explanation of program changes or adjustments.	36
A16.  Plans for tabulation, and publication and project time schedule.	37
A17.  Displaying the OMB Approval Expiration Date.	38
A18.  Exceptions to the certification statement identified in Item 19.	38

Appendices
APPENDIX A. SECTION 4(b) OF THE FOOD AND NUTRITION ACT OF 2008

APPENDIX B. SECTIONS 6, 14, AND 17 OF THE NATIONAL SCHOOL LUNCH ACT

APPENDIX C. SECTION 4 OF THE CHILD NUTRITION ACT OF 1966

APPENDIX D. THE EMERGENCY FOOD ASSISTANCE ACT OF 1983

APPENDIX E. SECTIONS 4(a) AND 5 OF THE AGRICULTURE AND CONSUMER PROTECTION ACT OF 1973

APPENDIX F. 7 CFR PART 247

APPENDIX G. 7 CFR PART 250

APPENDIX H. 7 CFR PART 251

APPENDIX I. 7 CFR PART 253

APPENDIX J. 7 CFR PART 254

APPENDIX K. BURDEN NARRATIVE

APPENDIX L. FOOD DISTRIBUTION PROGRAMS: IMPROVING ACCESS AND PARITY FINAL RULE

APPENDIX M. FNS-7 DESTINATION DATA FOR FOOD DELIVERIES

APPENDIX N. WBSCM SCREENSHOTS
	APPENDIX N(1) HOME PAGE
	APPENDIX N(2) FNS-52 DOMESTIC REQUISITION ENTRY
	APPENDIX N(3) FNS 53 MULTI-FOOD REQUISITION ENTRY
	APPENDIX N(4) FNS-57 SHIPMENT RECEIPT SCREEN

APPENDIX O. FNS-152 MONTHLY DISTRIBUTION OF DONATED FOODS TO FAMILY UNITS

APPENDIX P. FNS-153 MONTHLY CSFP REPORT AND QUARTERLY ADMINISTRATIVE FINANCIAL STATUS

APPENDIX Q. FNS-155 INVENTORY MANAGEMENT REGISTER

APPENDIX R. FNS-667 REPORT OF TEFAP ADMINISTRATIVE COSTS

APPENDIX S. FNS-929 ANNUAL REPORT OF ELIGIBLE RECIPIENT AGENCIES

APPENDIX T. FNS-930 INDIVIDUALS RECEIVING USDA FOODS FOR HOME CONSUMPTION 
 
APPENDIX U. SF-424 FEDERAL FINANCIAL REPORT

APPENDIX V. SF-425 FEDERAL FINANCIAL REPORT
APPENDIX V(1) FOODS PROGRAM REPORTING SYSTEM (FPRS) HOMEPAGE

APPENDIX W. 0584-0293 FOOD DISTRIBUTION BURDEN TABLE

APPENDIX X. WBSCM RESOURCES FOR CUSTOMER ORGANIZATIONS
	APPENDIX X(1) 1.0 WBSCM PORTAL SETTINGS AND NAVIGATION
	APPENDIX X(2) 2.0 WBSCM USER ACCESS & SECURITY
	APPENDIX X(3) 3.0 WBSCM ORGANIZATION MAINTENANCE
	APPENDIX X(4) 4.0 WBSCM ENTITLEMENT MANAGEMENT
	APPENDIX X(5) 5.0 WBSCM CATALOG MAINTENANCE
	APPENDIX X(6) 6.0 WBSCM ORDERING
	APPENDIX X(7) 7.0 WBSCM RECEIPTING
	APPENDIX X(8) 8.0 WBSCM COMPLAINTS
	APPENDIX X(9) 9.0 WBSCM RECALLS

APPENDIX Y. (1) PUBLIC COMMENT SUBMISSION 1

APPENDIX Y. (2) PUBLIC COMMENT SUBMISSION 2

APPENDIX Y. (3) PUBLIC COMMENT SUBMISSION 3

APPENDIX Y. (4) PUBLIC COMMENT SUBMISSION 4

APPENDIX Y. (5) PUBLIC COMMENT SUBMISSION 5

APPENDIX Y. (6) PUBLIC COMMENT SUBMISSION 6

APPENDIX Y. (7) PUBLIC COMMENT SUBMISSION 7


APPENDIX AA. INVITATION TO COMMENT ON FOOD DISTRIBUTION BURDEN ESTIMATES

APPENDIX BB. FPRS SCREENSHOTS

APPENDIX CC. 0584-0595 FNS-10, FNS-44, FNS-292











A1. Circumstances that make the collection of information necessary.

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 information collection request.  Additionally, this revision will implement the two revised and seven new collections associated with the Food Distribution Programs: Improving Access and Parity final rule, 89 FR 87228 (October 31, 2024) (see Appendix L). The new collections associated with this revision are necessary to help the Agency ensure State agencies appropriately use USDA Foods, support program access for eligible populations, and gain new information about program operators and program participation.  
The Food Distribution Programs of the Department of Agriculture (USDA), Food and Nutrition Administration (FNA) assist American farmers and needy people by purchasing USDA Foods and delivering them to State agencies that, in turn, distribute them to organizations for use in providing food assistance to those in need.  USDA Foods help to meet the nutritional needs of: 
    • Victims of Presidentially-declared disasters and other situations of distress; 
    • Elderly persons participating in the Commodity Supplemental Food Program (CSFP);
    • Low-income, unemployed or homeless people provided foods through household distributions or prepared meals under The Emergency Food Assistance Program (TEFAP);
    • Needy persons in households on Indian reservations participating in the Food Distribution Program on Indian Reservations (FDPIR) and Food Distribution Program for Indian Households in Oklahoma (FDPIHO);
    • Children from preschool age through high school in FNA Child Nutrition Programs and nonprofit summer camps;
    • Pre-school and school-age children, elderly, and functionally impaired adults enrolled in child and adult day care centers participating in the Child and Adult Care Food Program (CACFP); and 
    • Needy persons served by charitable institutions.
Effective administration of Food Distribution Programs is dependent on the collection and submission of information to FNA from State and recipient agencies. This information includes, for example, the kinds of USDA Foods most acceptable to recipients, the quantities of foods ordered and where the food is to be delivered, verification of the receipt of a food order, and the amounts of USDA Foods in inventory.
Authorizing legislation allows the Secretary broad authority to establish regulatory provisions promoting accountability in the use of USDA Foods by Federal, State, and private agencies.  Below are the primary legal authorities.       
    • Section 4(b) of the Food and Nutrition Act of 2008, as amended (7 U.S.C. 2013(b)) (Appendix A);

    • Sections 6, 14, and 17 of the National School Lunch Act, as amended (42 U.S.C. 1755, 1762a, and 1766) (Appendix B);
    • Section 4 of the Child Nutrition Act of 1966, as amended (42 U.S.C. 1733) (Appendix C);
        ◦ The Emergency Food Assistance Act of 1983, as amended (7. U.S.C. 7501 et. seq.) (Appendix D); and 
        ◦ Sections 4(a) and 5 of the Agriculture and Consumer Protection Act of 1973, as amended (7 U.S.C. 612c note) (Appendix E).
Additionally, the regulatory information for these forms can be found in CFR 7 Parts 247-254, as described in Table 1 also see (Appendices F through J).
A2. Purpose and Use of the Information.

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 information reported and the records kept for purposes of review under 7 CFR Parts 240, 247, 250, 251, 253, and 254 are used by State and recipient agencies and FNA regional and headquarters offices for the purpose of administering USDA Food Distribution Programs. Depending on the information requirements, respondents will provide information either quarterly, monthly, semi-annually, annually, or on an as-needed basis.  The frequencies are based on program requirements.  The collections are primarily mandatory for State, local, and Tribal Governments, and Businesses (non-profits, and private for-profit entities). The only part of this collection necessary to obtain benefits is from Individuals/Households who participate and are identified as program recipients. The individual program applications are State-provided forms. FNA does not provide any templates or examples to the States but does offer to review the forms if the States have questions. Some of the information related to program food distribution and the use of USDA Foods will be shared with State governments. See Appendix K (Burden Narrative) for a breakdown of the reporting and recordkeeping requirements contained in each of the relevant parts of the Federal regulations. There are no third-party reporting requirements associated with this collection. 

247 Commodity Supplemental Food Program.  
Information collections for part 247 ensure that State agencies appropriately use USDA Foods and administrative funds to serve adults at least 60 years of age or older and who meet income eligibility requirements. Information collections are used to understand how State agencies operate CSFP, to understand which local agencies operate the program and their contact information, and to ensure that appropriate inventory and financial management practices are followed. With regard to forms that individuals must complete to receive benefits, the requirements for CSFP forms are outlined in § 247.8, Individuals applying to participate in CSFP. Certification periods are determined by the State as outlined in § 247.16. 

250 Donation of Foods for Use in the United States, Its Territories and Possessions and Areas Under Its Jurisdiction. Information collections for part 250 provide the Department with information necessary to ensure that State agencies receive, distribute, and monitor the distribution of USDA Foods for further distribution and use in food assistance programs, or to provide assistance to eligible persons in accordance with applicable legislation. Information collections allow State agencies to order USDA Foods as needed for distribution in their State, allow the Department to better track inventories of USDA Foods during Disaster Household Distributions, provide the Department with information about the distribution of USDA Foods throughout the State and which local agencies receive USDA Foods, ensure that appropriate inventory and financial management practices are followed, record any instances of misuse of foods or funds, and document resultant claims actions which may be pursued. The collection no longer includes reporting requirements related to household information required in disasters and situations of distress if the issuance of Disaster Supplemental Nutrition Assistance Program (D-SNAP) benefits has been approved.

251 The Emergency Food Assistance Program. Information collections for part 251 ensure that State agencies use USDA Foods and administrative funds appropriately to serve persons who need food assistance due to inadequate household income and reside in the geographic location served by the State agency at the time of applying for assistance. Information collections are used to understand how State agencies operate TEFAP, which local agencies operate the program, the contact information of local agencies with agreements with the TEFAP State agency, and to ensure that appropriate inventory and financial management practices are followed.

253 Administration of the Food Distribution Program for Households on Indian Reservations & 254 Administration of the Food Distribution Program for Indian Households in Oklahoma.  Information collections for part 253 and 254 ensure that Indian Tribal organizations or other entities administering the program appropriately use USDA Foods and administrative funds appropriately to serve eligible persons who need food assistance. Information collections also enable the Department to ensure that, when applicable, the Food Distribution Program is operated concurrently with the Supplemental Nutrition Assistance Program (SNAP) on Indian reservations. Information collections provide the Department with information about the distribution of USDA Foods throughout the area served by the Indian Tribal organization or other administering agency, ensure that appropriate inventory and financial management practices are followed, record any instances of misuse of foods or funds, and document resultant claims actions which may be pursued. Information collections also help FNA to assess and provide decisions on specific requests to modify or waive regulatory requirements. With regard to forms that individuals must complete to receive benefits, the requirements for FDPIR forms are outlined in § 253.7, Certification of households and § 254.5 Household eligibility.  

Forms for Food Distribution Program Reporting
Table 1 provides information about each of the forms used for information. 
Table 1: The Purpose of Donated Food Forms and Data Collection Instruments 
Form number
Regulation
Purpose
Collection (Paper and Electronic) 
FNS-7 Destination Data for 
Food Deliveries 
(Appendix M)
7 CFR §250.11(a)
Distributing agencies arrange for delivery of USDA Foods to storage facilities. State distributing agencies complete Form FNS-7. The form is used in all food distribution programs and contains information on the destination point for USDA Foods shipments, including the optimal day and time for deliveries, and the means of shipment. It is submitted whenever changes in destination data are made.  
Email
FNS-52 Food Requisition
(Appendix N(2))
7 CFR §250.58
State Distributing Agencies or National Regional Offices fill out this form to order USDA Foods. This information is collected so States can receive the specific foods they want. This occurs on an as needed basis depending on inventory levels. 
Electronic collection using Web Based Supply Chain Management (WBSCM)

FNS-53 Requisition for 
Multi-Food Shipments
(Appendix N(3)) 
7 CFR §250.58
State Distributing Agencies use this form to order various types of USDA Foods. This information will allow states to get the USDA Foods of their choosing for their program. While states may make requests for various foods to be an ordering option, submitting this single form is how they will go about actually ordering more than one type of USDA Foods. This occurs on an as needed basis depending on inventory levels.
Electronic collection using Web Based Supply Chain Management (WBSCM) 
FNS-57 Report of 
Shipments Over, Short,
and/or Damaged
(Appendix N(4))
7 CFR §250.11(b), 253.8(f), & 254.3(a)
This is to gather information on shipments that have more food than ordered, do not contain the entire order, and/or have damaged goods. How these situations arise will differ. However, submitting this single form is the avenue they will use to share this information. This occurs on an as needed basis depending on the status of the shipment. 
Electronic collection using Web Based Supply Chain Management (WBSCM) 
FNS-152 Monthly
Distribution of Donated 
Foods to Family 
Units (used in FDPIR)
(Appendix O)
7 CFR §250.18(a)
ITOs or State Distributing Agencies will combine inventory data and submit the form to the appropriate regional office monthly. How each state gathers the information will differ. However, submitting the single form is the avenue they will use to share this information.

Electronic collection using Food Programs Reporting Systems (FPRS), Form is uploaded as an excel file to FPRS 
FNS-153 Monthly CSFP 
Report and Quarterly 
Administrative Financial 
Status
(Appendix P)
7 CFR §247.29(a) & (b)(2)(ii)

State Distributing Agencies submit the form to the appropriate regional office monthly. How each state gathers the information will differ. However, submitting the single form is the avenue they will use to share this information.
Electronic collection using Food Programs Reporting Systems (FPRS) 
FNS-155 Inventory 
Management Register
(Appendix Q)
7 CFR §250.18(a)
The FNS-155 captures by type, USDA Foods physically warehoused in any State-operated or State-contracted storage facility that exceeds a cumulative 6-month inventory. USDA Foods remaining in these warehouses at the end of the report month shall be counted as State inventory until such commodities are distributed to recipient and/or sub- distributing agencies. This is done twice a year.
Email
FNS-667 Report of TEFAP 
Administrative Costs
(Appendix R) 

7 CFR §251.9(e) & 251.10(b)(1)
On a quarterly basis, State distributing agencies must identify funds obligated and disbursed to cover administrative costs associated with the program at the State and local level to show that they are meeting the matching requirement. State distributing agencies also submit a final report.  State distributing agencies identify their matching administrative contribution on Form FNS-667 “Report of TEFAP Administrative Costs.”
Electronic collection using Food Programs Reporting Systems (FPRS) 
FNA-929 Annual Report of TEFAP Eligible Recipient Agencies
(Appendix S)
7 CFR 251.10(b)(3) 
Annually, TEFAP State agencies must provide the list of eligible recipient agencies to FNA. The report specifies whether each eligible recipient agency has an agreement with the State agency or with another eligible recipient agency.
Electronic collection using Food Programs Reporting Systems (FPRS)
FNA-930 Individuals Receiving USDA Foods for Home Consumption in The Emergency Food Assistance Program
(Appendix T)
7 CFR 251.10(b)(4)
Quarterly, TEFAP State agencies must submit information on the number of individuals that accessed USDA Foods for home consumption via TEFAP each month in the quarter. 
Electronic collection using Food Programs Reporting Systems (FPRS)

In addition to the Agency-developed forms above, FNA also uses OMB Standard Forms SF-424 (Appendix U), and SF-425 (Appendix V), in the Food Distribution programs. The burden hours associated with the activities reported on these forms are cleared in other OMB packages and are not included in the total burden hours listed in this statement. However, since this information has been included in past renewals at OMB’s request, a description of the forms is listed below:
SF-424
The SF-424 form is an OMB approved collection under OMB# 4040-0004. The SF-424 was established as the government-wide standard core data set and form for grant applications on July 31, 2003. The SF-424 (Research and Related (R&R) Family) Form is used in all grant applications. This form collects information including type of submission, applicant information, type of applicant, and proposed project dates. Out of the total burden of 20,803 hours and 20,803 responses for this form, FNA estimates that the Food Distribution programs will use 117 hours and 117 responses.
253.4(d), Application by an Indian Tribal Organization (ITO) or State agency.  An ITO or State agency wishing to administer FDPIR on one or more Indian reservations completes an application, utilizing Form SF-424, “Application for Federal Assistance,” and submits it to the FNA Regional Office, along with pertinent information. The application includes projected administrative costs for the program, of which a minimum of 80 percent are met by Federal grant. Applications are completed annually using Form SF-424. The burden for this requirement is associated with 253.5(h) & 254.3(a), ITO Applications in the Burden Table (Appendix W).
SF-425 
FNA also uses SF-425, Federal Financial Report, which is one of the forms under OMB# 4040-0014. SF-425 is approved for FNA use under OMB# 0584-0594 Food Programs Reporting System (FPRS), expiration date September 30, 2026.  Out of the total burden of 13,912 hours and 9,275 responses for this form for FNA, FNA estimates that the FD programs will use 4,198.5 hours and 2,799 responses. The SF-425 form is a required Office of Management and Budget (OMB) financial reporting form to track the status of financial data tied to a particular Federal grant award. Grant recipients must submit completed SF-425 form.
247.29(b)(1), Reports and recordkeeping. State agencies in CSFP submit Form SF-425, Financial Status Report, to report the financial status of the program at the close of the fiscal year. The burden for this requirement is associated with 247.26, Closeout Procedures in the Burden Table (Appendix W). 
251.13(g), Reporting requirements. State agencies receiving Farm to Food Bank Project funds submit a completed SF-425 form semiannually, including a final report, to explain the amount of funds received, obligated, and liquidated for the implementation of Farm to Food Bank Projects.  The burden for this requirement is associated with 251.13(g), Reporting Requirements in the Burden Table (Appendix W).
253.11(j)(2), Accounting for Funds Received and Financial Status Reports. ITOs and State agencies receiving funds for FDPIR through a Letter of Credit must submit to the FNA Regional Office quarterly financial reports and an annual financial report regarding their use of administrative funds utilizing Standard Form SF-425 “Financial Status Report”. The burden for this requirement is associated with 253.11(b) & 254.3(a), Management of Administrative Funds in the Burden Table (Appendix W).
FNS-152, FNS-153, FNS-667 (Appendices O – R) are all approved under OMB# 0584-0594 Food Programs Reporting System (FPRS), expiration date September 30, 2026.  However, for this renewal, these forms and their associated reporting burden will remain with this OMB collection number, OMB# 0584-0293.

OMB# 0584-0594 Food Program Reporting System (FPRS)
In addition, this collection uses other forms that are covered under OMB# 0584-0594 Food Programs Reporting System (FPRS), expiration date September 30, 2026, to report data associated with this collection: FNS-10, FNS-44, FNS-191, and FNS-292 (Appendix CC).  These forms and their associated reporting burden are approved as part of the burden for OMB# 0584-0594, so their reporting burden is not duplicated here. However, any recordkeeping burden that is associated with these forms is included in the burden for this collection and not included in OMB control number: 0584-0594. Copies of these forms are provided merely for reference purposes. Please note that when accessing the forms in FPRS, users see a Welcome Page before they access their individual forms. The Welcome Page contains the OMB control number, Expiration Date and an OMB Burden Disclosure Statement that covers all of the forms in FPRS. FNA generally combines the Welcome Page and the specific form into one file, but the agency has been having difficulty combining these into one file so the Welcome Page and the individual forms are provided as separate attachments (Appendix BB).
See Appendix K (0584-0293 Burden Narrative) for a breakdown of the reporting and recordkeeping requirements contained in each of the relevant parts of Federal regulations.   

A3.  Use of information technology and burden reduction.  

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.

FNA makes every effort to comply with the E-Government Act of 2002. FNA encourages its State agency partners to offer electronic submission to participants whenever feasible. Currently, all State agencies that provide USDA Foods to schools and other FNA nutrition programs are using the Web Based Supply Chain Management System (WBSCM). Approximately 315 State agencies and Indian Tribal Organizations submit data to USDA electronically using WBSCM.  Approximately 942,616 responses are submitted electronically via WBSCM. This breaks down to:
•	State, Local, Tribal reporting responses = approximately 2.2% of total responses; 
•	State, Local, Tribal recordkeeping responses = less than 0.1% of total responses;
•	Private For-Profit reporting responses = approximately 21% of total responses; and 
•	Private For-Profit recordkeeping responses = approximately 21% of total responses.
The link for WBSCM can be found at: https://www.fns.usda.gov/usda-foods/wbscm
Specific to the revisions from the final rule, FNA estimates that the revision to the information collection due to the final rule will add an additional 943 responses. Out of the 943 new responses in this revision, FNA estimates that 943 (approximately 100%) are submitted electronically.
For the information collection overall, FNA estimates that approximately 942,616 responses pertaining to the reporting and recordkeeping burdens in this revision are collected electronically via WBSCM. Out of 4,040,298 responses for this collection, FNA estimates that 23.3% are collected electronically. For more information on WBSCM see Appendix X, WBSCM Resources for Customer Organizations.

Burden Reduction Efforts 
During the 60-day comment period after the proposed rule, Food Distribution Programs: Improving Access and Parity, 88 FR 54908 (August 14, 2023) was published, FNA collected comments regarding the administrative burden associated with this rule. In response to comments, FNA made several changes to proposed provisions to reduce the overall burden or frequency of reporting:
    • The final rule added a new provision at 247.5(b)(16) requiring CSFP State agencies to make publicly available a list of CSFP local agencies on a publicly available internet web page. The State agency must post the name, address, and a contact telephone number for all CSFP local agencies. State agencies are required to update this information annually. During the 60-day comment period, FNA received 4 comments that an annual requirement to post the name, address, and a contact telephone number for all distribution sites in each State would cause an increase in administrative burden. As such, FNA has revised this provision to only require local agencies (those entities that have a direct agreement with the State agency) to be publicly posted by the State. This reduces the total number of entities that need to be posted and reduces the overall burden associated with this provision. 
    • The final rule added a new requirement that State distributing agencies operating a Disaster Household Distribution (DHD) must submit a biweekly report on the number of individuals served and on the amount of USDA Foods issued for the duration of the DHD. During the 60-day comment period, FNA received 8 comments that requiring a weekly report would cause an increase in administrative burden. As such, FNA has revised the requirement from a weekly report to a biweekly report. FNA also received comments requesting that the reporting mechanism be user-friendly and be a reasonable process that uses modern technology.  FNA plans to implement electronic reporting for this provision and will take these suggestions into account. 
    • The final rule provision added a new requirement for TEFAP State agencies to post the name, address, and a contact telephone number for all eligible recipient agencies which have an agreement with the TEFAP State agency to publicly available websites. FNA requires State agencies to update this information annually.  During the 60-day comment period, FNA received 10 comments that an annual requirement to post the name, address, and a contact telephone number for all eligible recipient agencies in each State would cause an increased administrative burden. As such, FNA has revised this provision to only require eligible recipient agencies that have an agreement with the State agency to be publicly posted by the State. This reduces the total amount of eligible recipient agencies that need to be posted and reduces the overall burden associated with this provision. 
    • The final rule removed the requirement that TEFAP distribution sites collect and maintain a household address on record. Each distribution site must still collect and maintain records of each household receiving USDA Foods for home consumption. The records must contain: the name of the household member receiving the USDA Foods; the number of persons in the household; and the basis for determining that the household is eligible for USDA Foods.  The removal of the address collection requirement is expected to reduce the burden associated with this recordkeeping requirement by 50%. This is a mandatory recordkeeping collection for local agencies.  


A4.  Efforts to identify duplication. 

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.

There is no similar data collection effort available. Every effort has been made to avoid duplication. FNA has reviewed USDA reporting requirements. FNA solely administers and monitors the Food Distribution Programs.  

A5.  Impacts on small businesses or other small entities.  

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.

The information being requested or required has been held to the minimum burden required for the intended use. Although smaller businesses or entities are involved in this data collection effort, they deliver the same program benefits and perform the same function as any other entity or business. Thus, they maintain the same kinds of information on file. FNA estimates that approximately 1 percent, or approximately 68 of the 6,886 Private for Profit respondents, are small entities.

A6.  Consequences of collecting the information less frequently.  

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 ongoing information collection which includes requirements that are mandatory for the purpose of administering an ongoing program as mandated by statute and regulation. This is primarily a mandatory data collection, although the collection does contain requirements that are required to obtain or retain a benefit. The principal consequences of less frequent collection would be the loss of management control. The data relates to statutory and regulatory requirements. Its collection assists FNA in being a good steward in monitoring Federal funds and detecting or correcting problems that result from a State agency's failure to satisfy statutory and regulatory requirements. The frequencies for the reporting and recordkeeping requirements range from on occasion to monthly, depending on the requirement.
In addition, the new additions to the information collection will improve the Department’s ability to understand how USDA Foods are distributed during times of disaster, situations of distress, and through TEFAP. This information collection will enable the Department to more clearly analyze how TEFAP is distributed within states, including which local agencies distribute foods, where those local agencies are located, and how many people receive USDA Foods for home consumption. The information collected will ensure program integrity and support the Department’s ability to process and review administrative waiver requests in FDPIR. The principal consequences of less frequent collection would limit the Department’s ability to understand how USDA Foods are utilized, including available national inventories during disasters and situations of distress and throughout the emergency feeding network. Please refer to the Burden Narrative (Appendix K) for the frequency of the specific requirements in this collection.

A7.  Special circumstances relating to the Guidelines of 5 CFR 1320.5.  

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.

Forms FNS-7 Destination Data for Delivery of Donated Foods; FNS-52, Food Requisition; FNS-53 Multi-Food Requisition; FNS-57, Receipt of Shipments; FNS-152, Monthly Distribution of Donated Foods to Family Units; FNS-153, Monthly Report of the Commodity Supplemental Food Program and Quarterly Administrative Financial Status Report and FNS-667 Report of The Emergency Food Assistance Program Administrative Costs are collected more frequently than quarterly to ensure efficient management of the Food Distribution programs. Timely ordering, receipt, inventory control, and accounting of USDA Foods and funds are necessary to ensure the programs continue operating and the funds are spent during the appropriate time periods.
New additions to this information collection require that one additional form be submitted to the agency more often than quarterly. State distributing agencies that are operating a disaster household distribution (DHD) must complete a bi-weekly report for the duration of the DHD. This information is required to improve USDA’s and State distributing agencies’ understanding of the quantity and types of USDA Foods available for emergency response and facilitate USDA’s efforts to replace USDA Foods used in disaster response. 

There are no other special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.5.

A8.  Comments to the Federal Register Notice and efforts for consultation.  

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.	

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.

A 60-day Federal Register Notice was published in the Federal Register on March 19, 2026 (91 FR 13272). The public comment period ended on May 18, 2026. FNA received 46 comments during the comment period. Two (2) comments were not germane to FNA Food Distribution collections. Forty-four (44) of the comments were relevant and pertained to this information collection.
FNA received 2 comments from State agencies on the FNS-153 Monthly Report of the CSFP and Quarterly Administrative Financial Status Report and the FNS-155 Inventory Management Register (See Appendices Y (1) and Y (2)). Comments requested changing the FNS-153 reporting from monthly to quarterly to help agencies track inventory, and to streamline the FNS-153 and FNS-155 to be less labor intensive. FNA is committed to collecting and implementing relevant feedback on policy, administrative, and operations issues to ensure appropriate and efficient management of our programs. FNA agrees that reducing burden, where possible, will help our programs run smoothly, and will consider this feedback.
FNA received 2 comments generally in support of the renewal of the information collections with encouragement that FNA ensures reporting and recordkeeping is clear, consistent, practical, streamlined, and to potentially reduce duplicative reporting and simplifying forms. (See Appendices Y (3) and Y (4)). FNA is committed to working with our program partners to continue to modernize and streamline program requirements to reduce overall burden and will consider this feedback.
FNA received 3 distinct comments regarding burden associated with USDA Foods in the National School Lunch Program (NSLP), including 2 unique comments and 1 comment that was submitted 38 times. (See Appendices Y (5), Y (6) and Y (7)). One (1) State agency commented that USDA Foods inventory reporting in NSLP is burdensome because it is manual for their stakeholders. One (1) regional association requested simplified reporting for USDA Foods in NSLP, including integrating systems, expanding training, and reducing overall administrative inventory systems. Lastly, the 38 duplicate comments encourage FNA to revisit the burden estimates for USDA Foods in NSLP to revise the burden estimates up to account for the time taken with recordkeeping and reporting. The comments also request streamlining documentation, eliminating redundant data collection, aligning overlapping requirements, and expanding electronic systems to reduce burden. FNA works to ensure that redundancies in data collection are minimal and encourages electronic data collection and will continue to work with recipient agencies to identify future opportunities to streamline program operations. Estimated burden hours are intended to be an average burden across the country and depending on the operation of NSLP within each state, the actual time for each reporting and/or recordkeeping burden may be higher or lower than the average estimate. In recognition of these comments and to better capture the burden, FNA is revising the burden hours for 250.19(a), Recordkeeping of Agreements, Reports, and Other Records, Records Related to the Receipt, Distribution, and Inventory of Donated Foods – Child Nutrition Programs Recipient Agencies from 5 minutes to 6 minutes per response. This change, which will be more representative of the time taken by recipient agencies to maintain records relating to the receipt, distribution, and inventory of donated foods, will change the estimated burden from 25,039.20 hours per year to 31,299.00 hours per year for the Child Nutrition Programs Recipient Agencies responses for 250.19(a), Recordkeeping of Agreements, Reports, and Other Records, Records Related to the Receipt, Distribution, and Inventory of Donated Foods.
Additionally, a 60-day Federal Register Notice was embedded in the Food Distribution Programs Access and Parity proposed rule, RIN # 0584-AE92, which was published in the Federal Register on August 14, 2023 (88 FR 54908). Comments were received and evaluated on the information collection requirements during the comment period after publication of the proposed rule. During this time, interested members of the public had the opportunity to provide FNA with comments concerning the necessity, practical utility, accuracy, and merit of the information collection activities proposed. FNA received 155 comments on the proposed rule, none of which were specific to the cost or burden hour estimates for the proposed information collection.
FNA received 8 comments regarding the general administrative burden associated with the proposed requirement that State distributing agencies must complete a weekly report if the disaster household distribution persists for longer than 14 calendar days (See Appendices Z (1), Z (2), Z (4), Z (5), and Z (8) for a representative sample of comments received). In response to these comments, FNA revised this requirement in the final rule to now require that State distributing agencies submit a biweekly report for the duration of a disaster household distribution. FNA estimates that the final rule provision resulted in a decrease of 10 burden hours relative to the proposed requirement from the proposed rule.  
FNA received 10 comments generally related to the administrative burden associated with the proposed requirement for TEFAP State agencies to publicly post the name, address, and a contact telephone number for all eligible recipient agencies (See Appendices Z (3), Z (6), Z (7), Z (9) and Z (10) for a representative sample of comments received). As proposed, State agencies would be required to update this information annually. In response to comments, FNA has revised this provision in the final rule to only require eligible recipient agencies that have an agreement with the State agency to be publicly posted by the State. Therefore, FNA estimates that this final rule resulted in a decrease of 216 burden hours relative to the proposed provision. 
FNA received 4 comments on the general administrative burden associated with the proposed requirement for CSFP State agencies to post the name, address, and a contact telephone number for all distribution sites in each State (See Appendices Z (9) and Z (10) for a representative sample of comments received).  In response to comments, FNA has revised this provision in the final rule to only require local agencies (those entities that have a direct agreement with the CSFP State agency) to be publicly posted by the State.
FNA consults with FNA Regional offices regarding any changes as the result of legislative, regulatory, or administrative changes. FNA Regional offices are in daily contact with State agencies, which provide feedback on FNA processes and procedures for this information collection. Feedback from the State agencies is then used by FNA to help shape the burden estimates for this collection.    
FNA actively solicited input on the proposed Information Collection Request (ICR) revision from key stakeholders (see Appendix AA. Invitation to Comment on Food Distribution Burden Estimates). On April 9, 2026, FNA contacted the individuals/organizations listed below about burden estimates and/or other characteristics associated with this data collection. The 3 organizations contacted did not provide any comments or feedback on the proposed ICR revision.
    1. Jaclyn Cantu, President
American Commodity Distribution Association 
[email protected]
    2. Shirley Bojorquez, President
National Commodity Supplemental Food Program Association
[email protected]
    3. Carrie Calvert, Vice President, Agriculture and Nutrition Government Relations
Feeding America
[email protected]

A9.  Explain any decisions to provide any payment or gift to respondents.  

Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

Respondents are not paid or provided with any gifts.  


A10.  Assurances of confidentiality 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 complies with the Privacy Act of 1974. Personally identifiable information is not collected for most of this collection. However, households applying for CSFP, TEFAP, and USDA Foods in disasters do provide some personally identifiable information. Households applying for CSFP, disaster programs, and TEFAP apply directly at the local agency.  
In TEFAP, regulations at § 251.10(a)(3) require local agencies to collect the name of households applying to receive USDA Foods for home consumption. In the Food Distribution Programs: Improving Access and Parity final rule (Appendix L), FNA added new confidentiality requirements to protect any PII which local agencies may collect in new language at 251.10(c).  FNA does not provide TEFAP local agencies with eligibility forms nor is the application information that is obtained at the local agency sent to FNA.  
In CSFP, the local agency collects information required in § 247.8, which includes the name and address of each applicant.  Additionally, § 247.8(b) has a required pre-printed statement:
“I authorize the release of information provided on this application form to other organizations administering assistance programs for use in determining my eligibility for programs and for program outreach purposes. (70 FR 47063, Aug. 11, 2005, as amended at 79 FR 38750, July 9, 2014; 85 FR 68721, Oct. 30, 2020)” 
This statement is approved by OMB under this control number. This is a requirement for the local agency to include in their application form. FNA does not provide the local agencies with the forms nor is the application information that is obtained at the local agency sent to FNA. The Department has not proposed changes to this regulatory requirement.  
This ICR does not include any forms that require a Privacy Act Statement. The FNA Privacy Officer reviewed and confirmed on May 29, 2025, that a Privacy Act System of Records Notice (SORN) is not applicable to this collection.  

A11.  Justification for any questions of a sensitive nature.    

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 sensitive questions involved in this information collection.  

A12.  Estimates of the hour burden of the collection of information.  

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.

 The estimated reporting burden for this information collection including the number of respondents, frequency of response, average time to respond and annual hour burden are shown in the attached Burden Narrative (Appendix K) and Burden Table (Appendix W). Revisions in the burden hours are due to program changes due to the Final Rule and to update estimated burden based on comments received on the proposed collection.
FNA estimates that with this revision, this collection will have 815,362 respondents, 4,040,298 responses, and 890,743 burden hours. The overall information collection burden is estimated to decrease by 327,695 burden hours and by 4,447 responses annually due to program changes due to the rule and burden estimate changes in response to comments received. FNA expects that this rule will decrease the total estimated burden hours from 1,218,438 to 890,743 hours and the responses from 4,044,745 to 4,040,298 responses. The revisions would increase the approved reporting burden by 1,031 hours and decrease the approved record-keeping burden by 328,726 hours.
The estimated burden revisions for this information collection, including the number of respondents, frequency of responses, average time to respond, and annual hour burden are shown in the table below.  



                 APPENDIX W: Burden Table                                            
Regulatory Section
Information Collected
Estimated Number of Respondents
Annual Responses per Respondent
Total Annual Responses
Number of Burden Hours per Request
Estimated Total Burden Hours
Previous Submission: Total Hours per Person
Difference Due to Program Changes or in Burden Estimates
REPORTING BURDEN ESTIMATES
Affected Public:  State and Local Agencies (including Indian Tribal Organizations and U.S. Territories)
250.69(d)(3) &
250.70(d)(3)
Disaster Household Distribution Bi-Weekly Report 
7
15
105
1
105.00
0
105.00
247.5(b)(16)
Public Posting of Availability of USDA Foods (CSFP)
59
1
59
4
236.00
0
236.00
251.4(l)
Public Posting of Availability of USDA Foods (TEFAP)
54
1
54
4
216.00
0
216.00
251.10(b)(3)
Report of Eligible Recipient Agency List to FNS (TEFAP)
54
1
54
1
54.00
0
54.00
251.10(b)(4)
Recipients of USDA Foods for Home Consumption (TEFAP)
54
4
216
2
432.00
0
432.00
253.12
Administrative Waivers (FDPIR)
11
1
11
8
88.00
0
88.00
Subtotal Reporting: State and Local Agencies
239
23
499
20
1,131
0
1,131
Affected Public:  Private Not for Profit
250.69(d) and 250.70(d)
Disaster Agency Reporting of Household Information
0
0
0
0
0
50
-50
Subtotal Reporting: Private Not for Profit
0
0
0
0
0
50
-50
Affected Public:  Individuals
250.69(d) and 250.70(d)
Household Information Reporting for Disasters and Situations of Distress
0
0
0
0
0
50
-50
Subtotal Reporting: Individuals
0
0
0
0
0
50
-50
GRAND SUBTOTAL: REPORTING
239
23
499
20
1,131
100
1,031
 
 
 
 
 
 
 
 
 
RECORDKEEPING BURDEN ESTIMATES
Affected Public:  State and Local Agencies (including Indian Tribal Organizations and U.S. Territories)
250.19(a)

Recordkeeping of Agreements, Reports, and Other Records (Records Related to the Receipt, Distribution, and Inventory of Donated Foods – Child Nutrition Programs Recipient Agencies)

20,866
15
312,990
0.1
31,299.00
25039.2
6,259.80
251.10(a)(3)
Eligible Recipient Agency List (TEFAP)
54
1
54
1
54.00
0
54.00
Subtotal Record Keeping: State and Local Agencies
20,920
16
313,044
1
31,353
25,039
6,314
Affected Public:  Private Not for Profit
251.10(a)(4)
Eligibility Determination and Collection of Participating Household Information (TEFAP)
1,600
1
1,600
211
336,800
671,840
-335,040
Subtotal Record Keeping: Private Not for Profit
1,600
1
1,600
211
336,800
671,840
-335,040
GRAND SUBTOTAL: RECORDKEEPING
1,654
2
1,654
212
336,854
671,840
-334,986
GRAND TOTAL: REPORTING AND RECORDKEEPING 
22,759
40
315,143
232
369,284
696,979
-327,695

The overall estimated burden revisions for this information collection including the number of respondents, frequency of responses, average time to respond, and annual hour burden are shown in the attached Appendix W – 0584-0293 Food Distribution Burden Table and explained through the attached Appendix K Burden Narrative. A summary of the revised burden estimates appears below:

Table 2: Reporting and Record Keeping 
Reporting





Affected Public
Est. No. of Respondents
No. of Responses per Respondent
Total Annual Responses
Est. total Hours per Response
Est. total Burden
State, Local, and Tribal Governments
26,403
1,709.01
233,283.24
231.51
60,415.75
Private For Profit
3,443
202.45
861,681.33
0.03
26,093.88
Private Not for Profit
740
1.00
740.00
0.76
564.50
Individual
723,200.00
1.97
1,425,700.00
0.25
361,600.00
Total Burden Estimates
753,786.00
3.34
2,521,404.57
0.18
448,674.13




        














Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.



We estimate the total cost to respondents to be $27,090,829.74 per year for reporting and recordkeeping combined for all Food Distribution Programs. The respondent cost is the estimated total burden and uses the mean hourly wage rate of $33.54, defined in the May 2025, “Occupational Employment Statistics” published by the U.S. Department of Labor, Bureau of Labor Statistics (https://www.bls.gov/oes/current/oes211093.htm) for State, Local, and Tribal Governments, Private for Profit, and Private Not for Profit members of the Affected Public, plus $7.25 as the Federal minimum wage for Individuals (applicants), which was last set in July 2009 (U.S. Department of Labor, https://www.dol.gov/general/topic/wages/minimumwage). With a burden of 890,742.66 hours, the base annual respondent cost is estimated at $20,369,044.92. An additional 33% of the estimated base annual respondent cost must be added to represent fully loaded wages, equaling $6,721,784.82. Thus, the total annual respondent cost is $27,090,829.74.

Table 3: Respondent Cost 

Affected Public
Est. No. of Respondents
Total Annual Responses
Est. Total Burden
Hourly Wage Rate
Respondent Cost*
State, Local, and Tribal Governments
26,403
704,965.70
102,190.27
$33.54 
$3,427,461.76
Private For Profit
3,443
1,896,110.33
88,765.60
$33.54 
$2,977,198.22
Private Not for Profit
740
13,522.00
338,186.79
$33.54 
$11,342,784.94
Individual
723,200.00
1,425,700.00
361,600.00
$7.25 
$2,621,600.00
TOTAL
753,786
4,040,298.03
890,742.66
 
$27,090,829.74

*Respondent Cost has 33% added to the total to account for fringe benefits 


A13.  Estimates of other total annual cost burden.

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 annual capital, start-up, or ongoing operation/maintenance costs to respondents of the food distribution programs.

A14.  Provide estimates of annualized cost to the Federal government.  

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.

It is estimated that federal employees receiving an average General Schedule (GS) grade 12 step 05 wage for the Washington DC area 2026 OMB Salary Table ($55.80 hourly), take approximately 7 staff years to analyze data received from this information collection:  

Headquarters Staff      2.00 staff years
Regional Staff             5.00 staff years
Total Staff Years         7.00 staff years

An additional 33% of the estimated base annual cost to the Federal government must be added to represent fully loaded wages, equaling $268,107.84.  Thus, the total annual Federal cost is $39,480,555.84. 
7 staff years or 14,560 hours at $55.80 per hour:
 $812,448.00 
     33% for Fringe Benefits
 $268,107.84
Cost of maintaining WBSCM Annually:
 $38,400,000.00
Total Federal Cost:                                              
 $39,480,555.84

A15.  Explanation of program changes or adjustments.

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 and renewal of a currently approved collection as the result of the final rule, Food Distribution Programs: Improving Access and Parity, 89 FR 87228 (October 31, 2024) and in response to comments received from the notice, Agency Information Collection Activities: Renewing Burden Number 0584-0293 (91 FR 13272). The current burden inventory for this request is 1,218,437.86 burden hours and 4,044,745.03 responses.  This revision seeks 890,743 burden hours and 4,040,298 responses.

The reporting and record-keeping burdens covered by this information collection request which relate to the Food Distribution Programs Final Rule 89 FR 87228 (October 31, 2024) include requirements that involve collecting information on the quantities and types of USDA Foods being provided nationally and within States during disasters and situations of distress, the organizations providing USDA Foods to eligible households through CSFP and TEFAP and their locations for a clearer understanding of service coverage, the number of persons served by TEFAP distribution of USDA Foods for home consumption, and to collect waiver requests from States and Indian Tribal Organizations. Overall, this submission reflects a decrease in recordkeeping and reporting of 333,955 hours due to the Final Rule.

There is also a recordkeeping burden change for 250.19(a), Recordkeeping of Agreements, Reports, and Other Records, Records Related to the Receipt, Distribution, and Inventory of Donated Foods – Child Nutrition Programs Recipient Agencies. This change, which will be more representative of the time taken by recipient agencies to maintain records relating to the receipt, distribution, and inventory of USDA Foods, will change the estimated burden from 25,039.20 hours per year to 31,299.00 hours per year, an increase of 6,259.80 burden hours annually.

As a result of the revisions to this collection, FNA estimates there is a net decrease of 327,695 hours and 4,447 annual responses to the existing information collection due to program changes as a result of the final rule and the revision mentioned above. 

A16.  Plans for tabulation, and publication and project time schedule. 

For collections of information whose results are planned to be published, outline plans for tabulation and publication.

This submission does not involve the collection of information through statistical methods.  There are no plans to publish any of the information collected.

A17.  Displaying the OMB Approval Expiration Date.

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 instruments.

A18.  Exceptions to the certification statement identified in Item 19.  

Explain each exception to the certification statement identified in Item 19 of the OMB  83-I" Certification for Paperwork Reduction Act."

No exceptions are made to the certification statement.