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Supporting Statement for OMB Clearance for the 2027 Farm to School Census

Part B

Revision to OMB # 0584-0646, 2027 Farm to School Census 

February 2025

Amy Rosenthal
Social Science Research Analyst
Evidence, Analysis and Regulatory Affairs Office
Food and Nutrition Service
United States Department of Agriculture
1320 Braddock Place
Alexandria, Virginia 22314
Phone: 703-305-2245
Email: [email protected]
TABLE OF CONTENTS
B1.	Respondent Universe and Sampling Methods	1
B2.	Procedures for the Collection of Information	2
B3.	Methods to Maximize the Response Rates and to Deal with Nonresponse	3
B4.	Test of Procedures or Methods to be Undertaken	5
B5.	Individuals Consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data	6

TABLES
Table B.1 Summary of respondent universe and response rates	2
Table B.2 Individuals consulted on statistical aspects of study design	8

APPENDICES
A.1 			Section 18 of the Richard B. Russell National School Lunch Act
A.2			Section 305 of the 2010 Healthy Hunger Free Kids Act
B.1			Census Survey Instrument
B.1a 		Census Survey Instrument Sample Screenshots
B.2			Census Frequently Asked Questions (FAQs)
B.3			Census Preparation Worksheet
C.1			Recruitment Email from FNS To State Child Nutrition (CN) 
Directors
C.2	Recruitment Email from Study Team to State CN Directors 
C.3			Intro Email from State CN Directors to SFAs
C.4			Initial Email from Study Team to SFAs
C.5			Reminder Emails from Study Team to SFAs
C.6			Reminder Email Request from Regional Lead to State CN Directors
C.7			Reminder Email Template from State CN Directors to SFAs
C.8			Reminder Letter to SFAs
C.9			Follow-Up Telephone Call Script
F			NASS Comments and FNS Response
G			Estimated Annualized Burden 
B1.	Respondent Universe and Sampling Methods
Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection method to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons) in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the collection as a whole. If the collection had been conducted previously, include the actual response rate achieved during the last collection.
The potential respondent universe for the 2027 Farm to School Census (Census) includes State, Local, and Tribal governments (directors of public school food authorities (SFAs) participating in the National School Lunch Program (NSLP), state Child Nutrition (CN) directors); businesses or other for-profit organizations (directors of private SFAs participating in the NSLP); and not for profit organizations (directors of not for profit SFAs participating in the NSLP). The Census survey will be distributed to all public and private SFAs (including residential child care institutions) participating in the NSLP in the 50 states, American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, the U.S. Virgin Islands, and Washington, D.C. State CN staff will provide contact information for the SFAs in their respective state or territory. No data will be collected from households. 
The universe of 56 state CN directors will be asked to provide a list of public and private SFAs that administer the NSLP in their state or territory for the purpose of constructing an up-to-date Census contact list (Appendix C.1). The same staff will be asked to send two email reminders (Appendix C.6) to all SFAs in their state or territory. The expected response rate for the request to provide contact information and to send email reminders is 100 percent (see Table B.1).
For the Census survey, the potential universe is approximately 18,600 SFA directors (15,600 government, 2,000 business and 1,000 not for profit). This is based on a total of 18,538 SFAs from which the Food and Nutrition Service (FNS) collected meal claims data from in school year 2023-24. We anticipate a 67 percent overall response rate to the survey, based on the 67 percent overall response rate observed for the 2023 and 2019 Farm to School Census. 
No sampling is required for this information collection.   
Table B.1 Summary of respondent universe and response rates 
Type of Respondent
Estimated Universe Size
Expected Response Rate
Target Completed Responses
State Child Nutrition directors
56
100%
56
SFA directors (public schools)
15,600
67%
10,452
SFA directors (private schools)
2,000
67%
1,340
SFA directors (not for profit schools)
1,000
67%
670
Total
18,656
70%
13,316
B2.	Procedures for the Collection of Information
Describe the procedures for the collection of information including:
    • Statistical methodology for stratification and sample selection;
    • Estimation procedure;
    • Degree of accuracy needed for the purpose described in the justification;
    • Unusual problems requiring specialized sampling procedures; and
    • Any use of periodic (less frequent than annual) data collection cycles to reduce burden.
Information to build the contact list for SFA directors will be collected from the relevant state CN agency. All State CN directors will be asked to provide contact information in order to create an accurate contact list, so there will be no sampling of state CN agencies. The FNS National Office will liaise with Community Food Systems Division (CFSD) Regional Specialists to alert the relevant agencies (Appendix C.1), and the study team will provide telephone and email support to CN directors as requested. Based on previous experience, we expect that directors will primarily provide the data in Excel files, but we will be prepared to work with directors should it be more convenient for them to provide the data in a different format.
The Census survey will be sent to all SFAs participating in the NSLP in any State or territory, so there will be no sampling of SFAs. SFAs will receive an email with a unique link to participate. SFAs will receive up to nine reminder emails to encourage their completion of the survey, and some will receive a phone call and/or mailing as well (Appendices C.7-C.9). As such, no specialized sampling procedures are planned.
The Farm to School Census is a periodic data collection. The 2027 Census will be the fifth collection in fourteen years (previous iterations were administered in 2013, 2015, 2019 and 2023).
B3.	Methods to Maximize the Response Rates and to Deal with Nonresponse
Describe methods to maximize response rates and to deal with issues of non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield "reliable" data that can be generalized to the universe studied. 
The request for contact information is expected to achieve a 100 percent response rate, and the Census survey is expected, based on response to the 2019 and 2023 Censuses, to receive a 67 percent response rate. The approach to achieving high response rates builds on prior FNS study experience. The ultimate response rate depends on successfully contacting those sampled, securing their participation in the study, and offering support and completion reminders, all of which have been carefully addressed in the study plan.  
CN agencies will receive an introductory email from the FNS National Office to introduce the 2027 Census and outline what is requested of them, notably, providing contact information for all SFA directors in their state or territory (Appendix C.1). Building on a successful strategy from the 2023 Census administration, FNS will also offer a webinar to introduce State CN directors to the 2027 Census process. For the 2027 Census, FNS will be administering the survey in Spring 2027 to ask about the 2026-2027 school year, whereas the 2023 and 2019 Census administrations occurred in the fall and asked about the previous school year. Given the high rates of year-to-year turnover in SFA directors, we anticipate this will maximize the likelihood of having the correct contact information and ensure delivery of the survey to the appropriate SFA representative. 
For communication with SFAs, we will distribute engaging recruitment materials with standardized language to describe the study and encourage participation. (Appendices C.3-C.5, C.7-C.8) . The emails announcing the Census and inviting the SFA to participate will emphasize the importance of this study as well as offer information so that SFAs understand what is being asked of them (Appendix C.3-C.4). Contact information will be used for initial correspondence and will be updated as needed throughout the data collection period to facilitate communication with the respondents. (Respondents will be asked to email the study team in order to update contact information.) 
To encourage participation and discourage unit nonresponse, the study team will include in each email a frequently asked questions document to answer common SFA questions that may lead to nonresponse if unanswered (Appendix B.2). SFAs can also ask questions via the study email or phone number. Staff will be readily available to clarify survey questions and work with participants to resolve technical issues. 
The introductory material of the survey (Appendix B.1) as well as the outreach emails sent to SFA directors (Appendices C.3-C.5 and Appendix C.7) will include a link to a worksheet (Appendix B.3) to make SFA directors aware of key questions that will be asked of them on the survey. This will help ensure that the respondent can gather necessary information before beginning the survey and/or request assistance from a colleague who might have the appropriate knowledge. The survey will also be designed such that more than one person can respond to survey questions, so that the initial recipient can forward to colleagues who may be more equipped to respond to some or all survey questions. We also will highlight in the survey introductory material (Appendix B.1), the frequently asked questions (Appendix B.2), and email communications (Appendices C.3-C.5) that several individuals can access the survey via the emailed link, so that the appropriate person can respond to each question. The web survey will allow respondents to save and exit the survey at any point, and then return to access and complete the survey later (see example navigation menu in Appendix B.1a). 
Using data from the 2023 Census, we have streamlined and purposively arrange the 2027 survey questions to enhance the respondent experience and discourage item nonresponse. As in 2023, a survey may be considered complete for the purposes of analysis if the SFA provides responses to a minimum number of key questions. 
SFA directors, including those who have begun but not completed a survey, will receive email follow-up reminders approximately every ten days (Appendices C.5 and C.7). Up to two follow-up telephone calls may be made to sampled units who have not completed the survey by the end of May (Appendix C.9). SFAs that have not opened the survey will also receive a mailing to the SFA address (Appendix C.8). 
We anticipate that adjusting the timing of the survey to the spring will help minimize both unit and item nonresponse. Based on feedback from Regional Office and State CN agency staff, fall is a particularly busy time for SFA directors, as they begin the school year, account for multiple holidays, and deal with common weather events (i.e., hurricanes). By spring, school food procedures should be routine, and SFA staff may have more time to respond to the survey. Asking at the end of the school year about that year should also contribute to lower item nonresponse and improve the quality of information collected. SFA directors should be more likely to be aware of farm to school activities that occurred that year. Given the high turnover rates of SFA directors, many may be new in the fall and not aware of the farm to school activities that occurred previously.
B4.	Test of Procedures or Methods to be Undertaken
Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of tests may be submitted for approval separately or in combination with the main collection of information. 
Pre-testing is not necessary for collecting SFA contact information from State CN directors. 
The 2027 Census survey is based on the instrument used in the 2023 and 2019 Census, which was cognitively pre-tested as described in the previously approved Information Collection (OMB No. 0584-0646, expiration date May 31, 2025. 
In comparison to the 2023 survey instrument, six questions have been removed; these were related to COVID-19 or collected detailed information about benefits and challenges experienced by SFAs, local spending, and sources of local purchases. Some survey language has been slightly reworded to match current USDA definitions. One new question and seven new response options were added to collect more detail about charter school representation (in response to GAO-25-106846 School Meal Programs: Additional Data and Outreach Could Help Charter School Participation), farm to school funding, cost-related challenges of farm to school, use of micropurchases, and use of farm to school materials. All changes have been designed to ensure comparability between the 2027 and 2023 Census.
To confirm these minor changes, we plan to conduct a pretest with no more than 9 SFA directors in Fall 2026. For pre-testing, a sample of up to nine directors from SFAs that vary in food service operations, urbanicity, and size will be recruited. The directors will review an electronic version of the full survey instrument and provide feedback during a telephone interview. We will ask specifically about the overall burden and the revised content. The pretest will focus on new or changed content and is expected to result in only minor changes to survey question wording and response options. A non-substantive change request memorandum will be submitted to OMB if more significant changes are required. We will update the survey instrument (Appendix B.1) as well as associated materials (i.e., the worksheet (Appendix B.3)) according to their feedback.
B5.	Individuals Consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data
Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency.
Table B.2 lists individuals consulted on statistical aspects of the design. The study team is led by Amy Rosenthal (FNS Project Officer). Other staff who will collect and/or analyze the data will depend on the contractor who wins the award to administer the 2027 Census.
Table B.2 Individuals consulted on statistical aspects of study design
Reviewer
Affiliation
Phone
Email
Conor McGovern
FNS/USDA
(703) 457-7740
[email protected]
Amy Rosenthal
FNS/USDA
(703) 305-2245
[email protected]
Ashley Chaifetz
FNS/USDA
(703) 457-7741
[email protected]
Jeffry Hunt
NASS/USDA
(202) 720 5359
[email protected]