0584-0479 Burden Worksheet

Appendix_F_FRA_Final_Rule_PRA_Burden_Table_v1_10-3-2024[1].xlsx

Supplemental Nutrition Assistance Program: Work Requirements and Screening

0584-0479 Burden Worksheet

OMB: 0584-0479

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Overview

Burden Summary
Assumptions
Federal Cost Summary
Respondents Cost Summary
Labor Rates


Sheet 1: Burden Summary


FNS SNAP ABAWD ICR Reporting Estimate (OMB Control No. 0584-0479)

Activity Citation Number of Respondents Frequency of Response Total Annual Responses Hours per Response Annual Burden (hours) Hourly Wage Rate Total Annualized Cost of Respondent Burden Previously Approved Burden Hours Change in Burden Hours Due to an Program Change Total Change in Burden Hours

A B C D E = C x D F G = E x F H I = (G x H) J K = G - J L = J + K

Start-Up Burden

Affected Public: State Agencies

Update of eligibility system with new requirements (including coding for modified exceptions, updating language on the Notice of Adverse Action and Consolidation Work Notice) 7 CFR 273.24(c)(7), (8), (9), and (10) 53 1 53 4,729 250,637 $52.96 $13,273,885.90 0 250,637 250,637

Update policy manuals, guidance, and other documents with new requirements 7 CFR 273.24(c)(7), (8), (9), and (10), 273.24(k), 273.24(l), 273.7(b)(3) 53 1 53 80 4,240 $53.09 $225,116.86 0 4,240 4,240

Develop and provide training to staff on new requirements 7 CFR 273.24(c)(7), (8), (9), and (10), 273.24(k), 273.24(l), 273.7(b)(3) 53 1 53 80 4,240 $53.09 $225,116.86 0 4,240 4,240

Take training on new requirements 7 CFR 273.24(c)(7), (8), (9), and (10), 273.24(k), 273.24(l), 273.7(b)(3) 105,030 1 105,030 2 210,060 $32.15 $6,752,609.77 0 214,740 214,740

Reporting Burden Total for Start-Up Burden 105,083 1 105,189 4.46 469,177 $43.64 $20,476,729.40 0 473,857 473,857

Ongoing Burden

Affected Public: State Agencies

Applying Modified Exception Criteria

Additional verification of hours worked and countable months in another State at initial or recertification application for ABAWDs newly subject to the work requirement 7 CFR 273.2(f)(1), (f)(2), and (f)(8)(i) 53 9,757.93 517,171 0.0917 47,407 $32.15 $1,523,959.67 0 47,407 47,407

Additional issuance of the Consolidated Work Notice for ABAWDs newly subject to the work requirement 7 CFR 273.7(c)(1) 53 9,757.93 517,171 0.083 43,098 $32.15 $1,385,417.88 0 43,098 43,098

Additional review of the oral explanation of the work requirements for ABAWDs newly subject to the work requirement 7 CFR 273.7(c)(1) 53 9,757.93 517,171 0.083 43,098 $32.15 $1,385,417.88 0 43,098 43,098

Additional issuance of the Notice of Adverse Action for ABAWDs newly subject to the work requirement who do not meet it 7 CFR 273.13(a) 53 5,321.81 282,056 0.067 18,804 $32.15 $604,466.69 0 18,804 18,804

Screening
Screening for exemptions from the general work requirement at initial application 7 CFR 273.7(b)(3) 53 312,245.28 16,549,000 0.067 1,103,267 $32.15 $35,465,720.59 0 1,103,267 1,103,267

Screening for exemptions from the general work requirement at recertification application 7 CFR 273.7(b)(3) 53 49,789.96 2,638,868 0.067 175,925 $32.15 $5,655,287.48 0 175,925 175,925

Screening for exceptions from the ABAWD work requirement and time limit at initial application 7 CFR 273.24(k) 53 97,735.85 5,180,000 0.067 345,333 $32.15 $11,101,119.87 0 345,333 345,333

Screening for exceptions from the ABAWD work requirement and time limit at recertification application or during the certification period 7 CFR 273.24(k) 53 67,498.49 3,577,420 0.067 238,495 $32.15 $7,666,673.40 0 238,495 238,495

ABAWD Waivers

Preparation and submission of Labor Market Data to support ABAWD waiver request 7 CFR 273.24(f) 33 1 33 35 1,155 $32.74 $37,820.01 1,155 0 0

Preparation and submission of Labor Surplus Area designation or EB Trigger Notice criteria to support ABAWD waiver request 7 CFR 273.24(f) 2 1 2 4 8 $37.38 $299.06 8 0 0

Reporting Burden Sub-Total for Ongoing Burden to State Agencies 53 561,865.86 29,778,890.42 0.068 2,016,588.31 $32.13 $64,788,063.48 1,163 2,015,425 2,015,425

Affected Public: Individuals

Applying Modified Exception Criteria

Additional response to verification of hours worked and countable months in another State at initial or recertification application for ABAWDs newly subject to the work requirement 7 CFR 273.2(f)(1), (f)(2), and (f)(8)(i) 517,170.50 1 517,170.50 0.0917 47,407 $22.74 $1,078,041.91 0 47,407 47,407

Additional review of of the Consolidated Work Notice for ABAWDs newly subject to the work requirement 7 CFR 273.7(c)(1) 517,170.50 1 517,170.50 0.083 43,098 $22.74 $980,038.10 0 43,098 43,098

Additional review of the oral explanation of the work requirements for ABAWDs newly subject to the work requirement 7 CFR 273.7(c)(1) 517,170.50 1 517,170.50 0.083 43,098 $22.74 $980,038.10 0 43,098 43,098

Additional review of the Notice of Adverse Action for ABAWDs newly subject to the work requirement who do not meet it 7 CFR 273.13(a) 282,056 1 282,056 0.067 18,804 $22.74 $427,596.90 0 18,804 18,804

Screening

Screening for exemptions from the general work requirement at initial application 7 CFR 273.7(b)(3) 16,549,000 1 16,549,000 0.067 1,103,267 $22.74 $25,088,284.00 0 1,103,267 1,103,267

Screening for exemptions from the general work requirement at recertification application 7 CFR 273.7(b)(3) 2,638,868 1 2,638,868 0.067 175,925 $22.74 $4,000,523.77 0 175,925 175,925 leave a note as to why we did that

Screening for exceptions from the ABAWD work requirement and time limit at initial application 7 CFR 273.24(k) 5,180,000 1 5,180,000 0.067 345,333 $22.74 $7,852,880.00 0 345,333 345,333

Screening for exceptions from the ABAWD work requirement and time limit at recertification application or during the certification period 7 CFR 273.24(k) 3,577,420 1 3,577,420 0.067 238,495 $22.74 $5,423,368.72 0 238,495 238,495

Reporting Burden Sub-Total for Ongoing Burden to Individuals 29,778,855.42 1 29,778,855.42 0.068 2,015,425.31 $22.74 $45,830,771.49 0 2,015,425.31 2,015,425.31

Reporting Burden Total for Ongoing Burden 29,778,908.42 2 59,557,745.85 0.068 4,032,013.61 $27.44 $110,618,834.97 1,163 4,030,850.61 4,030,850.61

Reporting Burden Total for All Burden (Start-Up + Ongoing) 29,883,991.42 2 59,662,934.85 0.075 4,501,190.61 $29.12 $131,095,564.36 1,163 4,504,707.61 4,504,707.61















































59,662,899.85








Sheet 2: Assumptions

FNS SNAP ICR Assumptions (OMB Control No. 0584-0479)
Item Regulatory Citation Estimate
Number Data Source
Annual Costs
Number of individuals newly subject to the time limit who will need to verify work hours 7 CFR 273.2(f)(1), (f)(2), and (f)(8)(i) 517,171 Estimated based on the average projected SNAP caseloads for FY 2025-2030 and FNS projections of the number of individuals age 50 to 54 who will be newly subject to the time limit and are not exempt. This number may include individuals who may be exempt as a veteran or individual experiencing homelessness.
Number of individuals newly subject to the time limit who will need to receive the Consolidated Work Notice and oral explanation of the work requirements 7 CFR 273.7(c)(1) 517,171 Estimated based on the average projected SNAP caseloads for FY 2025-2030 and FNS projections of the number of individuals age 50 to 54 who will be newly subject to the time limit, are not exempt, and do not live in an area covered by a waiver. This number may include individuals who may be exempt as a veteran or individual experiencing homelessness.
Number of individuals newly subject to the time limit who are not meeting the work requirement and will receive a Notice of Adverse Action 7 CFR 273.13(a) 282,056 Estimated based on the average projected SNAP caseloads for FY 2025-2030 and FNS projections of the number of individuals age 50 to 54 who will be newly subject to the time limit, are not working at least 20 hours, are not exempt, and do not live in an area covered by a waiver.
Number of staff who will be trained on new requirements 7 CFR 273.24(c)(7), (8), (9), and (10), 273.24(k), 273.24(l), 273.7(b)(3) 105,030 Estimated based Bureau of Labor Statistics (BLS) Occupational Employment and Wages Statistics data from May 2023; Occupation Code 43-4061 Eligibility Interviewers, Government Programs, which estimates 54,920 individuals are employed in this occupation State Government (excluding schools and hospitals) and 50,110 in Local Government (excluding schools and hospitals). Available at https://www.bls.gov/oes/2023/may/oes434061.htm.

Number of individuals who need to be screened for the general work requirements at initial application 7 CFR 273.7(b)(3) 16,549,000 Estimated from the Characteristics of Supplemental Nutrition Assistance Program Households: Fiscal Year 2022; Table A.23, Number of participants who are non-elderly adults. https://fns-prod.azureedge.us/sites/default/files/resource-files/ops-snap-fy22-characteristics.pdf
Number of individuals who need to be screened for the general work requirements at recertification application 7 CFR 273.7(b)(3) 5,180,000 Estimated from the Characteristics of Supplemental Nutrition Assistance Program Households: Fiscal Year 2022; Table A.25, Number of participants with work registrant status. https://fns-prod.azureedge.us/sites/default/files/resource-files/ops-snap-fy22-characteristics.pdf
Number of individuals who need to be screened for the ABAWD time limit at initial application 7 CFR 273.24(k) 5,180,000 Estimated from the Characteristics of Supplemental Nutrition Assistance Program Households: Fiscal Year 2022; Table A.25, Number of participants with work registrant status. https://fns-prod.azureedge.us/sites/default/files/resource-files/ops-snap-fy22-characteristics.pdf
Number of individuals who need to be screened for the ABAWD time limit at recertification application or during the certification period 7 CFR 273.24(k) 3,577,420 Estimated based on the average projected SNAP caseloads for FY 2025-2030 and FNS projections of the share of ABAWDs in the caseload after implementation of changes to ABAWD eligbility (approximately 9.2% of the SNAP caseload)

Sheet 3: Federal Cost Summary

FNS SNAP ICR Federal Cost Estimate (OMB Control No. 0584-0479)
Activity Estimated Total Annual Burden Hours  Estimated Hourly Wage Rate  Cost (US$) (approx.) 
Preparation of Information Collection
Drafting – National Office Program Analyst (GS 13/1) 80 $75.17 $6,013.73
Reviewing – National Office Branch Chief (14/1) 10 $88.83 $888.31
Costs to Federal Workers   $6,902.04
Add 50% Federal Share of State Cost $42,651,455.97
Total Cost to Federal Government (Federal workers cost + 50% State Cost)  $42,658,358.01

Sheet 4: Respondents Cost Summary

FNS SNAP ICR Federal Cost Estimate (OMB Control No. 0584-0479)
Burden Activity Estimated Total Annual Burden Hours  Estimated Hourly Wage Rate  Cost (US$) (approx.) 
Affected Public: State Agencies
Start-Up Costs
Update of eligibility system with new requirements (including coding for modified exceptions, updating language on the Notice of Adverse Action and Consolidation Work Notice) 250,637 $52.96 $13,273,885.90
Update policy manuals, guidance, and other documents with new requirements 4,240 $53.09 $225,116.86
Develop and provide training to staff on new requirements 4,240 $53.09 $225,116.86
Take training on new requirements 210,060 $32.15 $6,752,609.77
Estimated Start-Up Costs (Before 50% Federal reimbursement offset) $20,476,729.40
Ongoing Costs
Additional verification of hours worked and countable months in another State at initial or recertification application for ABAWDs newly subject to the work requirement 47,407 $32.15 $1,523,959.67
Additional issuance of of the Consolidated Work Notice for ABAWDs newly subject to the work requirement 43,098 $32.15 $1,385,417.88
Additional review of the oral explanation of the work requirements for ABAWDs newly subject to the work requirement 43,098 $32.15 $1,385,417.88
Additional issuance of the Notice of Adverse Action for ABAWDs newly subject to the work requirement who do not meet it 18,804 $32.15 $604,466.69
Screening for exemptions from the general work requirement at initial application 1,103,267 $32.15 $35,465,720.59
Screening for exemptions from the general work requirement at recertification application 175,925 $32.15 $5,655,287.48
Screening for exceptions from the ABAWD work requirement and time limit at initial application 345,333 $32.15 $11,101,119.87
Screening for exceptions from the ABAWD work requirement and time limit at recertification application or during the certification period 238,495 $32.15 $7,666,673.40
Preparation and submission of Labor Market Data to support ABAWD waiver request 1,155 $32.74 $37,820.01
Preparation and submission of Labor Surplus Area designation or EB Trigger Notice criteria to support ABAWD waiver request 8 $37.38 $299.06
Estimated Ongoing Costs (Before 50% Federal reimbursement offset) $64,826,182.55
Estimated Total Cost to State Agencies (Before 50% Federal reimbursement offset) $85,302,911.95
Total Cost to State Agencies (State worker cost minus 50% Federal reimbursement) $42,651,455.97
Affected Public: Individuals
Ongoing Costs
Additional verification of hours worked and countable months in another State at initial or recertification application for ABAWDs newly subject to the work requirement 47,407 $22.74 $1,078,041.91
Additional review of the Consolidated Work Notice for ABAWDs newly subject to the work requirement 43,098 $22.74 $980,038.10
Additional review of the oral explanation of the work requirements for ABAWDs newly subject to the work requirement 43,098 $22.74 $980,038.10
Additional review of the Notice of Adverse Action for ABAWDs newly subject to the work requirement who do not meet it 18,804 $22.74 $427,596.90
Screening for exemptions from the general work requirement at initial application 1,103,267 $22.74 $25,088,284.00
Screening for exemptions from the general work requirement at recertification application 175,925 $22.74 $4,000,523.77
Screening for exceptions from the ABAWD work requirement and time limit at initial application 345,333 $22.74 $7,852,880.00
Screening for exceptions from the ABAWD work requirement and time limit at recertification application or during the certification period 238,495 $22.74 $5,423,368.72
Estimated Total Costs to Individuals $45,830,771.49
Total Costs to Respondents (State Agencies + Individuals) $88,482,227.47

Sheet 5: Labor Rates

FNS SNAP ICR Labor Rates (OMB Control No. 0584-0479)
Type Updated Estimate
Number Data Source
State Agency Program Staff $32.15 Bureau of Labor Statistics (BLS) Occupational Employment and Wages Statistics data from May 2023; Occupation Code 43-4061 Eligibility Interviewers, Government Programs, Median Hourly Wage Rate = $24.17. Available at https://www.bls.gov/oes/2023/may/oes_nat.htm. We have multiplied this wage rate by 1.33 to represent fully-loaded wages, resulting in a reimbursement value of $32.15 ($24.17 x 1.33) per burden hour.
State Agency Program Manager $53.09 Bureau of Labor Statistics (BLS) Occupational Employment and Wages Statistics data from May 2023; Occupation Code 11-9151 Social and Community Service Managers, Median Hourly Wage Rate for State Government = $39.92. Available at https://www.bls.gov/oes/2023/may/naics4_999200.htm#11-9151. We have multiplied this wage rate by 1.33 to represent fully-loaded wages, resulting in a reimbursement value of $53.09 ($39.92 x 1.33) per burden hour.
Computer Developers $52.96 Bureau of Labor Statistics (BLS) Occupational Employment and Wages Statistics data from May 2023; Occupation Code 15-0000 Computer and Mathematical Operations, Median Hourly Wage Rate for State Government = $39.82. Available at https://www.bls.gov/oes/2023/may/naics4_999200.htm#15-0000. We have multiplied this wage rate by 1.33 to represent fully-loaded wages, resulting in a reimbursement value of $52.96 ($39.82 x 1.33) per burden hour.
Program Analyst (GS-13/1)  $75.17 OPM Salary Table data for 2024, including locality pay for Washington-Baltimore-Arlington, DC-MD-WV-PA, for GS-13/1 = $56.52. Available at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/24Tables/html/DCB_h.aspx. We have multiplied this wage rate by 1.33 to represent fully-loaded wages.
Branch Chief  (GS-14/1)  $88.83 OPM Salary Table data for 2024, including locality pay for Washington-Baltimore-Arlington, DC-MD-WV-PA, for GS-14/1 = $66.79. Available at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/24Tables/html/DCB_h.aspx. We have multiplied this wage rate by 1.33 to represent fully-loaded wages.
Public $22.74 Bureau of Labor Statistics (BLS) Current Population Survey data for median weekly earnings for full time workers over age 16 over last four quarters (Q3 2023 through Q2 2024). Available at: https://beta.bls.gov/dataViewer/view/timeseries/LES1252881500. We have converted the earnings into an hourly wage rate and applied a 20 percent reduction to account for taxes and other work-related costs ($1,137 / 40 = $28.43 * 0.80 = $22.74).
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