USDA Request for Comment: Documentation Related to Meal Pattern Final Rule

Why It Matters 

USDA is required by the Paperwork Reduction Act of 1995 to determine whether new program requirements will be overly burdensome or costly to program operators. Although USDA estimates how much time and money updates will create, program operators may have additional insight based on their experience operating the program that can better inform USDA’s estimation. Operators can share their estimation of how much time it will take to collect required documentation and any additional costs to their organization that may result from it. Operators can also recommend methods of data collection that will minimize the burden of data collection. 

 

Comments Requested 

FNS has requested comments regarding: 

• whether this recordkeeping is necessary, 
• how much time it will take to collect this information and how much it will cost your organization 
• what methods would be best to collect this information 
• whether there are strategies to minimize the time and cost burden by using technology 

 

Recordkeeping Requirement Outlined in the Final Rule 

The final rule states that SFSP and CACFP sponsors, institutions, or facilities that choose to use this menu planning option must maintain documentation demonstrating that the site serves primarily American Indian or Alaska Native participants. However, the final rule does not outline specific recordkeeping requirement and instead states that USDA will issue guidance on acceptable data that can be used to report participant demographics. USDA mentions participant self-reporting, school data, or census data as potential data sources and lists the following examples: 

• For enrolled sites, the sponsor, institution, or facility determines, based on participant self-reporting, that American Indian or Alaska Native participants represent the largest demographic group of enrolled participants. 
• For enrolled sites, the sponsor, institution, or facility provides a certifying statement indicating that the site primarily serves American Indian or Alaska Native participants. 
• For non-enrolled sites, the sponsor, institution, or facility determines that American Indian or Alaska Native participants represent the largest demographic group of participants served by the site, based on school or census data. 

 

Estimation of Burden 

CACFP 

USDA estimates the recordkeeping requirement would require approximately 70 institutions and 540 facilities to collect and maintain documentation each year to demonstrate that the site serves primarily American Indian or Alaska Native participants. They estimate that it takes approximately 1.25 hours to collect and maintain such documentation, resulting in an estimated 763 annual burden hours. 

FNS has also accounted for start-up costs of $305,000 for the CACFP operators associated with menu changes because of this final rule. 

SFSP 

USDA estimates the recordkeeping requirement would require approximately 20 SFSP operators to collect and maintain documentation each year to demonstrate that the site serves primarily American Indian or Alaska Native participants. They estimate that it takes approximately 1.25 hours to collect and maintain such documentation, resulting in an estimated 25 annual burden hours. 

FNS has also accounted for start-up costs of $10,000 for the SFSP operators associated with menu changes because of this final rule. 

 

For more information, read the request for comment for the Child and Adult Care Food Program, Summer Food Service Program, School Breakfast Program, and/or National School Lunch Program. Reach out to policy@cacfp.org with any questions.