Comment Request - SNAP Quality Control
There are three components of the Quality Control (QC) system that are covered in this required information collection. They are: (1) The sampling plan; (2) the arbitration process; and (3) the good cause process. Each State is required to develop a sampling plan that demonstrates the integrity of its case selection procedures. The QC system is designed to measure each State agency's payment error rate based on a statistically valid sample of SNAP cases. A State agency's payment error rate represents the proportion of cases that were reported through a QC review as being ineligible, as well as the proportion of SNAP benefits that were either overissued or underissued to SNAP households.
The QC system contains procedures for resolving differences in review findings between State agencies and FNS. This is referred to as the arbitration process. The QC system also contains procedures that provide relief for State agencies from all or a part of a QC liability when a State agency can demonstrate that a part or all of an excessive error rate was due to an unusual event that had an uncontrollable impact on the State agency's payment error rate. This is referred to as the good cause process.
The approved burden for the QC system includes the burden for the QC sampling plan, the arbitration process and the good cause process. The currently approved burden for total reporting burden for the QC system is 1,544.91 hours, an increase of 167.91 hours. (1) The annual reporting burden associated with the QC sampling plan remains at 265 hours. (2) We estimate the annual reporting burdens associated with arbitration and (3) good cause processes to total 791.1 and 320 hours, respectively. The decrease in the revised burden from the currently approved 792 to 791.1 hours for the arbitration process is due to a decrease in the estimated number of responses per State agency. These decreases are a result of State agencies less frequently disagreeing with FNS' findings. The requested annual reporting burden for the good cause process remains at 320 hours.
In addition, we are adding two additional forms to the reporting burden: FNS 74A, Template for QC-related New Investment Plans and FNS 74B, Template for QC-related New Investment Plan Progress Reports. These two templates are being added to this collection in an effort to formalize the regulatory requirements of these two items for States that are subject to QC-related new investments.
Based on the number of State agencies subject to the QC-related new investment requirement over the last three years and feedback from those State agencies that responded to our inquiry, we estimate the amount of time to create a QC-related new investment plan is approximately 32 hours. This estimate includes determining root causes of a State agency's error rate, exploring methods to address those causes, and writing up the plan to address those causes. In addition, we estimate it takes approximately 5 hours to complete a progress report updating FNS on the status of the activities in the State agency's relevant QC-related new investment plan. We estimate the total annual reporting burden for 4 State Agencies to complete a new investment plan to be 128 hours and 40 hours for the progress report.
The requested annual recordkeeping burden associated with the QC sampling plan remains at 1.25 hours per year. The revised annual recordkeeping burdens associated with arbitration has increased from 0.7788 hour to 1.4868 hours and the good cause process has remained at 0.0472 hour. The estimated recordkeeping burden for the QC-related new investment plan and progress reports total 0.0944 hour and 0.1888 hours respectively.