NCEP [Noncitizen Eligibility and Certification Provisions] Passback Notes and Drafts Marked 11/7/00 [2]
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OCR Page 1 of 9511/7 drafts
EOP Passback Notes
Final FSP Rule: Non-Citizen Eligibility and Certification Provisions of PRWORA
General Comments
1.
Pages 2-3, FNS states that it is finalizing changes to the proposed rule that, "exclude from
income on-the-job training payments received under the Summer Youth Employment and
Training Program as required by Section 702 of the Job Training Reform Amendments of
1992.' Please change reference to WIA, consistent with the rule.
FNS correction accepted.
2.
The reference to EO 12372 (page 6, 12 obsolete. EO 13132 on Federalism requires
consultation with state and local governm its when a final rule issued by an agency has
federalism implications as defined by the Executive Order. Please include a discussion of
federalism under EO 13132, including a discussion of your consultation process, and
either include a Federalism Certification or explain why one is not needed in this case.
FNS correction accepted.
3.
Regarding the discussion of the Paperwork Reduction Act on pages 6-7, do any of the
provisions of this rule alter either the ntent of the previously approved collections
under OMB #s 0584-0064, 0584-0096, 0584-0083, or 0584-0350 or the burden on
respondents? Please clarify which if any of the information collection requirements are
no longer necessary? Submit any changes to OMB as soon as possible.
FNS will redraft this section to update, as instructed by OMB on 11/7/00. Holding
pending addition of all reporting and recordkeeping burden.
4.
In the discussion of the Regulatory Impact Analysis on page 10, please correct the typo,
" count all or part, or none of..."
FNS correction accepted.
5.
Also in the Regulatory Impact Analysis (page 12), FNS discusses the costs and benefits
associated with the final rule. Why are savings to the program included as costs? Did
FNS leave out additional benefits, or was the single sentence included under the benefits
section intended to be inclusive? Can the benefits to state agencies resulting from
increased flexibility be quantified?
Suggested revisions to the RIA will follow shortly.
6.
In page 13 of the RIA under the discussion of Section 402 - Alien Eligibility, please edit
as follows, "The exceptions are those admitted as lawful permanent residents who have
been credited with earned at least 40 quarters of coverage
FNS correction accepted.
7.
On pages 24-26 of the RIA, the vehicle policy included in the rule is misstated. The rule
does not eliminate the equity test. Please edit this discussion to reflect the fact that the
new policy is "one car per adult at fair n arket value", with the fmv vs. equity test
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