Comment on FR Doc # 2011-20796

The proposed rule does not include an effective date and does not indicate if this proposal would affect current automated data processing projects that have already been approved. If the proposal is retroactive to projects underway, then we have concerns with the proposed change. Specifically, Section 277.18(i) indicates that there will be significant involvement from FNS with the testing phase of the program and FNS concurrence is needed from testing to pilot as a condition of federal financial participation. Our previously approved APDs and Project Plans may not have allotted sufficient time for FNS involvement and/or approval of test plan/activities prior to and after system implementation which will result in more time being added to IT projects already approved and underway.