Supporting Statement-112106

3

Supporting Statement for Form SSA-1425,

Reporting Changes That Affect Your Social Security Payment

(OMB 0960-0073)

20 CFR 404, Subparts D & E

A. Justification

1. Sections 202(b)(1), (c)(1), (d)(1), (e)(1), (f)(1), (g)(1), (h)(1), (t)(1); 203(b)(1), (c), (h)(1)(A); and 205(a) of the Social Security Act (the Act) provide that once a person is determined by the Social Security Administration (SSA) to be entitled to Social Security benefits, the law requires such person to notify SSA of any change in circumstances which could affect continued entitlement and receipt of checks. Entitlement includes retirement, disability, wife’s, husband’s, child’s, widow’s, widower’s, mother’s, father’s, or parent’s benefits. Sections 20 CFR 404.301-305, 404.310-311, 404.330-.333, 404.335-.341, 404.350-.352, 404.370-.371, 404.401-.402, 404.408(a), 404.421-.425. 404.428-.430, 404.434-.437, 404.439-.441, 404.446-.447, 404.450-.455 and 404.468 of the Code of Federal Regulations set forth the procedures and policies for implementing the Act.

Sections 202, 203, and 205 of the Act set out how earnings, death, divorce, annulment, marriage, no longer having a child in care, going outside the United States, etc., affect a person’s continuing entitlement to retirement and survivors benefits.

2. In order to make proper determinations as to benefit payment increases, decreases, suspensions or terminations of entitlement (depending on the event reported), it is essential that persons notify SSA of these events. Form SSA-1425 is furnished by SSA, to beneficiaries, to be completed and returned to SSA only in the event of a reportable change in the beneficiary’s circumstances. The entire form will not be completed; only the situation which has changed will be reported.

3. Improved information technology which would reduce the burden is not available. Form SSA-1425 is not currently scheduled for implementation of the Government Paperwork Elimination Act (GPEA) due to the moderate volume of respondents, agency priorities and limited resources. An inter-component group reviewed many forms to decide which were the best candidates to be placed on the SSA web site for access by the public. The SSA-1425 was considered but did not get selected.  A consideration in selecting which forms to do first was SSA’s limited resources to convert the forms. One of the reporting items on the SSA-1425 is to report a change of address.  Since that is a common event, change of address is now an option on the SSA website.  It is under the "What you can do online" menu. So, while the entire form itself is not scheduled to go online, some of the reporting events will be considered in the future when resources allow, but firm dates have not been set. 

4. The nature of the information being collected and the manner in which it is collected preclude duplication. There is no other collection instrument used by SSA that collects data similar to that collected here.

5. This collection does not have a significant impact on a substantial number of small businesses or other small entities.

6. Collection must take place based upon the need of the applicant. If the information were collected less frequently, it could result in incorrect payments to beneficiaries because the records might be incomplete or inaccurate and may not reflect the beneficiary’s current status. Therefore, the information can not be collected less frequently. If the information was not collected, SSA would not know if the benefit payment was correct until after the agency learned of any change in circumstances; then overpayments could have occurred. If the change was reported timely, SSA could update the records and make any needed payment changes. There are no technical or legal obstacles which prevent burden reduction.

7. There are no special circumstances that would cause this information collection to be conducted in a manner that is not consistent with 5 CFR 1320.5.

8. The 60-day advance Federal Register Notice was published on January 4, 2007 at 72 FR 357. The 30-day Federal Register Notice was published on March 15, 2007 at 72 FR 12244. There have been no outside consultations with members of the public.¹

9. SSA provides no payment or gifts to the respondents.

10. The information requested is protected and held confidential in accordance with 42 U.S.C. 1306, 20 CFR 401 and 402, 5 U.S.C. 552 (Freedom of Information Act), 5 U.S.C. 552a (Privacy Act of 1974) and OMB Circular No. A-130.

11. The information collection does not contain any questions of a sensitive nature.

12. Form SSA-1425 will be used by approximately 70,000 respondents annually. The estimated average response time is 5 minutes, for a total of 5,833 burden hours. The total burden is reflected as burden hours, and no separate cost burden has been calculated. All respondents will be individuals/households.

13. There is no known cost burden to the respondents.

14. The annual cost to the Federal government is approximately $107,800.00. This estimate is a projection of the costs for printing and distributing the collection instrument and for collecting the information.

15. There are no changes in the public reporting burden.

16. The results of the information collection will not be published.

17. OMB has granted SSA an exemption from the requirement that the expiration date for OMB approval be printed on its program forms. SSA produces millions of public-use forms, many of which have a life cycle longer than that of an OMB approval. SSA does not periodically revise and reprint its public-use forms (e.g., on an annual basis). This exemption was granted so that otherwise useable editions of forms would not be taken out of circulation because the expiration date had been reached. In addition, Government waste has been avoided because stocks of forms will not have to be destroyed and reprinted.

18. SSA is not requesting an exception to the certification requirements at 5 CFR 1320.9 and related provisions at 5 CFR 1320.8(b)(3).

B. Collections of Information Employing Statistical Methods

Statistical methods are not used for this information collection.

1 The first FR dated 01/04/07 was published as an extension; however subsequent to this publication, minor revisions to the form were requested. We published the second notice as a revision.