Supporting Statement for VA Form 22-8794
(OMB Control Number 2900-0262)
1) Each school and training facility approved by VA must have a VA Certifying Official on staff. This person is responsible for submitting to the VA each student’s enrollments or hours worked (for On-the-Job/Apprenticeship training), any changes made to those enrollments or hours, and often, applications to VA for education benefits. This form provides to the VA, the names and signatures of those persons authorized to submit, certify, and notify VA of any new hours or enrollments of their VA students.
The appropriate statute and regulations are attached. They are:
38 U.S.C. 3034(a), 3241, 3492, 3680 and 3684(a).
10 U.S.C. 16136(b) and 16166(b).
2) The VA uses the designation of Certifying Official(s) to maintain current records as to who the person is within the school or training facility who reports to the VA information necessary to correctly award benefits and act as a contact point regarding compliance of the records kept and reports submitted to VA.
3) Technology and funding currently available to VA Education Service does not include the ability to receive and validate electronic signatures; electronic collection of this required information is not an immediate option. The current method of collecting this information is the most efficient possible and causes the least amount of burden on the public. It’s hoped that as funding becomes available and security issues resolved, collection of this information may be done electronically rather than on paper.
4) VA is not aware of any duplication of this information collection, nor is it very likely.
5) The information collection burden cannot be reduced for the smaller education institutions or job training establishments. The entries required for this information collection imposes only a minimal burden on the smaller VA approved facilities, equal to that of the larger institutions.
6) The consequences that would result if this form was not submitted as needed, each time the person filling the position of Certifying Official changes could lead to erroneous student information being reported by someone other than the designated Certifying Official and could therefore, lead to fraud.
7) The collection of information does not require any special circumstances.
8) The public was informed of the right to submit comments on this information collection on pages 3195-3196 of the Federal Register dated January 24, 2007. No comments have been received in response. Consultations outside the VA have not been held since the last submission for approval. The Certifying Officials and the facilities they represent always have the opportunity to suggest any changes to this form.
9) VA does not provide any payment or gifts to the respondents.
10) Once received in the VA Regional Processing Office (RPO) or Regional Office (RO), the form is processed and retained in the approval file for that facility with other information maintained by VA regarding VA approval of the school or training establishment. Our assurance of confidentiality and security are covered in our System of Records, Compensation, Pension, Education and Rehabilitation Records, VA (58VA 21/22), which are contained in the Privacy Act.
11) None of the information collected is considered to be of a sensitive nature.
12) The estimated annual burden for collection of the information is 533 hours. We arrived at this figure by estimating that this form takes 10 minutes to complete; multiplying the total annual responses (3,200) by the time required to complete this form (10 minutes) gives 32,000 minutes, or 533 total annual hours.
The annual cost to the public is $8,667.00, based on an estimated 3,200 submissions annually. This cost was determined by considering the estimated number of responses received annually (3,200), each taking approximately ten minutes to complete (32,000 minutes, or 533 hours) at $15.00 per hour. This total cost is $7,995.00.
Mailing costs are $672.00, computing the cost of postage at 39¢ and envelopes at 3¢ for the responses. Since approximately half of these forms are brought to the RPO by the ELR after collection, we estimate only half of the forms require mailing. The total amount of postage required to mail half of the forms is $672.00.
Summary of cost to the public:
$7,995.00 Completion Time
$ 672.00 Mailing
$8,667.00 TOTAL
13) There are no record keeping costs associated with this information collection.
14) Cost to the Federal government for the administering this form is estimated at $13,468.00, based upon 3,200 submissions. This cost was derived using the following:
Processing costs are $13,368.00. This figure was determined considering 3,200 responses with a processing time of 10 minutes each, for a total of 533 hours. The Education Liaison Representative (ELR) with jurisdiction over the school or training facility is charged with processing the VA Form 8794; currently, ELRs are paid at the GS 11 level; a GS 11/5 is paid a base hourly rate of $25.08.
Administrative costs are $100.00 for form printing and distribution.
Summary of Federal costs:
$13,368.00 Processing Costs
$ 100.00 Administrative Costs
$13,468.00. TOTAL
15) The change in the annual burden is the result of an increase in the number of forms used, as well as an increase in processing costs. Previously the processing cost was based upon work performed by a person at the GS 10/5 level, however the average ELR is now paid at the GS 11 level.
16) VA does not publish this information or make it available for public use.
17) The collection instrument, VA Form 22-8794, may be reproduced and/or stocked by VA personnel. This VA form does not display an expiration date, and if required to do so it would result in unnecessary waste of existing stocks of this form. As this form is submitted to OMB for approval every three years, this date requirement would also result in an unnecessary burden on the respondents and would delay Department action on the benefit being sought. VA also seeks to minimize the cost to itself of collecting, processing, and using the information, by not displaying the expiration date. For these reasons, VA continues to seek an exemption that waives the displaying of the expiration date on VA Form 22-8794.
18) The collection of this information fully complies with all the requirements of 5 C.F.R. 1320.8(b)(3).
This collection of information by the Veterans Benefits Administration does not employ statistical methods.
Applicable Laws
Title 10 U.S.C. 16136 - Administration of program
Title 10 U.S.C. 16166 - Administration of program
Title 32 U.S.C., Chapter 32, Subchapter IV, Section 3241, Requirements
Title 34 U.S.C., Chapter 34, Subchapter V, Section 3492, Tutorial Assistance
Title 38 U.S.C., Chapter 30, Subchapter IV, Section 3034(a), Program Administration
Title 38 U.S.C., Chapter 36, Subchapter II, Section 3680 - Payment of educational assistance or subsistence allowances
| File Type | application/msword |
| File Title | Supporting Statement for VA Form 22-8794 |
| Author | jill good |
| Last Modified By | Denise McLamb |
| File Modified | 2007-03-21 |
| File Created | 2007-03-21 |