Supporting Statement--0019

Supporting Statement for Form SSA-781,

Certificate of Responsibility

For Welfare and Care of Child Not in Applicant's Custody

20 CFR 404.330, 404.339-404.341 and 404.348-404.349

0960-0019

A. Justification

1. Sections 202(b)(l)(B), 202 (c)(l)(B), and 202(g)(l)(E) of the Social Security Act (the Act) and 20 CFR 404.330, 404.339-404.341 and 404.348-.349 of the Code of Federal Regulations contain the "in-care" entitlement requirement and the conditions under which "in-care" is met. A requirement for entitlement for mother’s or father’s benefits, or as a spouse who is under age 62 and is a mother or father, is that the spouse, mother or father must have in his/her care an entitled child of the number holder who is under age 16 or disabled.

2. The Social Security Administration (SSA) uses the information collected by form SSA-781 to determine if the "in-care" entitlement requirement is met. Respondents are applicants for Spouse and Mother’s and Father’s benefits.

3. The electronic submission of application/form data is an Agency goal as an alternative means of doing business with SSA, unless face to face contact with the individual is required as part of the intake process or the circumstances are so sensitive or complex that the completer would be better served interacting with a trained SSA employee. That being said, electronic intake can only occur if there is functional equivalency on the backend to receive and process the electronic submission. This expenditure of Systems resources must compete with other priority initiatives over very limited funds. The SSA-781, due to its low volume of usage, cannot compete with the legislative mandates that are driving the use of these funds; therefore, this collection is not currently scheduled for electronic information.

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. If the information on form SSA-781 is not collected for each non-custodial claimant seeking benefits based on having a child in care, SSA cannot determine whether the statutory "in ­care" requirement is met. Therefore, legally, this information cannot be collected less frequently.

7. There are no special circumstances that would cause an information collection to be conducted inconsistent with 5 CFR 1320.5.

8. The 60-day advance Federal Register Notice was published on March 29, 2007 at 72 FR 14845, and SSA has received no public comments. The second Notice was published on June 27, 2007, at 72 FR 35294. There have been no outside consultations with members of the public.

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

10. The information provided in this form 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. Approximately 14,000 respondents will use form SSA-781 annually. The estimated average response time is 10 minutes for a total of 2,333 burden hours. The total burden is reflected as burden hours and no separate cost burden has been calculated.

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

14. The annual cost to the Federal Government is approximately $21,560. This estimate is a projection of the costs for printing and distributing the collection instrument and for collecting the information.

15. There is no change in the public reporting burden.

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

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.