12-19-07 memo

OMB Passback on the SSA-3368

OMB No. 0960-0579

(1) Since the internet form takes over 2x the time as the paper form/EDCS, please include a disclaimer on the website where this form can be downloaded from (similar to what SSA did for the i3441 form).”

SSA Response

Actually, the Internet doesn’t take more than 2x the time it takes to do the paper form. The reason is because the Internet i3368/69 encompasses the information collected on both the paper SSA-3368 (Disability Report-Adult), and paper

SSA-3369 (Work History Report). The time we reported in the Supporting Statement for the i3368/69 was an average of 2 ½ hrs. The time we reported for the paper SSA-3368 was an average of 1 hr. The time we reported in the separate Supporting Statement for the paper SSA-3369 (0960-0578), which OMB approved on 12/7/07, was also an average of 1 hr. Thus, the combined time for filling out the two paper forms is 2 hrs. So, if an individual had more than one job (which is when the SSA-3369 information must be collected), the estimated time difference between completing the i3368/69 and the two paper forms is only 30 min. Our Internet systems data for the 6-month period 5/07-10/07 indicates that 61% of claimants who completed the i3368/69 had more than one job. For the 40% of claimants during this time period who had only one job, the estimated time difference between completing just the i3368 portion of the i3368/69 and the paper SSA-3368 would still be only

30 min.)

On 12/4/07, OMB approved Welcome page language for the iAppeals process

(0960-0144) that includes the following sentences: “We estimate it will take

18 to 20 minutes, with an average of 19 minutes, to complete Part 1 [i.e., the appeal request]; and 15 to 45 minutes, with an average of 30 minutes, to complete Part 2 [i.e., the i3441 Appeal Disability Report]. If you do not want to use the Internet to request your appeal, there are Other Ways to Request an Appeal or Complete a Disability Report.” We will model this format and will include the following similar-type language on the Welcome page for the Adult Disability and Work History Report. “We estimate it will take 2 to 3 hours, with an average of 2 ½ hours, to complete the Adult Disability and Work History Report. If you do not want to use the Internet to complete the Adult Disability and Work History Report, please see Applying in Person or Over the Phone.”

Current “Welcome!” Page

We will also revise the “We estimate” sentence within the current Paperwork Reduction Act Statement on the “About this Internet Form” Internet page to read, “We estimate that it will take you 2 to 3 hours, with an average of 2 ½ hours, to respond, but total time required will depend upon the number of questions you need to answer.”

Current “About this Internet Form” Page

(2) page 10: Please put the instructions (“if the person completing this form is other…”) at the top of the box, before “name of person completing this form.” Implied in those instructions is the assumption that the person completing the form is the disabled person: therefore, the disabled person should not need to state this.

(SSA Response) In the “Name of person completing this form”  box, we will add a checkbox with the following instruction:  “(Check this box if you are the disabled person.)”

(3) The justification for #17 is that this form is not changed that often. However, ROCIS would suggest otherwise (please note that none of the renewals have been extensions: they have all been changes or revisions). Given that this form is revised almost every time it is submitted to OMB, please provide a stronger rationale for not printing the expiration date. As part of this rationale, please explain how respondents are supposed to know which version of the form is the most current and what would happen if respondents completed an “obsolete” form.

Our field offices distribute the paper forms to respondents who request them.  If the expiration date were to be printed on the forms and field offices forget to destroy the expired forms, even though the forms were not really “obsolete” from an SSA information usability standpoint, the field offices could inadvertently send out the expired forms to respondents to complete.  This could cause respondents to be confused about why they are receiving an expired form to complete and to recontact the field offices, and result in unnecessary extra work for the field offices.  Respondents know which version of the form is the most current because we print the current edition date on the bottom of the form.  We also identify there the dates of any prior edition(s) that may be still be used.   If an earlier version of the form is actually “obsolete” from an SSA information usability standpoint, we would specifically instruct our field offices to destroy any remaining stocks of the obsolete version.  So, it would be extremely rare and unlikely that a respondent would get their hands on, complete, and submit an obsolete version of the form.  If that should occur, however, we would still use as much of the information shown on the obsolete form as we can and update it as necessary with any additional information collected on the current version that had not been collected on the obsolete version.   

12/19/2007