Supporting Statement for 2900-0028
A. Justification
VA Form 3215, Application of Service Representative for Placement on Mailing List
1. Under 38 U.S.C. 5904, the Secretary of Veterans Affairs may recognize representatives of veteran service organizations in the preparation, presentation, and prosecution of claims under laws administered by the Department of Veterans Affairs (VA). In addition, the Secretary is requested to operate an outreach services program (38 U.S.C. 7722) to ensure veterans and beneficiaries have information about benefits and services to which they may be entitled. To support these two programs, the Secretary distributes copies of publications as requested by service organization representatives.
2. VA Form 3215 is used to process a request from a service organization to be placed on the mailing list for specific VA publications as identified by the service organization representatives on this form. The form is used to control the distribution of documents and to ensure only the minimum copies necessary are distributed. Moreover, the information on the form is used by VA regional offices for forwarding publications to the service organizations to be used in rendering services and representation of veterans, their spouses and dependents.
3. The information requested from the public is limited. Use of improved technology to further reduce the burden placed on the public for this information collection is not feasible, since the amount of information provided is limited and is submitted by individuals who may not have access to automated systems.
4. There is no known duplication. This information is not available from an alternate source.
5. This information collection does not involve small businesses or other small entities.
6. The information is collected as required from the service organization representative as needed. VA does not set a time frequency for collecting this information.
7. There are no special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.6.
8. The VA notice was published in the Federal Register on November 16, 2007, pages 64706-64707. No consultation with persons outside the VA has been made because the information collection is required by law and completion of the form is voluntary. No comments were received.
9. Decision to provide any payment or gift to respondents does not apply.
10. No assurance of confidentiality of the information is provided.
11. There are no questions of a sensitive nature.
12. Estimate of Information Collection Burden
a. Number of respondents is estimated at 150 per year.
b. Frequency of response is generally once annually or on occasion.
c. Annual burden is 25 hours.
d. The estimated response time of 10 minutes per form is based on the trial use by VA staff members. No adjustments are necessary.
e. The total estimated cost to the respondent is $500 (25 hours x $20 per hour).
13. This submission does not involve any record keeping costs.
14. Estimated Cost to the Federal Government
$385.00 Estimated Processing Cost (150 forms x 10 minutes x $15.41 per hour (GS 4/5
average hourly salary of review personnel)
$90.00 Design/Printing/Distribution Cost
$475.00 Total Estimated Cost to the Government
15. There is no change in burden hours.
16. The results of this information will be neither tabulated nor published.
17. The form may be reproduced or stocked by the respondents. The form does not display an expiration date; to do so would result in unnecessary waste of existing stocks of this form. OMB approval is required every 3 years. As such, the expiration date requirement would also result in an unnecessary burden on the respondents and would delay the Department’s action on requests from respondents. By not displaying the expiration date, VA seeks to reduce its cost for collecting, processing, and using the information. For these reasons, VA continues to seek exemption from displaying the expiration date on VA Form 3215.
18. This submission does not contain any exceptions to the certificate statement.
B. Collections of Information Employing Statistical Methods
Statistical methods are not appropriate in this instance.
VA Form 3288, Request for and Consent to Release of Information from Claimant’s Records
1. Veterans and their beneficiaries regularly request that copies of documents or information contained in their benefits or medical records be released to third parties, such as insurance companies, physicians and other individuals. The Privacy Act of 1974 (5 U.S.C. 552a) and the VA’s confidentiality statue (38 U.S.C., 5701) as implemented by 38 CFR 1.526(a) and 38 CFR 1.576(b) require individuals to provide written consent before documents or information can be disclosed to third parties not allowed to receive records or information under any other provision of law, i.e., routine use of a record in a system of records. VA Form 3288 contains the minimum information that must be provided in writing before a record or information is released.
2. The form is completed by veterans or beneficiaries to provide the VA with a written consent to release records or information. Use of the form ensures an individual gives an informed written consent for the release of records or information about himself/herself that is consistent with the statutory requirements of the Privacy Act of 1974 and the VA’s confidentiality statutes.
3. The data and information on this form are subject to the Privacy Act as it contains personal data and information, and requires the signature of the respondent prior to the release of information. VA is required to guard the privacy and protect the information from being altered as well as authenticate identity and signature of the respondent. At the present time, electronic signatures and authentication technologies are being evaluated and tested within the Department and will be deployed in the near future. Until the appropriate technologies are deployed, this form will not be electronically accessible.
4. No efforts have been made to identify duplication because the information is unique to each individual case and cannot be duplicated.
5. The collection of information does not involve small businesses or entities.
6. This information collection is not a recurring or repetitive report. The information is collected only when a veteran or beneficiary requests disclosure of records or information subject to the Privacy Act and the VA’s confidentiality statutes. In addition, the requested information is not available from an alternate source.
7. There are no special circumstances requiring collection in a manner inconsistent with 5 CFR 1320.6 guidelines.
8. The VA notice was published in the Federal Register on November 16, 2007, pages 64706-64707. No consultations with persons outside the VA have been made because the information collection is required by law and completion of the form is voluntary. No comments were received.
9. Decision to provide any payment or gift to respondents does not apply.
10. No assurances of confidentiality are provided except for those implied in the Privacy Act of 1974 and 38 CFR 1.526.
11. There are no questions of a sensitive nature on the form.
12. Estimate of Information Collection Burden
a. Number of respondents is estimated at 151,000
b. Frequency of response is generally one-time.
c. The total annual burden is estimated at 18,875 hours.
d. The estimated response time of 7.5 minutes is based on trial use with VA staff unfamiliar with the form. No adjustments are necessary.
e. The total estimated cost to the respondent is $283,125 (18,875 hours x $15/hour).
13. This submission does not involve any record keeping costs.
14. Estimated Cost to the Federal Government
$1,284 Estimated printing cost (151,000 forms @ $8.50 per 1,000).
$371,460 Estimated cost for processing (151,000 forms x 12 minutes per form x
$12.30/hour (average salary of processing personnel)).
$61,910 Estimated cost for mailing (151,000 forms x .41¢).
$434,654 Total cost to the Government.
15. There is no change in the burden hours.
16. The information collection is not for publication purposes.
17. The collection instrument, VA Form 3288, does not display an expiration date, and if required to do so would result in unnecessary waste of existing stocks of this form. The form is subject to OMB approval every 3 years and as such, the expiration date requirement would also result in an unnecessary reprinting cost to the VA if no other changes were required. The VA continues efforts to minimize its cost to itself. For the reasons stated, VA continues to seek an exemption that waives the displaying of the expiration date on VA Form 3288.
18. There are no exceptions to the certification statement identified in Item 19, Certification for Paperwork Reduction Act Submission, of OMB Form 83-I.
B. Collections of Information Employing Statistical Methods
Statistical methods are not appropriate in this instance.
Form Letter 70-2, Request to Correspondent for Identifying Information
1. This form letter is used by the Department of Veterans Affairs (VA) to obtain additional information from a correspondent when the incoming correspondence does not provide sufficient or accurate information to identify a specific veteran. Failure to obtain this information will prevent the VA from taking their further action on the correspondence. Bold type is used to emphasize why the VA is soliciting the information and what is required of the correspondent for the VA to properly provide assistance.
2. The information is used by VA personnel to identify a specific veteran, determine the location of a specific file, and to accomplish the action requested by the correspondent; such as, process a benefit claim or file material in an individual’s claims folder. Completion of FL 70-2 is voluntary and failure to furnish the requested information has no adverse effect on either the veteran or the correspondent.
3. The data and information on this form are subject to the Privacy Act as it contains personal data and information, and requires the signature of the respondent prior to the release of information. VA is required to guard the privacy and protect the information from being altered as well as authenticate identity and signature of the respondent. At the present time, electronic signatures and authentication technologies are being evaluated and tested within the Department and will be deployed in the near future. Until the appropriate technologies are deployed, this form will not be electronically accessible.
4. There is no duplication involved. The use of FL 70-2 occurs only when there is not sufficient or accurate data to identify the veteran in the incoming correspondence.
5. The collection of information does not involve small businesses or entities.
6. This information collection is not a recurring or repetitive report. The information is collected only when the original incoming correspondence does not contain the information necessary to identify the appropriate veteran. The requested information is not available from an alternate source.
7. There are no special circumstances requiring collection in a manner inconsistent with 5 CFR 1320.6 guidelines.
8. The VA notice was published in the Federal Register on November 16, 2007, pages 64706-64707. Consultations outside the VA have not been held since the last submission for approval. The respondents have a continuing opportunity to comment of this form letter. No comments were received.
9. Decision to provide any payment or gift to respondents does not apply.
10. No assurances of confidentiality are provided except for those implied in the Privacy Act of 1974 and 38 CFR 1.526.
11. There are no questions of a sensitive nature on the form letter.
12. Estimate of Information Collection Burden
a. Number of respondents is estimated at 45,000
b. Frequency of response is generally one-time.
c. The total annual burden is estimated at 3,750 hours.
d. The estimated response time of 5 minutes is based on trial use with VA staff No adjustments are necessary.
e. The total estimated cost to the respondent is $56,250 (3,750 hours x $15/hour).
13. This submission does not involve any recordkeeping costs.
14. Estimated Cost to the Federal Government
$400 Estimated development and printing cost for 45,000 form letters.
$37,012 Estimated cost for processing (45,000 form letters x 5 minutes per letter x $9.87/hour (average salary of processing personnel)).
$18,450 Estimated cost for mailing (45,000 form letters x .41¢).
$55,862 Total cost to the Government.
15. There is no change in burden hours.
16. The information collection is not for publication purposes.
17. The collection instrument, FL 70-2, does not display an expiration date, and if required to do so would result in unnecessary waste of existing stocks of this form letter. The form letter is subject to OMB approval every 3 years and as such, the expiration date requirement would also result in an unnecessary reprinting cost to the VA if no other changes were required. The VA continues efforts to minimize its cost to itself. For the reasons stated, VA continues to seek an exemption that waives the displaying of the expiration date on FL 70-2.
18. There are no exceptions to the certification statement identified in Item 19, Certification for Paperwork Reduction Act Submission, of OMB Form 83-I.
B. Collections of Information Employing Statistical Methods
Statistical methods are not appropriate in this instance.
38 CFR 1.519(A) Lists of Names and Addresses
Title 38 U.S.C., 5701(f)(1) authorizes the VA to disclose mailing lists of veterans and their dependents to nonprofit organizations, but only for certain specific and narrow purposes. Criminal penalties are provided for improper use of the list by the organization in violation of subsection (f) limitations. The information collection in this regulation ensures that any disclosure of a list under this subsection is authorized by law. The VA must ascertain that the applicant is a nonprofit organization and intends to use the list for a proper purpose; if not, Title 38 U.S.C., 5701(a) prohibits disclosure. The additional information collection (specific geographical locations, point of contact, and type of output and signature of organization head) is necessary to ensure timely and accurate processing of each application. Failure to obtain this information will prevent the Department from fulfilling its statutory obligations.
2. The information is used by the VA in the manner and for the purpose stated in the above paragraph. Without this information VA could not meet its obligations under Title 38 U.S.C., 5701(f), and could not assure that disclosure of a list is proper.
3. The data is subject to the Privacy Act as it contains personal data and information, and requires the signature of the respondent prior to the release of information. VA is required to guard the privacy and protect the information from being altered as well as authenticate identity and signature of the respondent. At the present time, electronic signatures and authentication technologies are being evaluated and tested within the Department and will be deployed in the near future. Until the appropriate technologies are deployed, this form will not be electronically accessible.
4. When the same organization submits more than one request, duplicate information is not required to the extent when it is already on file with the VA. The same VA office processes all applications and can therefore avoid unnecessary duplication.
5. The collection of information does not involve small businesses or entities.
6. Information, which is already available, is used to the extent possible. There is no specific reporting format. For the reasons indicated above, the frequency of this collection, and the amount of information collected cannot be reduced if VA is to meet its statutory obligations and continue to process applications for mailing lists.
7. There are no special circumstances requiring collection in a manner inconsistent with 5 CFR 1320.6 guidelines.
8. The Department notice was published in the Federal Register on November 16, 2007, pages 64706-64707. No comments were received.
9. No payments or gifts to respondents have been made under this collection of information.
10. None.
11. No information of a sensitive nature is collected.
12. Estimate of Information Collection Burden
a. The number of respondents is estimated at 50 per year.
b. Frequency of response is generally one-time.
c. Annual burden is 50 hours.
d. The estimated response time is 60 minutes per request.
e. Total estimated cost to respondents is $750 (50 hours x $15 per hour).
13. This submission does not involve any record keeping costs.
14. Estimated Annualized Cost to the Federal Government
The estimated annual VA cost of collecting the information under 38 CFR 1.519(a) is based upon 5.33 hours total VA time per request times an average hourly cost of $22.96 per hour (50 requests x 5.33 minutes x $22.96/60=$102.00).
15. The annual burden hours have not changed.
16. This information is not collected by statistical methods nor is it published.
17. Not applicable.
18. This submission does not contain any exceptions to the certification statements.
B. Collections of Information Employing Statistical Methods
Statistical methods are not appropriate in this instance.
| File Type | application/msword |
| File Title | Supporting Statement for 2900-0028 |
| File Modified | 2008-02-20 |
| File Created | 2008-02-20 |