supporting_statement_--_0189_(F)

4

Supporting Statement for Forms:

SSA-2930-BK, RSI/DI Quality Review

Case Analysis-Sampled Number Holder;

SSA-2931-BK, RSI/DI Quality Review

Case Analysis-Auxiliaries/Survivors;

SSA-2932-BK, RSI/DI Quality Review

Case Analysis-Parent; and

SSA-4659-BK, RSI/DI Quality Review

Case Analysis-Stewardship AET Workbook

OMB No. 0960-0189

A. Justification

1. Section 205(a) of the Social Security Act (the Act) authorizes the Commissioner of the Social Security Administration (SSA) to conduct the quality review process, which entails collecting information related to the accuracy of payments made under the Old-Age, Survivors and Disability Insurance Program. Sections 228(a)(3), 1614(a)(1)(B) and 1836(2) of the Act require a determination of the citizenship/alien status of the beneficiary.

2. The information on Forms SSA-2930, SSA-2931 and SSA-2932 is used by SSA to establish a national payment accuracy rate for all cases in payment status and to serve as a source of information regarding problem areas in the Retirement and Survivors Insurance (RSI) and Disability Insurance (DI) programs. The information is also used to measure the accuracy rate for newly adjudicated RSI/DI cases. SSA uses the information on Form SSA-4659 to evaluate and determine the effectiveness of the annual earnings test and to use the results in developing ongoing improvements in the process. Each respondent is sent an appointment letter for the interview. About 25% of the respondents will have a face-to-face contact review and receive one of the following letters for an appointment: SSA-L8550-U3 (Appointment Letter – Sample Individual), SSA‑L8551‑U3 (Appointment Letter – Sample Family), or the SSA-L8552-U3 (Appointment Letter – Rep Payee). The other 75% of respondents will receive a notice for a telephone contact review; either the SSA-L8553-U3 (Beneficiary Telephone Contact) or the SSA-L8554-U3 (Rep Payee Telephone Contact) notice.

So that the beneficiary will be prepared for the interview included in each notice is an SSA-85 (Information Needed to Review Your Social Security Claim) which lists the information the respondents will need to gather to prepare for the interview and a form SSA-2935 (Authorization to the Social Security Administration to Obtain Personal Information) so that if necessary SSA will be able to obtain information to verify the correctness of the payment to the beneficiary. The respondents are a statistically valid sample of all RSI/DI beneficiaries in current pay status or their representative payees.

3. While these forms are available as PDF versions on the SSA website, beneficiaries never fill out the forms directly. All of the information on these forms is collected through interviews with the beneficiaries. SSA estimates that 75% of these interviews are conducted over the telephone while 25% are conducted face-to-face in a field office. No matter whether the interview is done over the telephone or face-to-face, the SSA employee conducting the interview writes down the answers to the questions directly on the paper form. At this time we have no computer program to record this information, as SSA has determined that it would not be cost effective to make this form available electronically given the low volume of respondents.

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 impact small businesses or other small entities.

6. If the information collection were not conducted or were conducted less frequently, SSA would be unable to effectively evaluate and recommend ongoing improvements in the RSI/DI program. In addition, insufficient coverage would result, data on the effects of policy and program changes would be lost, and users of this data (including Congress, SSA, other Federal agencies, the media and the general public) would have to plan without firm knowledge of program characteristics. There are no technical or legal obstacles that 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 November 5, 2007 at 72 FR 62510, and SSA has received no public comments. The second Notice was published on February 27, 2008 at 73 FR 10505. There have been no outside consultations with members of the public.

The first Federal Register Notice did not show the burden estimates for the various letters sent with the Quality Review Forms, the SSA-85, the SSA-8552 and the SSA-2935. The second Federal Register Notice has incorrect information in the burden chart as one form was accidentally removed from the chart before publication. While the burden hours shown on the chart are correct, the number of responses shown is not. We have remedied all of these changes in #12 below.

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

10. The information requested on these forms is protected and held confidential in accordance with 42 U.S.C. 1306, 20 CFR 401 and 422, 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. A quality review analyst, during a face-to-face or telephone interview completes the forms with the beneficiary. In the Paperwork Reduction Act Statement on the cover letters sent to the interviewee, SSA has placed a time estimate of 40-50 minutes to read the instructions, gather the information, and respond to all the questions (including responding to the interview questions). This was done to simplify the time estimate for the beneficiary. The average completion time noted above is based on field experience. The estimated reporting burden per form is as follows:

Form Number	Annual Responses	Frequency	Burden Hours Per Response (minutes)	Total Annual Burden Hours
SSA-2930	1,500	1	30	750
SSA-2931	750	1	30	375
SSA-2932	100	1	20	33
SSA-4659	325	1	10	54
SSA-L8550-U3	375	1	5	31
SSA-L8551-U3	90	1	5	8
SSA-L8552-U3	30	1	5	3
SSA-L8553-U3	1690	1	5	141
SSA-L8554-U3	165	1	5	14
SSA-8552	2350	1	5	196
SSA-85	2350	1	5	196
SSA-2935	2350	1	5	196
Totals	12,075	-	-	1,997

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 $3,317. This estimate is a projection of the costs for printing and distributing the collection instrument and for collecting the information.

15. Previously these forms were being used for two reviews: the Index of Dollar Accuracy (IDA) Review (2,500 cases selected) and the Stewardship Review (1,500 cases selected). The IDA review was for new awards and the Stewardship Review looks at any person in current pay on the record. We are no longer collecting information for the IDA Review which has caused a decrease in the number of respondents by 2,500.

Also, because the number of respondents for the Stewardship Review is dependent on how many individuals are on the current pay status record, the number of respondents for Stewardship Review can fluctuate. For instance, if a Number Holder (NH) and a spouse with a child were on the record, then one workbook would be used for the NH and another for the spouse and child (student). Therefore, two workbooks would be used for three respondents on the earnings statement. Because we cannot be certain that we will need more than one workbook per respondent at the time of selection, SSA has decided to report only the exact number of beneficiaries chosen for the Stewardship Review (1,500 cases) rather than add in the extra 300 cases which were previously added to account for the possibility that more than one individual may be listed on the record for any given respondent.

We also show an increase due to a program change, as each respondent in current pay will receive an appointment notice for either a face-to-face review or a telephone review along with an SSA-85, an SSA-8552 and an SSA-2935. Previously, we did not include these notices as they did not request information from the public. Now that our notices request information, and we are also using three new forms to collect additional information, we are including them in this clearance request.

15. Results of the information collection are prepared in the Office of Assistance and Insurance Program Quality (OAIPQ) and are published by the Office of Quality Assurance and Performance Assessment (OQA).

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 clearance. 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.