memo

TO: John Kramer, OMB Desk Officer

FROM: Summer King, SAMHSA’s OMB Clearance Officer

SUBJECT: Revised Reporting Burden for the OTP Mortality Reporting Form

This memorandum describes the changes to the reporting burden in the Supporting Statement submitted to OMB for the OTP Mortality Reporting Form. The revision includes the addition of the estimated annual reporting requirement to Medical Examiners which was previously omitted. Specifically, section 12 of the Supporting Statement is revised to the following:

Estimates of Annualized Hour Burden

The annualized burden of information collection for OTPs to report mortality data on patients who, at the time of death, were enrolled in OTPs certified to operate by SAMHSA is set forth in the tables that follow. In addition, 10 percent of the reports (230 reports) may require additional follow-up with the Medical Examiner (ME).

The total number of burden hours annually for OTP respondents is approximately 1,150 hours, while the total burden hours annually for Medical Examiners is approximately 23 hours.

Estimated Annual Reporting Requirement Burden for OTP

Form Name	Number of facilities (OTPs)	Responses per facility	Burden/  Response (Hours) to OTP	Annual Burden (Hours) to OTP	Average OTP hourly wage	Total cost to OTP
SAMHSA OTP Mortality Report	1,150	2 per year	0.5	1150	18.56	21,344

Estimated Annual Reporting Requirement Burden for Medical Examiner (ME)

Form Name	Number of ME follow-ups	Responses per ME	Burden/  Response (Hours) for ME	Annual Burden (Hours) for ME	Average ME hourly wage	Total cost for ME
SAMHSA OTP Mortality Report	230	1 per year	0.1	23	23.27	535.21

The total number of respondents is 1,380 and the total annual burden is 1,173 hours.

Estimated Costs of Reporting Burdens

Hourly labor costs involved in reporting requirements vary greatly between programs. Employees involved in complying with reporting requirements range from counselors earning an average of $15 an hour, licensed practical nurses and registered nurses earning an average of $18 to $29 per hour, administrators earning an average of $35 per hour, and physicians earning an average of $75 per hour. The estimated average hourly wage for program personnel to complete the Mortality is $18.56.  Multiplying the estimated average hourly wage by 1.5 to account for non-wage labor costs, an estimated hourly labor cost of $27.84 is obtained. The estimated total annualized cost to the treatment program respondents for preparing the OTP Mortality Reporting Form using $27.84 as the hourly cost figure is $40,020.   In addition, 10 percent of the OTP mortality reports may require a 10 minute follow-up with the Medical Examiner earning an average of $23.27 per hour. The estimated total annualized cost to the Medical Examiners is $535.21. These wage estimates were obtained from the U.S. Department of Labor, Bureau of Labor Statistics, and Occupational Employment Statistics Web site.