Supporting Statement For Form SSA-2490-BK,
Application for Benefits Under a U.S.
International Social Security Agreement
20 CFR 404.1925
OMB No. 0960-0448
A. Justification
1. Section 233(a) of the Social Security Act authorizes the President to enter into international Social Security agreements between the United States and foreign countries. Under such agreements, called Totalization agreements, retirement, survivors, disability and derivative benefits may be based on combined periods of coverage from the two agreement countries. 20 CFR 404.1925 of the Code of Federal Regulations provides that if an applicant files for benefits from one country, that application can constitute an application for benefits from the other country, provided the applicant expresses the intent to claim benefits from the other country. In order to assist the other country in determining a right to benefits under its law, or in identifying coverage under its social insurance system, each country obtains certain information from the applicant that is exchanged with the other country. The form SSA-2490-BK is the application used by the United States (U.S.) to obtain information needed to process claims for U.S. benefits under the existing and any future Social Security agreements. With a few exceptions, this form is also used to obtain information needed to initiate processing of claims for benefits from the foreign country.
Form SSA-2490-BK is completed by applicants who are applying for benefits from the United States under any Social Security agreement and wish to receive those benefits through a U.S. claims taking facility such as a Social Security Field Office or Foreign Service Post. With the exception of claims for foreign benefits under the agreements with Australia, Canada, Japan, South Korea and Spain, Form SSA-2490-BK will also be completed by applicants filing for foreign benefits at a U.S. claims taking facility. Applicants for benefits from Australia, Canada, Japan, South Korea and Spain will complete a special application form unique to those agreements. The Social Security Administration (SSA) uses the information on the form to determine eligibility for benefits from the United States based on combined U.S. and foreign credits and to fulfill its obligation to obtain information that our agreement partners need to determine eligibility for benefits under their systems. The respondents are individuals who are applying for old-age, survivors or disability benefits from the U.S. or from a Totalization agreement country.
Currently the SSA-2490-BK is not available electronically because of the low volume of usage. However, the SSA-2490-BK is available to SSA field offices through the Modernized Claims System version which can be used when the person is filing for U.S. retirement or disability Totalization benefits only or U.S. retirement or disability Totalization benefits and concurrently for foreign benefits. Approximately 42 percent of the claims filed under the agreements are completed using the MCS version of SSA-2490-BK.
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 an impact on small businesses or other small entities.
6. Collection of the information is initiated when an individual indicates his or her desire to claim benefits and is not initiated at the discretion of SSA. If the information were not collected when an individual expressed a desire to claim benefits, SSA could not determine eligibility of that applicant for U.S. benefits based on combined credits. Also, SSA would not be able to fulfill its obligation to obtain information that our agreement partners need to determine eligibility for benefits under their systems. Because the information is only collected when an individual indicates his or her desire to claim benefits, it cannot be collected less frequently. 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.
The 60-day advance Federal Register Notice published on July 1, 2008, at 73 FR 37524, and SSA received no public comments. The second Notice published on September 17, 2008, at 73 FR 53919. There have been no outside consultations with members of the public.
The information collected by Form SSA-2490-BK has been agreed upon previously by countries with which we have Social Security agreements and has in the past been collected on multiple forms rather than the Form SSA-2490-BK.
9. SSA provides no payment or gifts to the respondents.
10. The information requested 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. SSA receives approximately 26,700 for the SSA-2490-BK annually. Of that total, approximately 42% are completed electronically using MCS. Regardless of whether the information is completed manually or electronically, the estimated average response time is 30 minutes per form for a total of 13,350 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 $205,590.00. This estimate is a projection of costs for printing and distributing the form and for collecting the information.
15. The increase in the public reporting burden is because the United States entered into a Social Security agreement with Japan. The SSA-2490-BK is used to apply for U.S. Totalization benefits under this new agreement.
16. The results of the information collection will not be published.
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. Collection of Information Employing Statistical Methods
Statistical methods are not used for this information collection.
| File Type | application/msword |
| File Title | Supporting Statement For Form SSA-2490-BK, |
| Author | Gerry Shepherd |
| Last Modified By | Davidson, Liz |
| File Modified | 2008-09-17 |
| File Created | 2008-09-17 |