3220-0171

OMB NO. 3220-0171

Justification

RUIA Claims Notification and Verification System

RRB Form ID-4K, ID-4K (Internet), ID-4E, and ID-4E (Internet)

1. Circumstances of information collection - Section 5(b) of the Railroad Unemployment Insurance Act, as amended by the Railroad Unemployment Insurance and Retirement Improvement Act of 1988 (P.L. 100-647), requires that effective January 1, 1990, when a claim for benefits is filed with the Railroad Retirement Board (RRB), the RRB shall provide notice of such claim to the claimant's base-year employer or employers and afford such employer or employers an opportunity to submit information relevant to the claim before making an initial determination on the claim. When the RRB initially determines to pay benefits to a claimant under this Act, the Board shall provide notice of such determination to the claimant’s base-year employer or employers.

*Whereas the law requires that notice be provided and the opportunity to respond to the notice, the decision to respond to any particular notice is voluntary.

The procedures pertaining to such notice and the opportunity for response are prescribed in 20 CFR 320.10.

2. Purposes of collecting/consequences of not collecting the information - The purpose of the claims notification system is to provide two notices to a claimant's base year employer (and current employer, if not the same as the base year employer), regarding the filing of each application and claim for benefits filed under the Railroad Unemployment Insurance Act. Each notice allows the base-year employer the opportunity to provide information which may be relevant to the proper adjudication by the RRB of the employee's claims.

The first notice, Form Letter ID-4K, Prepayment Claims Verification Notice, is sent by the RRB when an application or each subsequent claim is filed. The second notice, Form Letter ID-4E, Notice of RUIA Claims Determinations, is sent when the RRB allows the claim for payment.

Railroad employers may elect to receive ID-4K, prepayment notices of applications and claims by one of three options:

Option 1

 Form ID-4K, Prepayment Claims Verification Notice, is a computer-generated paper notice of all unemployment applications, unemployment claims, and sickness claims received from employees of a railroad company on a particular day which is mailed on a daily basis to officials designated by railroad employers. The notice contains information about applications and claims received and entered onto the Railroad Unemployment Claims System database (RUCS) on the preceding business day. Employers who are mailed Form ID-4K are instructed to telephone the adjudicating RRB office if information can be provided within three business days, and to mail information to the RRB after three business days.

Option 2

 An electronic data interchange (EDI) - equivalent of the Form ID-4K notice is transmitted to participating railroads on a daily basis, generally on the same day that applications and claims are received and entered onto RUCS. Employers participating in the electronic notification process are encouraged to respond electronically.

A burden statement for the collection of RUIA appeal information and a Paperwork Reduction Act notice are incorporated in RRB in RRB circular letter UI-C-229. This circular is mailed to railroad Chief Executive Officers and Unemployment and Sickness Insurance Contact Officials, and is available for access and viewing on the RRB web-site.

Option 3

Form ID-4K(Internet), Prepayment Claims Verification Notice provides employers with an Internet filing option as part of its overall plan to provide our customers with, when practical, a substitute for paper. The ID-4K(Internet) which provides and collects essentially the same information as the ID-4K, is posted on a daily basis on ERS, generally on the same day that applications and claims are entered into RUCS and provides employers the ability to respond more quickly by utilizing the RRB’s Employer Reporting System (ERS).

Form ID-4K (Internet), which consists of a series of computer screens, is filed electronically by employers who have obtained access to the RRB’s Employer Reporting System (ERS) by completing RRB Form BA-12, Application for Employer Reporting Internet Access (OMB approved 3220-0008), which provides information used by the RRB to evaluate the level of access requested and documents the level of access granted.

The required Paperwork Reduction Act Notice/burden statement and estimate are included in RRB Circular UI-C-229 and through a link on the ID-4K (Internet) screens.

Railroad employers are allowed three business days from the date of the RRB’s notice to respond either by mail, telephone, EDI or the Internet before a decision is made to pay or deny a claim. If no response is received by the third business day, a determination is made on the employee’s claim based on the information available.

Under all options, the RRB sends the base year railroad employer, or employers, an application or claim notice either by Form ID-4K, electronically or via the Internet. Each notice contains the following specific information:

 employee name, date last worked, social security number,

 employee's reason for not now working, payroll identification number,

 days claimed by the employee for unemployment or sickness benefits,

 local RRB office and telephone number.

The employer then has the opportunity to compare the information provided in the RRB notice with available personnel and work force records,(i.e., payroll, timekeeping, crew management, and employee status records). An employer responds to an application or claim notice if a comparison of the application or claim information with employer records reveals one or more of the conditions which have been determined to involve questionable claims for benefits. Comparison of the application or claim information with employer records may either be performed mechanically or manually. In addition to responding to the specific information provided in the RRB notice, the railroad employer is able to provide any additional information considered relevant to the employee's eligibility for RUIA benefits. Upon receipt of the information from the employer, the RRB's adjudication office determines whether to pay or deny benefits.

Railroad employers may respond to RRB notices of applications and claims either by EDI, mail, or telephone. Employers are allowed three business days from the date of the RRB's notice to provide a response before a decision is made to pay or deny a claim. If no response is received by the third business day, a determination is made on the employee's claim based on the information available. Employers participating in the electronic notification process are encouraged to respond electronically. Employers who are mailed Form Letter ID-4K are instructed to telephone the adjudicating RRB office if information can be provided within three business days, and to mail information to the RRB after three business days.

A burden statement for the collection of RUIA appeal information and a Paperwork Reduction Act notice are incorporated in RRB Circular Letter No. UI-C-229. This circular letter is mailed to railroad Chief Executive Officers and Unemployment and Sickness Insurance Contact Officials, and is available for access and viewing on the Internet at http://www.rrb.gov.

The RRB proposes no changes to any of the Form ID-4K options.

Railroad employers may elect to receive ID-4E, post-payment notices of applications and claims by one of three options: Form ID-4E, ID-4E (Internet) or an electronic data interchange (EDI) equivalent ID-4E notices.

Option 1

Form ID-4E, Notice of RUIA Claim Determination, is sent daily and used to provide each base-year employer with notice when sickness or unemployment benefits have been approved by the RRB for payment to one of their employees. Upon receipt of notice that an individual’s claim for benefits has been allowed, either in whole or in part, the claimants base-year employer(s) may request a review of the determination to pay benefits, if the employer believes the determination is incorrect.

In essence, this is their second chance to challenge a claim for benefits. Since a base-year employer’s RUIA contribution rate is determined, in part; by the cumulative amount of RUIA benefits their employees are paid, it is in the base-year employer’s best interest to verify that RUIA benefits are correctly claimed and paid to their employees.

Option 2

An electronic data interchange (EDI) equivalent of the Form ID-4E notice. EDI notices of RUIA claim determinations are transmitted to participating railroads on a daily basis, generally on the same day that payments are approved.

The required Paperwork Reduction Act notice/burden statement is incorporated in RRB circular Letter No. UI-C-229. This circular letter is mailed to railroad Chief Executive Officers and Unemployment and Sickness Insurance Contact Officials and is available for viewing on the RRB’s web-site.

Option 3

Form ID-4E (Internet), Notice of RUIA Claim Determination provides employers an Internet filing option as part of its overall plan to provide our customers with the option, when practical, as a substitute for paper. The ID-4E (Internet) collects essentially the same information as the ID-4E, is available on a daily basis, generally the same day that payments are approved and provides employers the ability to respond more quickly by utilizing the RRB’s Internet-based Employer Reporting System (ERS).

Form ID-4E (Internet), which consists of a series of computer screens is filed electronically by employers who have obtained access to the RRB’s Employer Reporting System (ERS). Access to the RRB’s ERS by completing RRB Form BA-12, Application for Employer Reporting Internet Access (OMB approved 3220-0008), which provides information used by the RRB to evaluate the level of access requested and document the level of access granted.

The required Paperwork Reduction Act Notice/burden statement and estimate are included in RRB Circular UI-C-229 and through a link on the ID-4E screens.

The RRB proposes no changes to any of the Form ID-4E options.

Under all options, the RRB sends the base year railroad employer, or employers, a post-payment notice of application or claims, by Form ID-4E, electronically, or on the Internet. Each notice contains the following information:

 Employee name, Social Security Number

 Claim Beginning date, Claim Profile (a series of 14 numeric codes indicating the days claimed and allowed, and the days denied in the claim period),

• Gross Payable, Charged (the amount of benefits payable with respect to the claim),

• (change) (the amount of benefits previously not reported to the employer,

• Type (sickness benefits (SI) or unemployment benefits (UI),

• Benefit Year (BY)

• Payroll Identification Number (Employee)

• Local RRB office

The RRB proposes no changes to Form ID-4E.

To our knowledge, no other agency uses Forms comparable to the ID-4K, ID-4K(Internet), ID-4E, ID-4E(Internet). Completion is voluntary.

3. Planned use of improved information technology or technical/legal impediments to further burden reduction - In the case of notices sent by electronic data interchange (EDI), information from each unemployment application, unemployment claim and sickness claim filed under the Railroad Unemployment Insurance Act is formatted into a message for transmission via the RAILINC telecommunications network to each participating employer.

RAILINC Corporation is a subsidiary of the Association of American Railroads. Message formats comply with EDI formats and standards approved by the Data Interchange Standards Association.

Further, consistent with previously stated GPEA goals, the RRB offers Internet-based equivalents for both Forms ID-4K and ID-4E in order to provide employers an Internet filing option as part of its overall plan to provide our customers with the option, when practical, as a substitute for paper.

4. Efforts to identify duplication - This information collection does not duplicate any other information collection.

5. Small business respondents - N.A.

6. Consequences of less frequent collection - N.A.

7. Special circumstances - N.A.

8. Public Comments/consultations outside the agency – In accordance with 5 CFR 1320.8(d), comments were invited from the public regarding the information collection. The notice to the public was published on page 43480 and 43481 of the July 25, 2008, Federal Register. No comments or requests for additional information were received.

9. Payments or Gifts to Respondents - N.A.

10. Confidentiality - Privacy Act Systems of Records RRB-7, Applications for Unemployment Benefits and Placement Service under Railroad Unemployment Insurance Act, and RRB-21, Railroad Unemployment and Sickness Insurance Benefit System. An RRB Privacy Impact Assessment related to the collection can be found at http://www.rrb.gov/pdf/PIA/PIA_EE_ID-4E_ID-4K_9-30-2008_public.pdf

11. Sensitive questions - There are no questions of a sensitive nature.

12. Estimate of respondent burden -The current estimated annual burden for this collection is unchanged as follows:

Current Burden

RRB Messages	Responses	Time(Min)	Burden
UI Applications/Claims
Mainframe (EDI) ID-4K	9,800	---*	126
ID-4K (paper)	500	2	17
ID-4K(Internet)	1,500	2	50
ID-4E (paper)	30	2	1
ID-4E (Internet)	30	2	1
Subtotal	11,860		195
Sickness Claims
Mainframe (EDI) ID-4K	5,050	---*	84
ID-4K (paper)	750	2	25
ID-4K (Internet)	1,000	2	33
ID-4E (paper)	20	2	1
ID-4E (Internet)	20	2	1
Subtotal	6,840		144
Total	18,700		339

*The burden for the railroad employers receiving EDI messages has been calculated in the following manner. We estimate that 10 minutes a day would be required on average for each of the 5 railroad employers to operate the system. Based on 251 workdays in a year, we calculate the number of burden hours to be 210 hours, of which we allocated 60 percent to unemployment transactions (126 hours) and 40 percent to sickness transactions (84 hours).

13. Estimate of annual cost to respondents or record keepers - N.A.

14. Estimated cost to Federal government - N.A.

15. Explanation for change in burden – N.A .

16. Time schedule for data collections and publication - The results of this collection will not be published.

17. Request not to display OMB expiration date - The ID-4K, ID-4K (Internet), ID-4E and ID-4E (Internet) will seldom be revised. Given the costs associated with programming necessary to revise the computer-generated letter, Internet and EDI equivalent versions of the forms in order to keep the appropriate OMB expiration date in place, the RRB requests authorization to not display the expiration date on the form.

18. Exceptions to Certification Statement - None

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