0960-0735 supporting statement (8-23-09)

SUPPORTING STATEMENT FOR FORM SSA-44:

MEDICARE PART B INCOME-RELATED PREMIUM -- LIFE-CHANGING EVENT FORM

OMB No. 0960-0735

SSA-44

A. Justification

1. Introduction/Authoring Laws and Regulations

Section 1839(i) of the Social Security Act, as codified by section 418.1125-418.1201 of the Code of Federal Regulations, mandates a Medicare Part B premium subsidy reduction resulting in higher Medicare Part B premiums for Medicare Part B enrollees with income above a specific threshold. This premium subsidy reduction is the “income-related monthly adjustment amount (IRMAA).”

The responsibility for determining the amount of Medicare Part B monthly premiums and the categories of monthly income-related adjustment amounts lies with the Centers for Medicare & Medicaid Services in the Department of Health and Human Services (HHS). However, the Social Security Administration (SSA) is responsible for several aspects of the process. Tasks performed by SSA as part of the Medicare Part B rules include the following:

1) Determining which Medicare Part B recipients are subject to the monthly adjustment amount based on Federal tax return information from the Internal Revenue Service (IRS);

2) Deciding which category of adjustment recipients are subject to and when the adjustment is effective;

3) Accepting information from recipients that updates or clarifies the tax data provided by IRS;

and

4) Making new initial determinations based on certain life-changing events.

Since SSA makes determinations based on past IRS tax data, it is possible that recipients’ financial situations may have changed due to a life-changing event (LCE), and that SSA’s IRMAA eligibility determination would no longer be accurate. SSA defines a life-changing event as: 1) marriage, 2) divorce/annulment, 3) spousal death, 4) work stoppage, 5) work reduction, 6) loss of income due to property loss, and 7) loss of pension income. Medicare Part B recipients who experience any of these LCEs and a resulting significant income reduction can use form SSA-44 to report them. This information collection request (ICR) is for form SSA-44.

2. Description of Collection

SSA uses the information collected by form SSA-44 to determine if the initial IRS tax data used for the beneficiary is up-to-date. If the agency determines the LCE significantly reduced the beneficiary’s income, we will use the information to update our original determinations or to make new initial determinations. The respondents are Medicare Part B enrollees with modified adjusted gross income over a high-income “threshold.”

2. Use of Information Technology to Collect the Information

Ninety percent of responses for this form are completed during field-office interviews, where respondents provide information and SSA employees enter the data electronically. Form SSA-44 is available on SSA's website for individuals to print, complete, and mail to SSA for processing.

2. Why We Cannot Use Duplicate Information

The nature of the information we are collecting and the manner in which we are collecting it preclude duplication. SSA does not use another collection instrument to obtain similar data.

2. Minimizing Burden on Small Respondents

This collection does not affect small businesses or other small entities.

2. Consequence of Not Collecting Information or Collecting it Less Frequently

If SSA did not collect the information on this form, we would have no means of allowing Medicare Part B recipients experiencing LCEs to report their new financial status, which would put SSA in violation of the relevant regulations. In addition, since SSA collects this information on an as- needed basis, we cannot collect it less frequently.

There are no technical or legal obstacles to burden reduction.

2. Special Circumstances

There are no special circumstances that would cause us to collect this information in a manner inconsistent with 5 CFR 1320.5.

8. Solicitation of Public Comment and Other Consultations with the Public

SSA published the 60-day advance Federal Register Notice on June 25, 2009, at 74 FR 30353, and we received no public comments. The second Notice published on August 19, 2009, at 74 FR 41959. SSA did not consult members of the public in the development of this form.

8. Payment or Gifts to Respondents

SSA does not provide payments or gifts to the respondents.

8. Assurances of Confidentiality

SSA protects and holds confidential the information it collects 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.

8. Justification for Sensitive Questions

The information collection does not contain any questions of a sensitive nature.

8. Estimates of Public Reporting Burden

Method of Information Collection	Number of Respondents	Frequency of Response	Average Burden Per Response (minutes)	Estimated Annual Burden (hours)
Personal Interview (SAS field office)	128,000	1	30	64,000
Form(mailed)	32,000	1	45	24,000
Totals	160,000	-	-	88,000

The total burden for this ICR is 88,000 hours. This figure represents burden hours, and we did not calculate a separate cost burden.

8. Annual Cost to the Respondents (Other)

This collection does not impose a known cost burden on the respondents.

14. Annual Cost to Federal Government

The annual cost to the Federal Government for this collection is approximately $8,419,173. This estimate is a projection of the costs for printing and distributing the collection instrument and for collecting the information.

15. Program Changes or Adjustments to the Information Collection Request

There has been an increase in burden hours, because when SSA completed the last clearance in 2006, the clearance was new and we estimated the numbers. We now have figures based on recorded data.

15. Plans for Publication Information Collection Results

SSA will not publish the results of the information collection.

17. Displaying the OMB Approval Expiration Date

OMB granted SSA an exemption from the requirement to print the OMB expiration date on its program forms. SSA produces millions of public-use forms with life cycles exceeding those of an OMB approval. Since SSA does not periodically revise and reprint its public-use forms (e.g., on an annual basis), OMB granted this exemption so SSA would not have to destroy stocks of otherwise useable forms with expired OMB approval dates, avoiding Government waste.

17. Exceptions to Certification Statement

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. Collections of Information Employing Statistical Methods

SSA does not use statistical methods for this information collection.

0960-0735 (SSA-44) supporting statement

2/3/2021

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