Justification
1. Introduction/Authoring Laws and Regulations
The Federal Employee Health Benefits (FEHB) Program allows dependent children of Federal employees to continue receiving health care benefits as covered family members until age 22. At 22, children terminated from the Federal employee’s coverage. However, as per section 5 CFR 890.302(d) of the Code of Federal Regulations, children ages 22 and older can continue to receive health benefits under the FEHB if they are incapable of self-support due to a disability that 1) pre-dated the child’s 22nd birthday, 2) is very serious, and 3) can be expected to last at least one year. Section 5 CFR 890.302(d) states that in order for federal employees’ children ages 22 or over to qualify for the FEHB; their physician must verify that they have a disability, which meets the three criteria cited above. Physicians use Form SSA-604, the Certificate of Incapacity, for children ages 22 and over whose parents are employees of the Social Security Administration (SSA). This OMB clearance request is a revision to an Existing Collection.
Description of Collection
Rules governing the Federal Employee Health Benefits (FEHB) plan require that the physician verify disability of Federal employees’ children ages 22 and over to
retain health benefits under the employees’ plans the physician must verify that the adult child has a disability that meets the following criteria: (1) Pre-dates the child’s 22nd birthday; (2) is very serious; and (3) can be expected to last at least one year. Physicians use Form SSA–604, the Certificate of Incapacity, to document and certify the disability of children ages 22 and over whose parents are SSA employees. SSA uses the information to determine adult children’s (age 22 and above) eligibility for coverage under a parent’s FEHB plan. The respondents are physicians of SSA employees’ children ages 22 or over who are seeking to retain health benefits under their parent’s FEHB coverage.
Use of Information Technology to Collect the Information
Form SSA-604 is available as a print-only PDF on SSA’s website. SSA did not create an electronic version of form SSA-ABC under the agency’s Government Paperwork Elimination Act (GPEA) plan because only 25,000 respondents complete the form. This is less than the GPEA cut-off of 50,000.
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.
Minimizing Burden on Small Respondents
This collection does not affect small businesses or other small entities.
Consequence of Not Collecting Information or Collecting it Less Frequently
If SSA did not collect the information, SSA employees with children ages 22 and over who qualify for the FEHB program because of their disabilities would have no means of applying to retain their health coverage. Because the physicians only complete the form once, we cannot collect it less frequently. There are no technical or legal obstacles to burden reduction.
7. Special Circumstances
There are no special circumstances that would cause SSA to conduct this information collection in a manner inconsistent with 5 CFR 1320.5
Solicitation of Public Comment and Other Consultations with the Public
SSA published the 60-day advance Federal Register Notice published on August 19, 2009, at 74 FR 41959, and we received no public comments. The second Notice published on October 26, 2009, at 74 FR 55080. We did not consult with the public in the revision/maintenance of this form.
Payment or Gifts to Respondents
SSA does not provide payments or gifts to the respondents.
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.
Justification for Sensitive Questions
The information collection does not contain any questions of a sensitive nature.
Estimates of Public Reporting Burden
Approximately 50 physicians take 45 minutes each to complete form SSA-604 each year, resulting in a burden of 38 hours. This figure represents burden hours, and we did not calculate separate cost burden.
13. Annual Cost to the Respondents (Other)
This collection does not impose a known cost burden to the respondents.
Annual Cost To Federal Government
The annual cost to the Federal Government is approximately $2,789.58. This cost is an estimate of the fees paid to SSA physicians for reviewing the form.
Program Changes or Adjustments to the Information Collection Request
When we cleared this IC in 2006, the burden was 29 hours. However, we are currently reporting a burden of 38 hours. The increase in burden hours is due to
More recipients are becoming aware of the benefit extension for children. SSA reviews all applications submitted.
16. Plans for Publication Information Collection Results
SSA will not publish the results of the information collection.
17. Displaying the OMB Approval Expiration Date
SSA is not requesting an exception to the requirement to display an expiration date.
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.
| File Type | application/msword |
| File Title | Title of Information Collection and Form Number(s) |
| Author | Naomi |
| Last Modified By | Davidson, Liz |
| File Modified | 2009-12-15 |
| File Created | 2009-12-15 |