Clarification of burden methodology used for this ICR

RE Form 5500 Paperwork Numbers for 2008 Forms - IRS.htm

Annual Return/Report of Employee Benefit Plan

Clarification of burden methodology used for this ICR

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From: Decressin, Anja - EBSA [[email protected]]
Sent: Monday, July 14, 2008 3:01 PM
To: Durbala R Joseph
Cc: Kirkland Glenn P; Reed Jim; Goodman, Elizabeth - EBSA; Cosby, Chris - EBSA
Subject: RE: Form 5500 Paperwork Numbers for 2008 Forms - IRS

Attachments: Form 5500 Paperwork Numbers for 2008 Forms - IRS; IRS 2008.xls
Hi,
 
I looked through my spreadsheets and at what I have sent you last year. This is all correct, no new methodology. It seems you have reported last year the whole paperwork burden in hours (not hours and costs). Our methodology separates out hours and costs. We have estimated the hours separately: a) sponsor hours are done in-house and need to be reported as hours (= hour burden; 2008: IRS+ SSA 593,000); b) provider hours are done by service providers and need to be paid for by plans (= cost burden), therefore we don't put them down as hours or time burden, we put them down as cost burden (2008: IRS + SSA $137.7 million).
 
So in 2007, I had expected that you reported (as indicated in my attached e-mail):
591,000 total burden hours
$134 million total burden costs
 
For 2008, I would expect you have to report
593,000 total time burden (Hours)
$137,7 million total cost burden (Dollars)
 
I am not sure what number you took last year for the responses. Actually, this is more an open question. We have two choices, either the number of filings, or the number of plans. Both have disadvantages. We have used the number of plans in the last year (780,000 responses, 1 plan has 1 response).
 
 
Sorry that it took me so long to respond, I was on leave last Thursday and Friday.
Please let me know if you have further questions.
 
Anja

-----------------------------------------
Anja Decressin
Chief, Division of Research and
 Economic Analysis
phone: (202) 693-8417
[email protected]

 


From: Durbala R Joseph [mailto:[email protected]]
Sent: Thursday, July 10, 2008 4:36 PM
To: Decressin, Anja - EBSA
Cc: Kirkland Glenn P; Reed Jim
Subject: FW: Form 5500 Paperwork Numbers for 2008 Forms - IRS
Importance: High

Anja,

 

The numbers we reported last year are much different than what you sent us this year.  Is there a new methodology being used to calculate burden for this form?

 

I have attached a copy of what was sent to us last when we submitted our 2007 change request.  It included 2008 estimates and 2009 estimates.  Are we to no longer use this data? 

 

Can you explain what numbers we are to be reporting?  This latest attachment only shows 2,000 burden hours for this IC, while listing that we estimate 780,000 responses per year.  That would be that it takes the average taxpayer less than 2/1000 of a second to complete this form.  Is this correct?

 

The attachments you sent us last year contained estimates for 2008 and 2009.  Should we use these figures instead?  Last year we reported:

 

1,139,244 Responses and

2,173,483 Total Burden Hours

 

What should we report this year?

  

 

R. Joseph Durbala

Tax Analyst, Special Products Section 

Tax Forms & Publications Division

SE:W:CAR:MP:T:T:SP

(202) 622-3634

Employee No. 50-12288

 

 

-----Original Message-----
From: Decressin, Anja - EBSA [mailto:[email protected]]
Sent: Friday, May 30, 2008 2:50 PM
To: Durbala R Joseph; Vrooman Vikki
Cc: Cosby, Chris - EBSA
Subject: Form 5500 Paperwork Numbers for 2008 Forms - IRS

 

Joe/Vikki,

Attached is my spreadsheet for IRS. Look under the 2008 tab and use the

numbers in the Tables.

Please let me know if you have questions.

Thanks

Anja

 

 

 

-----------------------------------------

Anja Decressin

Economist (PhD)

Office of Policy and Research

Employee Benefits Security Administration

Department of Labor, Washington DC

phone: (202) 693-8417

fax: (202) 219-4745

[email protected]

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