2900-0747 justification

Supporting Statement for

VA Form 21-526EZ,

Fully Developed Claim (Express Compensation Claim)

and VA Form 21-527EZ

Fully Developed Claim (Express Pension Claim)

(2900-0747)

A. Justification

1. The Department of Veterans Affairs (VA), through its Veterans Benefits Administration (VBA), administers an integrated program of benefits and services, established by law, for veterans, service personnel, and their dependents and/or beneficiaries. Public Law 110-389, Section 221 (a) required that VBA carry out the pilot study “Expedited Treatment of Fully Developed Claims” for a period of one-year. VBA has now decided to expand a modified version of the program to all 57 regional offices under the title “Express Claim Program”. VA Form 21-526EZ, Fully Developed Claim (Express Compensation Claim) and 21-527EZ, Fully Developed Claim (Express Pension Claim), will become the prescribed form for disability compensation or pension claims claimed under the Express Claim Program. The particular nature of the changes made to this form are to remove the barrier that only the VA Form 21-526 can be used for an original compensation or pension application for veterans who file a claim after discharge from service, append the Express Claim Notice and the Certification, and abridge the form to request only that information necessary to establish disability pension.

2. VA Form 21-526EZ and 21-527EZ will be appended to the Express Claim Notice and Certification. For eligible claims, the Express Claim Notice will satisfy the requirements under 38 U.S.C 5103. A VA Form 21-526EZ and 21-527EZ received at VBA along with the Express Claim Certification will, if all other Express Claim criteria are met, permit the claim to undergo special expeditious processing.

3. VA Form 21-526EZ and 21-527EZ will be available on the VBA website for downloading by claimants. Claimants may print and submit applications non-electronically. The Department is in process of adding several VA Forms to the Veterans Online Applications (VONAPP). VONAPP allows applicants to view, print, and submit applications electronically to VBA. VA Form 21-526EZ and 21-527EZ are forms VA plan to add to VONAPP.

4. Program reviews were conducted to identify potential areas of duplication; however, none were found to exist. There is no known Department or Agency which maintains the necessary information, nor is it available from other sources within our Department.

5. The collection of information does not involve small businesses or entities.

6. This form was redesigned into a “user friendly” form, incorporating plain English, to comply with the President’s Memorandum of June 1, 1998, Plain Language in Government Writing.

7. There is no special circumstance requiring collection in a manner inconsistent with 5 CFR 1320.6 guidelines.

8. The Department notice was published in the Federal Register Volume 74, Number 220, published on Tuesday, November 17, 2009. No comments were received.

9. No payments or gifts to respondents have been made under this collection of information.

10. The records are maintained in the appropriate Privacy Act System of Records identified as ‘‘Compensation, Pension, Education, and Rehabilitation Records—VA (58VA21/22/28)’’as set forth in Privacy Act Issuances, 1993 compilation found in 74 Fed. Reg. 117 (June 19, 2009).

11. There are no questions of a sensitive nature.

12. Estimate of Information Collection Burden.

a. Number of Respondents is estimated at 104,440 per year.

b. Frequency of Response is one time for most beneficiaries.

c. Annual burden is 43,517 hours.

d. The estimated completion time of 25 minutes is based on review by staff personnel.

e. The total estimated cost to respondents is $652,755, (43,517 x $15 per hour).

13. This submission does not involve any recordkeeping costs.

14. Estimated Costs to the Federal Government:

a. Processing/Analyzing costs $5,392,530

VA Form 21-526EZ

(GS-9/5 @ $28.04 x 104,440 x 25/60 minutes = $1,220,207)

(GS-5/5 @ $18.50 x 104,440 x 25/60 minutes = $ 805,058)

(GS-3/5 @ $14.73 x 104,440 x 25/60 minutes = $ 671,000)

VA Form 21-527EZ

(GS-9/5 @ $28.04 x 104,440 x 25/60 minutes = $1,220,207)

(GS-5/5 @ $18.50 x 104,440 x 25/60 minutes = $ 805,058)

(GS-3/5 @ $14.73 x 104,440 x 25/60 minutes = $ 671,000)

b. Printing and production cost $5,222

c. Total cost to government $5,397,752

15. The increase in burden is due to additional Regional Offices. Also VA Forms 21-526EZ, Fully Developed Claim (Express Compensation Claim), and 21-527EZ, Fully Developed Claim (Express Pension Claim), will replace the Certificate for Fully Developed Claim (VAF 21-0844). Both claims forms certification include the same information as VAF 21-0844, however, there is a substantial increase in the information provided and questions asked of claimants. These applications will still allow VA to process fully developed claims within 90 days of receipt as stated in the Federal Register notice for VAF 21-0844. A claim is considered fully developed when the claimant has no other information to submit and requires no additional VA assistance, except for obtaining federal records and ordering medical examinations.

16. The information collection is not for publication or tabulation use.

17. The collection instrument, VA Form 21-526EZ and 21-527EZ, may be reproduced and/or stocked by the respondents and veterans service organizations. This VA form does not display an expiration date, and if required to do so would result in unnecessary waste of existing stocks of this form. This form is submitted to OMB every 3 years. As such, this date requirement would also result in an unnecessary burden on the respondents and would delay Department action on the benefit being sought. VA also seeks to minimize its cost to itself of collecting, processing and using the information by not displaying the expiration date. For the reasons stated, VA continues to seek an exemption that waives the displaying of the expiration date on VA Form 21-526EZ and 21-527EZ.

18. This submission does not contain any exceptions to the certification statement.

B. Collection of Information Employing Statistical Methods

The data collection does not collect information employing statistical methods.