SUPPORTING STATEMENT FOR APPLICATION FOR APPROVAL OF A LICENSING OR CERTIFICATION TEST AND ORGANIZATION OR ENTITY;
38 CFR 21.4268
(2900-0697)
A. Justification.
1. Statute (38 U.S.C. 3689) authorizes the Secretary of Veterans Affairs to approve licensing and certification tests for payment under the educational programs if the tests and the organizations offering them meet certain statutory requirements. To meet these requirements, the organizations must make certain certifications, and supply necessary information to assess the test. The statute further allows the Secretary to delegate the approval functions to the State approving agencies (SAAs). The Secretary has done this for almost all approvals. Thus, the organizations will have to supply these certifications and information to the SAAs, and in a few instances, to the Department of Veterans Affairs (VA).
2. SAAs and VA will use the information to decide whether the licensing and certification tests, and the organizations offering them, should be approved for use under the education programs VA administers.
3. There are no means to collect this information electronically. The educational institutions and licensing and certification organizations seeking approval of their licensing and certification tests and/or organizations must supply the SAA with certifications and information to assess the test or organization. There is no form required in submitting this information.
4. VA is not aware of any duplication of this information collection.
5. The collection of information will not have a significant impact on a substantial number of small entities. Although, some testing organizations are small entities, the burden placed upon them is minor. The collection of this information is collected because it is required by statute.
6. If the SAAs and VA do not collect this information, no licensing or certification test could be approved. The statute specifically requires certain certifications before these tests can be approved for use by the organization offering them.
7. The collection of this information does not require any special circumstances.
8. The public was informed of the right to submit comments on this information collection. The notice is contained on page 47680 of the Federal Register dated August 6, 2010. No comments were received in response to this notice.
9. VA does not provide any gifts to respondents.
10. After processing, the approving organization, either an SAA or VA, will retain any written documents. Approval folders are destroyed occasionally, usually after the approved organization no longer wishes to be approved. If the approval folder is destroyed, the documents on which the information is collected will be destroyed also. Our assurance of confidentiality is covered by System of Records, Compensation, Pension, Education, and Vocational Rehabilitation and Employment Records – VA (58VA21/22/28) which is contained in the Privacy Act Issuances, 2007 Compilation.
11. None of the information collected is of a sensitive nature.
12. There will be approximately 528 annual applications seeking approval of tests and testing organizations. VA estimates that it will take an individual an average of 3 hours to supply evidence (528 x 3 hours / 60 = 1,584 hours per year).
The annual cost to respondents is $7,920 (528 respondents x $15.00 per hour).
13. This information collection does not involve any reporting or record keeping costs.
14. VA estimates that the total annualized cost to the government to collect the information required by § 21.4268 is $44,352 based on 528 responses annually. This cost is computed as follows.
The processing cost of $44,352 is based on an estimate that an SAA employee will have to review each application. The median salary for an SAA employee is $28 per hour. We estimate that it will take 3 hours to review each claim. 528 x 3 hours x $28 / 60 =$44,352. VA reimburses SAAs for the work they do for the Department according to a statutory amount they receive each fiscal year.
There are no administrative costs associated with this information collection.
15. The decrease in burden is due in part of many organizations taken advantage of the opportunity to have their tests approved for VA training.
16. VA does not publish this information or make it available for publication.
17. If the information collection in § 21.4268 is approved, VA will not indicate the expiration date of approval in the Code of Federal Regulations. Generally, OMB approvals are for three years or less. If VA displayed the expiration date, we would be routinely revising regulations just for dates. The OMB control number will be displayed in the regulation.
18. This information collection fully complies with all the requirements of 5 CFR 1320.8(b)(3).
B. Collection of Information Employing Statistical Methods.
This collection of information by the Veterans Benefits Administration does not employ statistical methods.
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT FOR § 21 |
| Author | Veterans Benefits Administrat |
| File Modified | 2010-10-15 |
| File Created | 2010-10-15 |