Supporting Statement for Form SSA-1699
Registration FOR APPOINTED REPRESENTATIVE SERVICES AND DIRECT PAYMENT
OMB No. 0960-0732
A. Justification
1. If individuals want to become official representatives for Social Security claimants, the Social Security Administration (SSA) needs to collect certain information from them to register/appoint them as representatives. SSA uses form SSA-1699, Registration for Appointed Representative Services and Direct Payment, for this purpose. Sections 206(a) and 1631(d) of the Social Security Act give SSA the authority to collect the information requested by Form SSA-1699.
In October 2009, SSA began using a newly revised version of form SSA-1699. However, due to user confusion, SSA realized it would not benefit the form’s users for us to continue using this new version (see February 2010 Information Collection Request (ICR) for details). Accordingly, we developed a revised SSA-1699, and in February 2010 OMB granted a six-month emergency clearance for this “interim” version.
Since receiving emergency clearance for the February 2010 version of form SSA-1699, we have conducted extensive conversations with representatives and professional representative organizations. These conversations helped us to realize we would need a longer period of time than originally anticipated to create an entirely new business process and accompanying forms/systems that would meet both the representatives’ and SSA’s needs. For this reason, we are making the “interim” emergency version of SSA-1699 our new permanent form, and we are seeking full clearance for this form in the current ICR.
Using this version of form SSA-1699 –the same one OMB approved in February 2010- SSA will collect information from appointed representatives of Social Security claimants who 1) want to register for direct payment of fees; 2) registered for direct payment of fees prior to 10/31/09, but need to update their information; 3) registered as appointed representatives on or after 10/31/09, but need to update their information; and 4) received a notice from SSA instructing them to complete this form. By registering these individuals, SSA 1) authenticates and authorizes them to do business with us, 2) allows them access to our records for the claimants they represent, 3) facilitates direct payment of authorized fees to appointed representatives, and 4) collects the information we will need to meet Internal Revenue Service (IRS) requirements to issue specific IRS forms if we pay these representatives in excess of a specific amount ($600).
Because we are planning a new form and business process, we did not invest resources in creating an electronic platform for this version of form SSA-1699 under the agency’s Government Paperwork Elimination Act plan. We plan to create an online version of the new form.
4. 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 gather similar data.
This collection does not significantly affect small businesses or other small entities.
6. If we did not collect this information, SSA would have no means of authenticating representatives, allowing them direct access to beneficiary records, facilitating direct payment of authorized fees to representatives, or issuing the necessary IRS forms. Since we will only collect the information on an as-needed basis, we cannot conduct the information collection less frequently.
There are no technical or legal obstacles to burden reduction.
7. There are no special circumstances that would cause SSA to conduct this information collection in a manner inconsistent with 5 CFR 1320.5.
8. SSA published an advance 60-day Federal Register Notice on May 26, 2010, at 75 FR 29599, and we did not receive any public comments. We published the 30-day Federal Register Notice on August 2, 2010, at 75 FR 45190. If we receive any public comments in response to the 30-day Notice, we will forward them to OMB.
SSA continues to hold discussions with the appointed representative community to ensure we develop a business process that meets their needs. We will consider the feedback received during these discussions as we move forward with the new business process and future iteration of the form.
9. SSA provides no payment or gifts to the respondents (except for payment of authorized fees).
10. SSA protects and holds confidential the information we are requesting 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.
11. This information collection does not contain any sensitive questions.
12. We estimate approximately 52,800 respondents will take 20 minutes each to complete this form, for a total of 17,600 hours. This figure represents burden hours, and we did not calculate a separate cost burden.
13. There is no known cost burden to the respondents.
14. The annual cost to the Federal Government is approximately $350,000. This estimate is a projection of the costs for printing and distributing the collection instrument and for posting a PDF of the form on our Internet site.
15. There are no changes to the public reporting burden since the February 2010 ICR.
16. SSA will not publish the results of the information collection.
17. OMB has exempted SSA from publishing the OMB approval expiration date on its program forms. SSA produces millions of public-use forms, many of which have a life cycle longer than that of an OMB approval. SSA does not periodically revise and reprint its public-use forms (e.g., on an annual basis). OMB granted this exemption to avoid destroying otherwise useable editions of forms, avoiding Government waste.
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.
SSA-1699 (0960-0732)
| File Type | application/msword |
| File Title | PSA Documentation |
| Author | Liz Davidson |
| Last Modified By | 889123 |
| File Modified | 2010-08-02 |
| File Created | 2010-08-02 |