Addendum to the Supporting Statement 0960-0525

Addendum to Supporting Statement

Requests for Social Security Earnings Information

Form SSA-7050-F4

20 CFR 404.810, 20 CFR 401.100

OMB No. 0960-0525

TERMS OF CLEARANCE

This information collection request is approved as submitted. OMB encourages SSA to explore the legality and feasibility of implementing electronic signature for this form, which would allow it to be completed electronically and report to OMB on its assessment with the next submission of this collection for approval.

SSA RESPONSE

SSA continues to explore the legality and feasibility of implementing electronic signature for the Form SSA-7050. Our assessment of electronic signature processing resulted in the following findings:

• SSA obtains and shares the data used to create the statement of earnings with the Internal Revenue Service (IRS). Thus, the original or “wet” signature requirements are subject to IRS regulations. SSA and IRS would need to collaborate and develop, change, and implement new Federal regulations regarding consent, authentication, and wet signature decoupling.

• The SSA’s Office of General Counsel opines that this type of authentication is new for SSA and would be very costly and resource intensive to develop. Executives must determine or decide whether to expend the necessary resources to develop the authentication protocols for a non-program related workload.

• SSA must ensure the electronic signature equates to the requirement under the Privacy Act for a written signature for consent to disclose, and thus meets OMB approval.

REVISIONS TO THE COLLECTION INSTRUMENT

Change 1 & Change 2 – Privacy Act (PA) statement language updated. PA statement now includes information from the credit card section of the form (formerly page 4), expands page 1 of form, and forces the “Information About Your Request” section to page 2.

Change 3 – Removed the Privacy Act statement from the credit card section of the form.

Justification for Changes 1, 2, & 3 – SSA’s OGC is conducting a systematic review of SSA’s PA statements on agency forms. As a result, SSA is updating the PA statement to replace outdated language.

OGC chose to eliminate the PA statement on the credit card section of the SSA-7050-F4, and instead combine that language with the PA statement that appears on the front page of the form. Further recommendations from OGC prompted the following additional changes:

Change 4 – Section 4 language moved to Section 6. Section 4 now reads “If you would like this information sent to you, please fill in the information below:”

Change 5 – Section 5 language was added “If you would like the information sent to someone else, please fill in the information below. I authorize the Social Security Administration to release my earnings information to:”

Change 6 – Section 6 language moved to Section 7. Section 6 now reads, “I am the individual to whom the record pertains (or a person who is authorized to sign on behalf of that individual). I understand that any false representation to knowingly and willfully obtain information from Social Security records is punishable by a fine of not more than $5,000 or one year in prison.”

Change 7 – This section is new to the Form SSA-7050 and contains the mailing address (formerly in Section 6).

Change 8 – The “Whose Earnings Can Be Requested” section moved to page 5 (formerly on page 3).

Justification for Changes 4, 5, 6, 7, & 8 - At the recommendation of OGC, we are clarifying the requestor consent language for the release of the earnings information to a third party