2900-0131 justification

SUPPORTING STATEMENT

VA FORM LETTER 29-615

REQUEST FOR SUPPLEMENTAL INFORMATION ON MEDICAL

AND NONMEDICAL APPLICATIONS

2900-0131

JUSTIFICATION:

1. The form letter is used by the policyholder to apply for new issue, reinstate or change plan on NSLI policies. The information is authorized by law, 38 CFR 8.11.

2. The information collected on the form letter is used by the Department of Veterans Affairs (VA) to establish the insured's eligibility for reinstatement, change of plan, or a new issue of insurance. The form is also used by the insured or their representatives as a certification of health. The VA must verify that the insured has not been ill or suffered or contracted any disease, infirmity or other injury which prevents the insured from attending his/her usual occupation. The insured must report any illness, disease, injury or medical treatments along with dates.

3. VA Form Letter 29-615 Should not be available on the Internet. This item is partially completed and appropriate paragraphs are inserted on an internal MS Word system (PC Letters) and mailed to the policyholder for completion and return. As a complete form, it would be of no use to the policyholder without the information VA would provide initially.

4. The information is not contained in any other VA records. Similar information is not available elsewhere.

5. The information does not involve any small businesses.

6. The form letter is designed for use by the insurance activity to determine the insured's eligibility for reinstatement, change of plan, or a new issue of insurance. The collection is generally conducted only once.

7. There are no special circumstances requiring that the collection be conducted in a manner inconsistent with the guidelines in 5 CFR Section 1320.6.

8. The Department notice was published in the Federal Register on May 2, 2011, pages 24571-24572. There were no comments received in response to this notice.

9. The information collected is supplied by the respondent. No remuneration is made.

10. The information collection conforms with the Privacy Act of 1974 and is subject to the conditions of disclosure contained therein. The records are maintained in the system identified as 36VA00, "Veterans and Armed Forces Personnel United States Government Life Insurance Records - VA" as contained in the Privacy Act Issuances, 1993 Compilation.

11. There are no questions of a sensitive nature.

12. We estimate that approximately 9,000 form letters a year will be received. We also estimate that it will take approximately 20 minutes to complete this form letter. We arrived at this estimate by initiating a trial with a VA staff member unfamiliar with the form. The annual burden will is 3,000 hours. The cost to reporting public is $45,000.00 (3,000 hours X $15/hour).

13. This submission does not involve any record keeping costs.

14. Cost to Government:

$8,091.00 Estimated mailing cost (9,000 X 2 minutes per

form X $15.51/hour (average salary for station

mail personnel) plus 9,000 form letters X 38.2 cents

each (presort discount)).

$8,388.00 Estimated cost for collections (9,000 X 4 minutes

per form X $13.98/hour (average salary of station

collections personnel)).

$14,873.00 Estimated cost for processing (9,000 form letters X

5 minutes per form X $19.83/hour (Average

salary for reviewers)).

$270.00 Estimated printing costs (9,000 X $30/1,000

forms).

$31,622.00 Total cost to the Government.

15. There have not been any program changes or adjustments.

16. The information is collected for insurance purposes only and there are no plans for publication.

17. The collection instrument, VA Form Letter 29-615, may be reproduced and/or stocked by the respondents and veteran service organizations. This VA form letter does not display an expiration date, and if required to do so would result in unnecessary waste of existing stocks of this form letter. This form letter is submitted to OMB for approval every three 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 Letter 29-615.

18. There are no exceptions to the certification statement identified in Item 19 of OMB Form 83-I.

Statistical Methods

The Veterans Benefits Administration does not collect information employing statistical methods.