Supporting Statement 0960-0730

Supporting Statement 0960-0730.docx

Identifying Information for Possible Direct Payment of Authorized Fees

OMB: 0960-0730

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Supporting Statement for Form SSA-1695

Identifying Information for Possible Direct Payment of Authorized Fees


OMB No. 0960-0730


  1. Justification

  1. Introduction/Authoring Laws and Regulations

Pursuant to sections 206(a) and 1631(d) of the Social Security Act, the Social Security Administration (SSA) collects the information on this form to facilitate direct payment of authorized fees to an attorney or other person who represents claimants for benefits before SSA. SSA also uses the information to meet any requirement to issue a Form 1099-MISC, pursuant to 26 USC 6041 and 26 USC 6045(f) of the United States Code, under the Internal Revenue Service.


  1. Description of Collection

SSA collects information on Form SSA-1695 to: 1) facilitate the direct payment of authorized fees to an attorney or other person who represent claimants for benefits before SSA; 2) meet any requirement to issue a Form 1099-MISC when SSA has paid the representative cumulative fees of $600 or more in a taxable year; and 3) establish a link between each claim for benefits and the data we collect on Form SSA-1699, and stored on an appointed representative database. The respondents are attorneys and other individuals who represent claimants for benefits before SSA.


  1. Use of Information Technology to Collect the Information

The SSA-1695 is available as a downloadable PDF, which the representatives can print, complete, and send to SSA. Form SSA-1695 does not become part of the claims file; after we enter it into the appropriate systems, SSA destroys the form.


  1. Why We Cannot Use Duplicate Information

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 collect similar data.


  1. Minimizing Burden on Small Respondents

This collection does not affect small businesses or other small entities.


  1. Consequence of Not Collecting Information or Collecting it Less Frequently

SSA does not currently have another process for collecting the information. The information provided by appointed representatives facilitates direct payment of authorized fees in each claim, and meets the requirements to issue a Form 1099-MISC. Therefore, if SSA did not collect the information, we would be unable to meet the requirements to issue a Form 1099-MISC, or to pay authorized fees directly. Since SSA collects this information on an as-needed basis, we cannot collect it less frequently. There are no technical or legal obstacles that prevent burden reduction.



  1. Special Circumstances

There are no special circumstances that would cause SSA to conduct this information collection in a manner inconsistent with 5 CFR 1320.5.


  1. Solicitation of Public Comment and Other Consultations with the Public

SSA published the 60-day advance Federal Register Notice on March 7, 2012 at 77 FR 13681, and we received no public comments. We published the 30-day Federal Register Notice on June 14, 2012 at 77 FR 35739. If we receive any comments in response to the 30-day Notice, we will forward them to OMB. There have been no outside consultations with members of the public.

  1. Payment or Gifts to Respondents

SSA provides no payment or gifts to respondents.


  1. Assurances of Confidentiality

SSA protects and holds confidential the information we collect 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.


  1. Justification for Sensitive Questions

The information collection does not contain any questions of a sensitive nature.


  1. Estimates of Public Reporting Burden

Approximately 10,000 respondents use Form SSA-1695 annually. We estimate a respondent may complete a form 40 times per year, for 400,000 responses. The estimated average response time is 10 minutes, for 66,667 burden hours. The total burden represents burden hours, and SSA did not calculate a separate cost burden.


  1. Annual Cost Burden to the Respondents (Other)

There is no known cost burden to the respondents.


  1. Annual Cost To Federal Government

The annual cost to the Federal Government is approximately $371,000. This estimate is a projection of the costs for printing and distributing the collection instrument, and for collecting the information.


  1. Program Changes or Adjustments to the Information Collection Request

There are no changes in the public reporting burden.


  1. Plans for Publication Information Collection Results

SSA will not publish the results of the information collection.


  1. Displaying the OMB Approval Expiration Date

OMB exempted SSA from publishing the expiration date for OMB approval on its 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 so SSA would not have to discontinue using otherwise usable editions of forms with outdated expiration dates. In addition, SSA avoids Government waste, because we will not have to destroy and reprint stocks of forms.


  1. Exception to Certification Statement

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).


  1. Collections of Information Employing Statistical Methods


SSA is not using statistical methods for this information collection


























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