Justification for the Non-Substantive Changes to iClaim - 0618

Justification for the Non-Substantive Changes to the Social Security Benefits Application:

Form SSA-1: Application for Retirement Insurance Benefits

Form SSA-2: Application for Wife’s or Husband’s Insurance Benefits

Form SSA-16: Application for Disability Insurance Benefits

Internet Claim (iClaim) Application Screens

20 CFR 404.310-404.311, 404.315-404.322, 404.330-404.333,

404.601-404.603, and 404.1501-404.1512

OMB No. 0960-0618

Background

Since the last OMB approval for 0960-0618 on 6/1/11, we are revising some of the iClaim screens. These new revisions contain mere language changes, and incorporate some questions we currently ask applicants residing in foreign countries via paper forms.  At this time, foreign residents cannot complete their benefits application solely using iClaim, as we require certain information regarding work and residency outside of the U.S.  At this time, we also require them to complete the foreign direct deposit paper form. To remove the need for these foreign applicants to complete paper forms, we are adding questions from the foreign paper forms to iClaim.  These changes will expedite the adjudication of claims filed online, and allow foreign applicants to complete the iClaim application; therefore, we are making the revisions effective in September of 2012.

Description of Revisions for iClaim Screens

Identification Section:

• Place of birth (Birth and Citizenship Screen) - The iClaim application currently collects birth information by asking applicants for their place of birth. However, some countries have modified their official name since the applicant’s time of birth. Therefore, we are adding the following language under the place of birth header, “Provide place of birth as it was known at the time of your birth” for clarification purposes (Modified Screen #1, pg. 1).

• Legal Resident Information (Birth and Citizenship Screen) - The iClaim application currently collects citizenship information by asking, “Are you a U.S. citizen?” However, we also need alien status and residence information. Therefore, we are adding “Are you a legal resident of the United States?” If the applicant answers “Yes,” then iClaim presents a free format box instructing the applicant to provide their “Permanent Resident Card” number as an optional field (Modified Screen #2, pg. 2).

• Military and diplomatic postal addresses (Contact Information Screen) – We added new selections to the current “State/Territory” drop down to give the option to enter an Army Post Office (APO), Fleet Post Office (FPO) or Diplomatic Post Office (DPO) address (Modified Screen #3, pg. 3).

• Third party applicants email address field (Contact Information Screen) – The current iClaim screen presents an option to provide an email address when a third party applicant is filing for the claimant. We determined there is not sufficient use for this field; therefore, we removed it from the page (Modified Screen #3, pg. 3).

General Section:

• Prior Marriages Screen – The iClaim application currently asks for prior marriage history by asking applicants for their current and prior marriage information. We are adding the following language in parenthesis “regardless of how long it lasted” to capture the most recent marriage of any duration for a divorced spouse applicant. The new language reads:

Please provide information about the prior marriages for which you answered “yes.” List your most recent marriage first (regardless of how long it lasted), and work backwards. If you are not sure of the marriage date, please enter your best guess and explain in the Remarks page near the end of the application”

(Modified Screen #4, pg. 4)

• Supplemental Information Screen – We added a new “U.S. Presence” section to the current iClaim screen to determine U.S residency. We added the following conditional question: “Have you been inside the United States for 30 consecutive days or longer?”

If the applicant answers “Yes,” the system generates a dropdown field to allow the applicant to input the dates of U.S. residency. The applicant can provide up to four occurrences (Modified Screen #5, pg.5). If the applicant answers “No,” the system does not generate anything, but allows the applicant to go to the next question.

• Total Earnings Screen – The iClaim application currently collects domestic wage information. However, we added new questions to capture foreign work. The following questions apply to past, present and future years:

• “Did you work outside the United States for salary, wages, or self-employment in 2011?” If the applicants answer “Yes” the system generates the following question:

• “Were all of your earnings subject to U.S. Social Security tax?” If the applicants answer “No,” a “month by month” field appears allowing the claimants to indicate the months they worked 45 hours or more (Modified Screen #6, pg.7 & 8). If the applicants answer “Yes,” the system does not generate the “month by month” field since we consider those wages under the domestic work.

• Other Pensions/Annuities Screen – The iClaim application currently asks applicants, “Did you ever work in a job where Social Security taxes were not deducted or withheld?” We are adding “U.S.” to the current question to read, “Did you ever work in a job where U.S. Social Security taxes were not deducted or withheld?” for clarification purposes (Modified Screen #7, pg. 9).

• Reduced Benefits Screen – We are adding “permanent” to the current statement for clarification purposes. The question will read, “I want the earliest month possible without a permanent age-related reduction” (Modified Screen #8, pg.10).

• Direct Deposit Details Screen – The iClaim application currently collects direct deposit information. However, we added language and modified the presentation of the question for clarification purposes. We also incorporated a new functionality to identify applicants who provided us with an address outside the United States in order to present new questions to collect International Direct Deposit (IDD) information. The changes are as follows:

Domestic Address:

• The current screen presents a check box to allow the applicants to indicate they do not have a bank account or other financial institution. We removed the check box and presented the new “Yes” or “No” question, “Do you own or co-own a bank account that you can use for Direct Deposit?” (Modified Screen #9, pg.11)

• If the applicants answer “Yes,” the system generates the “Account Information” field to allow them to provide the account type, routing and account numbers. We also added new language below the Account Information header, “Warning: Providing incorrect information may result in a delayed payment” (Modified Screen #9, pg.11)

• If the applicant answers “No,” the system generates an “Alert” message to inform the applicant about the new electronic payment mandate:

“When you apply for Social Security benefits, you must receive your payments electronically. If you do not have a bank account to use for direct deposit, you can still complete this claim online.

We will contact you to discuss your options. Many financial institutions have free bank accounts with direct deposit enrollment. In addition, the U.S. Department of the Treasury has a Direct Express® debit card program that you can use to obtain your benefits electronically” (Modified Screen #9, pg.12)

Foreign Address:

The following conditional questions appear on the direct deposit screen when the iClaim applicant provided a foreign address. Canadian residents screen’s functionality is slightly different and it is listed at the end of this section.

• “Do you own or co-own a bank account that you can use for Direct Deposit?” If the applicant answers “No,” then the system does not generate a subsequent question and the applicant proceeds to the next screen (New Screen #1, pg. 13). However, if the applicant answers “Yes,” the system generates the following question:

• “You provided us with an address outside the United States. Would you like to use a bank from a country that participates in International Direct Deposit (IDD)?” The applicant has the option to select “Yes” for international deposit or “No, use a U.S. bank” (New Screen #1, pg.14).

• If the response is “Yes,” the system generates a conditional drop down for the applicant to select the “Bank Country” (New Screen #1, pg.15). Depending on the country selected, the system then generates a two to four entry fields to collect the account information. Many of the countries have different entry requirements; therefore the entry fields are conditional (New Screen #1, pg.16). We also added new language below the Account Information header, “Warning: Providing incorrect information may result in a delayed payment.”

• If the response is “No, use a U.S. Bank,” the system generates the current bank fields for a “domestic” bank account (New Screen #1, pg.17).

As part of the screens mentioned above, we included a screen “pop up” to assist the applicant with a understanding of IDD. The “pop up” appears when the applicant hovers the mouse over the “IDD” segment (New Screen #1, pg.15).

• Canadian Residents – When the system identifies a Canadian address on the application, the following question generates, “You provided us with a Canadian address. Would you like to use Canadian Direct Deposit?” The applicant has the option to select “Yes” for Canadian direct deposit or “No, use a U.S. bank.”

• If the response is “Yes,” the system generates a conditional drop down for the applicants to select the “Bank/Financial Institution” and “currency” type. Depending on the bank selected, the system generates two to three entry fields to collect the account information. Canadian Banks have different entry requirements; therefore, the entry fields are conditional (New Screen #2, pg. 18). We also added new language below the Account Information header, “Warning: Providing incorrect information may result in a delayed payment.”

• If the response is “No, use a U.S. Bank,” the system generates the current bank fields for a “domestic” bank account (New Screen #2, pg.19).

Other Benefits Section:

• Other Health Insurance Coverage (Health Insurance Screen) – The iClaim application currently collects Health Insurance coverage information, however, we added language for clarification. We added “current” to the questions which will read:

• “Are you covered under a Group Health Plan through your own current employment?” (Modified Screen #10, pg.20)

• If the respondents answer “No,” the following question appears, “Are you covered under a Group Health Plan through another person’s current employment?” (Modified Screen #10, pg.21)

Review & Submit Section:

• Overall Summary (Electronic Signature and Submission Screen) – At the end of the application, the system currently presents language explaining the electronic signature and submission agreement. However, we are adding language specifically related to U.S residency and foreign work. The language will appear when the system identifies the applicant as living outside the U.S or as a legal resident.

• The system will display the following language if the applicant answers, “Yes” to the question, “Are you a legal resident of the United States?”

“I agree to notify the Social Security Administration promptly if I abandon my U.S. residence status OR if the Department of Homeland Security notifies me that my resident status has been revoked or abandoned. I understand that if I am a U.S. resident, my worldwide income is subject to U.S. income tax in the same way as the income of a person living in the U.S.” (Modified Screen #11, pg.22) item#1.

• The system will display the following language to all applicants (except Medicare Only) as part of the reporting responsibilities dictated on the current benefits application:

“I agree to notify the Social Security Administration promptly if I (or any person for whom I receive benefits) become employed or self-employed while outside the U.S., change citizenship, or go (for 30 days or more) to any country other than the residence address I have entered in this application.

I agree to return any payments which are not due.” (Modified Screen #11, pg.22) item#2.

Slight Burden Increase for Foreign Respondents

As we mentioned above, the revised iClaim screens will only present the foreign form questions dependent on whether the respondents supply a foreign address, and then based solely on how they respond to subsequent questions. Therefore, we estimate only a slight increase in burden of 3 minutes on average per foreign respondent. Based on SSA’s current estimates for foreign respondents, we expect approximately 8,291 individuals will apply using iClaim using a foreign address, for a total of 415 burden hours for foreign First Party iClaim users.

Therefore, we updated our burden chart for the entire iClaim portion of 0960-0618 as follows:

Collection Method	Number of Respondents	Frequency of Response	Average Burden Per Response (minutes)	Estimated Annual Burden (hours)
iClaim 3rd Party	28,118	1	15	7,030
iClaim Applicant after 3rd Party Completion	28,118	1	5	2,343
First Party iClaim Domestic Applicant	541,851	1	15	135,463
Medicare-only iClaim	200,000	1	10	33,333
First Party iClaim Foreign Applicant	8,291	1	3	415
Totals	806,378			178,584

Updated Totals for Entire Collection

5,332,509

1,282,304

6