Tribal FEGLI Supporting Statement_7.2.13

Tribal FEGLI Supporting Statement_7.2.13.doc

FEGLI Implementation Questionnaire for Tribal Employers

OMB: 3206-0260

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SUPPORTING STATEMENT FOR DISTRIBUTION OF FEGLI IMPLEMENTATION QUESTIONNAIRE TO TRIBES AND

URBAN INDIAN ORGANIZATIONS



Under the provisions of the Paperwork Reduction Act of 1980 (title 44, U.S. Code, Chapter 35), the Office of Personnel Management (OPM) is submitting to the Office of Management and Budget (OMB) a request to distribute a questionnaire regarding access to the Federal Employees’ Group Life Insurance (FEGLI) program coverage for Tribes and urban Indian organizations. This questionnaire will gather information needed to properly develop and implement section 409 of the Indian Health Care Improvement Act (IHCIA), which was enacted as part of the Affordable Care Act. This provision authorizes Tribes and Tribal organizations carrying out programs under the Indian Self Determination and Educational Assistance Act (ISDEAA) or urban Indian organizations carrying out programs under Title V of the IHCIA to purchase coverage, rights, and benefits under the Federal Employees Health Benefits (FEHB) Program and FEGLI for their employees.



JUSTIFICATION


  1. Explain the circumstances that make the collection of information necessary. Include identification of any legal or administrative requirements that necessitate the collection.


In order to successfully implement access to FEGLI coverage for eligible Tribes and urban Indian organizations, an understanding of the scope of the project is needed. There is currently limited data available that could be used to provide a reasonable estimate of the anticipated number of enrollees, or the anticipated number of participating tribal entities. Additionally, there is no information available regarding the existing methods of premium collection or type of coverage used by Tribes and urban Indian organizations. Receipt of the above mentioned data, along with information related to the types of life insurance coverage currently accessed by Tribes and urban Indian organizations, and the cost thereof, will allow OPM to properly develop and effectively implement this project.


In order to effectively allow OPM to determine the costs associated with the implementation, operation and enrollment in FEGLI, there is a need to gather information. The feasibility of creating and maintaining technology, and more specifically, the extent to which technology needs to be implemented, is contingent in large part on the number of anticipated enrollees. The number of interested tribal organizations and their projected enrollment will impact the cost per enrollee.


The information provided by respondents as a result of this questionnaire will aid in determining the costs and procedures associated with this project. OPM’s implementation strategy will be directly impacted by the number of predicted enrollees. As a result, the information gathered from this questionnaire will aid in the development of a system that is both reasonably priced and appropriately laid out to meet the needs of the anticipated enrollees.





  1. Indicate how, by whom, and for what purpose the information is to be used.


The information collected will be compiled for purposes of answering the above mentioned questions related to the implementation of this project and the associated costs. The questionnaire is being distributed to approximately 700 tribal entities, so there is no need for an automated collection method, even with a 100 percent response rate.


  1. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection.


The questionnaire will be distributed to tribal organizations along with a letter, fact sheet and current FEGLI rates, which is to be distributed in accordance with the standard methods used by the Indian Health Service (IHS). These letters are distributed by IHS on a regular basis, so there is already an effective method of distribution in place. Responses will be submitted via email, fax, or postal mail, allowing all tribal entities the opportunity to respond regardless of available technology.


  1. Describe efforts to identify duplication.


Duplication will be minimized because OPM is responsible for administering the FEGLI program and is therefore the only entity collecting this information.


  1. If the collection of information impacts small businesses or other small entities, describe the methods used to minimize the burden.


Not applicable.


  1. Describe the consequence to Federal program or policy activities if the collection were conducted less frequently.


This is a one time collection. Not collecting this information will impair the ability of OPM to properly develop and effectively implement this project. There is no other data or resource available that can provide the information needed to complete this project.


  1. Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.6.


Not applicable.


  1. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to OMB.


Not applicable.


  1. Explain any decision to provide any payment or gift to respondents other than re-enumeration of contractors or grantees.


Not applicable.


  1. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.


Access to the information collected on this questionnaire will be strictly controlled and limited to appropriate OPM personnel and other authorized Federal personnel. This information will be used strictly for purposes of properly developing this project, and will not be otherwise distributed or released. The responses will be submitted via fax, email, or postal mail, and will be maintained in confidential files. All authorized personnel with access to this information agree to and adhere to rules of behavior on the safe handling of data when accessing information collected. All records developed from the information collected will be purged and destroyed in accordance with record keeping schedules. OPM certifies that the information collection complies with the Privacy Act of 1974.


  1. Provide additional justification for any questions of a sensitive nature such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.


Not applicable.


  1. Provide estimates of the hour burden of collection of information.


We estimate that it will take approximately five minutes to complete each questionnaire. There are approximately 700 respondents, which indicate approximately 58 total burden hours. We do not anticipate that respondents will incur any costs associated with the completion and submission of this questionnaire.


  1. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.


There is no annual cost burden.


  1. Provide estimates of annualized cost to the Federal Government. Also provide a description of the method used to estimate cost which should include quantification of hours, operational expenses (such as equipment, overhead, printing and support staff) and any other expenses that would not have been incurred without the paperwork burden.


There is no annualized cost to the Federal Government associated with this information collection. This is a one time distribution.


  1. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.


Not applicable.


  1. For collections of information whose results will be published, outline plans for tabulation and publication.


Not applicable. The results of this information collection will not be published.


  1. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate


We do not seek approval to not display the expiration date.


  1. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.


No exceptions.

File Typeapplication/msword
File TitleSupporting Statement for Paperwork Reduction Act Submission
Authorgmperryman
Last Modified ByCEKane
File Modified2013-07-02
File Created2013-07-02

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