Justification Statement_VA FORM 21P-530 final 11-25-13

Supporting Statement for VA Form 21P-530

Application for Burial Benefits

(2900-0003)

A. Justification

1. The Department of Veterans Affairs (VA), through its Veterans Benefits Administration (VBA), administers an integrated program of monetary burial benefits for deceased veterans. VA requests information necessary to administer these benefits on the application form for burial benefits, VA Form 21P-530, under the authority of 38 U.S.C. §§ 2302, 2303, 2307, and 2308. Revisions to VA Form 21P-530 include: 1) add a block with checkmarks to clarify the claimant’s relationship to the deceased Veteran; 2) remove the block for funeral home as claimant; 3) reorganize, into separate parts, the claim for burial allowance, the claim for plot or internment allowance, and the claim for transportation reimbursement; and 4) excepting burial allowance following death in a VA medical facility and transportation expense remove requirements that claimants provide costs and proof of payment thereof.

2. VA uses VA Form 21P-530 to gather the necessary information from claimants to determine eligibility for all of VBA’s monetary burial benefits: burial allowance, plot or interment allowance, and transportation reimbursement.

3. VA Form 21P-530 is available on the One-VA Forms Website for downloading by claimants. Claimants may print and submit applications non-electronically. VA Form 21P-530 is also available in Veterans Online Applications (VONAPP). VONAPP allows applicants to view, print, and submit applications electronically to VBA. In the last fiscal year, VA received approximately 150,000 VA Form 21P-530. VA estimates that less than one percent of VA Forms 21P-530 are currently received electronically. However, electronic submissions are trending upward.

4. Program reviews were conducted to identify potential areas of duplication; none were found to exist. There is no known Department or Agency which maintains the necessary information to process burial benefits, nor is that information available from any other sources within our Department.

5. This collection of information indirectly impacts small businesses because funeral businesses provide services for which VA provides these benefits. However, VA will reduce the burden for persons applying for burial benefits and the providers of funeral services because it reduces the documentation required from claimants to obtain payment of burial benefits. The proposed rulemaking would eliminate the need for claimants to provide receipts of burial and funeral expenses actually incurred except in claims for transportation expenses or where the death occurred in a VA Medical Facility.

6. The VA burial benefit requires current information to determine eligibility for benefits. Without the information provided on this form, it would not be possible to obtain the information needed to make a determination and reimburse a claimant. The amended collection of information will reduce the information collection burden for surviving spouses seeking burial benefits by using information about the spouse already in VA systems at the date of the veteran’s death.

7. There is no special circumstance requiring collection in a manner inconsistent with 5 CFR 1320.6 guidelines.

8. The Department notice was published in the Federal Register on ( Insert Date ) ( Volume __, No. __ ) ( page/pages ) ( Insert Page Number(s) ). ( No or number ) comments were received in response to this notice.

9. No payments or gifts to respondents have been made under this collection of information.

10. The records are maintained in the appropriate Privacy Act System of Records identified as 58VA21/22/28, ‘‘Compensation, Pension, Education and Vocational Rehabilitation and Employment Records – VA’’ as set forth in Privacy Act Issuances, 1993 compilation found in 77 Fed. Reg. 42593 (July 19, 2012). Any disclosures of information obtained in this collection are made pursuant to the provisions of the Privacy Act, 38 U.S.C. § 5701, and 38 U.S.C. § 7332.

11. There are no questions of a sensitive nature.

12. Estimate of Information Collection Burden.

a. Number of Respondents is estimated at 150,000 per year.

b. Frequency of Response is on occasion for most beneficiaries.

c. Annual burden is 37,500 hours.

d. The estimated completion time of 15 minutes is based on review by staff personnel and previous usage of this form.

e. The total estimated cost to respondents is $562,500 (37,500 hours x $15 per hour).

13. This submission does not involve any recordkeeping costs.

14. Estimated Costs to the Federal Government:

a. Processing/Analyzing costs $2,237,550

(GS-12/5 @ $32.73 x 150,000 x 2 minutes = $163,650)

(GS- 5/5 @ $14.90 x 90,000 x 37 minutes = $826,950)

(GS- 3/5 @ $11.86 x 90,000 x 37 minutes = $658,230)

(GS- 5/5 @ $14.90 x 60,000 x 22 minutes = $327,800)

(GS- 3/5 @ $11.86 x 60,000 x 22 minutes = $260,920)

GS-12/5 authorizer workload will not decrease. We expect the time previously required to process all such claims (45 min.) to be reduced by 8 minutes as a result of efficiencies obtained in this rulemaking. We further expect the processing time required for burial claims automatically paid to eligible survivors (60,000 of 150,000) as a result of the rulemaking to be reduced by an additional 15 minutes.

b. Redesign costs (GS-13/10 @ $55.46 x 8 hours = $443.68) $444

c. Total cost to government $2,237,994

15. The annual reporting burden has decreased. VA has revised downward its estimate of burden hours based on more accurate historical data for the number of burial claims received annually, now projected to be 150,000 each year. In addition to the reduction in estimated claims, VA estimates that the amount of time necessary for claimants to complete the application for burial benefits is reduced from 22 minutes to 15 minutes. This is due to the program change whereby VA will no longer require claimants to provide evidence of actual costs incurred except for transportation expenses.

16. The information collection is not for publication or tabulation use.

17. The collection instrument, VA Form 21P-530, may be reproduced and/or stocked by the respondents and veterans service organizations. This VA form does not display an expiration date, and if required to do so would result in unnecessary waste of existing stocks of this form. This form is submitted to OMB every 3 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 21P-530.

18. This submission does not contain any exceptions to the certification statement.

B. Collection of Information Employing Statistical Methods

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