3220-0151

OMB NO. 3220-0151

Justification

Representative Payee Monitoring

RRB Form G-99a and G-99c

1. Circumstances of information collection - Under Section 12 of the Railroad Retirement Act (RRA), the Railroad Retirement Board (RRB) may pay annuity benefits to a representative payee when an employee, spouse, or survivor annuitant is incompetent or a minor. The RRB periodically requires representative payees to account for the use of benefits received on behalf of the beneficiary. The procedures pertaining to the appointment and responsibilities of a representative payee and the accountability requirement authorizing the RRB to conduct periodic monitoring of representative payees, including a written accounting of benefit payments received, are prescribed in 20 CFR 266.

2. Purposes of collecting/consequences of not collecting the information - The RRB uses the following forms to conduct an on-going representative payee monitoring program.

Form G-99a, Representative Payee Report, is used by the RRB to obtain information needed to determine whether the benefit payments certified to the representative payee have been used for the annuitant's current maintenance and personal needs, and whether the representative payee continues to be concerned with the annuitant's welfare. The form is computer-generated and released from RRB headquarters directly to the representative payee, along with an envelope for returning the completed form to the RRB field office shown in the lower portion of the form. Release of the G-99a is triggered by information stored in the RRB's Checkwriting Integrated Computer Operation (CHICO) file. The identifying information and the reporting period beginning and ending dates in the upper portion of the form are computer printed by the RRB before the form is released. Form G-99a, also contains the Paperwork Reduction Act/Privacy Act Notices and a listing of representative payee duties. At the time of appointment, the RRB furnishes each representative payee an informational booklet, RB-5, Your Duties As Representative Payee (OMB approved 3220-0052). The RB‑5 contains an account book that the RRB recommends the representative payee use for maintaining a record of his or her use of railroad retirement benefits on behalf of an annuitant.

The field office is responsible for controlling the return of the completed G-99a within the 15‑day time period prescribed on the form. If the initial G-99a is not returned within the prescribed 15-day period, a follow-up G-99a is released by the field office. If the follow-up G‑99a is not returned within 15 days, the field office schedules an interview with the representative payee to obtain more detailed information.

The RRB proposes to change Form G-99a as follows:

• Consistent with 20 CFR 266.4(g), which states that “the RRB may consider whether a representative payee has ever been convicted of a felony or a misdemeanor under the statutes of the Board or the Social Security Act, or convicted of a felony under any other Federal or state law” the RRB proposes the deletion of the limiting phrase “within the past 15 years” from Item 9 of Form G-99a.

• Minor non-burden impacting editorial and formatting changes.

Form G-99a is similar to Form SSA-623-F6, Representative Payee Report, OMB No. 0960‑0068.

Form G-99c, Representative Payee Evaluation Report, is used by an RRB field office to obtain more detailed information from a representative payee who fails to complete and return a Form G-99a, or in situations when the returned Form G-99a indicates the possible misuse of funds by the representative payee. Form G-99c contains specific questions concerning the representative payee's performance, and is used by the RRB to determine whether or not the representative payee should continue in that capacity.

Form G-99c is a three-part form completed by the RRB based on information provided during an interview with a representative payee (Part I), the annuitant (Part II), and the custodian of the annuitant, if any (Part III). Options for conducting the interview include:

• at an RRB field office,

• by telephone,

• at an itinerant point, or

• at the annuitant's residence.

The identifying information above Part I of the form is entered by the RRB representative prior to the interview with the representative payee. After furnishing the information requested on Form G-99c, the representative payee and custodian (if any) are required to sign the Form G‑99c and are advised of the penalties resulting from fraudulent statements or for withholding information to misrepresent a fact material to determining a right to a payment under the Railroad Retirement Act.

The RRB proposes the following changes to Form G-99C:

• Consistent with 20 CFR 266.4(g), which states that “the RRB may consider whether a representative payee has ever been convicted of a felony or a misdemeanor under the statutes of the Board or the Social Security Act, or convicted of a felony under any other Federal or state law” the RRB proposes the deletion of the limiting phrase “within the past 15 years” from Item 7 of Form G-99c.

• a minor editorial change to the Paperwork Reduction Act language.

Form G-99c is similar to Form SSA-624-F5, Representative Payee Evaluation Report, OMB No. 0960-0069.

3. Planned use of improved information technology or technical/legal impediments to further burden reduction - None at present time. Forms are initiated by RRB with prefilled data.

4. Efforts to identify duplication - This data collection does not duplicate any other data collection.

5. Small business respondents - N.A.

6. Consequences of less frequent collection - Each payee reports on a triennial basis. Less frequent reporting would not be advisable considering the circumstances.

7. Special Circumstances - None

8. Consultations outside the agency - In accordance with 5 CFR 1320.8(d), comments were invited from the public regarding the information collection. The notice to the public was published on page 416 of the January 3, 2014, Federal Register. No comments or requests for additional information were received.

9. Payments or gifts to respondent - None

10. Confidentiality - Privacy Act System of Records, RRB-22, Railroad Retirement Survivor and Pensioner Benefit System. In accordance with OMB Circular M-03-22, a Privacy Impact Assessment for this information collection was completed and can be found at http://www.rrb.gov/pdf/PIA/PIA-BPO.pdf.

11. Sensitive questions - N.A.

12. Estimate of respondent burden - The estimated annual burden for the information collection is unchanged as follows:

Current Burden

Form Number	Annual Responses	Time (Minutes)	Burden (Hours)
G-99a (legal and all other, excepting parent for child)	5,400	18	1,620
G-99c (Parts I and II)	300	24	120
G-99c (Parts I, II, and III)	120	31	62
Total	5,820		1,802

13. Estimated annual cost to respondents or record keepers - N.A.

14. Estimate of cost to Federal Government - N.A.

15. Explanation for change in burden - N.A.

16. Time schedule for data collection and publication - The results of this collection will not be published.

17. Request not to display OMB expiration date - Given the costs associated with redrafting, reprinting, and distributing the forms in this collection in order to keep the appropriate OMB expiration date in place, the RRB requests the authority to not display the OMB expiration date on the forms associated with this collection.

18. Exceptions to Certification Statement - None

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