SuppStmt, VAF 21-0304, 7-29-14

Supporting Statement for:

(2900-0572)

VA Form 21-0304

Application for Benefits for Certain Children with Disabilities Born of Vietnam and Certain Korea Service

A. Justification

1. The Department of Veterans Affairs (VA), through its Veterans Benefits Administration (VBA), administers an integrated program of benefits and services established by law for veterans, service personnel, and their dependents and/or beneficiaries. 38 U.S.C. 1805 provides for payment of benefits for a child with spina bifida who is the natural child of a veteran who served in the Republic of Vietnam during the Vietnam era. 38 U.S.C. 1815 provides for payment of benefits for a child with certain birth defects who is the natural child of a female veteran who served in the Republic of Vietnam during the Vietnam era.

The Final Rule RIN 2900-AO81, Standard Claims and Appeals Forms, which requires all claims for benefits to be submitted on an application or form prescribed by the Secretary. VA is codifying its regulations to standardize the use of all VA forms, to include VA Form 21-0304.

2. VA Form 21-0304 is used to gather the necessary information to determine eligibility for the monetary allowance and the appropriate level of payment. It would be impossible to administer this benefit program without this collection of information.

3. VA Form 21-0304 is available on the One-VA Website in a fillable electronic format. VBA is currently hosting this form on a secure server and does not currently have the technology in place to allow for the complete submission of the form. Validation edits are performed to assure data integrity. Efforts within VA are underway to provide a mechanism to allow the information to be submitted electronically with a recognized signature technology. There currently is no utility process in place that will allow the data submitted on the form to be incorporated with an existing centralized legacy database.

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

5. The collection of information does not involve small businesses or entities.

6. VA Form 21-0304 is used to determine the monetary allowance for a child born with spina bifida or certain birth defects who is the natural child of a Vietnam veteran. Without this information, VA would be unable to effectively administer this law.

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 proposed rule, RIN 2900-AO81, Standard Claims and Appeals Forms, in the Federal Register on October 31, 2013, Vol. 78, No. 211, pages 65490-65509. No comments were received.

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

10. We are complying with the provisions of 38 U. S. C. 5701 and the Privacy Act of 1974, and 5 U. S. C. 522a. The records are maintained in the appropriate Privacy System of Records identified “Compensation, Pension, Education, and Vocational Rehabilitation and Employment Records-VA (58VA21/22/28),” published at 74 FR 29275 on June 19, 2009, and last amended 75 FR 22187 (April 27, 2010).

11. There are no questions of a sensitive nature.

12. Estimate of Information Collection Burden.

1. Number of Respondents is estimated at 430 per year.

2. Frequency of Response is one time.

3. Annual burden: 72 hours.

4. The estimated completion time: 10 minutes.

5. According to the U.S. Bureau of Labor Statistics Average Hourly Earnings, the cost to the respondent is $24, making the total cost to the respondents an estimated $1,728 (72 hours x $24 per hour).

13. This submission does not involve any recordkeeping costs.

14. Estimated Costs to the Federal Government:

    1. Processing/Analyzing costs $4,389

(GS-9/5 @ $28.04 x 430 x 10/60 minutes = $2,009)

(GS-5/5 @ $18.50 x 430 x 10/60 minutes = $1,325)

(GS-3/5 @ $14.73 x 430 x 10/60 minutes = $1,055)

2. Printing and production cost ($45/thousand) $45

3. Total cost to government $4,434

15. There is no change in the reporting burden even with the Final Rulemaking RIN 2900-AO81, “Standard Claims and Appeals Forms” which requires all claims for benefits to be submitted on an application or form prescribed by the Secretary. However, the estimated costs to the federal government have been revised to reflect updated data.

16. We are not seeking approval to omit the expiration date for OMB approval.

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

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

B. Collection of Information Employing Statistical Methods

The data collection does not employ statistical methods.