CMS-10407 Supporting Statement 30-day_2-12-15_508MM

Supporting Statement for the Information Collection Requirements Contained in
Summary of Benefits and Coverage and Uniform Glossary
(CMS-10407/OMB Control Number 0938-1146)
A. Justification
1.

Circumstances Making the Collection of Information Necessary
The Patient Protection and Affordable Care Act, Pub. L. 111-148, was signed into law on
March 23, 2010, and the Health Care and Education Reconciliation Act of 2010, Pub. L.
111-152, was signed into law on March 30, 2010 (collectively known as the “Affordable
Care Act”). The Affordable Care Act amends the Public Health Service Act (PHS Act) by
adding section 2715 “Development and Utilization of Uniform Explanation of Coverage
Documents and Standardized Definitions.” This section directs the Secretary, in consultation
with the National Association of Insurance Commissioners (NAIC) and a working group
comprised of stakeholders, to develop standards for use by a group health plan and a health
insurance issuer in compiling and providing to applicants, enrollees, and policyholders and
certificate holders a summary of benefits and coverage (SBC) explanation that accurately
describes the benefits and coverage under the applicable plan or coverage. Section 2715 also
requires 60-days advance notice of any material modification in any of the terms of the plan
or coverage that is not reflected in the most recently provided summary and the
development of standards for the definitions of terms used in health insurance coverage.
A notice of proposed rulemaking (NPRM) was published on August 22, 2011 (76 FR
52442) with an accompanying document (76 FR 52475) containing the templates,
instructions, and related materials for implementing the disclosure provisions under PHS
Act 2715. The NPRM proposed to add section 200 to Part 147 of Title 45 of the Code of
Federal Regulations. A final rule was published on 02/14/2012.
Section 147.200(a)(1) requires a group health plan and a health insurance issuer to provide a
written summary of benefits and coverage for each benefit package to entities and
individuals at specified points in the enrollment process.
As specified in §147.200(a)(2), a plan or issuer will populate the SBC with the applicable
plan or coverage information, including the following: (1) a description of the coverage,
including cost sharing, for each category of benefits identified in guidance by the Secretary;
(2) exceptions, reductions, and limitations of the coverage; (3) the cost-sharing provisions of
the coverage, including deductible, coinsurance, and copayment obligations; (4) the
renewability and continuation of coverage provisions; (5) coverage examples that illustrate
common benefits scenarios (including pregnancy and serious or chronic medical conditions)
and related cost sharing; (6) identifying information for the plan or coverage and contact
information for questions and for obtaining a copy of the plan document or the insurance
policy, certificate, or contract of insurance (such as a telephone number for customer service
and an Internet address for obtaining a copy of the plan document or the insurance policy,
certificate, or contract of insurance); (7) for plans and issuers that maintain one or more
networks of providers, an Internet address (or similar contact information) for obtaining a
1

list of network providers; (8) for plans and issuers that provide prescription drug coverage
through a formulary, an Internet address (or similar contact information) for obtaining
information on prescription drug coverage; (9) an Internet address (or similar contact
information) where a consumer may review and obtain the uniform glossary; and (10) with
respect to coverage beginning on or after January 1, 2014, a statement about whether the
plan or coverage provides minimum essential coverage as defined under section 5000A(f) of
the Internal Revenue Code and whether the plan’s or coverage’s share of the total allowed
costs of coverage meets applicable requirements.
In order to produce coverage examples, a plan or issuer will simulate claims processing for
clinical care provided under each scenario using the services, dates of service, billing codes,
and allowed amounts provided by HHS. Benefits scenarios will be based on recognized
treatment guidelines as defined by the National Guideline Clearinghouse. Allowed amounts
for each service will be based on national averages. Plans and issuers will follow
instructions for estimating and displaying costs in a standardized format authorized by HHS.
The purpose of the coverage examples tool is to help consumers synthesize the impact of
multiple coverage provisions in order to compare the level of protection offered by a plan or
coverage for common benefit scenarios. In the first year of implementation, two coverage
examples (having a baby and managing type 2 diabetes) will be required in the SBC.
Because the statute additionally requires the Secretary to “provide for the development of
standards for the definitions of terms used in health insurance coverage,” including specified
insurance-related and medical terms, the Departments have interpreted this provision as
requiring plans and issuers to make available a uniform glossary of health coverage and
medical terms that is two double-sided pages in length. Plans and issuers must include an
Internet address in the SBC for consumers to access the glossary and provide a paper copy
of the glossary within seven days upon request. Plans and issuers may not modify the
glossary provided in guidance by the Departments.
Finally, “if a group health plan or health insurance issuer makes any material modification
in any of the terms of the plan or coverage involved (as defined for purposes of section 102
of the ERISA) that is not reflected in the most recently provided summary of benefits and
coverage, the plan or issuer shall provide notice of such modification to enrollees not later
than 60 days prior to the date on which such modification will become effective.” Thus, the
Departments will require 60-days advance notice of any material modification in any of the
terms of the plan or coverage that (1) affects the information required to be included the
SBC; (2) occurs during the plan or policy year, other than in connection with renewal or
reissuance of the coverage; and (3) is not otherwise reflected in the most recently provided
SBC. A plan or issuer may satisfy this requirement by providing either an updated SBC or a
separate notice describing the modification.
HHS is requesting three-year approval by the Office of Management and Budget so that
plans and issuers may begin using the forms for making the disclosures under PHS Act
section 2715 and the final regulations.

2

2.

Purpose and Use of Information Collection
This information collection will ensure that approximately 90 million consumers shopping
for or enrolled in private, individually purchased or non-federal governmental group health
plan coverage receive the consumer protections of the Affordable Care Act. Employers,
employees, and individuals will use this information to compare coverage options prior to
selecting coverage and to understand the terms of, and extent of medical benefits offered by,
their coverage (or exceptions to such coverage or benefits) once they have coverage.

3.

Use of Information Technology
The SBC template will be made available in MS Word, a widely available word processing
application. Plans and issuers may choose to populate the template manually or to develop
automated systems to capture and report the data in the required format.
With respect to coverage examples, HHS will make available in an Excel worksheet the
clinical benefits scenario(s), including specific services, dates of service, billing codes, and
allowed charges associated with each scenario. Plans and issuers will simulate claims
processing under each scenario to illustrate how a consumer could expect to share costs with
the plan or coverage. Plans and issues may either generate these outputs using automated
systems or perform the calculations manually, such as using Excel.
An issuer is permitted to provide the SBC electronically, such as via e-mail or posting on
the Internet, if certain safeguards are met to ensure the manner of disclosure results in actual
receipt. Flexibility for electronic disclosure will help reduce cost and administrative burden
and increase timeliness and accuracy. The Department anticipates approximately 70 percent
electronic distribution in the individual market and approximately 44 percent electronic
distribution in the group market. 1

4.

Efforts to Identify Duplication and Use of Similar Information
Under the federal health care reform insurance Web portal requirements, 45 CFR 159.200,
HHS collects summary information about health insurance products that are available in the
individual market. To reduce duplication for purposes of the SBC collection, we will permit
individual market issuers compliant with the Web portal collection to voluntarily report to
the Web portal for display the five additional data elements (not currently collected through
the Web portal collection) for each coverage example. Issuers providing the additional data
elements to Web portal collection will be deemed to satisfy the requirement to provide an
SBC to individuals in the individual market requesting summary information, prior to
submitting an application for coverage.

1

The Departments’ estimate is based on statistics published by the National Telecommunications and Information
Administration, which indicate 30 percent of Americans do not use the Internet. U.S. Department of Commerce,
National Telecommunications and Information Administration, Digital Nation (February 2010), available at
http://www.ntia.doc.gov/reports/2010/NTIA_internet_use_report_Feb2010.pdf.

3

Under the Employee Retirement Income Security Act (ERISA) disclosure requirements, 29
CFR 2520.104b-2, the plan administrator of an employee benefit plan subject to of Part 1 of
Title I of ERISA is required to disclose to participants and beneficiaries similar plan
information in a summary plan description (SPD). Plan administrators will modify the SPD
information for purposes of this collection to generate a standardized summary of plan
benefits and costs. Non-federal governmental plans are not subject to the SPD requirements,
however, some non-federal governmental plans voluntarily comply with the SPD
regulations, reducing the burden of reporting.
5.

Impact on Small Businesses or Other Small Entities
Small businesses are not significantly affected by this collection. The information used to
populate the form is readily available and disclosed by plans and issuers as part of their
current operations. No capital costs are required for this effort. The electronic distribution of
information should also ease burden among some plans and issuers. Limiting distribution of
the SBC for covered individuals who reside at the same address, as well as other provisions
designed to reduce unnecessary duplication, will also reduce the frequency of reporting.
Finally, the vast majority of health insurance issuers and third-party administrators are not
small businesses. 2 Small businesses are not significantly affected by this collection.

6.

Consequences of Less Frequent Collection
This collection is required to fulfill the statutory requirements under PHS Act section 2715
and the final regulations. This collection will ensure that, at multiple points in the
enrollment process, consumers have consistent and clear information with which to
understand and compare plan and coverage options. If this collection is not conducted, or is

2

As discussed in the Web Portal interim final rule (75 FR 24481), HHS examined the health insurance industry in
depth in the Regulatory Impact Analysis prepared for the proposed rule on establishment of the Medicare Advantage
program (69 FR 46866, August 3, 2004). In that analysis, HHS determined that there were few if any insurance
firms underwriting comprehensive health insurance policies (in contrast, for example, to travel insurance policies or
dental discount policies) that fell below the size thresholds for ‘‘small’’ business established by the Small Business
Association (SBA). Currently, the SBA size threshold is $7 million in annual receipts for both health insurers (North
American Industry Classification System, or NAICS, Code 524114) and TPAs (NAICS Code 524292).
Additionally, as discussed in the Medical Loss Ratio interim final rule (75 FR 74918), HHS used a data set created
from 2009 National Association of Insurance Commissioners (NAIC) Health and Life Blank annual financial
statement data to develop an updated estimate of the number of small entities that offer comprehensive major
medical coverage in the individual and group markets. For purposes of that analysis, HHS used total Accident and
Health (A&H) earned premiums as a proxy for annual receipts. HHS estimated that there were 28 small entities with
less than $7 million in A&H earned premiums offering individual or group comprehensive major medical coverage;
however, this estimate may overstate the actual number of small health insurance issuers offering such coverage,
since it does not include receipts from these companies’ other lines of business. These 28 small entities represent
about 6.4 percent of the approximately 440 health insurers that are accounted for in this Economic Impact Analysis
of the NPRM. Based on this calculation, the Departments assume that there are an equal percentage of TPAs that are
small entities. That is, 48 small entities represent about 6.4 percent of the approximately 750 TPAs that are
accounted for in this RIA.

4

conducted less frequently, consumers will not receive the protections to which they are
entitled under the Affordable Care Act.
7.

Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
In some instances, respondents are required to compile and provide a written SBC in fewer
than 30 days. Issuers will provide the SBC to individuals in the individual market and to
group health plans in the fully-insured group market as soon as practicable but not later than
7 business days after receiving an application for health coverage. If there is any change in
the information required to be in the SBC before the first day of coverage, issuers will
updated and provide a current SBC not later than the first day of coverage. Additionally,
plans and issuers will provide the SBC to any individual as soon as practicable but not later
than 7 business days after receiving a request for an SBC or for summary information about
health coverage, and they will provide the uniform glossary within 7 days of a request. Plans
and issuers may have to provide multiple copies of the SBC or glossary depending on the
number of requests.

8.

Comments in Response to the Federal Register Notice/Outside Consultation
A Federal Register notice was published on Nov. 24, 2014 at 79 FR 69854, providing the
public with a 60-day period to submit written comments on the ICR.
One comment was received during the 60-day comment period. The comment raised a
concern that the ICR does not reflect amendments to the Civil Rights Act of 1964, which
include people with disabilities as protected from discrimination. Because this ICR is a
renewal without amendments to the underlying rules or requirements, we are not revising
the ICR to include new references to the Civil Right Act of 1964, or any amendments to it.
We note that other requirements may apply to group health plans, and health insurance
issuers in the group and individual markets, related to nondiscrimination and ensuring
access for people with disabilities. Such requirements are not a part of this ICR, and are not
addressed by it.
The Departments have continued to consult with industry experts, including health
insurance issuers and groups representing employers with self-funded health plans, to gain
insight into the hour and burden associated with this collection, the tasks and level of effort
required, and the availability of data.

9.

Explanation of any Payments/Gifts to Respondents
Respondents will not receive any payments or gifts as a condition of complying with this
information collection request.

10. Confidentiality
This collection does not require the disclosure of trade secrets or other confidential
information. No individually identifiable personal health information will be collected.
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11. Justification for Sensitive Questions
No sensitive information will be collected.
12. Burden Estimate (Hours & Wages)
Each group health plan and health insurance issuer offering group or individual health
insurance coverage must provide a summary of benefits and coverage (SBC) to entities and
individuals at specified points in the enrollment process. This disclosure must include,
among other things, coverage examples that illustrate common benefits scenarios and
related cost sharing. Additionally, plans and issuers must make the uniform glossary
available in electronic form, with paper upon request, and provide 60-days advance notice of
any material modifications in the plan or coverage.
This analysis includes the coverage examples are part of the SBC disclosure, therefore the
Department calculates a single burden estimates for purposes of this section, assuming the
information collection request for the SBC (not including coverage examples) totals six (6)
sides of a page in length and assuming the information collection request for coverage
examples totals two (2) sides of a page in length.
While regulations require issuers in the group market to provide the required documents for
those plans that are self-insured a simplify assumption is made. It is believed that many
self-insured plans hire third-party administrators (TPAs) to administer the plan, therefore the
burden to prepare the documents will be calculated at the TPA level even while
acknowledging the plans and the plan participants in actually bear these costs.
With respect to the individual market, issuers are responsible for generating, reviewing
updating, and distributing SBCs. With respect to non-Federal governmental plans, the
Department assumes fully-insured plans will rely on health insurance issuers and selfinsured plans will rely on TPAs to perform these functions. While plans may prepare SBCs
internally, the Department makes this simplifying assumption because most plans appear to
rely on issuers and TPAs for the purpose of administrative duties, such as enrollment and
claims processing. Thus, the Department uses health insurance issuers and TPAs as the unit
of analysis for the purposes of estimating administrative costs.
The Departments estimate there are a total of 500 issuers and 1,050 TPAs affected by this
information collection.3 Because the Department of Health and Human Services shares the
hour and cost burden for fully-insured plans with the Departments of Labor and the

3 The estimate for the number of issuers is based on the number of issuers for the group and individual market filing
with the Department for the Medical Loss Ratio regulations. The number of TPAs is based on the U.S. Census’s
2011 Statistics of U.S. Businesses that reports there are 3,157 TPA’s. Previous discussions with industry experts
led to assuming about one-third of the TPA’s (1,052) could be providing services to self-insured plans.

6

Treasury HHS assumes 50 percent of the hour and cost burden estimates for individual
issuers and 15 percent of the burden for TPAs to account for those TPAs serving selfinsured non-Federal governmental plans.
To account for variation in costs due to firm size and the number of plans and individuals
they service, the Department divides issuers into small, medium, and large. 4 Accordingly,
the Department estimates approximately 175 small, 250 medium, and 75 large issuers. The
Department lacks information to create a similar split for TPAs, so assumes a similar
distribution there for the Department estimates approximately 368 small, 526 medium, and
158 large TPAs.
The estimated hour burden and equivalent cost for the collections of information are
as follows:
The Department estimates an administrative burden on Issuers and TPAs to make
appropriate changes to IT systems and processes and make updates to the SBCs and
Coverage Examples. It is estimated that large firms will incur 150 hours, medium firms 115
hours and small firms 75 hours to perform these tasks. The burden will be split between IT
professionals (55 percent), benefits professionals (40 percent), and legal professions (5
percent) with hourly labor rates of $81.03, $61.44, and $126.56 respectively. 5 Clerical labor
rates are $29.60 per hour.
Table 1 shows the calculations used to obtain the hour burden (43,300 hours) and its
equivalent cost burden ($3.3 million) for issuers and TPAs to prepare the SBCs and
coverage examples.
In addition clerical hours used to prepare and distribute the disclosures (see question 13
below for more details) would have a hour burden of 279,000 hours with an equivalent cost
of $8.3 million.
The total hour burden for this information collection would be 322,400 hours with an
equivalent cost of $11.5 million.

4

The premium revenue data come from the 2009 NAIC financial statements, also known as “Blanks,” where
insurers report information about their various lines of business. The Department defines small issuers as those with
total earned premiums less than $50 million; medium issuers as those with total earned premiums between $50
million and $999 million; and large issuers as those with total earned premiums of $1 billion or more.

5 The estimated 2014 hourly labor rates include wages, other benefits, and overhead based on data from the National
Occupational Employment Survey (March 2013, Bureau of Labor Statistics) and the Employment Cost Index
(September 2013, Bureau of Labor Statistics); the 2012 estimated labor rates are then inflated to 2014 labor rates.

7

TABLE 1.-- Update SBC including Coverage Examples

Type of Labor

Number
of Firms

Hours
Per
Firm

Cost
per
Hour

Total
Hour
Burden

Equivalent
Costs

Issuers

Large

IT

75

41.3

$81

3,094

$250,687

Benefits

75

30.0

$61

2,250

$138,240

Legal

75

3.8

$127

281

$35,595

5,625

$424,522

Sub-Total

Medium

IT

250

31.6

$81

7,906

$640,643

Benefits

250

23.0

$61

5,750

$353,280

Legal

250

2.9

$127

719

$90,965

14,375

$1,084,888

Sub-Total

Small

IT

175

20.6

$81

3,609

$292,468

Benefits

175

15.0

$61

2,625

$161,280

Legal

175

1.9

$127

328

$41,528

6,563

$495,275

Sub-Total

TPAs

Large

IT

158

12.4

$81

1,955

$158,434

Benefits

158

9.0

$61

1,422

$87,368

Legal

158

1.1

$127

178

$22,496

3,555

$268,298

Sub-Total

Medium

IT

526

9.5

$81

4,990

$404,374

Benefits

526

6.9

$61

3,629

$222,990

8

Legal

526

0.9

$127

Sub-Total

Small

454

$57,417

9,074

$684,782

IT

368

6.2

$81

2,277

$184,505

Benefits

368

4.5

$61

1,656

$101,745

Legal

368

0.6

$127

207

$26,198

4,140

$312,448

43,331

$3,270,212

Sub-Total

Total

TABLE 2.-- Preparation and Distribution Costs

Number of
Disclosures

Number of
Disclosures
Sent on
Paper

15,750

7,875

Clerical
Hour
Burden

Total
Equivalent
Cost

Group Health Plan

SBC with Coverage
Examples

131.25

$3,885

SBC with Coverage Examples- Participants and Beneficiaries
Upon Application or
Eligibility
Upon Renewal
Beneficiaries Living Apart

Sub-Total

222,680

111,340

1,855.67

$54,928

17,129,262

8,564,631

142,743.85

$4,225,218

33,000

33,000

550.00

$16,280

8,708,971

145,150

$4,296,426

17,384,942

Uniform Glossary

428,232

428,232

7,137

$211,261

Notice of Modification

342,585

171,293

2,855

$84,504

9

Individual Market

SBC with Coverage
Examples
Uniform Glossary

Notice of Modification

21,784,217

6,535,265

108,921

$3,224,064

762,448

762,448

12,707

$376,141

130,705

2,178

$64,481

16,744,788

279,080

$8,260,762

435,684.34

Total

41,153,858

Deemed Compliance Reporting (45 CFR 147.200(a)(4)(iii)(C))
Under §147.200(a)(4)(iii)(C), if individual health insurance issuers provide information
required by these final regulations to the HHS Secretary’s Web portal (HealthCare.gov,
currently approved under OMB Control Number 0938-1086), as established by 45 CFR
159.120, then they will be deemed to have satisfied the requirement to provide an SBC to
individuals who request information about coverage prior to submitting an application for
coverage. Individual health insurance issuers already provide most SBC content
elements to HealthCare.gov, except for five data elements related to patient responsibility
for each coverage example: deductibles, co-payments, co-insurance, limits or exclusions,
and the total of all four cost-sharing amounts.
Accordingly, the additional burden associated with the requirements under
§147.200(a)(4)(iii)(C) is the time and effort it would take each of the 320 issuers in the
individual market submitting data to HealthCare.gov to enter the five additional data
elements into an Excel spreadsheet. We estimate that it will take these issuers about 160
hours, at a total estimated cost of $4,800, for each coverage example. For two coverage
examples, the burden and cost would be about 320 hours at a cost of about $9,600.
In deriving these figures, we used the following hourly labor rates and estimated the time
to complete each task: $30.78/hr and 0.5 hr/issuer for clerical staff to enter data into an
Excel spreadsheet, or about $15 per respondent per coverage example.

6

For the collection instrument associated with this provision, see the Plan and Benefits Template included in the
Information Collection Request package for OMB Control Number 0938-1086 available at:
http://www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRA-ListingItems/CMS-10433.html?DLPage=1&DLFilter=10433&DLSort=1&DLSortDir=descending

10

13. Estimates of other Total Annual Cost Burden to Respondents or Record
Keepers/Capital Costs
SBC
The Department estimates that there will be about 39.2 million SBCs delivered with 15,800
going to non-federal governmental plans, 17.4 million to policy holders in non-federal
governmental plans, and 21.8 million going to participants and beneficiaries in the
individual market annually. 7
The Department assumes 50 percent of the SBCs going to plans and plan participants would
be sent electronically while 70 percent of SBCs would be sent electronically in the
individual market. Accordingly, the Department estimates that about 23.9 million SBCs
would be electronically distributed, and about 15.3 million SBCs would be distributed in
paper form. The Department assumes there are costs only for paper disclosures, with de
minimis costs for electronic disclosures. The SBC, with coverage examples, would be eight
pages in length. Paper SBCs sent to participants would have no postage costs as they could
be included in mails with other plan materials, however all notices sent to beneficiaries
living apart would be mailed and have a 49 cent postage costs. Printing costs would be five
cents per page. Each document sent by mail would have a one minute preparation burden,
with the task performed by a clerical worker. This clerical hour burden is discussed in
question 12 above.
The total cost burden to prepare and distribute the SBC would be $6.1 million.
Uniform Glossary – The Department assumes that 2.5 percent of those who receive paper
SBCs, will request glossaries in paper form (that is, about 1.2 million glossary requests).
The total cost burden to prepare and distribute the Uniform Glossaries would be $822,000.
Notice of Modifications – The Department assumes that issuers and plans will send notices
of modifications to covered individuals, and that 2 percent of covered individuals will
receive such notice (that is,788,000 notices). As with the SBC, 50 percent of plans and
plan participants and 70 percent of policy holders in the individual market will receive
electronic notices. Paper notices are assumed to be of the same length as an SBC, eight
pages and will incur a postage cost of 49 cents.
The total cost burden to prepare and distribute the Uniform Glossaries would be $269,000.
The total annual cost burden is estimated to be $7.2 million.
TABLE 3.-- Preparation and Distribution Costs

7 Based on the 2012 Current Population Survey the Department estimates there are 21.7 million policy holders in
the individual market and 17.1 million policy holders in non-federal governmental plans.

11

Number of
Disclosures

Number of
Disclosures
Sent on
Paper

15,750

7,875

Material
and
Printing
Costs

Postage
Costs

Total Cost
Burden

Group Health Plan

SBC with Coverage
Examples

$3,150

$3,150

111,340

$44,536

$44,536

8,564,631

$3,425,852

$3,425,852

33,000

$13,200

$16,170

$29,370

8,708,971

$3,483,588

$16,170

$3,499,758

SBC with Coverage Examples- Participants and Beneficiaries
Upon Application or
Eligibility

222,680

Upon Renewal

17,129,262

Beneficiaries Living Apart

Sub-Total

33,000

17,384,942

Uniform Glossary

428,232

428,232

$85,646

$209,833

$295,480

Notice of Modification

342,585

171,293

$68,517

$83,933

$152,450

21,784,217

6,535,265

$2,614,106

762,448

762,448

$152,490

$373,599

$526,089

435,684.34

130,705

$52,282

$64,046

$116,328

41,153,858

16,744,788

$6,459,780

$747,582

$7,207,361

Individual Market

SBC with Coverage
Examples
Uniform Glossary
Notice of Modification

Total

$2,614,106

14. Annualized Cost to Federal Government
Government program staffing costs include one GS-14 and one GS-9 with a break down as
follows to provide technical assistance to respondents.
12

GS-14: hourly rate $54.31 at 5 hours a week

Annual cost: $14,121

GS-9: hourly rate $26.65 at 5 hours a week:

Annual cost: $6,929
Total: $21,050

15. Explanation for Program Changes or Adjustments
The total hour burden estimate associated with this collection has increased 22,180 hours.
Estimates have been adjusted to account for new estimates of the number of issuers, plans,
participants and beneficiaries affected by the information collection. Also labor rates have
been adjusted.
16. Plans for Tabulation and Publication and Project Time Schedule
There are tabulation or publication dates associated with this information collection request.
17. Reason(s) Display of OMB Expiration Date is Inappropriate
The Departments request an exemption from displaying the expiration date, as these forms
will be used on a continuing basis. To include an expiration date would result in having to
discard a potentially large number of forms.

13