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. Title 38 U.S.C. 5101(a) provides that a specific claim in the form provided by the Secretary must be filed in order for benefits to be paid to any individual under the laws administered by the Secretary. VA Form 21P-527EZ will be the prescribed form for Veterans Pension applications.
VA Form 21P-527 will be used by Veterans to apply for pension benefits after they have previously applied for pension or for service-connected disability compensation using one of the prescribed forms under 38 U.S.C 5101(a). A veteran might reapply for pension if a previous compensation or pension claim was denied or discontinued, or if the veteran is receiving compensation and the veteran now believes that pension would be a greater benefit.
Because VA’s proposed rulemaking 2900-AO73 has not been finalized, and because the proposed revisions are based almost entirely on new requirements contained in the rulemaking, VBA decided to not pursue the revisions at this time. Instead, VBA requests an extension of the expiration date for the application forms under the active Information Collection Request (201407-2900-020).
Note
An erroneous Federal Register notice for OMB Control Number 2900-0002 was published at 80 FR 70081 on November 12, 2015. The erroneous notice referenced an unassociated information collection. A corrected notice was published at 80 FR 75703 on December 3, 2015.
VA Form 21P-527EZ, Application for Pension, is the prescribed form for claiming Veterans Pension under the Fully Developed Claim program. VA Form 21P-527EZ is used to gather the necessary information to determine a veteran’s eligibility for Veterans Pension. Without the information, VA will not be able to determine a Veteran’s eligibility to the benefit. A Veteran may also use this form to file a new Veterans Pension claim after VA has discontinued a previous pension award and the Veteran is requesting his or her benefits be reinstated.
VA Forms 21P-527EZ and 21P-527 are available on the VA Website in a fillable electronic format. VBA currently hosts these forms 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 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.
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 VA.
The collection of information does not involve small businesses or entities.
VA would be unable to determine a Veteran’s eligibility for Veterans Pension benefits if this information is not collected. The collection is submitted on an ad hoc (one time) basis, and cannot be submitted less frequently.
There is no special circumstance requiring collection in a manner inconsistent with 5 CFR 1320.6 guidelines.
The sponsor’s notice was published in the Federal Register on Friday, August 7, 2015 (80 FR 47563-47564 [two pages]), soliciting comments on the information collection.
VBA received eighty-three (83) public comments in response to the sponsor’s notice. All comments received referenced VBA’s proposed revisions to the application forms. Since VBA decided to pursue an extension of the currently approved versions of the forms, these comments are largely addressed.
In the sponsor’s notice, the frequency of response was erroneously listed as “annually.” The actual frequency of response will be on an ad hoc (one time for most applicants) basis. Twenty-five (25) commenters took issue with VBA collecting this information on an annual basis, as the burden would be too great on all pension beneficiaries, and specifically too great for elderly or infirm beneficiaries. VBA agrees that requiring annual submission of this information is too burdensome. The 30-Day Federal Register Notice will provide the corrected “One-Time” reporting frequency.
An additional thirteen (13) commenters noted that VA previously required Pension beneficiaries to verify their income annually by completing a form known as an Eligibility Verification Report (EVR). That program was suspended in 2012. The commenters stated that the annual reporting requirement for this Information Collection in effect re-establishes the EVR program. The annual reporting requirement in the 60-Day Federal Register Notice was inaccurate, and VA is not re-establishing the EVR program.
Fifty-one (51) commenters stated VA’s application process is too complex, too many forms are required to complete the process, and forms are too long. We appreciate the commenters’ concerns regarding the complexity of the application process. We have designed the forms to minimize the burden imposed on the applicant and collect only the information necessary to properly administer the benefit.
Twenty-three (23) commenters took issue with the annual respondent burden hours of 84,000 hours. This number is calculated by multiplying the estimated number of respondents by the estimated number of hours required to complete the form. We have revised the estimated number of hours required to complete the 21P-527EZ from 50 minutes to 25 minutes. This change has reduced the burden hours to 59,230 hours. The previous approval of this Information Collection authorized 59,230 burden hours, so the revised forms do not present an increased respondent burden.
Four (4) commenters stated VA should receive the financial data requested in the forms from the Internal Revenue Service (IRS) and/or the Social Security Administration (SSA), based on a claimants federal tax return documents. VA exchanges data with various federal agencies to improve the integrity of the Pension program.
Three (3) commenters expressed concern regarding a disabled individual’s ability to understand and complete the forms. We appreciate the difficulty disabled individuals face in completing the forms without assistance, but the information requested on the forms is required to properly administer the pension benefit.
The Veterans of Foreign Wars of the Unites States (VFW) submitted one comment which addressed several topics, some of which have been discussed above. VFW noted boxes 8 and 9 on the VA Form 21P-527 EZ are duplicated in Section III of the form. VA agrees the information requested is duplicative and we revised the form to remove the duplication.
VFW stated the instructions on the form create ambiguity about which sections are required to be completed and which sections are conditionally required. VA agrees with the comment and we revised various parts of the form to improve clarity.
VFW stated Section V of the 21P-527EZ has not been updated to comply with Obergefell v. Hodges. VA disagrees with this assessment, as all references to the Veteran’s sex and the spouse’s sex have been removed. VA has not published new regulations or policies which could provide an impetus to update the form to collect information regarding same-sex marriages covered by the Obergefell decision. If and when new regulations are published, the form may be updated to collect additional information.
VFW suggested that the form be compatible with optical-recognition scanning, and be made available electronically and to create the ability to submit the form via the eBenefits portal. VA does not currently have compatible technology for optical recognition scanning. VA agrees such technology would be useful, but we are unable to implement the suggestion at this time. The forms will be made available on the va.gov website in the PDF format. VA is pursuing eBenefits functionality to allow the electronic submission of the 21P-527EZ. However, we are unable to project the deployment date of this functionality.
VA received thirteen (13) additional comments which did not contain specific areas of improvement or concern.
VBA did not consult with outside persons or entities on the modifications to this information collection.
No payments or gifts to respondents have been made under this collection of information.
The records are maintained in the appropriate Privacy Act System of Records identified as “Compensation, Pension, Education, and Vocational Rehabilitation and Employment Records-VA (58VA21/22/28),” published at 74 FR 29275 (June 19, 2009).
There are no questions of a sensitive nature.
Number of Annual Respondents: 118,197 respondents
VA
Form 21P-527EZ – 101,086 respondents
VA Form 21P-527 –
17,111 respondents
Frequency of Response: One-time
Estimated Completion Time – 1 hour
VA Form 21P-527EZ – 25 Minutes (0.42 hours)
VA Form 21P-527 – 1 hour
Total Burden Hours – 59,230 hours
VA Form 21P-527EZ –
42,119 hours
VA Form 21P-527 – 17,111 hours
The population of respondents is composed entirely of Veterans of the United States Military. Therefore, all respondents are of either a working or retirement age. Entitlement to VA Pension benefits is based upon permanent and total disability, or advanced age (65 or greater), so VA expects most applicants to meet at least one of the two criteria. However, further assumptions about the population (such as education, current employment, and future earning potential) are impossible because of the wide variability of these factors within the respondent populations. Therefore, VBA chose to use generalized wage data to calculate the cost burden to respondents.
The Bureau of Labor Statistics gathers information on full-time wage and salary workers. According to the latest available data (as of February 29, 2016), the median weekly earnings of full-time wage and salary workers are $809.00. Assuming a forty (40) hour work week, the median hourly wage is $20.23.
VBA estimates completing this form will take one hour. Therefore, VBA estimates the cost burden for each respondent to be $20.23. There are no expected overhead costs for completing the application.
VBA estimates the total cost of all respondents to be $1,198,223.00 (59,230 burden hours x $20.23 per burden hour).
The submission does not involve any record-keeping costs
Processing/Analyzing costs $3,962,554
VA Form 21P-527EZ
(GS-11/5@ $33.92 x 101,086 x 25/60 minutes = $1,428,682)
(GS-9/5 @ $28.04 x 101,086 x 25/60 minutes = $1,181,021)
(GS-5/5 @ $18.50 x 101,086 x 25/60 minutes = $ 779,205)
VA Form 21P-527
(GS-11/5 @ $33.92 x 17,111 x 25/60 minutes = $241,835)
(GS-9/5 @ $28.04 x 17,111 x 25/60 minutes = $199,914)
(GS-5/5 @ $18.05 x 17,111 x 25/60 minutes = $131,897)
Printing and production cost ($90/thousand) $10,638
Total cost to government $3,973,192
Since VBA decided to not pursue the proposed revisions, there are no burden hour changes. In the active ICR, the respondents’ Annual Cost Burden was not calculated. VBA included the calculation in this ICR (see item 12 of this supporting statement for the calculation).
The information collected is not for tabulation.
We are not seeking to omit the expiration date.
This submission does not include any exceptions to the certification statement.
No statistical methods are used in this data collection.
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File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
File Title | SUPPORTING STATEMENT FOR VA FORM 10-2065, FUNERAL ARRANGEMENTS; VA FORM 10-10, APPLICATION FOR MEDICAL BENEFITS; VA FORM 10-10I, |
Author | Preferred Customer |
File Modified | 0000-00-00 |
File Created | 2021-01-24 |