OMB Passback - 2900-0020 (VA Form 29-336) 11-16-16

SUPPORTING STATEMENT

VA FORM 29-336

DESIGNATION OF BENEFICIARY

2900-0020

JUSTIFICATION:

1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.

This form is used by the insured to designate a beneficiary and select an optional settlement to be used when the insurance matures by death. The information is required to determine the claimant’s eligibility to receive the proceeds. The information on the form is required by law, 38 USC Sections 1917, 1949 and 1952.

2. Indicate how, by whom, and for what purposes the information is to be used; indicate actual use the agency has made of the information received from current collection.

The data collected on the form is used by the personnel in the Insurance Division to determine who is eligible to receive the proceeds of the insurance.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

VA Form 29-336 is available on the One-VA web site 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. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

The information is not contained in any other VA records. Similar information is not available elsewhere.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The information does not involve any small businesses.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently as well as any technical or legal obstacles to reducing burden.

This form is designed for use by the insured to designate his/her beneficiary and select a settlement option to be used when the insurance matures by death. If the information is not collected, or is collected less frequently, the VA Insurance Center will not have up to date information in order to pay the proceeds of the insurance policies according to the Veteran’s last wishes.

7. Explain any special circumstances that would cause an information collection to be conducted more often than quarterly or require respondents to prepare written responses to a collection of information in fewer than 30 days after receipt of it; submit more than an original and two copies of any document; retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years; in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study and require the use of a statistical data classification that has not been reviewed and approved by OMB the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently as well as any technical or legal obstacles to reducing burden.

There are no special circumstances requiring that the collection of information be conducted in a manner inconsistent with the guidelines in 5 CFR Section 1320.6.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the sponsor’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the sponsor in responses to these comments. Specifically address comments received on cost and hour burden.

The Department notice was published in the Federal Register on Monday, March 21, 2016, Vol. 81, No. 54, Page 15151- 15152. No comments were received.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

The information collected is supplied by the respondent. No remuneration is made.

10. Describe any assurance of privacy, to the extent permitted by law, provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The information collection conforms with the Privacy Act of 1974 and is subject to the conditions of disclosure contained therein. The records are maintained in the system identified as 36VA29, “Veterans of Uniformed Services Personnel Programs of U.S. Government” as contained in the Privacy Act Issuances, 1993 Compilation.

11. Provide additional justification for any questions of a sensitive nature (Information that, with a reasonable degree of medical certainty, is likely to have a serious adverse effect on an individual's mental or physical health if revealed to him or her), such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private; include specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive nature.

12. Estimate of the hour burden of the collection of information:

Estimate of Information Collection Burden:

a. Number of Respondents: 83,500

b. Frequency of Response: On Occasion

c. Annual Burden Hours: 13,917 hours

d. Estimated Completion Time: 10 minutes

e. The respondent population is composed of Veterans. VBA cannot make further assumptions about the population of respondents because of the variability of factors such as the educational background and wage potential of respondents. Therefore, VBA used general wage data to estimate the respondents’ costs associated with completing the information collection.

The Bureau of Labor Statistics gathers information on full-time wage and salary workers. Accordingly, the median weekly earnings of full-time wage and salary workers are $929.20, effective May 2015. Assuming a forty (40) hour work week, the median hourly wage is $23.23 based on the BLS wage code – “00-0000 All Occupations”.

Legally, respondents may not pay a person or business for assistance in completing the information collection and a person or business may not accept payment for assisting a respondent in completing the information collection. Therefore, there are no expected overhead costs for completing the information collection. VBA estimates the total cost to all respondents to be $323,291.91 (13,917 burden hours x $23.23 per hour).

13. Provide an estimate of the total annual cost burden to respondents or record-keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

This submission does not involve any record keeping costs.

14. Provide estimates of annual cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

Cost to Government:

$75,067.00 Estimated mailing cost (83,500 X 2 minutes per

form X $15.51/hour (average salary for station

mail personnel) plus 83,500 X 38.2 cents each

(presort discount)).

$38,911.00 Estimated cost for collections (83,500 X 2 minutes

per X $13.98/hour (average salary of station collections

personnel)).

$27,597.00 Estimated cost for processing (83,500 forms X 1

minute per form X $19.83/hour (average salary

for reviewers)).

$3,758.00 Estimated printing costs (83,500 X $45/1,000 forms).

$145,333.00 Total cost to the Government.

15. Explain the reason for any burden hour changes since the last submission.

There is no change in respondent burden.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

The information is collected for insurance purposes only and there are no plans for publication.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The collection instrument, VA Form 29-336, is a beneficiary designation form utilized by the Veteran to name the rightful recipient of the life insurance benefit. Unlike other VBA benefits, VA Life Insurance is a contract between the Veteran and the government where VA Form 29-336 is not adjudicated at the time of receipt, but is adjudicated after the death of the insured Veteran, which is typically many years after receipt of the VA Form 29-336. It is kept on record indefinitely. VA Form 29-336 is legally binding; the designation cannot be overruled by a will, divorce decree, or court order. A printed expiration date on the form would result in unnecessary confusion to the respondent and potential legal issues.

VA Form 29-336 is submitted to OMB for review and approval every three years. Including a printed expiration date on the form may lead respondents to believe they have to resubmit the form each time it expires. Consequently, the risk of the printed expiration date presenting difficulties relative to the validity of the form is high and may result in unnecessary delay in payment of insurance proceeds at a time when financial need for survivors is critical, particularly when families need the insurance proceeds to pay last expenses for the decedent. Additionally, a printed expiration date on the beneficiary designation form could potentially be used to support a contested claim; the claimant may claim that the named beneficiary is not the rightful recipient if there is an expiration date on the form. VA requests an exemption to waive displaying the expiration date on VA Form 29-336 for the reasons outlined above.

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB 83-I.

There are no exceptions to the certification statement identified in Item 19 of

OMB Form 83-I.

B. Collection of Information Employing Statistical Methods

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