Supporting Statement for Form SSA-8202-BK
Statement for Determining Continuing Eligibility for
Supplemental Security Income Payment
20 CFR 416.204
OMB No. 0960-0145
A. Justification
Introduction/Authoring Laws and Regulations
Title XVI, part A, Section 1611(c)(1) of the Social Security Act (Act) requires that the Commissioner of the Social Security Administration (SSA) shall redetermine eligibility for, and the amount of, Supplemental Security Income (SSI) payments. 20 CFR 416.204 of the Code of Federal Regulations provides that the SSA conduct redeterminations (RZs) periodically on a scheduled basis, or when we receive notification of a change that would affect an SSI recipient's continued eligibility or payment amount.
Description of Collection
SSA uses Form SSA-8202-BK to conduct low and middle-error profile (LEP/MEP) telephone or face-to-face RZ interviews with SSI recipients and representative payees, if applicable. SSA conducts LEP redeterminations interviews on a 6-year cycle, and MEP redeterminations annually. SSA requires the information we collect during the interview to determine whether: (1) SSI recipients met, and continue to meet, all statutory and regulatory requirements for SSI eligibility; and (2) they received, and are still receiving, the correct payment amounts. This information includes non-medical eligibility factors such as income, resources, and living arrangements. Respondents may have to obtain information from employers or financial institutions to complete Form SSA‑8202. The respondents are SSI recipients and their representatives, if applicable.
Use of Information Technology to Collect the Information
SSA employees document the information gathered during the interview process through our Modernized SSI Claims System (MSSICS) and its paper equivalent, Form SSA-8202-BK. In addition, SSA conducts electronic interfaces with records of other government entities whose records contain information that may affect a recipient’s SSI eligibility or payment amount. We must verify any conflicting information we get through these interfaces with the recipient. Based on our data, we estimate approximately 85% of respondents under this OMB number use the electronic version.
Why We Cannot Use Duplicate Information
Form SSA-8203-BK also collects information similar to that collected by Form SSA-8202-BK. Form SSA-8203-BK (OMB Number 0960-0416) is a more comprehensive, complex redetermination form used to conduct high-error profile (HEP) redeterminations. It is not a self-help form and SSA field office personnel always complete it by conducting personal contact interviews through MSSICS. Form SSA-8202-BK is a simpler design not intended for use in HEP redeterminations. Conducting LEP and MEP redeterminations using Form SSA‑8203-BK instead of Form SSA-8202-BK creates an unnecessary burden on the recipients at a higher cost to the Federal government. Therefore, SSA does not use the two forms for the same purpose
Minimizing Burden on Small Respondents
This collection does not affect small businesses or other small entities.
Consequence of Not Collecting Information or Collecting it Less Frequently
If we did not use Form SSA-8202-BK during RZ interviews, potential eligibility or events affecting payment would go undetected. This can adversely affect recipients through underpayments (i.e., erroneously low SSI payments) or overpayments (excessive SSI payments which may result in collection activities). We perform MEP redeterminations annually. In addition, since SSA collects a majority of LEP on a 6-year cycle, we cannot collect it less frequently. Collecting these types of redeterminations less frequently would compromise program integrity. There are no technical or legal obstacles to burden reduction.
Special Circumstances
There are no special circumstances that would cause SSA to conduct this information collection in a manner inconsistent with 5 CFR 1320.5.
Solicitation of Public Comment and Other Consultations with the Public
The 60-day advance Federal Register Notice published on December 29, 2015, at 80 FR 81409, and we received no public comments. The 30-day FRN published on March 4, 2016 at 81 FR 11636. If we receive any comments in response to this Notice, we will forward them to OMB. SSA did not consult with the public in the revision of this form.
Payment or Gifts to Respondents
SSA does not provide payments or gifts to the respondents.
Assurances of Confidentiality
SSA protects and holds confidential the information it collects in accordance with 42 U.S.C. 1306, 20 CFR 401 and 402, 5 U.S.C. 552 (Freedom of Information Act), 5 U.S.C. 552a (Privacy Act of 1974), and OMB Circular No. A-130.
Justification for Sensitive Questions
The information collection does not contain any questions of a sensitive nature.
Estimates of Public Reporting Burden
Modality of Completion |
Number of Respondents |
Frequency of Response |
Average Burden Per Response (minutes) |
Estimated Total Annual Burden (hours) |
SSA-8202-BK |
10,307 |
1 |
21 |
3,607 |
MSSICS |
2,289,599 |
1 |
20 |
763,200 |
Totals |
2,299,906 |
|
|
766,807 |
The total burden is 766,807. This figure represents burden hours, and we did not calculate a separate cost burden.
Annual Cost to the Respondents (Other)
This collection does not impose a known cost burden to the respondents.
Annual Cost To Federal Government
The annual cost to the Federal Government is approximately $19,928,172. This estimate is a projection of costs for printing, postage, envelopes, maintenance to the MSSICS application, and SSA staff time.
Program Changes or Adjustments to the Information Collection Request
The significant increase in burden hours is due to obtaining actual, updated Management Information provided for the respondents who completed the information collection via MSSICS. The last IC contained incomplete estimates for MSSICS respondents, so we are correcting that now.
Plans for Publication Information Collection Results
SSA will not publish the results of the information collection.
Displaying the OMB Approval Expiration Date
OMB granted SSA an exemption from the requirement to print the OMB expiration date on its program forms. SSA produces millions of public-use forms with life cycles exceeding those of an OMB approval. Since SSA does not periodically revise and reprint its public-use forms (e.g., on an annual basis), OMB granted this exemption so SSA would not have to destroy stocks of otherwise useable forms with expired OMB approval dates, avoiding Government waste.
Exceptions to Certification Statement
SSA is not requesting an exception to the certification requirements at 5 CFR 1320.9 and related provisions at 5 CFR 1320.8(b)(3).
B. Collection of Information Employing Statistical Methods
SSA does not use statistical methods for this information collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | SUPPORTING STATEMENT FOR FORM |
| Author | 054310 |
| File Modified | 0000-00-00 |
| File Created | 2021-01-24 |