3220-0156

OMB No. 3220-0156

Justification

Employer’s Deemed Service Month Questionnaire

RRB Form GL-99

1. Circumstances of information collection – Under Section 3(h) of the Railroad Retirement Act (RRA), service performed for a covered railroad employer or as an employee representative is creditable toward an annuity under the RRA. Such annuities are based on an employee’s earnings credits and months of service. Section 3(i) of the Act, as amended by the Railroad Retirement Solvency Act of 1983 (P.L. 98-76) provides that after 1984, the Railroad Retirement Board (RRB) under certain circumstances, may deem additional months of service for an employee who has worked less than 12 months in a calendar year and who also satisfies certain eligibility requirements, including the existence of an employment relation between the employee and his or her employer.

The procedures pertaining to the deeming of additional months of service are contained in the RRB’s regulations 20 CFR 210, Creditable Railroad Service.

2. Purposes of collecting/consequences of not collecting the information - The RRB uses Form GL-99, Employer’s Deemed Service Months Questionnaire, to obtain needed information from railroad employers to determine whether an employee had an employment relationship with a covered railroad employer or was an employee representative during a month not worked.

Form GL-99 is generated and released by the RRB when an employer reports less than 12 months of service, additional employment relationship information is needed, and:

• there are six or more potential deemed months; or

• the employee has more than one employer in the calendar year; or

• the employee has no service months reported in the following calendar year.

The Railroad Retirement Board proposes the following changes to Form GL-99:

• Reword Employer Instructions section to show that Form BA-4 should be completed and submitted separately from the GL-99. The BA-4 is now completed electronically and cannot be submitted with the GL-99.

• Minor non-burden impacting editorial changes.

To our knowledge no other agency uses a form similar to GL-99.

3. Planned use of improved information technology or technical/legal impediments to further burden reduction – Budgetary and technology constraints prevent us from making further technological improvements at this time.

4. Efforts to identify duplication – This information collection does not duplicate any other information collection.

5. Small business respondents – N.A.

6. Consequences of less frequent collection – Not applicable since the deeming actions are part of the annual update of railroad employees’ service and compensation records.

7. Special Circumstances – None.

8. Public comments/consultations outside the agency – In accordance with 5 CFR 1320.8(d), comments were invited from the public regarding this information collection. The notice to the public was published on page 91391 of the December 29, 2015, Federal Register. No comments or requests for additional information were received from the public.

9. Payments or Gifts to respondents – N.A.

10. Confidentiality – Privacy Act System of Records, RRB-5, Master File of Railroad Employees’ Creditable Compensation. In accordance with OMB Circular M-03-22, a Privacy Impact Assessment for this information collection was completed and can be found at http://www.rrb.gov/pdf/PIA/PIA-BPO.pdf.

11. Sensitive questions – N.A.

12. Estimate of respondent burden – The current and proposed estimated burdens for this collection are as follows:

Current Burden

Form Number	Annual Responses	Time (Minutes)	Burden (Hours)
GL-99	4,000	2	133

Proposed Burden

Form Number	Annual Responses	Time (Minutes)	Burden (Hours)
GL-99	2,000	2	67

Responses Hours

Total burden change -2,000 -66

Adjustment -2,000 -66

13. Estimate of annual cost to respondents or record keepers – N.A

13. Estimate of cost to Federal Government – N.A.

13. Explanation for changes in burden –The burden has decreased by 2,000, from 4,000 to 2,000 and the burden hours have decreased by 66, from 133 to 67. This decrease is due to the RRB’s advanced system tracking capability that allows for an estimate of actual responses received in a given year.

14. Time schedule for data collection and publication – The results of this collection will not be published.

13. Request to not display OMB expiration date – The GL-99 is seldom revised. Given the costs associated with redrafting, reprinting, and distributing the form in order to keep the appropriate OMB expiration date in place, the RRB requests the authority to not display the expiration date on the form.

13. Exceptions to the Certification Statement – None

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