SUPPORTING STATEMENT FOR
PRINCIPLES OF EXCELLENCE COMPLAINT SYSTEM INTAKE
(OMB Control Number 2900–0797)
A. Justification.
1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.
Executive Order 13607, Establishing Principles of Excellence for Educational Institutions Serving Service Members, Veterans, Spouses, and Other Family Members, requires the establishment of a centralized complaint system for students receiving Federal military and veteran educational benefits. The purpose of the complaint system is to provide a standardized method to submit a complaint against an educational institution alleging fraudulent and unduly aggressive recruiting techniques, misrepresentation, payment of incentive compensation, failure to meet state authorization requirements, or failure to adhere to the Principles of Excellence as outlined in the Executive Order.
The VA’s Principles of Excellence Complaint System (PoECS) leverages DoD’s complaint system to intake and manage complaints utilizing their existing contract and systems architecture with each agency only having access to their data. The VA’s complaint system utilizes the same software platform as the DoD system. The complainants access the complaint system through the GI Bill website and eBenefits portal. Veterans, family members, or other members of the public are able to open links at either VA website location and enter the requested information. Complainants are offered the opportunity to review the information in their complaint prior to clicking on the submit button. Once a complaint is submitted, the complainant receives an email verifying that the complaint was received. At this point, the complaint is stored in the complaint system and is available to select VA employees for review. VA reviews the complaint and on behalf of the complainant shares the complaint with the institution which is subject of the complaint. VA requests the institution to formally respond to the complaint within 90 days. If an institution fails to respond within 90 days, VA will contact the institution and request a status update. Once VA receives a response from the institution, VA will forward the response to the complainant. At this point, VA will close the case. Valid complaints received are transmitted to the central repository at FTC Consumer Sentinel. The information in the central repository is the same information provided by the complainant. Authorized law enforcement officials who have been granted access to the FTC Consumer Sentinel database have access to view all complaints.
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 respondent submits a complaint about an educational institution online through either the GI Bill website or the eBenefit portal. The information gathered can only be obtained from the individual respondents. Valid complaints will be accepted from third parties.
The intake process for both DoD’s and VA’s complaint system share common data elements, but have some modifications specific to each agencies complaint handling process:
VA:
Institution/Employer: There are over 36,000 educational institutions that are approved for VA education benefits, while DoD has less than 7000.
Anonymous Complaints: PoECS allows for a user to file anonymous complaints. Based on working group discussions with CFPB and FTC, VA believes that allowing anonymous complaints will garner more ground truth on what is happening with veterans using their education benefits at different schools.
Required fields: As a result of allowing anonymous complaints, many of the fields that DoD requires a user to fill will not be required by VA
DoD:
Education Centers: DoD requires education center information that does not fall within the purview of VA.
Military Branch/Rank: DoD requires a user to select a service affiliation and pay grade.
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.
The PoECS leverages information technology to receive the complaint, case management for processing and referrals as necessary. Complaint Case Managers coordinate with educational institutions to reach a resolution for the individual. The complaints are uploaded to a central repository, FTC’s Consumer Sentinel Network. All complaints will be accessible by state and federal agencies and law enforcement via the central repository. In addition, VA compiles a profile at the institutional level the types of complaints received for other tools that provide streamlined comparisons of institutions. VA uses this profile information to conduct regular and risk-based compliance surveys for educational institutions.
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.
There is no known Department or agency which maintains the necessary information, nor is it available from other sources within our Department.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
The information collection involves individuals (Veterans, Servicemembers and their family members). The information may be collected directly from individuals or submitted on behalf of someone else. The information may also be submitted anonymously. There is no impact on education institutions or small businesses for the information collection.
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.
If this information is not collected, VA would not have a uniform manner for individuals to submit complaints for possible fraudulent, unduly aggressive recruiting, misrepresentation, or adherence with the Principles of Excellence against educational institutions. There are no technical or legal obstacles to reducing the burden of this information collection.
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 collection of this information does not require any special circumstances.
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 May 23, 2016,
Volume 81, Number 99, pages 32387-32388. No comments were received.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
VA does not provide any payment or gifts to respondents.
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.
Our assurance of privacy is covered by 38 U.S.C. 5701 and our System of Records, Principles of Excellence Centralized Complaint System – VA (170VA22).
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
None of the information collected is considered to be of a sensitive nature.
12. Estimate of the hour burden of the collection of information:
Estimate of Information Collection Burden:
Number of Respondents: 1,500
Frequency of Response: On occasion. (1,500 X 15 / 60 = 375 annual burden hours).
Annual Burden Hours: 375
Estimated Completion Time: 15 minutes
The respondent population is composed of Veterans requesting educational assistance to supplement tuition assistance. 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. According to the latest available BLS Current Population Survey (CPS) (http://www.bls.gov/cps/cpsaat39.htm) (dated February 10, 2015). Accordingly, the median weekly earnings of full-time wage and salary workers are $809.20. Assuming a forty (40) hour work week, the median hourly wage is $20.23. 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 $7,586 (1500 burden hours x $20.23 per hour).
13. Provide an estimate of the total annual cost burden to respondents or
recordkeepers 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.
The estimated cost to the Federal Government is $190,036 for the complaint system and case management activities for an estimated 1,500 complaints.
a. We estimate that it will take Complaint Case Managers 30 minutes for less complex routine complaints and 60 minutes for more complex egregious complaints. We estimate that 80% or 1,200 cases will be routine and 20% or 300 will be complex egregious. As such it will take an estimated 900 hours for case management activities handling complaints
b. Using the hourly rate for a GS13/5 in the Washington DC area of $50.04, 900 hours equates to $45,036. The General Schedule (GS) wage amount was determined using the OPM 2017 Locality Pay Areas for Washington-Baltimore-Arlington, DC-MD-VA-WV- and PA. Verification of this amount may be found in this link https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2017/DCB_h.pdf
c. In addition, the contract costs to leverage DoD’s complaint system is $145,000.
15. Explain the reason for any burden hour changes since the last submission.
This burden increase is due to an increase in the number of complaints.
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.
VA does not publish this information or make it available 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.
We are not seeking approval to omit the expiration date for OMB approval.
18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB 83-I.
This information collection complies with all requirements under 5 CFR 1320.8(b)(3).
B. Collection of Information Employing Statistical Methods.
This collection of information gathered by the Veterans Benefits Administration will not employ statistical methods.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 2021-01-23 |