Supporting Statement Part A

SUPPORTING STATEMENT – PART A

DD Form 2293, “Application for Former Spouse Payments from Retired Pay”, 0730-0008

A.  JUSTIFICATION

1.  Need for the Information Collection

In accordance with Title 10 U.S.C., Section 1408, “Payment of Retired or Retainer Pay in Compliance with Court Orders,” state courts may divide military pay as property or order alimony and child support payments from that retired pay. The former spouse may apply to the Defense Finance and Accounting Service (DFAS) for direct payments of these monies by using the DD Form 2293. The information collection is needed to provide DFAS the basic data needed to process the request.

2.  Use of the Information

The respondents to this information collection are spouses or former spouses (herein referred to as applicant) of military members who access the form through the DoD forms website. The applicant submits through U.S. Mail Service or by fax a DD Form 2293, “Application for Former Spouse Payments from Retired Pay,” to DFAS and a copy of a court order that requires the division of a member’s military retired pay, or orders the member to make monthly payment of either child support or alimony. The information from the DD Form 2293 is used by DFAS to process the applicant’s request as authorized under Title 10 U.S.C. Section 1408.

The information is required to properly identify the former spouse applicant and identify the service member, whose retired pay is to be deducted, by name, address and social security number. The DD Form 2293 was devised to standardize applications for payment under the Act. Information on the form is also used to determine the applicant’s current status and contains the statutory required certifications the applicant/former spouse must make when applying for payments.

After the application is reviewed for sufficiency, the application and the military member are advised whether the application will be honored or rejected, any further documentation needed, and if applicable, notifies when payments to the former spouse will be implemented by mail. The mail templates used to notify applicant if application is being honored or rejected will be submitted as part of the collection package.

The form is available on the DoD Forms website (http://www.dtic.mil/whs/directives/forms/index.htm). The Privacy Act Statement and Agency Disclosure Notice are available to the respondent on the form.

3.  Use of Information Technology

0% of responses are collected electronically. The use of information technology has been considered, but is not appropriate for purposes of this collection at this time. In addition to submitting the DD Form 2293, an applicant is required by law to submit supporting documentation such as state court orders and marriage certificates that would not be accessible electronically.

4.  Non-duplication

Investigation resulted in no findings of duplication of reporting or records. The DD Form 2293 is used by DFAS which is the only agency charged with enforcement of this law. No similar information or verification procedures currently exist that can be used for this information collection.

5.  Burden on Small Business

This collection of information does not have significant impact on small businesses or other entities.

6.  Less Frequent Collection

The form is only collected once, when the applicant initially applies.

7.  Paperwork Reduction Act Guidelines

There are no special circumstances that would require this collection to be conducted in a manner inconsistent with 5 CFR 1320.5(d)(2).

8.  Consultation and Public Comments

Part A: PUBLIC NOTICE

A 60-Day Federal Register notice for this collection of information was published on April 15, 2016 on 81 FR 22239. No public comments were received.

A 30-Day Federal Register Notice for the collection published on Tuesday, February 21, 2017. The 30-Day FRN citation is 82 FRN 11192.

Part B: CONSULTATION

No additional consultation apart from soliciting public comments through the 60-day Federal Register Notice was conducted for this submission.

9.  Gifts or Payment

No payment or gift will be provided to respondents, other than payments paid as entitlements resulting from certification requirements.

10.  Confidentiality

Respondents are assured confidentiality, to the extent provided by law, via the Privacy Act Statement on the form. DFAS certifies that the information collected is maintained in accordance with the Privacy Act of 1974, and OMB Circular A-130, Management of Federal Information Resources.

The SORN covered by this system is:

T7347b, Defense Military Retiree and Annuity Pay System at: http://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570196/t7347b/

The PIA covered by this system is:

Defense Retired and Annuitant Pay System at: http://www.dfas.mil/dam/jcr:4c735dde-6b84-4f24-8153-bd83643c98b1/PIA_DRAS_2010.pdf

Records Retention: Disposition for Retired and Annuitant Pay records range from 30 days to 56 years. The administrative records such as, change of address, electronic messages or tax records, that are not pay affecting, are destroyed using retention of 30 days or less than 6 years. All pay affecting documents such as retirement document, account computation information or entitlement/eligibility records are retained for six years or more and the pay histories are retained for 56 years. Records are destroyed by tearing, shredding, pulping, macerating, burning, or degaussing the electronic storage media.

11.  Sensitive Questions

Disclosure of the Social Security Number (SSN) is used for positive identification of the individual requesting payments. A justification memo is being submitted as part of the OMB submission package.

12.  Respondent Burden, and its Labor Costs

a.  Estimation of Respondent Burden

Estimation of Respondent Burden Hours
	Number of Respondents	Number of Responses per Respondent	Number of Total Annual Responses	Response Time (Amount of time needed to complete the collection instrument)	Respondent Burden Hours (Total Annual Responses multiplied by Response Time) Please compute these into hours)
DD 2293	25,000	1	25,000	30 minutes	12,500 hours
Total	25,000	1	25,000	30 minutes	12,500 hours

b.  Labor Cost of Respondent Burden

Labor Cost of Respondent Burden
	Number of Responses	Response Time per Response	Respondent Hourly Wage (Federal Minimum Wage *)	Labor Burden per Response (Response Time multiplied by Respondent Hourly Wage)	Total Labor Burden (Number of Responses multiplied by Response Time multiplied by Respondent Hourly Wage)
DD 2293	25,000	30 minutes	$7.25	$3.625	$90,625
Total	25,000	30 minutes	$7.25	$3.625	$90,625

* Department of Labor (https://www.dol.gov/general/topic/wages/minimumwage) cited on August 31, 2016.

13.  Respondent Costs Other Than Burden Hour Costs

Total operational costs are $25,000 for postage ($1 average cost to return form with supporting documents.)

14.  Cost to the Federal Government

Labor Cost to the Federal Government
	Paralegal Staff GS-9, Step 5 *	Team Attorney GS-13, Step 5 *	Total
Number of Responses	25,000	2000 **
Processing Time Per Response (in hours)	.5 hours	.5 hours
Hourly Wage of Worker(s) Processing Responses	$23.25	$40.10	$23.25/$40.10
Cost to Process Each Response (Processing Time Per Response multiplied by Hourly Wage of Worker(s) Processing Responses)	$11.63	$20.05	$11.63/20.05
Total Cost to Process Responses (Cost to Process Each Response multiplied by Number of Responses	$290,750	$40,100	$330,850

*2016 General Schedule (GS) Basic Locality Pay Tables (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2016/general-schedule/)

** DFAS Attorneys only review court orders for more difficult cases. Therefore 2,000 is the average of 25,000 total cases.

Operational and Maintenance Costs *
Equipment	Printing	Postage	Software Purchases	Licensing Costs	Other	Total
	$2500	$12,250			$1250	$16,000

*Costs: Printing (25,000 x $.10); Postage (25,000 x $.49); and Envelopes (25,000 x .05)

Total Cost to the Federal Government
Operational and Maintenance Costs	Labor Cost to the Federal Government	Total Cost (O&M Costs + Labor Cost)
$16,000	$330,850	$346,850

15.  Reasons for Change in Burden

This is a reinstatement with change of previously approved collection for which approval has expired. Total burden hours have increased from 6,722 to 12,500 based on increased time to complete form and gather supporting documents. Time to gather supporting documentation was not previously taken into account. The estimated time of completion was increased from 15 minutes to 30 minutes

16.  Publication of Results

The information collected will not be published or tabulated.

17.  Non-Display of OMB Expiration Date

Approval is not sought to avoid display of the expiration date for OMB approval of the information collection.

18.  Exceptions to "Certification for Paperwork Reduction Submissions"

There are no exceptions to the certification statement.

Version Effective August 5, 2016