Supporting Statement - 0016

Supporting Statement for Statement

Regarding Date of Birth and Citizenship

Form SSA-702

OMB No. 0960-0016

A. Justification

1. Introduction/Authoring Laws and Regulations

Section 205(a) of the Social Security Act (Act) gives the Commissioner of the Social Security Administration (SSA) the authority to make rules and regulations, and to establish procedures for collecting evidence from individuals applying for Social Security benefits. As provided in 20 CFR 404.716 of the Code of Federal Regulations, in the absence of preferred evidence of a claimant’s date of birth or citizenship, SSA may ask claimants to provide other convincing evidence. Other evidence we consider as convincing: family bibles; school and census records; and immigration or naturalization records. SSA may also use statements from other individuals who have knowledge of the claimant’s birth as evidence. Such statements, in combination with other convincing evidence, allow us to determine a claimant’s right to benefits. Section 401 of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 restricts the eligibility of aliens to receive public Federal benefits. To receive Title II, Old Age and Survivors Disability Insurance benefits, applicants must either be United States citizens or lawfully present in the United States. Section 1614(a)(1)(B) of the Act sets forth residency and citizenship requirements for Title XVI, Supplemental Security Income (SSI) eligibility. SSA will consider a statement by a person who has knowledge of the applicant’s birth in the United States, along with other evidence in file, in determining U.S. citizenship.

2. Description of Collection

When individuals apply for Social Security benefits and cannot provide preferred methods of proving age or citizenship, SSA uses Form SSA-702 to establish these facts. Specifically, SSA uses the SSA-702 to establish age as a factor of entitlement to Social Security benefits, or U.S. citizenship as a payment factor. Respondents are individuals with knowledge about the date of birth or citizenship of applicants filing for one or more Social Security benefits who need to establish age or citizenship.

3. Use of Information Technology to Collect the Information

Form SSA-702 is available as a portable document format (PDF) form. The form, which uses a third-party statement to help establish a claimant’s age as a factor of entitlement or U.S. citizenship as a payment factor, does not meet SSA’s policy requirements for alternative signature methods (e.g., electronic signature). In addition, SSA did not create an electronic version of form SSA-702 under the agency’s Government Paperwork Elimination Act (GPEA) plan because only 1,200 respondents complete the form. This is less than the GPEA cut-off of 50,000.

4. Why We Cannot Use Duplicate Information

The nature of the information we collect and the manner in which we collect it preclude duplication. SSA does not use another collection instrument to obtain similar data.

5. Minimizing Burden on Small Respondents

This collection does not affect small businesses or other small entities.

6. Consequence of Not Collecting Information or Collecting it Less Frequently If we did not use Form SSA-702, applicants would not receive their benefits, since proof of age or citizenship is necessary to receive Social Security benefits. Because we only collect the information once, we cannot collect it less frequently.

There are no technical or legal obstacles to burden reduction.

7. 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.

8. Solicitation of Public Comment and Other Consultations with the Public

The 60-day advance Federal Register Notice published on May 23, 2017, at

82 FR 23695, and we received no public comments. The 30-day FRN published on August 16, 2017 at 82 FR 38982. If we receive any comments in response to this Notice, we will forward them to OMB. We did not consult with members of the public in the maintenance of this form.

9. Payment or Gifts to Respondents

SSA does not provide payments or gifts to the respondents.

10. Assurances of Confidentiality

SSA protects and holds confidential the information we collect 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.

11. Justification for Sensitive Questions

The information collection does not contain any questions of a sensitive nature.

12. 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-7157	1,200	1	10	200

We based these figures on our current management information data. The total burden for this ICR is 200 hours. This figure represents burden hours, and we did not calculate a separate cost burden.

13. Annual Cost to the Respondents

This collection does not impose a known cost burden to the respondents.

14. Annual Cost to the Federal Government

The annual cost to the Federal Government is approximately $1,848. This estimate accounts for costs from the following areas: (1) designing, printing, and distributing the form; and (2) SSA employee information collection and processing time.

15. Program Changes or Adjustments to the Information Collection Request There are no changes to the public reporting burden.

16. Plans for Publication Information Collection Results

SSA will not publish the results of the information collection.

17. 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.

18. 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. Collections of Information Employing Statistical Methods

SSA does not use statistical methods for this information collection.