Supporting Statement for SSA-546
Workers' Compensation/Public Disability Benefit Questionnaire
20 CFR 404.408
OMB No. 0960-0247
Justification
Introduction/Authoring Laws and Regulations
Section 224 of the Social Security Act (Act) provides for the reduction of disability insurance benefits (DIB) if the combination of DIB and any workers' compensation (WC) or certain federal, state, or local public disability benefits (PDB) exceeds 80 percent of the worker's average current earnings. Section 20 CFR 404.408 of the Code of Federal Regulations authorizes SSA to reduce an individual’s Social Security claim when they are potentially eligible for WC and PDB.
Description of Collection
SSA field office staff conduct face-to-face interviews with applicants using the electronic SSA-546 WC/PDB screens in SSA’s Modernized Claims System (MCS) to determine if the worker’s receipt of WC or PDB payments will cause a reduction of DIB. The Respondents are applicants for Title II DIB.
Use of Information Technology to Collect the Information
In accordance with the agency’s Government Paperwork Elimination Act plan, SSA created an electronic version of Form SSA-546 in SSA’s Intranet system, MCS. Based on our data, we estimate 100% of the respondents use the electronic version through a personal interview with field office employees. The field office employees enter the information directly into the appropriate MCS screens. On the rare occasions that the MCS system is unavailable, the field office employee is able to access Interactive Computation Facility (ICF) common screens to input the information in SSA’s Intranet system, therefore alleviating the need for the paper or fillable PDF versions of Form SSA-546.
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.
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 the electronic Form SSA-546, it could result in an inaccurate computation of Social Security disability insurance benefits. Because we collect the information on an as needed basis, we cannot collect it less frequently. There are no technical or legal obstacles that prevent 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 July 13, 2017 at 82 FR 32431, and we received no public comments. SSA published the second Notice on September 19, 2017 at 82 FR 43804. If we receive comments in response to the 30-day Notice, we will forward them to OMB. We did not consult with the public in the revision of this form.
Payment or Gifts to Respondents
SSA provides no 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
Per our current management information (MI) data, approximately 248,000 respondents use the SSA-546 MCS screens annually:
Modality of Completion |
Number of Responses |
Frequency of Response |
Average Burden Per Response (minutes) |
Total Estimated Annual Burden (hours) |
MCS |
248,000 |
1 |
15 |
62,000 |
As per our current MI data, the total burden for this ICR is 62,000 hours. 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 on the respondents.
Annual Cost To Federal Government
The annual cost to the Federal Government is approximately $1,284,640. This estimate accounts for costs from the following areas: (1) SSA employee (e.g., field office, 800 number, DDS staff) information collection and processing time; and (2) systems development, updating, and maintenance costs.
Program Changes or Adjustments to the Information Collection Request
There are no program changes to the public reporting burden.
Plans for Publication Information Collection Results
SSA will not publish the results of the information collection.
Displaying the OMB Approval Expiration Date
SSA is not requesting an exception to the requirement to display an expiration date.
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).
Collection of Information Employing Statistical Methods
SSA does not use statistical methods for this information collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Sue Shinsky |
| File Modified | 0000-00-00 |
| File Created | 2021-01-22 |