RI25-049_OMB_Supporting_Stmt_2017_12_11_ccc

RI25-049_OMB_Supporting_Stmt_2017_12_11_ccc.docx

Verification of Full-Time School Attendance

OMB: 3206-0215

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OMB SUPPORTING STATEMENT


RI 25-49 – Verification of Full-Time School Attendance


  1. Justification


  1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.


Title 5, U. S. Code, Chapter 83, Section 8341, and Chapter 84, Section 8441, provide for survivor benefits for children of deceased Federal employees and annuitants, including adult students aged 18 to 22 who are unmarried and are full-time students in recognized schools. No more than a five-month break between school terms is permitted without loss of benefits for the period the child was not in school. RI 25-49, Verification of Full-Time School Attendance, which must be completed by the school, is used to verify that the student is or was attending school full-time.


  1. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.


RI 25-49 requires the payee to obtain school certification of the student’s enrollment. This form will be mailed to the payee during the spring term. When responses are received, the data will be used to determine whether the student should continue to receive annuity benefits, as well as whether the student has already received annuity to which he is not entitled. We have made editorial changes and updated the Privacy Act Statement. The Public Burden Statement meets the requirement of 5 CFR 1320.8(b)(3).


  1. 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.


Improved information technology will do little to reduce the burden. The information collected cannot be obtained from other sources. However, this form is available in a PDF fillable format on our website and meets our GPEA requirements.


  1. 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.


The forms are filed individually. Similar information is not available.


  1.  If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize.

This information collection request has no impact on small businesses and organizations.


  1. Describe the consequence to Federal/DHS program or policy activities if the collection of information is not conducted, or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.


The collection of this information is performed as needed to determine if the student has maintained an eligible status for survivor benefits. If this information is not collected annually OPM would be unable to determine the continuing eligibility or ineligibility of the student for survivor benefits. This could result in OPM making erroneous payments to those who no longer qualify for survivor benefits as a student. This information collection is consistent with the guidelines in 5 CFR 1320.6, except for 1320.6(b). An immediate response is required within 30 days to prevent payments to survivor annuitants who are no longer eligible.


  1. Explain any special circumstances that would cause an information collection to be conducted in a manner: On May 5, 2017, a 60 Day Federal Register Notice was published at 82 FR 21277.


There were no comments received.


  1. Federal Register Notice: Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice soliciting comments on the information collection prior to submission to OMB


Federal Register Notice: Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice soliciting comments on the information collection prior to submission to OMB.


  1. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.


No gifts or payments of any kind have been provided to any individuals who are connected to this collection.


  1. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.


This information collection is protected by the Privacy Act of 1974 and OPM regulations (5 CFR 831.106). The routine uses of disclosure appear in the Federal Register for OPM/Central-1 (73 FR 15013, et seq., March 20, 2008, effective April 21, 2008).



  1. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the 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.


This information collection does not include questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.


12. Provide estimates of the hour burden of the collection of information. The statement should:


a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desired. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

c. Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.


Approximately 10,000 forms will be processed annually. The form requires approximately 60 minutes for completion. A burden of 10,000 hours is estimated.

Form Name

Form Number

No. of Respondents

No. of Responses per Respondent

Average Burden per Response (in hours)

Total Annual Burden (in hours)

Average Hourly Wage Rate

Total Annual Respondent Cost

Verification of Full-Time School Attendance

RI 25-49

10,000

1

1 hour

10,000

$0

$0

There is no cost to the respondents.

The annualized cost to the Federal government is $26,200. This cost includes employee salary hours devoted to the program, forms and overhead.

13. Provide an estimate of the total annual cost burden to respondents or record-keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14.)


The cost estimate should be split into two components: (1) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.


If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection as appropriate.


Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information to keep records for the government, or (4) as part of customary and usual business or private practices.

There is no change in the respondent burden.


15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I. Changes in hour burden, i.e., program changes or adjustments made to annual reporting and recordkeeping hour and cost burden. A program change is the result of deliberate Federal government action. All new collections and any subsequent revisions of existing collections (e.g., the addition or deletion of questions) are recorded as program changes. An adjustment is a change that is not the result of a deliberate Federal government action. These changes that result from new estimates or actions not controllable by the Federal government are recorded as adjustments.


N/A


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.


No information collected from the form will be published.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain reasons that display would be inappropriate.

It is not cost-effective to reprint the whole supply of forms to change the OMB clearance expiration date. Therefore, we seek approval not to display the OMB clearance expiration date on the form.


18. Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.


There are no exceptions to the certification statement.


File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleOMB SUPPORTING STATEMENT
AuthorMEMOORE
File Modified0000-00-00
File Created2021-01-21

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