Supporting Statement for Form SSA-1694
Request for Business Entity Taxpayer Information
OMB No. 0960-0731
Justification
Introduction/Authorizing Laws and Regulations
Per Sections 206(a) and 1631(d) of the Social Security Act, the Social Security Administration (SSA) collects information to facilitate direct payment of authorized fees to an attorney, or other person, who represents claimants for benefits before SSA. SSA uses the Form SSA-1694, Request for Business Entity Taxpayer Information, to meet any requirement to issue a Form 1099-MISC, as per the Internal Revenue Code, 26 USC 6041 and 26 USC 6045(f) of the United States Code.
Description of Collection
SSA requires Law firms or other business entities to complete Form SSA-1694 if they wish to serve as appointed representatives and receive direct payment of fees from SSA. SSA uses the information we receive to issue a Form 1099-MISC. SSA also uses the information to allow business entities to designate individuals to serve as entity administrators authorized to perform certain administrative duties on their behalf, such as providing bank account information; maintaining entity information; and updating individual affiliations. Respondents are law firms or other business entities, which have attorneys, or other qualified individuals, as partners or employees who represent claimants before SSA.
Use of Information Technology to Collect the Information
In accordance with the agency’s Government Paperwork Elimination Act plan, SSA created an Internet version of Form SSA-1694. Based on our data, we estimate approximately 25% of respondents under this OMB number use the electronic version.
Why We Cannot Use Duplicate Information
The nature of the information we collect and the manner in which we collect it precludes duplication. SSA does not use another collection instrument to obtain similar data.
Minimizing Burden on Small Respondents
Law firms or other business entities need only complete the SSA-1694 when they initially register or need to makes changes. The time requirement for their response is minimal, accomplished via an Internet process. In this way, SSA minimized the burden on small businesses or other small entities.
Consequence of Not Collecting Information or Collecting it Less Frequently
If SSA did not collect this information, we would be unable to issue a
Form 1099-MISC. Because we collect the information on an as needed basis, we cannot collect it less frequently. There are no technical or legal obstacles to 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 May 9, 2018, at
83 FR 21328, and we received no public comments. The 30-day FRN published on July 26, 2018 at 83 FR 35526. If we receive any comments in response to this Notice, we will forward them to OMB.
Payment or Gifts to Respondents
SSA does not provide 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
Modality of Completion |
Number of Respondents |
Frequency of Response |
Average Burden Per Response (minutes) |
Estimated Total Annual Burden (hours) |
SSA-1694 paper form |
750 |
1 |
10 |
125 |
BSO Submission |
150 |
1 |
10 |
25 |
Totals |
900 |
|
|
150 |
The total burden for this ICR is 150 hours. We based these figures on current management information data. 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 $10,000. This estimate accounts for costs from the following areas: (1) designing, printing, and distributing the form; (2) SSA employee (e.g., field office, 800 number, DDS staff) information collection and processing time; and (3) systems development, updating, and maintenance costs.
Program Changes or Adjustments to the Information Collection Request
When we last cleared this collection in 2015, the burden was an estimated 334 hours. However, we are currently reporting an estimated burden of 150 hours. This change stems from a decrease in the estimated total number of respondents from 2000 to 900. Data obtained from SSA systems showed a decrease in the number of respondents applying to serve as appointed representative, which resulted in the burden change. There is no change to the burden time per response. Although the number of responses changed, SSA did not take any actions to cause this change.
Plans for Publication Information Collection Results
SSA will not publish the results of the information collection.
Displaying the OMB Approval Expiration Date
Paper version: OMB exempted SSA from the requirement to print the OMB approval expiration date on its forms. SSA produces millions of public-use forms, many of which have a life cycle longer than that of an OMB approval. 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 discontinue using otherwise usable editions of forms with outdated expiration dates. In addition, SSA avoids Government waste because we will not have to destroy and reprint stocks of forms.
Internet version on BSO: SSA is not requesting an exemption to the requirement to display the OMB approval expiration date for the Internet version of the SSA-1694.
Exception 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).
Collections of Information Employing Statistical Methods
SSA does not use statistical methods for this information collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Rauser, Kyle |
| File Modified | 0000-00-00 |
| File Created | 2021-01-20 |