Supporting Statement for
Certification of Prisoner Identity Information
20 CFR 422.107
OMB No. 0960-0688
Justification
Introduction/Authorizing Laws and Regulations
Section 205(c)(2)(B) of the Social Security Act (Act) authorizes the assignment of Social Security numbers (SSN). The Social Security Administration (SSA) regulations at 20 CFR 422.107 of the Code of Federal Regulations specify an applicant must provide documentary evidence of identity when applying for an original or replacement Social Security card. Section 702 of the Act authorizes SSA to establish rules and regulations appropriate to carry out the functions of the administration.
Description of Collection
SSA collects information needed to assign an SSN, as well as issue an original, duplicate, or corrected SSN card. SSA uses the SSN to keep an accurate record of an individual’s earnings, and to accurately pay benefits under the Social Security program. Inmates of Federal, State, or local prisons, either public or private (third party contracted by local, State, or Federal Government agency), may need an SSN card as verification of their SSN for school or work programs, or as proof of employment eligibility upon release from prison. Before SSA can issue a replacement Social Security card, applicants must show SSA proof of their identity. People who are in prison for an extended period typically do not have current identity documents. Therefore, under formal written agreement with the correctional institution, SSA allows prison officials to verify the identity of certain incarcerated U.S. citizens who need replacement Social Security cards. Inmates complete and sign Form SS-5 (OMB No. 0960-0066), Application for a Social Security Card, and a prison official certifies the inmate's identity using information found in the inmate's official file. Information prison officials provide comes from the official prison files sent on correctional facility letterhead; there is no standardized form used for this information collection. SSA uses this information to establish the applicant’s identity in the replacement Social Security card process. The respondents are prison officials who certify the identity of prisoners applying for replacement Social Security cards.
Use of Information Technology to Collect the Information
SSA did not create an electronic version of the Certification of Prisoner Identity Information under the agency’s Government Paperwork Elimination Act (GPEA) plan because only 1,000 respondents complete the collection annually. This is less than the GPEA cut-off of 50,000.
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 collect the information, we would have no means to prove the identity of the applicant who is requesting a replacement SSN card. This could create a hardship for prisoners who do not typically have the current documents we require as proof of identity. Because we request this 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 June 8, 2018, at
83 FR 26732, and we received no public comments. The 30-day FRN published on October 3, 2018 at 83 FR 49965. 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 Responses |
Frequency of Response |
Number of responses |
Average Burden per Response (minutes) |
Estimated Total Annual Burden (hours) |
Verification of Prisoner Identity Statements |
1,000 |
200 |
200,000 |
3 |
10,000 |
The total burden for this ICR is 10,000 hours. We based these figures on current management information data. 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 $157,500. This estimate accounts for costs from the following area: SSA employee (e.g., field office, 800 number, DDS staff) information collection and processing time.
Program Changes or Adjustments to the Information Collection Request
There are no changes in 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).
B. 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 | Karen Cool |
| File Modified | 0000-00-00 |
| File Created | 2021-01-21 |