A. Justification
Introduction/Authoring Laws and Regulations
The Social Security Administration (SSA) appoints representative payees on behalf of beneficiaries if we determine the beneficiaries should not receive their own benefits because they are incapable of managing those benefits. 20 CFR 404.2015 and 416.615 of the Code of Federal Regulations require medical evidence to determine if a beneficiary is capable of managing or directing the management of benefits payments. Sections 205, 807, and 1631(a) of the Social Security Act (Act) specifically state SSA has the authority to appoint a representative payee on behalf of a beneficiary. SSA is responsible for finding and appointing the best-qualified payee who is available and willing to serve.
Description of Collection
SSA appoints a representative payee in cases where we determine beneficiaries are not capable of managing their own benefits. In those instances, we require medical evidence to determine the beneficiaries’ capability of managing or directing their benefit payments. SSA collects medical evidence on Form SSA‑787 to: (1) determine beneficiaries’ capability or inability to handle their own benefits; and (2) assist in determining the beneficiaries’ need for a representative payee. The respondents are the beneficiary’s physicians or medical officers of the institution in which the beneficiary resides.
Use of Information Technology to Collect the Information
This form is available as a print-only PDF on SSA’s website. SSA did not create an electronic version of Form SSA-787 under the agency’s Government Paperwork Elimination Act, because we pre-fill the form with information specific to the beneficiary before sending it. Since we need to generate these forms with beneficiary-specific information each time we use it, we cannot make it available electronically for the medical professionals.
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
This collection does not significantly 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-787, the agency could not collect the necessary medical evidence for use in determining if beneficiaries are capable of managing their funds with or without a representative payee. Because we collect this information on an as needed basis, 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.
Solicitation of Public Comment and Other Consultations with the Public
The 60-day advance Federal Register Notice published on July 10, 2018, at
83 FR 31987, 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 contains some questions that may lead to the disclosure of sensitive information since we may include the beneficiary's medical history in the collection. However, this information is necessary to determine if a beneficiary can receive benefits directly.
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-787 |
131,556 |
1 |
20 |
43,852 |
The total burden for this ICR is 43,852 hours. We based these figures on current management information data. This figure represents burden hours, and we did not calculate a separate cost burden.
13. Annual Cost to the Respondents (Other)
This collection does not impose a known cost burden on the respondents.
Annual Cost to the Federal Government
The annual cost to the Federal Government is approximately $184,800. This estimate accounts for costs from the following areas: (1) designing, printing, and distributing the form; and (2) SSA employee (e.g., field office, 800 number, DDS staff) information collection and processing time.
15. Program Changes or Adjustments to the Information Collection Request
When we last cleared this IC in 2015, the burden was 20,000 hours. However, we are currently reporting a burden of 43,852 hours. This change stems from an increase in the number of respondents from 120,000 to 131,556. In addition, we raised the completion time from 10 to 20 minutes. We increased the number of questions to improve the quality of information collected through this instrument (see addendum for more information).
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.
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 |
| File Title | Title of Information Collection and Form Number(s) |
| Author | Naomi |
| File Modified | 0000-00-00 |
| File Created | 2021-01-20 |