2018 Draft Supporting Statement for Renewal (RTH-JJ)

OMB #2900-0358

VA Form 22-8873

Renewal Submission of IC - Supplemental Information for Change of Program or Reenrollment After Unsatisfactory Attendance, Conduct, or Progress

Justification

1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.

The Department of Veterans Affairs (VA) is authorized to pay education benefits to Veterans and other eligible persons pursuing approved programs of education under chapters 30, 32, 33, and 35 of title 38, U.S.C.; chapters 1606 and 1607 of title 10, U.S.C.; Section 903 of Public Law 96-342; and National Call to Service (NCS) (10 U.S.C., chapter 31, section 510). This information collection involves "change of program" and "unsatisfactory attendance, conduct, or progress" issues. 38 U.S.C. 3691 allows eligible persons to change their program of education and 38 U.S.C. 3474 addresses discontinuance for unsatisfactory conduct or progress.

2. Indicate how, by whom, and for what purposes the information is to be used; indicate actual use the agency has made of the information received from current collection.

Students use the form to change programs of education or to notify VA that they are making unsatisfactory progress in their programs of education.

VA uses the information provided from the current collection to ensure (1) that programs are suitable to a claimant's aptitudes, interests, and abilities and (2) that the cause of any past unsatisfactory attendance, progress, or conduct has been resolved. Without this information, VA could not determine further entitlement to education benefits.

3.  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.

Information technology is helping to reduce the burden.  The online electronic collection is made via the Vets.gov portal which utilizes computer algorithms that help guide the applicant to more thoroughly complete the application based on their responses to questions asked.  The implementation of Vets.gov in 2017 helps to reduce the burden on the veteran while enabling the Veteran to submit the application directly to the Regional Processing Office (RPO) with jurisdiction over the claim. As a result, the potential for errors are reduced and the application process is expedited.

4. 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.

Program reviews were conducted to identify potential areas of duplication and none were found. There is no known Department or agency which maintains this necessary information, nor is it available from other sources within our Department.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The collection of information does not pertain to or impact small businesses or entities.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently as well as any technical or legal obstacles to reducing burden.

Statute does not allow for further payment of educational assistance without the information collected on this form. Less frequent collection of this information would preclude VA's ability to determine whether further educational benefits can be authorized.

7. Explain any special circumstances that would cause an information collection to be conducted more often than quarterly or require respondents to prepare written responses to a collection of information in fewer than 30 days after receipt of it; submit more than an original and two copies of any document; retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years; in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study and require the use of a statistical data classification that has not been reviewed and approved by OMB.

There is no special circumstance requiring collection in a manner inconsistent with 5 CFR 1320.6 guidelines.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the sponsor’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the sponsor in responses to these comments. Specifically address comments received on cost and hour burden. The Department notice was published in the Federal Register on February 22, 2019, Volume 84, Number 36, page(s) 5813. No comments were received.

9. Explain any decision to provide any payment or gift to respondents, other

than remuneration of contractors or grantees.

No payments or gifts to respondents have been made under this collection of information.

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

The student is notified of the privacy protections through a notification at the end of the document. If the student responds, the information provided is retained permanently in the student's education folder. The notification cites 38 U.S.C. 5701 and System of Records, Compensation, Pension, Education, and Vocational Rehabilitation and Employment Records-VA (58VA21/22/28), which are contained in the Privacy Act Issuances, 2011 compilation.

11. Provide additional justification for any questions of a sensitive nature (Information that, with a reasonable degree of medical certainty, is likely to have a serious adverse effect on an individual's mental or physical health if revealed to him or her), such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private; include 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.

There are no questions of a sensitive nature.

12. Estimate of the hour burden of the collection of information:

The estimated annual burden hours, as indicated below, for the collection of this information is 8,860 burden hours, calculated based on 70,881 total responses received for 2015, 2016, 2017 and 2018.

1. Number of Respondents: 17,720

2. Frequency of Response: Annual

3. Annual Burden Hours: 8,860 (17,720 X 30 / 60 = 8,860)

4. Estimated Completion Time: 30 minutes

e. The respondent population is composed of Veterans. VBA cannot make further assumptions about the population of respondents because of the variability of factors such as the educational background and wage potential of respondents.

Therefore, VBA used general wage data to estimate the respondents’ costs associated

with completing the information collection.

The Bureau of Labor Statistics gathers information on full-time wage and salary workers. Accordingly, the median weekly earnings of full-time wage and salary workers is $999.20. Assuming a forty (40) hour work week, the median hourly wage is $24.98.

The general wage code of "00-000-0000 for "All Occupations" may be found by clicking this link https://www.bls.gov/oes/current/oes_nat.htm for “All Occupations” as of May 2018).

Legally, respondents may not pay a person or business for assistance in completing the information collection and a person or business may not accept payment for assisting a respondent in completing the information collection. Therefore, there are no expected overhead costs for completing the information collection. VBA estimates the total cost to all respondents to be $221,323 (8,860 burden hours X $24.98 per hour).

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

This submission does not involve any record-keeping costs. There is no cost to schools because VA pays each school that furnishes training under the various VA education programs a fee for processing all required VA reports or certifications for each veteran or other claimant. VA refers to these fees as "school reporting fees" which help schools to defray the costs of processing paperwork required to be submitted to VA. The reporting fee is in lieu of any other compensation or reimbursement. Reporting fees were established by Public Law 90-77 effective August 31, 1967 and are in 38 U. S. C. 3684.

14. Provide estimates of annual cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

Estimated Costs to the Federal Government are accessible through this link: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2019/GS_h.pdf

Grade	Step	Burden Time Employee	Hourly Wage Rate	Cost per Response	Total Responses	Gov. Cost
09	05	30min	$31.23	-	17,720	$276,698 (17,720 X $31.23 X 30 / 60)
	Overhead at 100%. Overhead costs are 100% of salary, and are the same as the wage listed above; and the amount is included in the total.					-
	Processing / Analyzing Cost					-
	Printing and Production Cost					-
Total Cost to Government						$276,698

The processing time estimates above are based on the actual amount of time employees of the grade level spend to process to completion a claim received on this form.

15. Explain the reason for any burden hour changes since the last submission.

There is a decrease in burden since the last submission due to the decrease in the number of claims received, the Sunset of the Chapter 1607 Reserve Educational Assistance Program educational program, and the termination of the Veteran Retraining Assistance Program (VRAP).

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.

The information collection is not for publication or tabulation use.

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

We are not seeking approval to omit the expiration date for OMB approval.

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

This submission does not contain any exceptions to the certification statement.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection of information does not employ statistical methods.