3220-0155

OMB No. 3220-0155

Justification

Supplement to Claim of Person Outside the United States

RRB Form G-45

1. Circumstances of information collection - Under the Social Security Amendments of 1983 (Public Law 98-21), which amends Section 202(t) of the Social Security Act, effective January 1, 1985, the Tier I or the overall minimum (O/M) portion of an annuity, and Medicare benefits payable under the Railroad Retirement Act to certain beneficiaries living outside the United States, may be withheld.

The benefit withholding provision of P.L. 98-21 applies to divorced spouses, spouses, minor or disabled children, students and survivors of railroad employees who (1) initially became eligible for Tier I amounts, O/M shares, and Medicare benefits after December 31, 1984; (2) are not U.S. citizens or U.S. nationals; and (3) have resided outside the U.S. for more than six consecutive months starting with the annuity beginning date. The benefit withholding provision does not apply, however, to a beneficiary who is exempt under either a treaty prior to August 1, 1956, or a totalization agreement between the U.S. and the country in which the beneficiary resides or an individual who is exempt under other criteria specified in P.L. 98-21.

2. Purposes of collecting/consequences of not collecting the information

Form G-45, Supplement to Claim of Person Outside the United States, is used by the Railroad Retirement Board (RRB) to obtain the information needed to determine applicability of the withholding provision of P.L. 98-21.

The form is used:

 as a supplement to a benefit application from a non-U.S. citizen to whom the non-payment provision may apply, or

 as an independent vehicle when a beneficiary informs the RRB of a change in country of residence, which may involve ­applying the benefit withholding provision of P.L. 98-21.

Completion of Form G-45 is self-explanatory. The identifying information requested in the upper right-hand corner of the form is pre-filled before the form is released. When mailed to an applicant or beneficiary, the RRB includes a pre-addressed return envelope.

Form G-45 is patterned after the Social Security Administration's Form SSA-21, Supplement to Claim of Person Outside the United States, OMB No. 0960-0051.

The RRB proposes minor non-burden impacting changes to Form G-45 to update the RRB contact title and the RRB ZIP Code in the Paperwork Reduction Act and Privacy Act Notices.

3. Planned use of improved information technology or technical/legal impediments to further burden reduction - None at this time. Not cost effective due to low volume. Form is sent by the RRB with pre-filled data.

4. Efforts to identify duplication - This information collection does not duplicate any other information collection.

5. Small business respondents - N.A.

6. Consequences of less frequent collection - Not applicable since the information is requested only once for each incident involving a change in the country of residence by an applicant or beneficiary.

7. Special circumstances - None

8. Public comments/consultations outside the agency - In accordance with 5 CFR 1320.8(d), comments were invited from the public regarding the information collection. The notice to the public was published on page 63907 of November 19, 2019, Federal Register. No comments or requests for additional information were received.

9. Payments or gifts to respondents - None.

10. Confidentiality - Privacy Act System of Records, RRB-22, Railroad Retirement, Survivor and Pensioner Benefit System. In accordance with OMB Circular M-03-22, a Privacy Impact Assessment for this information collection was completed and can be found at https://www.rrb.gov/sites/default/files/2017-06/PIA-BPO.pdf.

11. Sensitive questions - N.A.

12. Estimate of respondent burden - The estimated annual burden for the collection remains unchanged.

Form Number	Annual Responses	Time (Minutes)1/	Burden (Hours)
G-45	100	10	17

1/The RRB has been collecting the information on this form since OMB approved the information collection. Based on a sampling done when the form was originally created, the office calculated the estimated time, which includes time for getting the needed data and reviewing the completed form

13. Estimated annual cost to respondents or record keepers - N.A.

14. Estimate of cost to Federal Government - N.A.

15. Explanation for change in burden - N.A.

16. Time schedule for publication - The results of this collection will not be published.

17. Request not to display OMB expiration date - The RRB started an extensive multi-year IT Modernization Initiative at the beginning of Fiscal Year 2019 to transform our operations into the 21^st Century using multiple contractor services to improve mission performance, expand service capabilities, and strengthen cybersecurity. In addition, we received a new Chief Information Officer (CIO) on September 2, 2019 who is reviewing our estimated project timeline milestone dates. Once finalized, we will provide OMB with a consolidated project timeline.

Given that the form in this collection are seldom revised; the costs associated with redrafting, reprinting, and distributing forms in order to keep the appropriate OMB expiration date in place; and our desire to reevaluate after the completion of the modernization project, the RRB requests the authority to not display the expiration date on the forms

18. Exceptions to Certification Statement - None

~ 3 ~