A. Justification
Introduction/Authoring Laws and Regulations
Section 1613(b) of the Social Security Act (Act), and 20 CFR 416.1240 -416.1245 of the Code of Federal Regulations allow the Social Security Administration (SSA) to pay benefits to applicants and recipients for Supplemental Security Income (SSI) who meet all of the requirements for payment, but exceed the non‑liquid resource limit. SSA makes these payments on a conditional basis. The recipients of conditional benefits acknowledge the benefits are overpayments, and that they are due to pay SSA back when their property sells. SSA documents this agreement using the Agreement to Sell Property, Form SSA-8060-U3.
Description of Collection
Individuals or couples who are otherwise eligible for SSI payments, but whose resources exceed the allowable limit, may receive conditional payments if they agree to dispose of the excess non-liquid resources and make repayments. SSA uses Form SSA-8060-U3 to document this agreement, and to ensure the individuals understand their obligations. Respondents are applicants for, and recipients of, SSI payments who will dispose of excess non-liquid resources.
Use of Information Technology to Collect the Information
SSA collects the information on Form SSA-8060-U3 through a personal interview with the applicant, after which we print the form for the applicant or recipient’s signature, and scan the form back into the electronic folder. In accordance with the agency’s Government Paperwork Elimination Act plan, SSA created an Intranet version of Form SSA-8060-U3. Based on our data, we estimate approximately 100% of respondents under this OMB number use the Intranet version through a personal interview with SSA staff.
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.
5. Minimizing Burden on Small Respondents
This collection does not 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-8060-U3, we would have no way to make conditional benefit payments to otherwise eligible and potentially needy applicants. 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.
8. Solicitation of Public Comment and Other Consultations with the Public
The 60-day advance Federal Register Notice published on February 25, 2020, at 85 FR 10804, and we received no public comments. The 30-day FRN published on July 22,2020, at 85 FR 44352. If we receive any comments in response to this Notice, we will forward them to OMB. We did not consult with the public in the revision of this form.
9. Payment or Gifts to Respondents
SSA does not provide payments or gifts to the respondents.
10. 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.
11. Justification for Sensitive Questions
The information collection does not contain any questions of a sensitive nature.
12. Estimates of Public Reporting Burden
Modality of Completion |
Number of Respondents |
Frequency of Response |
Average Burden per Response (minutes) |
Estimated Total Annual Burden (hours) |
Average Theoretical Hourly Cost Amount (dollars)* |
Average Wait Time in Field Office (minutes) ** |
Total Annual Opportunity Cost (dollars)*** |
SSA-8060-U3 |
20,000 |
1 |
10 |
3,333 |
$25.72* |
24** |
$291,485*** |
* We based this figures on average U.S. citizen’s hourly salary, as reported by Bureau of Labor Statistics data, https://www.bls.gov/oes/current/oes_nat.htm.
** We based this figure on the average FY 2020 wait times for field offices, based on SSA’s current management information data.
*** This figure does not represent actual costs that SSA is imposing on recipients of Social Security payments to complete this application; rather, these are theoretical opportunity costs for the additional time respondents will spend to complete the application. There is no actual charge to respondents to complete the application.
In addition, OMB’s Office of Information and Regulatory Affairs is requiring SSA to use a rough estimate of a 30-minute, one-way, drive time in our calculations of the time burden for this collection. OIRA based their estimation on a spatial analysis of SSA’s current field office locations and the location of the average population centers based on census tract information, which likely represents a 13.97-mile driving distance for one-way travel. We depict this on the chart below:
Total Number of Respondents Who Visit a Field Office |
Frequency of Response |
Average One-Way Travel Time to a Field Office (minutes) |
Estimated Total Travel Time to a Field Office (hours) |
Total Annual Opportunity Cost for Travel Time (dollars)**** |
20,000 |
1 |
30 |
10,000 |
$257,200 |
****We based this dollar amount on the Average Theoretical Hourly Cost Amount in dollars shown on the burden chart above.
Per OIRA, we include this travel time burden estimate under the 5 CFR 1320.8(a)(4), which requires us to provide “time, effort, or financial resources expended by persons [for]…transmitting, or otherwise disclosing the information,” as well as 5 CFR 1320.8(b)(3)(iii) which requires us to estimate “the average burden collection…to the extent practicable.” SSA notes that we do not obtain or maintain any data on travel times to a field office, nor do we have any data, which shows that the average respondent drives to a field office, rather than using any other mode of transport. SSA also acknowledges that respondents’ mode of travel and, therefore, travel times vary widely dependent on region, mode of travel, and actual proximity to a field office.
NOTE: We included the total opportunity cost estimate from this chart in our calculations when showing the total opportunity cost estimates in the paragraph below.
We base our burden estimates on current management information data, which includes data from actual interviews, as well as from years of conducting this information collection. Per our management information data, we believe that 10 minutes accurately shows the average burden per response for reading the instructions, gathering the facts, and answering the questions. Based on our current management information data, the current burden information we provided is accurate. The total burden for this collection instrument is 3,333 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $548,685. SSA does not charge respondents to complete our applications.
13. Annual Cost to the Respondents (Other)
This collection does not impose a cost burden on the respondents.
Annual Cost To Federal Government
The annual cost to the Federal Government is approximately $1,457,466. This estimate accounts for costs from the following areas:
Description of Cost Factor |
Methodology for Estimating Cost |
Cost in Dollars* |
Designing, Printing, and Distributing the Form |
Design Cost + Printing Cost + Distribution Cost |
$1,299 |
SSA Employee (e.g., field office, 800 number, DDS staff) Information Collection and Processing Time |
GS-9 employee x # of responses x processing time |
$88,167 |
Systems Development, Updating, and Maintenance |
GS-9 employee x man hours for development, updating, maintenance |
$1,368,000 |
Total |
|
$1,457,466 |
SSA is unable to break down the costs to the Federal government further than we already have. First, since we work with almost every US citizen, we often do bulk mailings, and cannot track the cost for a single mailing. We do not track design costs or upkeep costs (as these are based on employee time and may vary from collection to collection). In addition, it is difficult for us to break down the cost for processing a single form, as field office and State Disability Determination Services staff often help respondents fill out several forms at once, and the time it takes to do so can vary greatly per respondent. As well, because so many employees have a hand in each aspect of our forms, we use an estimated average hourly wage, based on the wage of our average field office employee (GS-9) for these calculations. Finally, SSA prefers not to provide breakdowns of estimated payment to employees who process these items for a variety of reasons (only one of which is that it is not possible to do this entirely accurately).
15. Program Changes or Adjustments to the Information Collection Request
There are no changes to the public reporting burden.
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 |
| Author | 742577 |
| File Modified | 0000-00-00 |
| File Created | 2021-01-14 |