Supporting Statement Renewal 2020 Comments Added

SUPPORTING STATEMENT FOR

PRINCIPLES OF EXCELLENCE COMPLAINT SYSTEM INTAKE

(OMB Control Number 2900–0797)

A. Justification.

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

Executive Order 13607, Establishing Principles of Excellence for Educational Institutions Serving Service Members, Veterans, Spouses, and Other Family Members, requires the establishment of a centralized complaint system for students receiving Federal military and veteran educational benefits. The purpose of the complaint system is to provide a standardized method to submit a complaint against an educational institution alleging fraudulent and unduly aggressive recruiting techniques, misrepresentation, payment of incentive compensation, failure to meet state authorization requirements, or failure to adhere to the Principles of Excellence as outlined in the Executive Order.

The VA’s Principles of Excellence Complaint System (PoECS) leverages DoD’s complaint system to intake and manage complaints utilizing their existing contract and systems architecture with each agency only having access to their data. The VA’s complaint system utilizes the same software platform as the DoD system. The complainants access the complaint system through the GI Bill website and eBenefits portal. Veterans, family members, or other members of the public are able to open links at either VA website location and enter the requested information. Complainants are offered the opportunity to review the information in their complaint prior to clicking on the submit button. Once a complaint is submitted, the complainant receives an email verifying that the complaint was received. At this point, the complaint is stored in the complaint system and is available to select VA employees for review. VA reviews the complaint and on behalf of the complainant shares the complaint with the institution which is subject of the complaint. VA requests the institution to formally respond to the complaint within 90 days. If an institution fails to respond within 90 days, VA will contact the institution and request a status update. Once VA receives a response from the institution, VA will forward the response to the complainant. At this point, VA will close the case. Valid complaints received are transmitted to the central repository at FTC Consumer Sentinel. The information in the central repository is the same information provided by the complainant. Authorized law enforcement officials who have been granted access to the FTC Consumer Sentinel database have access to view all complaints.

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.

The respondent submits a complaint about an educational institution online through either the GI Bill website or the eBenefit portal. The information gathered can only be obtained from the individual respondents. Valid complaints will be accepted from third parties.

The intake process for both DoD’s and VA’s complaint system share common data elements, but have some modifications specific to each agencies complaint handling process:

VA:

• Institution/Employer: There are over 36,000 educational institutions that are approved for VA education benefits, while DoD has less than 7000.

• Anonymous Complaints: PoECS allows for a user to file anonymous complaints. Based on working group discussions with CFPB and FTC, VA believes that allowing anonymous complaints will garner more ground truth on what is happening with veterans using their education benefits at different schools.

• Required fields: As a result of allowing anonymous complaints, many of the fields that DoD requires a user to fill will not be required by VA

DoD:

• Education Centers: DoD requires education center information that does not fall within the purview of VA.

• Military Branch/Rank: DoD requires a user to select a service affiliation and pay grade.

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.

The Principles of Excellence Complaint (Feedback Tool) System leverages information technology to receive the complaint, case management for processing and referrals as necessary. Complaint Case Managers coordinate with educational institutions to reach a resolution for the individual. The complaints are uploaded to a central repository, FTC’s Consumer Sentinel Network. All complaints will be accessible by state and federal agencies and law enforcement via the central repository. In addition, VA compiles a profile at the institutional level the types of complaints received for other tools that provide streamlined comparisons of institutions. VA uses this profile information to conduct regular and risk-based compliance surveys for educational institutions.

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; however, none were found to exist. There is no known Department or agency which maintains the necessary information, nor is it available from other sources within VA.

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

The information collection involves individuals (Veterans, Servicemembers and their family members). The information may be collected directly from individuals or submitted on behalf of someone else. The information may also be submitted anonymously. There is no impact on education institutions or small businesses for the information collection.

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.

If this information is not collected, VA would not have a uniform manner for individuals to submit complaints for possible fraudulent, unduly aggressive recruiting, misrepresentation, or adherence with the Principles of Excellence against educational institutions. There are no technical or legal obstacles to reducing the burden of this information collection.

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 circumstances 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 publications 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 April 3, 2020, Volume 85, Number 65, page 19075.  There were two comments received.

COMMENT #1

June 2, 2020

Nancy Kessinger

Veterans Benefits Administration (20M33), Department of Veterans Affairs

810 Vermont Avenue NW Washington, DC 20420

Submitted electronically via: http://regulations.gov

Re: OMB Control No. 2900-0797 Agency Information Collection Activity: Principles of Excellence Complaint System Intake

Dear Ms. Kessinger,

Student Veterans of America (SVA) submits this comment to address the Department of Veterans Affairs’ (hereinafter “VA” or “the Department”) extension of currently approved collection activity through the Principles of Excellence Complaint Intake System.

Established in 2008, SVA is a national nonprofit founded to empower student veterans as they transition to civilian life by providing them with the resources, network support, and advocacy needed to succeed in higher education and beyond. With over 1,500 Campus Chapters across the U.S. and in four countries overseas, serving 750,000 student veterans and military-connected students, SVA establishes a lifelong commitment to each student’s success, from campus life to employment, through local leadership workshops, national conferences, and top-tier employer relations. As the largest chapter-based student organization in America, we are a force and voice for the interests of veterans in higher education, and SVA places the student veteran at the top of our organizational pyramid.

INTRODUCTION

The Principles of Excellence Complaint Intake System was born out of Executive Order 13607, which was issued “to ensure that Federal military and veterans educational benefits programs are providing service members, veterans, spouses, and other family members with the information, support, and protections they deserve…”¹ More specifically, the Executive Order called for, among other things, the creation of a “centralized complaint system for students receiving Federal military and veterans educational benefits to register complaints that can be tracked and responded to by the Departments of Defense, Veterans Affairs, Justice, and Education, the CFPB, and other relevant agencies…”² VA’s version of this complaint system is the GI Bill Feedback Tool.

¹ Exec. Order No. 13607, 77 Fed. Reg. 26861 (Apr. 27, 2012) available at https://www.govinfo.gov/content/pkg/FR-2012-05-02/pdf/2012- 10715.pdf.

² Id. at 25863.

INPUT ON INFORMATION COLLECTED

Below, SVA addresses the necessity and practical utility of the information collected through the GI Bill Feedback Tool. We also provide several recommendations for maximizing the overall quality, utility, and clarity of the information collected.

Necessity and Practical Utility

The GI Bill Feedback Tool helps students make informed decisions about how to use their education benefits while simultaneously protecting taxpayer dollars. It also provides federal agencies with essential information so they can monitor institutional misconduct and hold bad-actor schools accountable.

The Feedback Tool is critical to the Veterans Benefits Administration’s (VBA) mission of effectively administering education programs for student veterans and military-connected students. The information collected through the tool, particularly when made available through its sister system, the GI Bill Comparison Tool, helps students make positive choices about how to use their limited, earned education benefits. By collecting feedback from current students and publishing it, the tools help future students avoid low-quality institutions and get the most out of their benefits.

Moreover, the information collected through the Feedback Tool protects taxpayer dollars. Since the tool assists students in making informed decisions about how to use their military and veteran benefits, it also helps ensure the taxpayer dollars that fund these benefits flow to quality institutions that provide good return on investment. All federal agencies are responsible for being good stewards of taxpayer dollars, and the information collected through the Feedback Tool is essential to VA being able to fulfill this duty.

Last, but not least, the Feedback Tool provides federal administrative agencies and other law enforcement agencies with important information that aids them in holding bad-actor schools accountable. VA recently claimed this feedback resulted in 166 schools being reviewed and 21 of those institutions being stripped of their eligibility to receive VA education funds.³ The government’s ability to monitor and enforce the Principles of Excellence and other consumer protection laws would be severely crippled without the information collected through the GI Bill Feedback Tool.

Protecting and Improving the Quality, Utility, and Clarity of the Information

SVA strongly believes improving the quantity and quality of information available to veterans allows them to make better-informed decisions about how to use their education benefits.⁴ To that end, we provide recommendations below to maximize the quality, utility, and clarity of the information collected through the GI Bill Feedback Tool.

Continue to Accept Anonymous Submissions

SVA supports the Department’s willingness to accommodate submission of anonymous student complaints through the Feedback Tool. The tool currently allows students to submit both anonymous and non-anonymous complaints. Requiring students to identify themselves, especially when non-anonymous complaints are sent to a student’s school,⁵ would likely cause some students to fear retaliation and may have a chilling effect on their willingness to report complaints. We thank the Department for facilitating submission of anonymous student complaints and request it preserve this option in future versions of the tool.

Increase Transparency

SVA recommends the Department improve the transparency of the Feedback Tool by expanding the scope of complaint information that is made public. Currently, the GI Bill Comparison Tool only displays the number of complaints submitted in the last 24 months disaggregated into several broad categories. ⁶ The tool includes a “source” link for the complaints, but it only directs users to the Comparison Tool’s “About” page, which simply explains how the tool functions.⁷ This link provides no additional, specific information about a school’s complaints.

SVA encourages the Department to publish and maintain a comprehensive database of all school-specific complaints submitted through the Feedback Tool. Students should be given the option to disclose their narrative comments publicly, and those comments should be included in the database. The feedback database should be presented in a familiar interface, preferably one that mirrors other popular review websites. This means it should include helpful user features like search, filters, and sorting. We further recommend the Department include a link on each school’s profile page in the GI Bill Comparison tool that directs students to a full, detailed list of complaints submitted about that institution. This will help students identify and better understand the true nature of complaints submitted about each school. It will also improve the ability of advocates and researchers to monitor and analyze past and present institutional compliance with the Principles of Excellence and other laws.

⁵ Feedback, U.S. DEPARTMENT OF VETERANS AFFAIRS (Feb. 26, 2019), https://www.benefits.va.gov/GIBILL/Feedback.asp.

⁶ E.g., GI Bill Comparison Tool – Ashford University, U.S. DEPARTMENT OF VETERANS AFFAIRS, https://www.va.gov/gi-bill-comparison- tool/profile/21123205.

⁷ GI Bill Comparison Tool: About This Tool, U.S. DEPARTMENT OF VETERANS AFFAIRS (May 8, 2020), https://www.benefits.va.gov/gibill/comparison_tool/about_this_tool.asp.

Revise Feedback Topic Names and Descriptions

SVA recommends VBA revise the names of certain feedback topics to include language that student veterans and military-connected students would more readily identify with. ⁸ For example, the word “recruiting” in the topic name “Recruiting and Marketing” could be replaced with the phrase “admissions or enrollment.”⁹ Most students experience deceptive recruiting practices when interacting with an “admissions advisor,” “military advisor,” or someone with a similar title – not a “recruiter.”¹⁰ Unless they are competitive athletes, most students do not have contact with a recruiter and do not think about the enrollment process as them being recruited. Replacing the word “recruitment” with “admissions or enrollment” better matches most student experiences.

We also ask that VBA expand the feedback topic descriptions to help students better understand which category best matches their experience. For instance, the current “Quality of Education” topic only provides the following description: “The school doesn’t have qualified teachers.” This description is far too limited. Quality of education is an expansive topic which might include, among other things, a lack of promised experiential learning, inadequate course materials, or the absence of other promised resources. Many of the other topic descriptions suffer from a similar lack of clarity and detail. The Department should consider including one or two broad topic descriptions under each topic name and add a hover-over icon next to each topic with additional descriptions or hypothetical scenarios. This would help veterans more easily identify which topic is the proper selection for their complaint.

We encourage the Department to review the separate coalition comment we have signed on to for a full list of proposed revisions for topic names and descriptions.

Issue Caution Flags for Student Complaints

SVA recommends VBA place caution flags on institutions in the GI Bill Comparison Tool that receive a substantial number of student complaints. The Department currently places a caution flag on schools in the GI Bill Comparison Tool when “VA or other federal agencies like the Department of Education or Department of Defense have applied increased regulatory or legal scrutiny to a program of education.”¹¹ VBA does not, however, use caution flags to mark schools that receive a large number of student complaints through the GI Bill Feedback Tool. Student veterans and military-connected students deserve to know when a school receives a disproportionately large number of complaints, and, in such cases, should be provided with a conspicuous warning in the form of a caution flag. ¹² VBA might consider issuing caution flags in two different scenarios: one flag for schools with a large number of complaints during a recent period and a separate flag for schools with a large number of total complaints.

⁸ See Veterans Serving Organizations VA Complaint System Comments 1-2 (Oct. 15, 2013) available at https://www.regulations.gov/document?D=VA-2013-VACO-0001-0555 (highlighting past requests by SVA and other veterans serving organizations for the Department to implement such changes).

⁹ See id.

¹⁰ See id.

¹¹ GI Bill Comparison Tool: About This Tool – Caution Flags, U.S. DEPARTMENT OF VETERANS AFFAIRS (May 8, 2020), https://www.benefits.va.gov/gibill/comparison_tool/about_this_tool.asp.

¹² See Letter from Derek Ranneberger, Director of Policy, Student Veterans of America and Walter Ochinko, Policy Director, Veterans Education Success to Robert Worley, Director of the Education Service, Department of Veterans Affairs 1 (May 10, 2016), available at https://vetsedsuccess.org/wp-content/uploads/2019/01/gi-bill-comparison-tool-letter-worley.pdf (explaining that “[v]eterans have only one shot at using their GI Bill benefits and, therefore, any caution flags that could inform veterans’ choice should be included on the Comparison Tool.”).

CONCLUSION

We thank the Department for its ongoing commitment to the Principles of Excellence and its collection and dissemination of critical complaint information through the GI Bill Feedback and Comparison Tools. This information is crucial to helping students make informed, positive choices about how to use their earned education benefits. The government also needs this information to monitor compliance with the Principles of Excellence and consumer protection laws, hold bad-actor schools accountable, and protect taxpayer dollars. SVA encourages the Department to continue improving the Feedback and Comparison Tool systems by implementing the recommendations made above.

SVA greatly appreciates your attention to this comment. If you have any questions, please feel free to contact Justin Hauschild directly by phone at 202-223-4710 or by email at [email protected].

Sincerely,

Lauren Augustine

Vice President of Government Affairs Student Veterans of America

VA Response: Thanks for your support regarding the VA Principles of Excellence Program. Your proposed recommendations have been submitted to VA leadership for acknowledgement and consideration. We will notify you regarding these proposals after we have completed our assessment.

Thanks again for your support.

COMMENT #2

June 2, 2020

Department of Veterans Affairs

Veterans Benefits Administration

810 Vermont Avenue NW

Washington, DC 20420

Via electronic submission

Re: Principles of Excellence Complaint System Intake, OMB Control No. 2900-0797

Dear Sir/Madam:

Thank you for the opportunity to comment on the collection of information by the Veterans Benefits Administration (VBA), as authorized by Executive Order 13607. The order seeks to “ensure that Federal military and veterans’ educational benefits programs are providing service members, veterans, spouses, and other family members with the information, support, and protections they deserve.” The order establishes “streamlined tools to compare educational institutions using key measures of affordability and value” and “a strong enforcement system through which to file complaints when institutions fail to follow” the Principles of Excellence. The goals of the Executive Order align with VA’s mission to serve and honor America’s veterans.

The complaint system is also codified in 38 U.S.C. § 3698. Section 3698(b)(2) states that the Secretary shall include “a centralized mechanism for tracking and publishing feedback from students and State approving agencies (SAAs) regarding the quality of instruction, recruiting practices, and post-graduation employment placement.”

We offer comments on the continuing need for this complaint system and suggestions for its improvement below.

Whether the proposed collection is necessary for the proper performance of VBA’s functions

We believe that the collection of this information is essential for the success of military connected students and the administration of educational benefits. The tracking and reporting of student feedback is essential because it:

• Arms prospective students with key information to make informed college choices.

Feedback from other veterans helps students compare educational institutions and make careful college selections.

• Enables VBA to provide “customer service” to veterans – to inform, support, and protect them. The Principles of Excellence feedback system, as codified in statute, is the primary method for students to lodge complaints against their school, to be heard, and to know that VBA “has their backs.”

1 Exec. Order No. 13607, 77 FR 25861 (2012).

2 38 U.S.C. § 3698, https://www.law.cornell.edu/uscode/text/38/3698.

• Provides VBA with a critical “early warning system” to enable proper oversight and efficient administration of the GI Bill. Student feedback can alert VBA to systemic

problems at schools – such as missing or mishandled GI Bill funds, changes to degree requirements, or loans taken out without the veteran’s permission.3

• Protects taxpayer funds from waste, fraud, and abuse. Knowing about problems enables VBA to stop “improper payments to ineligible colleges” – as VA’s Inspector

General pointed out.4

Ways to enhance the quality, utility, and clarity of the information to be collected. We offer recommendations to enhance the clarity of the complaint system and increase the accuracy of the information collected.

• Utilize complaints to trigger risk-based program reviews. Schools with complaints showing a pattern of abuse or even with a single complaint alleging serious illegality

should be subject to a risk-based review by SAAs.

• Do not deem complaints “invalid.” Neither 38 U.S.C. § 3698 nor the Executive Order envision VBA deeming so many complaints “invalid.” Moreover, at an August 2016

meeting, VBA pledged to attendees (including veterans and military service organizations, and representatives of the Departments of Defense and Education, the U.S.

Consumer Financial Protection Bureau, and the U.S. Federal Trade Commission – which explicitly stated they want all complaints uploaded to Sentinel) that VBA would deem

“valid” any complaint alleging a Principle of Excellence issue, so long as it was not about “hamburgers.” VBA’s federal agency partners made this request because they did not

think VBA had sufficient experience in consumer protection law to deem complaints invalid.

• Do not deem complaints “closed” until the student has an opportunity to react to the school’s response, as we have suggested since 2013.5 Veterans tell us that they have not felt supported when they receive a form letter from VBA stating that the complaint has been closed because the school has responded. Even though this letter invites veterans to share additional information, veterans often feel as though it would not be worthwhile because the complaint has been closed. Please ask the veteran if the school’s response is satisfactory. VBA can still close the complaint, but it should note if it was closed “to the satisfaction” of the student, just like the U.S. Consumer Financial Protection Bureau does.

3 Where the term “veteran” is used, we also refer to military-connected GI Bill beneficiaries.

4 VA’s Oversight of State Approving Agency Program Monitoring for Post-9/11 GI Bill Students, Department of

Veterans Affairs, Office of Inspector General, Dec. 3, 2018, https://www.va.gov/oig/pubs/VAOIG-16-00862-

179.pdf.

5 Public Comment, OMB Control No. 2900-NEW (Principles of Excellence Complaint System Intake), Oct. 15,

2013, https://vetsedsuccess.org/public-comment-by-veterans-military-organizations-providing-suggestions-for-vasstudent-

complaint-intake-system-2/.

• Ensure all complaints are uploaded and publicly available. All complaints should be public and searchable on the GI Bill Comparison Tool in order to increase public

confidence in VBA’s management of the feedback system; to prompt schools, states, SAAs, and accreditors to address problems; and to ensure prospective students have an

accurate picture of the concerns raised by other students.

o Do not limit the complaints shown on the Comparison Tool. Only those filed in the most recent 24 months appear. This is a change at VBA in response to

lobbying by schools. But veterans are VBA’s constituency; schools are not. Prospective students, SAAs, accreditors, other federal agencies, and academic

researchers deserve to know if a school has a long history of student complaints. If a school feels that it has made changes that address older complaints, it could

request a note on the profile to that effect.

o List all complaints – open or closed, as well as anonymous complaints or complaints deemed “invalid.” However, open, anonymous, or invalid complaints

could be weighted less.

o All complaints – whether open or closed – should be uploaded to Consumer Sentinel. Law enforcement agencies must have access to all student complaints if

they are to enforce the law. It is our understanding that complaints are uploaded only once they are validated and closed, so a significant number of complaints are

never shared with other agencies.

• Improve caution flags on the GI Bill Comparison Tool. As we wrote in 2016, caution flags are not consistently or uniformly posted.7 Veterans should always be warned if a school has legal or regulatory problems. VBA should also post a flag when a school has received a large number of student complaints.

• Give students the option to make the narrative portion of their complaint public.

“Yelp-style” feedback, which VBA has contemplated since 2014, would give military connected students a real sense of the experiences of fellow students at a school.

• Make the form more “user-friendly.” Veterans and military service organizations have made this request since 2013.8 VBA should preface the form with encouragement to

students to speak up and file their complaint. In addition, many of the terms and descriptions are not easy for students to understand. Specifically:

o Recruiting or marketing practices: Students would understand this category better if “recruiting” was replaced with “admissions or enrollment.” Likewise,

“marketing” could be replaced with “advertising.”

o Accreditation: The description currently says, “The school is unable to get or keep

accreditation.” But the Executive Order specifically explains that some bad actor

6 Id.

7 Letter to Robert Worley, Director of the Education Service, Department of Veterans Affairs, from Derek

Fronabarger, Director of Policy, Student Veterans of America, and Walter Ochinko, Policy Director, Veterans

Education Success (May 10, 2016), https://vetsedsuccess.org/wp-content/uploads/2019/01/gi-bill-comparison-toolletter-

worley.pdf.

8 Supra note 5.

schools lie to students about the accreditation they do have. A better description would include, “The school promised it had accreditation that was the same as

other schools”; “the degree you earned does not qualify you for the job you want”; and “the school told you that you would be able to obtain a license and you

cannot.”

o Financial concern: The current description, “The school is charging you a higher tuition or extra fees,” could be clarified by adding the phrase “than you expected”

or “than you were promised.” Please add additional examples, including, “The school promised the GI Bill would cover everything, but it didn’t” and “the school

promised a ‘veteran discount’ but never gave it to you.”

o Student loan: The description is too narrow. Please add additional examples, including, “The school signed you up for loans without your permission”; “the

school told you that you were signing up for grants, not loans”; and “the school told you that you needed to take out loans until your GI Bill payments came in.”

o Post-graduation job opportunity: The description is too narrow. Please add additional examples, including, “You can’t find a job in your field”; “the school

did not deliver the job placement help it promised”; and “the school promised that you would earn a specific amount of money after graduation.”

o Change in degree plan or requirements: The description is too narrow. Please add additional examples, including, “The school discontinued a program that you

were pursuing” and “the school signed you up for a program you did not want to study.”

o Quality of education: The description is too narrow. Please add additional examples, including, “The school did not deliver the ‘hands-on’ education it

promised”; “the school used outdated materials”; and “employers do not take your degree seriously.”

o Transfer of credits: Students frequently share that their school told them their credits would transfer to other schools. The description could be improved by

referencing this fact: “The school promised that your credits would transfer to other schools, but you have found out they won’t.” Another example would be,

“The school promised it would accept credits you had previously earned, but it didn’t.”

o Refund issues: The current description is not very clear, since students do not often receive refunds of the GI Bill. Please expand the description, such as, “The

school has not returned your GI Bill funds to VA after you withdrew from a class.”

o Other: Another issue that frequently arises is that a school does not accommodate a student’s military service, which the Executive Order requires schools to do.

This should be added to an existing category or shared as a new category of complaint.

We appreciate your consideration of these perspectives and recommendations and stand ready to provide any support necessary should VBA choose to implement them.

Sincerely,

VA Response: Thanks for your support for the VA Principles of Excellence Program. Your proposed recommendations regarding ways to improve this system have been submitted to VA leadership for acknowledgement and consideration. We will notify you regarding these proposals after we have completed our assessment.

Again, thanks again for your support.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

VA does not provide any payment or gifts to respondents.

10. Describe any assurance of privacy, to the extent permitted by law, provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

This information will be destroyed three years after date of final action on investigation or litigation. Our assurance of privacy is covered by 38 U.S.C. 5701 and our System of Records, Principles of Excellence Centralized Complaint System – VA (170VA22).

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

None of the information collected is of a sensitive nature.

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

Estimate of Information Collection Burden:

1. Number of Respondents: 1,596

2. Frequency of Response: On occasion. (1,596 X 15 / 60 = 399 annual burden hours).

3. Annual Burden Hours: 399

4. Estimated Completion Time: 15 minutes

5. The respondent population is composed of Veterans and their dependent students. 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_stru.htm 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 $39,868 (1596 burden hours x $24.98 per hour).

13. Provide an estimate 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.

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:

a. We estimate that it will take Complaint Case Managers 30 minutes for less complex routine complaints and 60 minutes for more complex egregious complaints. We estimate that 80% or 1,276 cases will be routine and 20% or 320 will be complex egregious. As such it will take an estimated 958 hours for case management activities handling complaints.

b. Using the hourly rate for a GS13/5 in the Washington DC area of $55.75, 958 hours equates to $53,409.

c. In addition, the contract costs to leverage DoD’s complaint system is $145,000. See Below:

Grade-DC	Step	Burden Time	Hourly Rate	Cost Per Response	Total Responses	Total
13	05	399	$55.75	--	1,596	$53,409
--	--	--	--	--	--	--
Overhead at 100% Salary						$53,409
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 Costs (399 hours X $55.75)						$53,409
Printing and Production Cost						$0
Contract Costs to Leverage DoD’s complaint system						$145,000
Total Cost to Government						$198,409

Note: The hourly wage information above for a GS-13/5 for the Washington DC area is based on the hourly 2020 General Schedule (Base) https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2020/DCB_h.pdf

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.

REPORTING FEE INFORMATION: 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

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

There was a slight increase to the burden hours due to a slight increase in the number of POE complaints received from the program’s inception; 1500 to

1596 responses.

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.

VA does not publish this information or make it available for publication.

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 information collection complies with all requirements under 5 CFR 1320.8(b)(3).

B. Collection of Information Employing Statistical Methods.

This collection of information gathered by the Veterans Benefits Administration will not employ statistical methods.

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