0704-0411_ssa_6.5.2020x

SUPPORTING STATEMENT - PART A

EXCEPTIONAL FAMILY MEMBER PROGRAM; DD Form 2792, DD Form 2792-1; OMB Control Number 0704-0411

Summary of Changes from Previously Approved Collection

• Overall number of respondents has increased from 44,555 to 98,608. This is due to a general increase in the number of family members filling out both forms. Additionally, 14,708 Special Education Teachers are now filling out DD 2792-1, in addition to family members.

• Removed all requirements and references to Social Security Numbers; the Sponsor’s DoD ID number was included as a replacement throughout the DD Forms 2792 and 2792-1.

• Increased the length of all phone, fax, and mobile number blocks throughout the DD Forms 2792 and 2792-1.

• Consolidated the Asthma, Behavioral Health, and Autism Spectrum Disorder / Developmental Delay addenda into three separate sections of Part A of the DD Form 2792.

• Added “Applied Behavior Analyst”, “Counselor (Specify)”, “Neuropsychologist”, and “Neuropsychiatrist” as care providers in Part B of the DD Form 2792.

• Updated the Diagnosis Information sections in Part A of the DD Form 2792 to include “Medical History Over the Last 12 Months” and more logically structure the information that is provided.

• Added a Provider Information authentication section at the bottom of each page of the DD Form 2792 completed by a qualified medical provider.

• Added a “Suction Machine” to the Medically Necessary Adaptive Equipment / Special Medical Equipment of the DD Form 2792. Additionally, certain pieces of equipment now require that the make and model are included in the “Description” column.

• Removed redundant blocks of the DD Form 2792 to reduce the total number of pages from 13 to 8 (including the instructions and authorizations pages).

• Spelled out acronyms the first time they appear on the DD Forms 2792 and 2792-1 (e.g., “Exceptional Family Member Program (EFMP)”).

• Added a note to the instructions of the DD Form 2792-1 that reads “If child is under 5 years old, is not enrolled in school or engaged with an Early Intervention Services program, and does not have any identified needs, the parents or guardians can fill out and sign page 2 of the DD Form 2792-1 and return to the requesting office. The completion of page 3 is not required in this case."

• Modified the “Education Services for Dependents 3 Years and Older” section of the DD Form 2792-1 to include more specific and logical questions regarding home-schooling.

• Updated language in the “School Information – For Students Ages 3 – 21” section of the DD Form 2792-1 to more appropriately collect information about students’ educational history.

1. Need for the Information Collection

The Individuals with Disabilities Education Act, (Sections 1400 et seq. of title 20, United States Code) and the Defense Dependents Education Act, (Sections 921 et seq. of title 20, United States Code) require the Department of Defense to provide early intervention services to developmentally delayed infants and toddlers (birth through 2) and special education and medically related services to children with disabilities from 3 through 21 years of age who are eligible to attend a DoD school. In order to ensure the availability of necessary medical and educational services for family members, the Department must identify those who have special health or educational needs. Medical and educational needs are also considered when approving family travel to an overseas or remote location where DoD must provide the services.

The Health Insurance Portability and Accountability Act (HIPAA) of 1996 (Public Law 94-191) requires specific language to advise the individuals that personally identifiable health information shall not be used or disclosed except for specifically permitted purposes, unless informed consent is provided by the individual. The Department is standardizing the information collection to ensure that appropriate information is collected and that it meets the data collection HIPAA requirements.

The National Defense Authorization Act (NDAA) for Fiscal Year 2010 (Public Law 111-84) requires procedures to identify members of the Uniformed Services who are members of military families with special needs, mechanisms to ensure their timely and accurate evaluations and enrollment.

2. Use of the Information

The purpose of this information collection is to 1) enroll sponsors into the Exceptional Family Member Program (EFMP), 2) match the special needs of family members against the availability of medical and educational services through the Family Member Travel Screening (FMTS) process, and 3) advise civilian employees about the availability of medical and educational services to meet the special needs of their family members. Respondents are Military members and DoD civilian employees, private physicians and school personnel. Respondents may access these information collection instruments online, or through paper copies provided to them. Similarly, the information collection instruments may be completed either by hand or digitally and returned via secure digital exchange or in-person using a paper copy of the information collection instruments.

This information collection is primarily used by the Uniformed Services to enroll family members who meet the criteria for special medical and educational needs into the EFMP as well as identifying individuals requiring special consideration when authorizing family travel to an overseas or remote location at government expense. The DD Form 2792, “Family Member Medical Summary,” and DD Form 2792-1, “Special Education/Early Intervention Summary,” are the forms associated with this information collection. The information is provided to both medical and educational screening personnel in overseas and remote locations for their determination of the availability of medical and education resources necessary to meet the family member’s needs. The medical and/or educational recommendation is supplied to the appropriate Military Department’s personnel department in determining the future assignment for the service member. This information collection may also be used to identify available medical and educational resources to DoD civilian employees who are considering a job overseas to assist them in deciding whether to relocate overseas with a family member who has special medical or educational needs. The information is not supplied to agencies outside of the Department of Defense. Respondents are required to update the forms every 3 years, and communication from the Military Departments may be sent to the respondent requesting an update to the information collection.

3. Use of Information Technology

The DD Form 2792 and DD Form 2792-1 are available to the public electronically online from the Department of Defense forms website (https://www.esd.whs.mil/Directives/forms/dd2500_2999/). The current electronic response rate is 30%. For respondents who have access to computerized information technology, the forms can be completed online and electronically signed using a Common Access Card (CAC). There are no current plans to submit the completed forms electronically due to the number of individuals who must sign the form (sponsor or family member, civilian physician and/or public school officials). Although the Department has electronically generated the form, the form includes confidential medical information that must be entered by a physician. At this time, it is not practical to require that this information be entered electronically.

4. Non-duplication

Investigation resulted in no findings of duplicate records. The information collection is not available in any centralized location and requires the assistance of military personnel and DoD civilian employees in providing information. Each form contains unique and original information that pertains only to the medical and educational needs of an individual family member. The information obtained through this collection is unique and is not already available for use or adaptation from another cleared source.

5. Burden on Small Businesses

This information collection does not impose a significant economic impact on a substantial number of small businesses or entities.

6. Less Frequent Collection

If this information is not collected it will be impossible for the Military Departments to consider the special medical and/or educational needs of family members when approving overseas travel, nor would it be possible to inform civilian employees of the availability of services overseas. If the information is collected less often, it may be inaccurate. This could result in an incorrect decision about assignment and thus a lack of adequate resources to meet the family member’s medical and/or educational needs. The Department would incur significant costs if family members are returned to the United States from an overseas location due to non-existent or insufficient medical support being available. In addition, families would not be enrolled into the program in a consistent manner.

7. Paperwork Reduction Act Guidelines

There are no special circumstances. This collection of information does not require collection to be conducted in a manner inconsistent with the guidelines delineated in 5 CFR 1320.5(d)(2).

8. Consultation and Public Comments

Part A: PUBLIC NOTICE

A 60-Day Federal Register Notice for the collection published on Wednesday October 24, 2018. The 60-Day FRN citation is 83 FR 53615.

No comments were received during the 60-Day Comment Period.

A 30-Day Federal Register Notice for the collection published on Friday May 1, 2020. The 30-Day FRN citation is 85 FRN 25408.

Part B: CONSULTATION

In preparation for the current submission, the program analyst responsible for EFMP policy from the Office of the Secretary of Defense convened a working group of the EFMP Managers from each Service to review the DD Forms 2792 and 2792-1. The group concurred that the requirement should remain for the collection of information at least every 3 years.

Consultations were conducted with the following individuals:

Name	Organization	Phone Number
Ms. Becky Tucker	US Army	(703) 681-8346
LT CDR William Haywood	US Navy	(703) 681-9080
Lt Col. Lisa Hoyt	US Air Force	(210) 395-9271
Ms. Jennifer Stewart	US Marine Corps	(703) 784-0298

9. Gifts or Payment

No payments or gifts are being offered to respondents as an incentive to participate in the collection.

10. Confidentiality

All data are protected by the Privacy Act of 1974 and are protected according to the regulations therein, and by related DoD directives and instructions. The Privacy Impact Assessment (PIA) is not applicable. The following System of Records Notices (SORNs) oversee the collection of the SSN. Completed forms are covered by official military personnel and special needs records. SORNs are maintained by each of the Services. The DoD Blanket Routine Uses found at http://dpclo.defense.gov/Privacy/SORNsIndex/BlanketRoutineUses.aspx apply to this collection.

Applicable SORNs:

Army

A0600-8-104b AHRC, Official Military Personnel Record (https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570054/a0600-8-104-ahrc/)

A0608b CFSC, Personnel Affairs: Army Community Service Assistance Files (https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570084/a0608b-cfsc)

Marine Corps

M01070-6, Marine Corps Official Military Personnel Files (https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570626/m01070-6/)

M01754-6 - Exceptional Family Member Program Records (https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570631/m01754-6/)

Navy

N01070-3, Navy Military Personnel Records System (https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570310/n01070-3/)

N01301-2, On-Line Distribution Information System (ODIS) (https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570320/n01301-2/)

Air Force

F036 AF PC C, Military Personnel Records System (https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/569824/f036-af-pc-c/)

F044 AF SG U, Special Needs and Educational and Developmental Intervention

Services

(https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/569875/f044-af-sg-u/)

DoD

DPR 34, Defense Civilian Personnel Data System (https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-Component-Article-View/Article/570697/dpr-34-dod/)

EDHA 16 DoD, Special Needs Program Management Information System (SNPMIS) Records (https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570679/edha-16-dod/)

EDHA 07, Military Health Information System

(https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570672/edha-07/)

OSD/JS, DMDC 02 Defense Enrollment Eligibility Reporting Systems (DEERS)

(https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/627618/dmdc-02-dod/)

Department of Defense Education Activity

DoDEA 26, Department of Defense Education Activity Dependent Children's School Program Files

(https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570576/dodea-29/)

DoDEA 29, DoDEA Non-DoD Schools Program

(https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570576/dodea-29/)

Records Retention and Disposition Schedules:

Army

• A0600-8-104b AHRC, Official Military Personnel Record: Soldiers records are offered to the National Archives 75 after years individual's final separation. The National Archives, after consultation with the Department of the Army, genealogists, historians, social scientists, and other interested parties, will then determine the disposition of the records based on any continuing administrative needs and their archival value. Records, if any, not selected for permanent retention by the Archives will be disposed of.

• A0608b CFSC, Personnel Affairs: Army Community Service Assistance Files: Destroyed after 2 years. Information may be transferred from one Army Community Service Center to another upon permanent change of station of service member.

Marine Corps

• M01070-6, Marine Corps Official Military Personnel Files: Official Military Personnel File records are permanent. Records of Marines who separated, retired, or whose military service obligation expired prior to 1 January 1998 are maintained at the National Personnel Records Center, 9700 Page Avenue, St Louis MO 63132-5100. The records of Marines with remaining military service obligation or contractual obligations after 31 December 1997 are maintained at Headquarters, U.S. Marine Corps, U.S. Marine Corps (Code MMSB), 2008 Elliot Road, Quantico, VA 22134-5030. Permanent records are transferred to the National Archives and Records Administration (NARA) 62 years after the completion of the service member's obligated service. For Official Military Personnel File records of Marine Corps members in the regular or reserve components as of 1 January 1998 or those members who separated, retired, or died while in service, in the year 1998 or later are maintained at the National Personnel Records Center, Military Personnel Records Branch, 9700 Page Avenue, St. Louis, MO 63132-5100.

• M01754-6 - Exceptional Family Member Program Records: The records retention has not been approved by the National Archives and Records Administration, until then treat as permanent.

Navy

• N01070-3, Navy Military Personnel Records System: Those documents that are designated as temporary in the prescribing regulations remain in the record until their obsolescence, or the member is separated from the Navy, then are removed and provided to the individual. Those documents designated as permanent are submitted to Navy Personnel Command at predetermined times to form a single personnel record in the Electronic Military Personnel Records System (EMPRS), and remain in EMPRS permanently. Permanent records are transferred to the National Archives and Records Administration 62 years after the completion of the service member's obligated service.

• N01301-2, On-Line Distribution Information System (ODIS): Destroy 1 month after release from active duty, when superseded or when no longer needed for reference, whichever is earliest. Paper records are disposed of by burning or shredding. Electronic records are deleted from encrypted hard drives.

Air Force

• F036 AF PC C, Military Personnel Records System: Records are retained 3 months after reporting, and then destroyed by tearing into small bits, pulping, shredding, burning, or macerating.

• F044 AF SG U, Special Needs and Educational and Developmental Intervention Services: A Special Needs Assignment Coordination Record is closed when criteria for the Q-Code identifier no longer is met, or the AD member separates or retires from military services. An Educational and Developmental Intervention Services, early intervention services record is closed when the child, 0-3 years old, has reached and maintained age appropriate skills and is determined to no longer require services. A related services record is closed when the school age child no longer requires services, passes the age criteria, transfers to a public education system. Cut off and transfer to the National Personnel Records Center, 9700 Page Blvd, St Louis, MO 63132-1547, 2-years after the end of the calendar year in which the Q-code deletion request has been affirmed by AFPC where they are destroyed after 25 years.

DoD

• DPR 34, Defense Civilian Personnel Data System: Records are retained for 25 years after an individual separates from the government and then the records are purged.

• EDHA 16 DoD, Special Needs Program Management Information System (SNPMIS) Records: Records are maintained until no longer needed for current business.

• EDHA 07, Military Health Information System: Disposition pending (treat records as permanent until the National Archives and Records Administration have approved the retention and disposition schedule).

• OSD/JS, DMDC 02 Defense Enrollment Eligibility Reporting Systems (DEERS): Records are maintained until no longer needed for current business.

Department of Defense Education Activity

• DoDEA 26, Department of Defense Education Activity Dependent Children's School Program Files: Documents and electronic records on enrollment and registration, school registration forms, parental correspondence, other notes and related information and similar records are destroyed five (5) years after transfer, withdrawal, or death of student. Tutor record files are destroyed six (6) years and three (3) months after period covered by account. Records of students not approved for the program are destroyed one year after end of school year.

• DoDEA 29, DoDEA Non-DoD Schools Program: Documents and electronic records on enrollment and registration, school registration forms, parental correspondence, other notes and related information and similar records are destroyed five (5) years after transfer, withdrawal, or death of student. Tutor record files are destroyed six (6) years and three (3) months after period covered by account. Records of students not approved for the program are destroyed one year after end of school year.

11. Sensitive Questions

All of the information on DD Form 2792 and DD Form 2792-1 is considered sensitive. The forms collect information about family members and their medical or educational needs. The purpose of the forms, however, requires that such information be collected so that the medical and educational needs can be met in the location they reside.

The DD Forms 2792 and 2792-1 are used to help match the needs of family members with the locations where their special needs can be met. Complete information increases the likelihood that the recommendation will accurately reflect the needs.

In considering the health and safety of these family members, decisions are made on an individual basis, not solely on a diagnosis. Gender provides additional information that is relevant to medical care. There is increased prevalence and severity of certain conditions that have a gender basis. There are chromosomal conditions that have gender differences regarding prognosis and types of care. There are gender differences in medication management.

In the special needs population, there are developmental issues that present differently depending on gender, especially in early intervention and preschool-aged populations.

Gender provides necessary information that helps to clarify the interventions and supports necessary to manage certain conditions and diseases.

12. Respondent Burden and its Labor Costs

Part A: ESTIMATION OF RESPONDENT BURDEN

1. Collection Instrument(s)

[DD Form 2792 “Family Member Medical Summary”]

Respondents: Family Members

1. Number of Respondents: 55,828 Family Members

2. Number of Responses Per Respondent: 1

3. Number of Total Annual Responses: 55,828 Family members

4. Response Time: 5 minutes

5. Respondent Burden Hours: 4,652 hours

[DD Form 2792 “Family Medical Summary”]

Respondents: Medical Providers

1. Number of Respondents: 11,166

2. Number of Responses Per Respondent: 1

3. Number of Total Annual Responses: 11,166

4. Response Time: 25 minutes

5. Respondent Burden Hours: 4,653 hours

[DD Form 2792-1 “Special Education / Early Intervention Summary”]

Respondents: Family Members

1. Number of Respondents: 16,906

2. Number of Responses Per Respondent: 1

3. Number of Total Annual Responses: 16,906

4. Response Time: 5 minutes

5. Respondent Burden Hours: 1,409

[DD 2792-1 “Special Education / Early Intervention Summary”]

Respondents: Special Education Members

1. Number of Respondents: 14,708

2. Number of Responses Per Respondent: 1

3. Number of Total Annual Responses: 14,708

4. Response Time: 20 minutes

5. Respondent Burden Hours: 4,902 hours

2. Total Submission Burden

   1. Total Number of Respondents: 98,608

   2. Total Number of Annual Responses: 98,608

   3. Total Respondent Burden Hours: 15,616 hours

Part B: LABOR COST OF RESPONDENT BURDEN

1. DD Form 2792 “Family Member Medical Summary”

Respondent: Family Member

1. Number of Total Annual Responses: 55,828 Family Members

2. Response Time: 5 minutes

3. Respondent Hourly Wage: $27.17

4. Labor Burden per Response : $2.18

5. Total Labor Burden: $121,705.04

[DD Form 2792 “Family Member Medical Summary”]

Respondents: Medical Providers

1. Number of Total Annual Responses: 11,166

2. Response Time: 25 minutes

3. Respondent Hourly Wage: $100

4. Labor Burden per Response: $42

5. Total Labor Burden: $468,972

[DD Form 2792-1 “Special Education / Early Intervention Summary”]

Respondents: Family Members

1. Number of Total Annual Responses: 16,906

2. Response Time: Response Time: 5 minutes

3. Respondent Hourly Wage: $27.17

4. Labor Burden per Response: $2.18

5. Total Labor Burden: $36,855.08

[DD Form 2792-1 “Special Education / Early Intervention Summary]

Respondents: Special Education Teachers

1. Number of Total Annual Responses: 14,708

2. Response Time: 20 minutes

3. Respondent Hourly Wage: $27.84

4. Labor Burden per Response: $9.19

5. Total Labor Burden: $135,166.52

2. Overall Labor Burden

   1. Total Number of Annual Responses: 98, 608

   2. Total Labor Burden: $762,698.64

Please see below for an explanation of how burden was estimated.

The Respondent hourly wage was determined by using the [Department of Labor Wage Website] ([http://www.dol.gov/dol/topic/wages/index.htm])

13. Respondent Costs Other Than Burden Hour Costs

There are no annualized costs to respondents other than the labor burden costs addressed in Section 12 of this document to complete this collection.

14. Cost to the Federal Government

Part A: LABOR COST TO THE FEDERAL GOVERNMENT

1. DD Form 2792 “Family Member Medical Summary”

1. Number of Total Annual Responses: 55,828

2. Processing Time per Response: 40 minutes

3. Hourly Wage of Worker(s) Processing Responses : $16.37

4. Cost to Process Each Response: $10.97

5. Total Cost to Process Responses: $612,433.16

2. DD Form 2792-1 “Special Education / Early Intervention Summary”

1. Number of Total Annual Responses: 16,906

2. Processing Time per Response: 40 minutes

3. Hourly Wage of Worker(s) Processing Responses : $16.37

4. Cost to Process Each Response: $10.97

5. Total Cost to Process Responses: $185,458.82

3. Overall Labor Burden to the Federal Government

   1. Total Number of Annual Responses: 72,734

   2. Total Labor Burden: $797,891.98

Part B: OPERATIONAL AND MAINTENANCE COSTS

1. Cost Categories

   1. Equipment: $0

   2. Printing: $64,654.46

   3. Postage: $0

   4. Software Purchases: $0

   5. Licensing Costs: $0

   6. Other: $0

Please see below for an estimation of how operational and maintenance costs.

Cost to Print DD Forms 2792 and 2792-1
	Number of Forms Completed per Year	Number of Pages per Form	Printing Cost per Page	Printing Cost
DD Form 2792 “Family Member Medical Summary”	55,828	8	$0.13	$58,061.12
DD Form 2792-1 “Special Education / Early Intervention Summary”	16,906	3	$0.13	$6,593.34
Total	72,734	N/A	N/A	$64,654.46

2. Total Operational and Maintenance Cost: $64,654.46

Part C: TOTAL COST TO THE FEDERAL GOVERNMENT

1. Total Labor Cost to the Federal Government: $797,891.98

2. Total Operational and Maintenance Costs: $64,654.46

3. Total Cost to the Federal Government: $862,546.44

15. Reasons for Change in Burden

The burden has increased since the previous approval due to the fact that the numbers of family members identified with special needs has risen and is expected to rise minimally over the next three years. Additionally, the total dollar amount reflects the increased use of non-military physicians and non-governmental school personnel to complete the forms.

16. Publication of Results

The results of this information collection will not be published.

17. Non-Display of OMB Expiration Date

We are not seeking approval to omit the display of the expiration date of the OMB approval on the collection instrument.

18. Exceptions to “Certification for Paperwork Reduction Submissions”

We are not requesting any exemptions to the provisions stated in 5 CFR 1320.9.