A. Justification
Introduction/Authoring Laws and Regulations
Section 205(c)(2)(A) of the Social Security Act and 20 CFR 404.702 of the Code of Federal Regulations require the Social Security Administration (SSA) to establish and maintain records of the wages and self-employment income of individuals. Whenever we receive reported earnings under a Social Security Number (SSN) that does not belong to a worker, SSA must identify the worker, determine the correct SSN to which SSA should credit the earnings, and remove the earnings from the incorrect Social Security record.
Description of Collection
When two or more individuals report earnings under the same SSN, SSA collects information on Form SSA-4156 to credit the earnings to the correct individual and the correct SSN. We send the SSA-4156 to the employer to: (1) identify the employees involved; (2) resolve the discrepancy; and (3) credit the earnings to the correct SSN. The respondents are employers involved in erroneous wage reporting for an employee.
Use of Information Technology to Collect the Information
This collection does not currently have a fully public-facing Internet version, as we prioritized other information collections for full electronic conversions. As per our 4/3/20 conversation with OIRA, we welcome OIRA to join our conversations with OMB on IT Mods; however, as our IT Mod programming is an ongoing project, we cannot provide timelines for when we will be able to make any particular ICR available via the Internet. We will convert existing ICRs to full electronic versions depending on how they fall within our overall IT Mod schema, but this unconnected to the PRA approval lifecycle.
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.
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-4156, SSA would be unable to resolve discrepancies when two or more individuals show earnings under the same SSN. Because we only collect the 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.
Solicitation of Public Comment and Other Consultations with the Public
The 60-day advance Federal Register Notice published on July 29, 2020 at 85 FR 45723, and we received no public comments. The 30-day FRN published on September 25, 2020 at 85 FR 60509. If we receive any comments in response to this Notice, we will forward them to OMB.
Payment or Gifts to Respondents
SSA does not provide payments or gifts to the respondents.
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.
Justification for Sensitive Questions
Item 6 of Form SSA-4156 asks for a physical description of the employee, which we only use to assist with identification. In these situations, SSA knows at least one worker is using another worker’s name or SSN. When SSA is unable to contact the persons involved, we need physical descriptions to distinguish between the SSN holder and the employee who is using the incorrect SSN. If SSA is able to contact one of the individuals involved, we use the information for identification purposes only.
Estimates of Public Reporting Burden
Please see the burden chart below:
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-4156 |
3,600 |
1 |
10 |
600 |
$25.72* |
24** |
$52,469*** |
* We based this figure on average U.S. worker’s hourly wages, 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)**** |
3,600 |
1 |
30 |
1,800 |
$46,296 |
**** 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.
The total burden for this ICR is 600 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $98,765. SSA does not charge respondents to complete our applications.
13. Annual Cost to the Respondents (Other)
This collection does not impose a known cost burden on the respondents.
Annual Cost To Federal Government
The annual cost to the Federal Government is approximately $ 24,822. 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 |
$212 |
SSA Employee (e.g., field office, 800 number, DDS staff) Information Collection and Processing Time |
GS-9 employee x # of responses x processing time |
$21,190 |
Systems Development, Updating, and Maintenance |
GS-9 employee x man hours for development, updating, maintenance |
$3,420 |
Total |
|
$24,822 |
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
When we last cleared this IC in 2017, the burden was 792 hours. However, we are currently reporting a burden of 600 hours. This change stems from a decrease in the number of responses from 4,750 to 3,600. There is no change to the burden time per response. Although the number of responses changed, SSA did not take any actions to cause this change. These figures represent current Management Information data.
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 |
| File Title | Title of Information Collection and Form Number(s) |
| Author | Naomi |
| File Modified | 0000-00-00 |
| File Created | 2021-01-13 |