Supporting Statement - 0546

Supporting Statement for Form SSA-L8125 and the Electronic Interim Assistance Reimbursement (eIAR) Process

20 CFR 416.1901, 416.1902, 416.1904, 416.1906, 416.1908, 416.1910, 416.1920, 416.1922

OMB Control No. 0960-0546

1. Justification

1. Introduction/Authoring Laws and Regulations

Sections 20 CFR 416.1901, 416.1902, 416.1904, 416.1906, 416.1908, 416.1910, 416.1920, 416.1922 of the Code of Federal Regulations, Section 1631(g) of the Social Security Act (Act), Public Law (P.L.) 94-365, and P.L. 100-203 of the Omnibus Budget Reconciliation Act of 1987 authorize the Social Security Administration (SSA) to reimburse State or local Interim Assistance Reimbursement (IAR) agencies for certain payments.

2. Description of Collection

When an individual begins to receive interim assistance (IA), the individual receiving the IA payment signs an authorization form with an IA agency to allow SSA to repay the IA agency for funds paid in advance prior to SSA’s determination on the individual’s claim. The authorization represents the individual’s intent to file for Supplemental Security Income (SSI), if they did not file an application prior to SSA receiving the authorization. Agencies who wish to enter into an IAR agreement with SSA need to meet the following requirements:

• Reporting Requirements – Each IA agency agrees to

  • (a) notify SSA of receipt of an authorization for initial claims or cases they are appealing, and (b) submit a copy of that authorization either through a manual or electronic process;

  • (c) inform SSA of the amount of reimbursement;

  • (d) submit a written request for dispute resolution on a determination;

  • (e) notify SSA of interim assistance paid (using the eIAR system or the SSA‑L8125);

  • (f) inform SSA of any deceased claimants who participate in the IAR program and;

  • (g) review and sign an agreement with SSA.

• Recordkeeping Requirements (h & i) – The IA agencies agree to retain all notices, agreement, authorizations, and accounting forms for the period defined in the IAR agreement for the purposes of SSA verifying transactions covered under the agreement.

• Third Party Disclosure Requirements (j) – Each participating IA agency agrees to send written notices from the IA agency to the recipient regarding payment amounts and appeal rights

• Periodic Review of Agency Accounting Process (k - m) – The IA agency makes the IAR accounting records of paid cases available for SSA review and verification. SSA conducts reviews either onsite or through the mail of the authorization forms; notices to the claimant; and accounting forms. Upon completion of the review, SSA provides a written report of findings to the IA agency director.

Once SSA makes a determination on the SSI claim, SSA notifies the IA agency of the determination (awards and denials). If SSA denies the claim or does not reinstate SSI benefits, SSA takes no further action unless the individual files an administrative appeal or appeals to a court, as appropriate. If the individual files an appeal, SSA notifies the IA agency and the claim moves through the appeal process. If SSA ultimately denies the case, neither SSA nor the agency takes further action. If SSA approves the claim or appeal, SSA notifies the IA agency and the reimbursement process begins.

Thirty-seven States and the District of Columbia participate in the IAR program. The IAR agreements with the States and the District of Columbia include the following requirements (the letters below correspond to those on the chart in #12):

1. State Notification of Receipt of Authorization (Electronic Process): The IA agency must notify SSA within a certain timeframe that the State has a valid authorization, which the individual signed allowing SSA to reimburse the State through the IAR process. The IA agency may do this through one of several State computer exchange processes.

2. State Submission of Copy of Authorization (Manual Process): The IA agency must submit to SSA within a certain timeframe a paper copy of the valid authorization, which the individual signed allowing SSA to reimburse the State through the IAR process. Some States prefer to use the manual process instead of the electronic process.

3. Computation of Amount of Reimbursement Due From SSA (eIAR system):

The electronic Interim Assistance Reimbursement (eIAR) system is an electronic process that uses computer screens located in the Government-to-Government Services Online (GSO) website. If SSA approves the SSI claim or reinstates SSI eligibility, SSA reimburses the IA agency for assistance it paid the recipient using the eIAR system or the paper Form SSA-L8125.

4. State Request for Determination – Dispute Resolution: If SSA and a state cannot agree on an issue in dispute under the agreement, the state may request that the Commissioner make a determination on the issue. The Commissioner’s determination is final and conclusive. The state maintains the right to seek judicial review. The Commissioner maintains the right to assert lack of jurisdiction with respect to any suit brought under the agreement.

5. Form SSA‑L8125: For cases falling under P.L. 100-203 and P.L. 108-203, covering installment payments; dedicated accounts; and direct pay for authorized representatives, SSA must ensure an IA agency does not send a residual payment to a recipient affected by these provisions. SSA does not mail the retroactive check to the IA agency. Instead, at the time of an award or reinstatement, SSA’s automated system generates an SSA-L8125 listing the SSI months and amounts in the IAR period to the agency to record the amounts of the assistance given the recipient in the same month the recipient is eligible for a SSI payment. SSA then prints and mails this automatically produced notice to the IA agency. The IA agency will then complete and send the form to the servicing SSA field office for issuance of its IAR check.

6. State Notification to SSA of Deceased Claimant: The IA agency must inform SSA of any deceased claimants. IA agencies may do this electronically through one of several state exchange processes.

7. Review/Signing Agreements: SSA Regional Office (RO) staff negotiates with the state to agree on the specific agreement for that state. The SSA staff has some leeway in revising the language to accommodate the state. However, the SSA central office must approve any changes. The state attaches to the agreement the list of the political subdivisions within the state that SSA and the state agree can participate in the IAR program.

8. Maintenance of Authorization Forms: The IA agency retains all notices and authorization forms for the period defined in the IAR agreement for the purpose of SSA verifying transactions covered under the IAR agreement.

9. Maintenance of Accounting Forms and Notices: The IA agency retains all accounting forms for the period defined in the IAR agreement for the purpose of SSA verifying transactions covered under the IAR agreement.

10. Written notice from State to Recipient Regarding Amount of Payment: The state sends to the recipient a notice explaining: (1) the amount of the IA payment the state paid to the recipient; (2) that SSA will notify the recipients how any remaining SSI money (if any) due to them will be released by SSA; and (3) the recipient’s right to a state hearing.

11. Retrieve and Consolidate Authorization and Accounting Forms: IA agencies must retrieve and consolidate their authorization and accounting forms for cases SSA RO staff identified for a sample review.

12. Participate in Periodic Review: SSA periodically conducts a sample review of IAR accounting records of paid IAR cases to verify the accuracy of the agency accountability report. RO staff review each agency every two or three years and the sample size ranges from 100% of cases (fifteen or fewer) to 35% of cases (greater than seven hundred). SSA provides the sample list to the agency, and RO staff conducts an onsite or mail review of the authorization forms; notices to the claimant; and accounting forms. Upon completion of the review, the RO staff writes and provides a report of findings to the agency Director and the Associate Commissioner for Income Security Programs, SSA.

13. Correct Administrative and Accounting Discrepancies: During the periodic review, if the RO staff finds accounting errors, the errors are resolved, but not necessarily corrected, prior to the completion of the review. If the IA agency does not correct the errors immediately, they will make the corrections shortly after the sample review and notify the RO of the corrections.

The respondents are State IA officers.

3. Use of Information Technology to Collect the Information

SSA created the eIAR Internet application in compliance with the Government Paperwork Elimination Act. All respondents use the eIAR system to report IAR. Currently, 27 States submit paper copies of the IAR authorization form to SSA. The remaining 11 States notify SSA about the IAR authorization using an electronic data exchange process through a matching agreement. We encourage States to use the electronic process but we work with the States to accommodate their preferences for submitting the authorizations and, in some cases, to accommodate limitations in a State’s computer system. For those states who still submit paper copies of the IAR authorization form to SSA, respondents can fax or mail in the authorization form to a local field office, and the field office enters the information into their system through back-end screens; usually as a grant reimbursement code. The eIAR system recieves all the information from the field office’s system except the amount of the IA the state paid the claimant while their claim is pending. The field offices have no access to eIAR.

IA agencies access the eIAR system using the GSO website. SSA communicates with the IA agency about an IAR case using the eIAR screens and email messages generated by the eIAR system. The IA agency communicates with SSA using the eIAR screens. The eIAR system enables the IA agency to use a web-based process to report to SSA how much money it paid to SSI claimants. When SSA approves an SSI claim, the eIAR system determines how much reimbursement is due to the IA agency and automatically pays that money to the IA agency’s bank account.

Based on our current management information data, approximately 99% of respondents under this OMB number use the eIAR Internet version (with the exception of the authorization form; however, we are trying to encourage more states to use eIAR for the authorization form as well). SSA processes the remaining one percent of reimbursement cases using the paper Form SSA‑8125-F6 that requires manual processing by the IA agency and SSA field offices, and which field office personnel must input into the back‑end system prior to the system-to-system transfer to eIAR. SSA offers the Form SSA-8125-F6 as a fillable PDF. SSA continues to encourage all respondents to use our eIAR Internet application; however, we keep the fillable Form available in case respondents need it for those few instances when the system is down for maintenance.

4. Why We Cannot Use Duplicate Information

The nature of the information we collect and the manner in which we collect it precludes 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 collect this information, the IA agencies would not have a way to receive the reimbursement money authorized by the agreement between the State and SSA. SSA collects and uses the information as it becomes available so the IA agency and the recipient can receive any SSI money due them in a timely manner. 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.

8. 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. We did not consult with the public in the maintenance of this form, or the eIAR screens.

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.

In addition, SSA protects information collected electronically through our Privacy Policy for Internet Services that ensures the confidentiality of all information provided by the requester. Our Internet privacy policy is:

• We collect personally identifiable information (name, SSA, DOB or email) only if specifically and knowingly provided by you.

• SSA will use personally identifying information you furnish only in conjunction with services you request as described at the point of collection.

• We sometimes perform statistical analyses of user behavior in order to measure customer interest in the various areas of our site. We will disclose this information to third parties only in aggregate form.

• We do not give, sell, or transfer any personal information to a third party.

• We do not enable “cookies.” (A “cookie” is a file placed on your hard drive by a Web site that allows it to monitor your use of the site, usually without your knowledge.)

SSA will provide access to screens that allow requests for personal information from SSA; allow the individual to make changes to personal information; or allow the individual to register personal and/or business information only upon verification of identity.

11. Justification for Sensitive Questions

The information collection does not contain any questions of a sensitive nature.

12. Estimates of Public Reporting Burden

Listed below is the burden hour estimate for the IAR information collection process included in the IAR Agreement between SSA and the State. The estimate includes reviewing and signing the IAR agreement between the State and SSA, which is a requirement for States that want to participate in the IAR reimbursement process.

Reporting Requirements

Modality of Completion	Number of Respondents (States)	Frequency of Response	Number of Responses	Average Burden Per Response (minutes)	Estimated Total Annual Burden Hours (hours)	Average Theoretical Hourly Cost Amount (dollars)*	Total Annual Opportunity Cost (dollars)**
a) State notification of receipt of authorization (Electronic Process)	11	6,973	76,703	1	1,278	$19.58*	$25,023**
b) State submission of copy of authorization (Manual Process)	27	1,894	51,138	3	2,557	$19.58*	$50,066**
c) State submission of amount of IA paid to recipients (using eIAR)	38	1,346	51,148	8	6,820	$19.58*	$133,536**
d) State request for determination – dispute resolution	(1)	1	2	30	1	$19.58*	$20**
e) State computation of reimbursement due form SSA using paper Form SSA‑L8125 or eIAR	38	1	38	30	19	$19.58*	$372**
f) State notification to SSA of deceased claimant	20	2	40	15	10	$19.58*	$196**
g) State reviewing/signing of IAR Agreement	38	1	38	212	456	$19.58*	$8,928**

Recordkeeping Requirements

Modality of Completion	Number of Respondents (States)	Frequency of Response	Number of Responses	Average Burden Per Response (minutes)	Estimated Total Annual Burden Hours (hours)	Average Theoretical Hourly Cost Amount (dollars)*	Total Annual Opportunity Cost (dollars)**
h) Maintenance of authorization forms	38	3,364	3127,832	3	6,392	$21.09*	$134,807**
i) Maintenance of accounting forms and notices	38	1,346	51,148	3	2,557	$21.09*	$53,927**

Third Party Disclosure Requirements

Modality of Completion	Number of Respondents (States)	Frequency of Response	Number of Responses	Average Burden Per Response (minutes)	Estimated Total Annual Burden Hours (hours)	Average Theoretical Hourly Cost Amount (dollars)*	Total Annual Opportunity Cost (dollars)**
j) Written notice from State to recipient regarding amount of payment	38	2668	101,384	7	11,828	$19.58*	$231,592**

Periodic Review of Agency Accounting Process

Modality of Completion	Number of Respondents (States)	Frequency of Response	Number of Responses	Average Burden Per Response (hours)	Estimated Total Annual Burden Hours (hours)	Average Theoretical Hourly Cost Amount (dollars)*	Total Annual Opportunity Cost (dollars)**
k) Retrieve and consolidate authorization and accounting forms	12	1	12	3	36	$21.09*	$759**
l) Participate in periodic review	12	1	12	16	192	$21.09*	$4,049**
m) Correct administrative and accounting discrepancies	6	1	6	4	24	$21.09*	$506**

Total Administrative Burden

Modality of Completion	Number of Respondents (States)	Frequency of Response	Number of Responses	Average Burden Per Response (minutes)	Estimated Total Annual Burden Hours (hours)	Average Theoretical Hourly Cost Amount (dollars)*	Total Annual Opportunity Cost (dollars)**
Total	38		459,501		32,170		$643,781**

* We based this figure on average Social and Human Services Assistants (https://www.bls.gov/oes/current/oes211093.htm), and Information and Records Clerks (https://www.bls.gov/oes/current/oes434199.htm).

** 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.

The total burden for this ICR is 32,170 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $643,781. 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.

14. Annual Cost To Federal Government

The annual cost to the Federal Government is approximately $352,702.  This estimate accounts for costs from the following areas:

Description of Cost Factor	Methodology for Estimating Cost	Cost in Dollars*
Design & Release Form Costs	Design Cost	$1,036
Distributing, Shipping, and Material Costs for the Form	As stated below SSA does not print or ship this form to field offices or to the public	$0
Printing and mailing/faxing the Form SSA L8125-F6 (from POMS) to the state (e) above by FO employees.	GS-11 employee x # of responses x processing time ($26.45 x 51 x 15 minutes)	$337
Receiving fax/mail of authorization from the state and input the GR code to the record (b) above.	GS-11 employee x # of responses x processing time (26.45 x 51,136 x 10 minutes)	$225,424
Full-Time Equivalent Costs	Out of pocket costs + Other expenses for providing this service	$0
Systems Development, Updating and Maintenance	2 GS-13 employees x man hours for development, updating, maintenance	$125,905
Quantifiable IT Costs	Any additional IT costs	$0
Total		$352,702

* We have inserted a $0 amount for cost factors that do not apply to this collection.

SSA is unable to break down the costs to the Federal government further than we already have.  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 completing this work (GS-11) for these calculations.  We did not include a distributing, shipping, or material cost amount for this collection, as most respondents use the eIAR system, or they print the fillable PDF from our website for themselves (we never distribute this form to field offices or respondents). However, we have calculated these costs as accurately as possible based on the information we collect for creating, updating, and maintaining these information collections

15. Program Changes or Adjustments to the Information Collection Request

When we last cleared this IC in 2017, the burden was 45,216 hours. However, we are currently reporting a burden of 32,170 hours. This change stems from a decrease in the number of responses from 2016 to 2019. 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

For the paper form SSA-L8125, we will not publish 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.

For the electronic version eIAR, SSA is not requesting an exception to the requirement to display the OMB approval expiration date.

18. 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).

2. Collections of Information Employing Statistical Methods

SSA is not using statistical methods for this information collection.

1 Average of about 2 States per year.

2 Hours.

3 Includes both denied and approved SSI claims.