RI38-031_OMBSupportingStmt_2020_12_30

OMB SUPPORTING STATEMENT

RI 38-31 – We Need More Information about Your Missing Payment

1. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

Title 5, U. S. Code, Chapters 83 and 84, authorizes the Office of Personnel Management (OPM) to make monthly payments of retirement benefits, as well as making one-time payments of refunds of retirement deductions and paying lump sums after the death of annuitants and employees. The Department of the Treasury makes these payments in the form of checks or electronic transfers of funds into financial institutions. When a payment is lost, stolen, missing, or does not go into the account of the payee, it is necessary for OPM to obtain a report from the respondent describing the missing payment and stating that the payment was not received or is missing. Such reports may be verbal or written using RI 38-31. When RI 38-31 is used to report that an electronic transfer of funds is missing, the financial institution also states that the payment was not received.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

The Office of Personnel Management (OPM) requests that OMB renew a previously-approved information collection with minor revisions, control number 3206-0187. RI 38-31 is designed to collect all the information needed by OPM and the Department of the Treasury to replace the payment as soon as possible. OPM also collects information about missing payments on the telephone. A written notice about the missing payment is not required. If this information is not collected, OPM cannot arrange for replacement payments.

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 information collected is detailed and can only be obtained from the respondents. There is no technology available to collect this information. However, this form is available on our website in a PDF fillable format and meets our GPEA requirement.

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.

Reports of missing payment are filed individually. There is no duplication because the respondents initiate the collection.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize.

Information is not collected from small businesses or other small entities.

6. Describe the consequence to Federal/DHS program or policy activities if the collection of information is not conducted, or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The collection is needed whenever a payment is reported missing. Less frequent collection would deprive annuitants of their source of income.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

•requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

•requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to 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;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

The collection is consistent with the guidelines in 5 CFR 1320.6.

8. Federal Register Notice: Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice soliciting comments on the information collection prior to submission to OMB.

On March 27, 2020, a 60 Day Federal Register Notice was published at 85 FR 17370 requesting comments. No comments were received.

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

No payment or gift is given to the respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

This information collection is protected by the Privacy Act of 1974 and OPM regulations

(5 CFR 831.106). The routine uses for disclosure appear in the Federal Register for

OPM/Central-1 (73 FR 15013, et seq., March 20, 2008).

1. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the 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.

The information collection does not include questions of a sensitive nature, such as sexual

behavior and attitudes, religious beliefs, and other matters that are commonly considered

private.

12. Provide estimates of the hour burden of the collection of information. The statement

should:

a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desired. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.
c. Provide estimates of annualized cost to respondents for the hour burdens for collections
of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

Approximately 8,000 reports of missing payments are processed each year. Of these, we estimate that 7,800 are reports of missing checks. Approximately 200 reports of missing checks are reported using RI 38-31 and 7,600 are reported by telephone. A response time of ten minutes per form reporting a missing check is estimated; the same amount of time is needed to report the missing checks or electronic funds transfer (EFT) payments using the telephone. The annual burden for reporting missing checks is 1,300 hours. The remaining 200 reports relate to EFT payments. No missing EFT payments are reported using RI 38-31. The annual burden for reporting missing EFT payments is 33 hours.

The total burden is 1,333 hours.

Form Name	Form Number	No. of Respondents	No. of Responses per Respondent	Average Burden per Response (in hours)	Total Annual Burden (in hours)	Average Hourly Wage Rate	Total Annual Respondent Cost
We Need More Information about Your Missing Payment	RI 38-31	8,000	1	.167	1,333	$3.60	$36,000.00

The Total Annual Respondent Cost is $36,000.00.

13. Provide an estimate of the total annual cost burden to respondents or record keepers

resulting from the collection of information. (Do not include the cost of any hour burden

shown in Items 12 and 14.)

The cost estimate should be split into two components: (1) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection as appropriate.

Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information to keep records for the government, or (4) as part of customary and usual business or private practices.

There is no cost to the respondents resulting from the collection of this information.

14. Provide estimates of annualized cost to the Federal Government. Also, provide a description

of the method used to estimate cost, which should include quantification of hours,

operational expenses (such as equipment, overhead, printing and support staff), and any

other expense that would have been incurred without this collection of information. You

may also aggregate cost estimates for Items 12, 13, and 14 in a single table.

The annualized cost to the Federal government is $37,700. The cost is determined by

employee hours devoted to the collection, forms cost, and overhead.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of

the OMB Form 83-I. Changes in hour burden, i.e., program changes or adjustments made to

annual reporting and recordkeeping hour and cost burden. A program change is the result

of deliberate Federal government action. All new collections and any subsequent revisions

of existing collections (e.g., the addition or deletion of questions) are recorded as program

changes. An adjustment is a change that is not the result of a deliberate Federal government

action. These changes that result from new estimates or actions not controllable by the

Federal government are recorded as adjustments.

This currently approved information collection has been adjusted to reflect an updated OMB nomenclature and edition year. The Public Burden Statement meets the requirements of 5 CFR 1320.8(b)(3). The Privacy Act Statement has been revised due to a systematic review by our Chief Privacy Officer.

There are no hour and cost burden changes.

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.

The results of this information collection are not published.

17. If seeking approval to not display the expiration date for OMB approval of the information

collection, explain reasons that display would be inappropriate.

The Retirement Services program office is the lone processor of the data collected on these

ICRs from approximately 2.8 million customers. The substance of each information

collection does not substantively change at each OMB renewal cycle, but according to

changes in law and regulation. These forms are printed and published (internet, intranet and

on-board systems) through various agencies for distribution to and implementation by

Government customers. Pursuant to title 5 CFR 1320.8(b)(1), it would not be appropriate to

display the OMB clearance expiration date where the form will not be revised for the

foreseeable future (e.g., because it is used to collect applicant, annuitant, or beneficiary

information required by long-standing statutory provisions), where use of the paper form is

prevalent, and where, accordingly, it will be expensive and burdensome to restock the paper

forms inventory with a new version. Last year, under current practice, Retirement Services

printed approximately 2 million documents subject to OMB clearance at a cost of

approximately $85,000. Our costs would rise substantially if additional revision cycles are

added. Lastly, by adding the OMB clearance expiration date to the existing format, the end

users of OPM’s ICRs may erroneously assume that the expiration date affects the validity of

the information collection when it is the OMB clearance expiration date and not reflective of

the substance. This may lead to additional submissions by customers, possible litigation and

increasing pressures on our Operations workloads. Therefore, we seek approval to not

display the OMB clearance expiration date on the forms and to communicate version

changes to the public via the revision date. The results of this collection are not published.

18. Explain each exception to the certification statement identified in Item 19 “Certification for
Paperwork Reduction Act Submissions,” of OMB Form 83-I.

There are no exceptions to the certification statement.