OMB SUPPORTING STATEMENT
RI 20-64 - Letter Reply to Request for Information
RI 20-64A - Former Spouse Survivor Annuity Election
RI 20-64B - Information on Electing a Survivor Annuity for Your Former Spouse
Justification
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, Section 8339(j)(3) and Section 8417 state that annuitants may elect, after retirement, to provide survivor annuity benefits for a former spouse.
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.
RI 20-64 is used by the Civil Service Retirement System to provide information about the amount of annuity payable after a survivor reduction, to explain the annuity reductions required to pay for the survivor benefit, and to give the beginning rate of survivor annuity. RI 20-64A is used to make the election, and RI 20-64B, an information booklet, are enclosed. This group of forms is needed to obtain an informed survivor benefits election from annuitants who are eligible to elect to provide survivor benefits for a former spouse. Using RI 20-64A, the annuitant may elect the survivor benefit, obtain any current spouse’s consent to the election, or decline to make the election. RI 20-64 has a space the annuitant may use to ask for information about electing less than the maximum survivor benefit. OPM could not comply with title 5 if this information were not collected. The Privacy Act Statement has been revised due to a systematic review by our Chief Privacy Officer. The Public Burden Statement meets the requirement of 5 CFR 1320.8(b)(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.
Use of information technology is contingent on changes to the law. The information collected is specific to the individual and can only be obtained from the respondents.
They must sign the election form. This form is available in a PDF fillable format on our website and meets our GPEA requirements.
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.
Since the respondents initiate the collection there is no duplication. There is no other way to obtain this information
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.
This collection of information does not impact small businesses and organizations.
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.
If this information were not collected, annuitants would be unable to elect survivor benefits provided by law.
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.
There are no special circumstances involved in the collection of this information.
This information collection is consistent with the guidelines in 5 CFR 1320.8(b)(3).
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.
A 60 day notice of proposed information collection was published in the Federal Register on March 23, 2020, Volume 85 FR 16394, giving persons outside the agency an opportunity to comment. No comments were received.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payment or gift is provided to these respondents, except any court-ordered benefits that are payable.
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).
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.
This 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 30 survivor elections on RI 20-64A will be processed per year and that of these 8 will use RI 20-64 to ask for information about electing a smaller survivor benefit. Form RI 20-64A requires 45 minutes to complete for a burden of 23 hours. Form RI 20-64 requires 8 minutes to complete for a burden of one hour. The total burden is 24 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 |
Letter Reply to Request for Information |
RI 20-64 |
8 |
1
|
.13 |
1
|
$2.80
|
$28.00
|
Former Spouse Survivor Annuity Election |
RI 20-64A |
30 |
1 |
.75 |
23 |
$16.13 |
$605.00 |
The Total Annual Respondent Cost is $633.00.
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 respondent.
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.
We estimate that the annualized cost to the Government is approximately $1,412. This
cost includes employee salary hours devoted to the program, 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.
There is no change in the respondent burden.
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.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | OMB SUPPORTING STATEMENT |
| Author | MEMOORE |
| File Modified | 0000-00-00 |
| File Created | 2021-01-13 |