FEHB_IVR_OMBSuppStmt_2020

FEHB_IVR_OMBSuppStmt_2020.docx

Federal Employee Health Benefits (FEHB) Open Season Express Interactive Response (IVR) System

OMB: 3206-0201

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OMB SUPPORTING STATEMENT


Federal Employees Health Benefits (FEHB) Open Season Express

Interactive Voice Response System (IVR) and Open Season Website


A. 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, Chapter 89, sections 8905 and 8905A specify the opportunities and

conditions under which a retiree, survivor annuitant, or former spouse of a retiree is eligible to

enroll or to change enrollment in the Federal Employees Health Benefits Program (FEHBP). The

FEHB Open Season Express IVR is used by retirees and survivors; it collects information for

changing FEHB enrollments, requesting plan brochures, requesting a change of address,

requesting cancellation or suspension of FEHB benefits, requesting to pay premiums directly

when the FEHB premium is greater than the monthly amount, or requesting a copy of the FEHB

Plan Accreditation and Customer Satisfaction Survey results.


  1. 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.


Retirement Services, OPM, determines whether all conditions permitting change in enrollment are met and implements the enrollment change. OPM also informs the health benefits carriers of the action. If this information were not collected, OPM could not comply with the provisions of title 5, U.S. Code, Chapter 89. Any change of address indicated is recorded in our data base. We have made editorial text changes to this information collection request (ICR). Including, updating the 2020 Federal Benefits Open Season dates. 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).


  1. 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.


In 1997, we implemented the Interactive Voice Response (IVR) system. This technology has improved our response to customers. This IVR system is a computer-based telephone system available 24 hours a day, 7 days a week. Annuitants will respond to OPM by using this system and their Personal Identification Number. This system gives the annuitants the ability to change their address, make a health benefits enrollment change, request plan brochures, request information on paying premiums directly to OPM, request satisfaction survey results, and request information on canceling or suspending their enrollment. No other information will be collected. The information collected can only be obtained from the respondents. The initial open season package contains a personalized cover letter, an Open Season Health Benefits Guide, and instructions on how to use the IVR system. Additionally, in 1998 we implemented an interactive web site where annuitants can do the same transactions available through the IVR system. If an annuitant requests additional open season information, such as plan brochures, we will provide the information needed along with a shorter version of the personalized cover letter and the same materials we provided in the initial package.


  1.  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.


Certifications are filed individually because this information is not available elsewhere. Duplication is minimized.


  1.  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 information collection request has no impact on small businesses and organizations.


  1. 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.


This information is collected annually during the health benefits open season at the discretion of

the respondent. The opportunity to change FEHBP enrollment at open season is a provision of

title 5, U.S. Code, Chapter 89.


  1. 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.


This information collection is consistent with the guidelines in 5 CFR 1320.6, except that the respondent must reply by the end of open season in order to effect the change at the beginning of the calendar year. Changes requested after open season ends cannot be implemented unless OPM has agreed to the delay.


  1. 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 April 14, 2020, Volume 85 FR 20727, giving persons outside the agency an opportunity to comment. No comments were received.


  1. 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 respondents, except any court-ordered benefits that are payable.


  1. 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 regulation
(5 CFR 831.106). The routine uses of 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 350,100 responses per year to the IVR and web system. The frequency of

response is on occasion. Each response takes approximately 10 minutes to complete. The annual

burden is 58,350 hours. The burden estimate is based on the combined number of responses

through the IVR and web.


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

Federal Employees Health Benefits (FEHB) Open Season Express Interactive Voice Response System (IVR) and Open Season Website

FEHB IVR

350,100

1

.167

58,350

$3.60

$1,575,450.00

The Total Annual Respondent Cost is $1,575,450.00.

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 change in the respondent burden.

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 estimated cost to the Federal government is $268,500. 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.


N/A


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.


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.




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