3220-0176

OMB NO. 3220-0176

Justification

Representative Payee Parental Custody Monitoring

RRB Form G-99d

1. Circumstances of information collection - Under Section 12(a) of the Railroad Retirement Act, the Railroad Retirement Board (RRB) (45 U.S.C. 231k) is authorized to select, make payments to, and conduct transactions with, a beneficiary's relative or some other person willing to act on behalf of the beneficiary as a representative payee. The RRB is responsible for determining if direct payment to a beneficiary or payment to a representative payee would best serve the beneficiary's interest.

Inherent in the RRB's authorization to select a representative payee is the responsibility to monitor the payee to assure that the beneficiary's interests are protected. Currently, the RRB has three basic categories of representative payees: (1) court appointed, (2) RRB appointed, and (3) parent-for-child. There are subcategories of these types of representative payees, based on various factors such as representative payee performance and the beneficiary’s living arrangements. One-third of the payees in categories one and two are monitored by the RRB every year so that each payee reports on a triennial basis (OMB Information Collection 3220-0151, Representative Payee Monitoring), with some representative payees monitored annually based on either a random selection or prior reporting performance . The RRB requires court-appointed payees to provide copies of the court accounting records and RRB-appointed payees to provide summarized accounting records.

All parent-for-child representative payees are monitored annually to verify that the parent retains custody of the child. The last monitoring was conducted in April 2020.

The monitoring of representative payee accountability by the RRB is prescribed in 20 CFR 266.7.

2. Purposes of collecting/consequences of not collecting the information - Form G-99D, Parental Custody Report, is computer-generated by the RRB when conducting the parent-for-child payee monitoring program, as the initial request for verification from the parent that they have custody of the child. The form is released from RRB headquarters directly to the payee, along with an envelope for its return to the responsible RRB field office shown in the lower portion of the form.

The parent-for-child payee's name, address, and other identifying information in the top portion of the form and the name and address of the responsible field office shown in the bottom portion of the form are pre-filled before the form is released.

The RRB field office is responsible for controlling the return of the completed Form G-99D within 30 days. If the initial form is not returned within the 30 days, the field office releases a follow-up Form G-99D showing "SECOND REQUEST" printed at the top of the form. If the follow-up Form G-99D is not returned after 15 days, the field office secures completion of Form G-99C, Representative Payee Evaluation Report, OMB No. 3220-0151. If the returned Form G‑99D indicates that the parent no longer has custody of the child, the field office initiates an investigation, which could result in a suspension of benefit payments, or the designation by the RRB of another representative payee in place of the parent.

The RRB proposes the following changes to Form G-99d:

• Minor change item 4 layout.

• Add new item 6 to solicit the total amount of railroad retirement benefits received for the child during the reporting period.

• Add new item 7 to solicit the dollar amount of railroad retirement benefits used for the child during the reporting period.

• Add new item 8 to solicit a description of how the railroad retirement benefits were used for the child during the reporting period.

• Add new item 9 to solicit how the surplus railroad retirement benefits, if any, were held for the child, for example, in cash, a checking account, a savings account, or other means and the tittle of any checking or savings accounts holding surplus benefits.

• Renumbered item 6 Certification to item 10.

• Update to the Paperwork Reduction Act and Privacy Act Notices to change the burden time from 5 to 15 minutes.

In addition to the required review under the Paperwork Reduction Act, Form G-99D was reviewed by staff from the RRB’s Office of General Counsel (OGC) and Office of the Inspector General (OIG). The OGC advised that the form was legally acceptable. Subsequently, the form has been reviewed and endorsed for use (pending OMB approval) by the RRB’s Board Members.

3. Planned use of improved information technology or technical/legal impediments to further burden reduction - None planned at this time. Not practicable as form is issued by RRB with pre-filled data.

4. Efforts to identify duplication - Form G-99D is similar to Form SSA-624-F5, Representative Payee Evaluation Report, OMB No. 0960-0069. The RRB is unable to use this form because it asks for information specific to SSA and SSA beneficiaries. This information collection does not duplicate any other RRB information collection.

5. Small business respondents - N.A.

6. Consequences of less frequent collection - Each payee will report on a triennial basis. Less frequent reporting would not be advisable considering the circumstances.

7. Special Circumstances - None

8. Public comments/consultations outside the agency - In accordance with 5 CFR 1320.8(d), comments were invited from the public regarding the information collection. The notice to the public was published on page 58077 of the September 17, 2020, Federal Register. No requests for further information or comments were received.

9. Payments or Gifts to Respondents - None

10. Confidentiality - Privacy Act System of Records, RRB-22, Railroad Retirement, Survivor, and Pensioner Benefit System. In accordance with OMB Circular M-03-22, a Privacy Impact Assessment for this information collection was completed and can be found at https://www.rrb.gov/sites/default/files/2017-06/PIA-BPO.pdf.

11. Sensitive questions - There are no questions of a sensitive nature.

12. Estimate of respondent burden - The current and proposed estimated annual burden for this information collection is as follows.

Current Burden

Form Number	Annual Responses	Time (Minutes)	Burden (Hours)
G-99d	800	5	67
Total	800		67

Proposed Burden

Form Number	Annual Responses	Time (Minutes)1/	Burden (Hours)
G-99d	2,100	15	525
Total	2,100		525

1/The RRB has been collecting the information on these forms since OMB approved the information collection. Based on a sampling done when the form was originally created, the office calculated the estimated time, which includes time for getting the needed data and reviewing the completed form.

Responses Hours

Total burden Change 1.300 +458

Adjustment 1,300 +458

12. Estimate of annual cost to respondents or record keepers - N.A.

12. Estimated cost to Federal Government - N.A.

12. Explanation for changes in burden - The overall burden estimated for the collection has

increased by 1,300 from 800 to 2,100 and the burden hours have increased by 458 hours from 67 to 525 hours.

The increase is due to the addition of four questions on the form that will increase the time required to gather information and to complete the form.

12. Time schedule for data collection and publication - The results of this collection will not be

published.

17. Request to not display OMB expiration date – The RRB started an extensive multi-year IT Modernization Initiative at the beginning of Fiscal Year 2019 to transform our operations into the 21^st Century using multiple contractor services to improve mission performance, expand service capabilities, and strengthen cybersecurity. In addition, we received a new Chief Information Officer (CIO) on September 2, 2019 who is reviewing our estimated project timeline milestone dates. We provided OMB with a consolidated project timeline.

Given that the forms in this collection are seldom revised; the costs associated with redrafting, reprinting, and distributing forms in order to keep the appropriate OMB expiration date in place; and our desire to reevaluate after the completion of the modernization project, the RRB requests the authority to not display the expiration date on the forms.

18. Exceptions to Certification Statement - None

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