20 CFR 404.716
OMB No. 0960-0097
Justification
Introduction/Authoring Laws and Regulations
Section 205(a) of the Social Security Act gives the Social Security Administration (SSA) broad authority to make rules and regulations, and establish procedures for the taking and furnishing of necessary evidence. Section 20 CFR 404.716 of the Code of Federal Regulations states SSA will ask for other evidence of age in the absence of preferred evidence of age (birth or religious record established before age five) for Title II retirement benefit requests. The SSA-1535-U3, Application for Search of Census Records for Proof of Age, is one of the forms that SSA uses to obtain evidence of age from the Bureau of the Census when preferred evidence of age, as described above, is unavailable from the claimant.
Description of Collection
An applicant for Title II retirement benefits must provide proof of age to obtain a benefit. When we are unable to determine proof of age, SSA may ask the U.S. Department of Commerce, Bureau of the Census, to search its records to establish a claimant’s date of birth. SSA sends Form SSA-1535-U3, Application for Search of Census Records for Proof of Age, to the Bureau of the Census after a respondent who does not have preferred evidence of age completes the form. The SSA‑1535-U3 provides the Bureau of the Census with sufficient identifying information about the respondent to allow an accurate search of census records to establish proof of age for the respondent. In addition, a completed SSA-1535-U3 is the formal request and, when signed by an authorized SSA employee, serves as the mechanism by which the Bureau of the Census bills SSA for the search. The respondents are applicants for Title II Social Security benefits who need to establish their age as a factor of entitlement.
Use of Information Technology to Collect the Information
This collection does not currently have a fully public-facing Internet version, as we prioritized other information collections for full electronic conversions. As per our 4/3/20 conversation with OIRA, we welcome OIRA to join our conversations with OMB on IT Mods; however, as our IT Mod programming is an ongoing project, we cannot provide timelines for when we will be able to make any particular ICR available via the Internet. We will convert existing ICRs to full electronic versions depending on how they fall within our overall IT Mod schema, but this is unconnected to the PRA approval lifecycle.
Why We Cannot Use Duplicate Information
The nature of the information we collect and the manner in which we collect it preclude duplication. SSA does not use another collection instrument to obtain similar data.
Minimizing Burden on Small Respondents
This collection does not affect small businesses or other small entities.
Consequence of Not Collecting Information or Collecting it Less Frequently
If we did not use Form SSA-1535-U3, we could not assist individuals needing a census record as evidence of age. Because we only use this form on an as needed basis, we cannot collect this information less frequently. There are no technical or legal obstacles to burden reduction.
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.
Solicitation of Public Comment and Other Consultations with the Public
The 60-day advance Federal Register Notice published on November 27, 2020 at 85 FR 76142, and we received no public comments. The 30-day FRN published on January 28, 2021 at 86 FR 7446. If we receive any comments in response to this Notice, we will forward them to OMB.
Correction Notice: The first Federal Register Notice shows incorrect burden information for the SSA‑1535-U3. We have corrected for this in the second Notice, in #12 below, and on ROCIS.
Payment or Gifts to Respondents
SSA does not provide payments or gifts to the respondents.
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.
Justification for Sensitive Questions
The information collection does not contain any questions of a sensitive nature.
Estimates of Public Reporting Burden
Please see the burden chart below:
Modality of Completion |
Number of Respondents |
Frequency of Response |
Average Burden Per Response (minutes) |
Estimated Total Annual Burden (hours) |
Average Theoretical Hourly Cost Amount (dollars)* |
Average Wait Time in Field Office (minutes)** |
Total Annual Opportunity Cost (dollars)*** |
SSA-1535 |
15 |
1 |
12 |
3 |
$25.72* |
24** |
$231*** |
* We based this figure on the average U.S. citizen’s hourly salary, as reported by the U.S. Bureau of Labor Statistics (https://www.bls.gov/oes/current/oes_nat.htm).
** We based this figure on the average FY 2020 wait times for field offices, based on SSA’s current management information data.
*** 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.
In addition, OMB’s Office of Information and Regulatory Affairs is requiring SSA to use a rough estimate of a 30-minute, one-way, drive time in our calculations of the time burden for this collection. OIRA based their estimation on a spatial analysis of SSA’s current field office locations and the location of the average population centers based on census tract information, which likely represents a 13.97-mile driving distance for one-way travel. We depict this on the chart below:
Total Number of Respondents Who Visit a Field Office |
Frequency of Response |
Average One-Way Travel Time to a Field Office (minutes) |
Estimated Total Travel Time to a Field Office (hours) |
Total Annual Opportunity Cost for Travel Time (dollars)**** |
15 |
1 |
30 |
8 |
$206 |
****We based this dollar amount on the Average Theoretical Hourly Cost Amount in dollars shown on the burden chart above.
Per OIRA, we include this travel time burden estimate under the 5 CFR 1320.8(a)(4), which requires us to provide “time, effort, or financial resources expended by persons [for]…transmitting, or otherwise disclosing the information,” as well as 5 CFR 1320.8(b)(3)(iii) which requires us to estimate “the average burden collection…to the extent practicable.” SSA notes that we do not obtain or maintain any data on travel times to a field office, nor do we have any data, which shows that the average respondent drives to a field office, rather than using any other mode of transport. SSA also acknowledges that respondents’ mode of travel and, therefore, travel times vary widely dependent on region, mode of travel, and actual proximity to a field office.
NOTE: We included the total opportunity cost estimate from this chart in our calculations when showing the total opportunity cost estimates in the paragraph below.
The total burden for this ICR is 3 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $437. SSA does not charge respondents to complete our applications.
Annual Cost to the Respondents (Other)
This collection does not impose a known cost burden to the respondents.
Annual Cost To Federal Government
The annual cost to the Federal Government is approximately $910. This estimate accounts for costs from the following areas:
Description of Cost Factor |
Methodology for Estimating Cost |
Cost in Dollars* |
Designing and Printing the Form |
Design Cost + Printing Cost |
$0 |
Distributing, Shipping, and Material Costs for the Form |
Distribution + Shipping + Material Cost |
$10 |
SSA Employee (e.g., field office, 800 number, DDS staff) Information Collection and Processing Time |
GS-9 employee x # of responses x processing time |
$900 |
Full-Time Equivalent Costs |
Out of pocket costs + Other expenses for providing this service |
$0 |
Systems Development, Updating, and Maintenance |
GS-9 employee x man hours for development, updating, maintenance |
$0 |
Quantifiable IT Costs |
Any additional IT costs |
$0 |
Total |
|
$910 |
* 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. First, since we work with almost every US citizen, we often do bulk mailings, and cannot track the cost for a single mailing. In addition, it is difficult for us to break down the cost for processing a single form, as field office staff often help respondents fill out several forms at once, and the time it takes to do so can vary greatly per respondent. As well, 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 (GS-9) for these calculations. However, we have calculated these costs as accurately as possible based on the information we collect for creating, updating, and maintaining these information collections.
Program Changes or Adjustments to the Information Collection Request
When we last cleared this IC in 2017, the burden was 3,606 hours. However, we are currently reporting a burden of 3 hours. This change stems from a decrease in the number of responses from 18,030 to 15. Over the past several years, hospitals have been automatically reporting births to the state and generating birth certificates. In addition, SSA streamlined the proof of age policy so we are able to use the information previously established within our systems. Both of these actions significantly reduced the need for applicants to provide proof of age. There is no change to the burden time per response. These figures represent current Management Information data.
SSA will not publish the results of the information collection.
Displaying 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.
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).
Collection of Information Employing Statistical Methods
SSA is not using statistical methods for this information collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | May 2000 |
| Author | Liz Calvo |
| File Modified | 0000-00-00 |
| File Created | 2021-02-04 |