SUPPORTING STATEMENT
Application for United States Flag for Burial Purposes
Justification
Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.
The Department of Veterans Affairs (VA) through its Veterans Benefits Administration (VBA), administers an integrated program of benefits and services, established by law, for veterans, service personnel, and their dependents and/or beneficiaries. A U.S. flag may be provided to the next-of-kin or friend of a deceased veteran who served honorably in the U. S. armed forces to drape the casket or accompany the urn. Information is requested by this form under the authority of 38 U.S.C. 2301. Regulatory authority is found in 38 CFR 1.10.
Indicate how, by whom, and for what purposes the information is to be used; indicate actual use the agency has made of the information received from current collection.
VA Form 27-2008 is used for the sole purpose of gathering the necessary information to determine eligibility for issuance of a burial flag to the next-of-kin or friend of a deceased Veteran.
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.
VA Form 27-2008 is available online on the VA Forms web page fillable electronic format on https://vbaw.vba.va.gov/bl/20/cio/20s5/forms/VBA-27-2008-ARE.pdf. VBA is currently hosting the form on a secure server and does not currently have the technology in place to allow for the complete submission of the form. Validation edits are performed to assure data integrity. Efforts within VA are underway to provide a mechanism to allow the information to be submitted electronically with a recognized signature technology. There currently is no utility process in place that will allow the data submitted on the forms to be incorporated with an existing centralized legacy database.
Describe efforts to identify duplication. Show specifically why all similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
Program reviews were conducted to identify potential areas of duplication; however, none were found to exist. There is no known Department or Agency which maintains the necessary information, nor is it available from other sources within our Department.
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
The collection of information does not involve small businesses or entities.
.
Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently as well as any technical or legal obstacles to reducing burden.
VA compensation and pension programs require claimants to file an application for benefits subsequent to the death of the veteran to determine eligibility for the benefit. Collection of this information is conducted at the time the next-of-kin or friend of a deceased veteran requests a burial flag. Without the information collected by VA Form 21-208, entitlement to the benefit could not be determined.
Explain any special circumstances that would cause an information collection to be conducted more often than quarterly or require respondents to prepare written responses to a collection of information in fewer than 30 days after receipt of it; submit more than an original and two copies of any document; 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 and require the use of a statistical data classification that has not been reviewed and approved by OMB.
There are no special circumstances requiring that the collection of information be conducted in a manner inconsistent with the guidelines in 5 CFR Section 1320.6.
If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the sponsor’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by sponsor in response to these comments. Specifically address comments received on cost and hour burden.
The last Department notice was published in the Federal Register on, December 30, 2020, Volume 85, No. 250, pages 86652 and 86653. No comments were received.
Explain any decision to provide any payment or gift to respondents.
The information collected is supplied by the respondent. No remuneration is made.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statue, regulation, or agency policy.
The records are maintained in the appropriate Privacy Act System of Records identified as 58VA21/22, "Compensation, Pension, Education and Rehabilitation Records - VA" as set forth in Privacy Act Issuances, 1993 compilation found in 42 Fed. Reg. 49726 (9/27//1977).
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; include 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.
There are no questions of a sensitive nature.
Estimate of the hour burden of the collection of information:
Estimate of Information Collection Burden:
Number of Respondents: 753,000 per year
b. Frequency of Response: one time per Veteran’s family
c. Annual Burden Hours: 535,026 hours
d. Estimated Completion Time: 15 minutes
e. The respondent population is composed of the general population. VBA cannot make further assumptions about the population of respondents because of the variability of factors such as the educational background and wage potential of respondents. Therefore, VBA used general wage data to estimate the respondents’ costs associated with completing the information collection.
The Bureau of Labor Statistics gathers information on full-time wage and salary workers. Accordingly, the median weekly earnings of full-time wage and salary workers is $954.40. Assuming a forty (40) hour work week, the median hourly wage is $24.98 based on the BLS wage code – “00-0000 All Occupations”.
Legally, respondents may not pay a person or business for assistance in completing the information collection and a person or business may not accept payment for assisting a respondent in completing the information collection. Therefore, there are no expected overhead costs for completing the information collection. VBA estimates the total cost to all respondents to be $4,721,220 (189,000 burden hours x $24.98 per hour).
Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.
This submission does not involve any record keeping costs.
Provide estimates of annual cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
Estimated Costs to the Federal Government:
Grade |
Step |
Burden Time |
Fraction of Hour |
Hourly Rate |
Cost Per Response |
Total Responses |
Total |
7 |
3 |
30 |
0.50 |
$19.06 |
9.350 |
753,000 |
$ 7,040,550.00 |
Overhead at 100% Salary |
$ 7,040,550.00 |
||||||
9 |
3 |
30 |
0.50 |
$23.32 |
11.660 |
753,000 |
$ 8,779,980.00 |
Overhead at 100% Salary |
$ 8,779,980.00 |
||||||
11 |
3 |
15 |
0.25 |
$28.21 |
7.053 |
753,000 |
$ 5,310,909.00 |
Overhead at 100% Salary |
$ 5,310,909.00 |
||||||
|
|
||||||
Processing / Analyzing Costs |
$ 21,131,439.00 |
||||||
Printing and Production Cost |
$ 23,500.00 |
||||||
Total Cost to Government |
$ 21,154,939.00 |
||||||
Overhead costs are 100% of salary and are same as the wage listed above and the amounts are included in the total.
Note: The hourly wage information above is based on the hourly 2020 General Schedule (Base) Pay (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2017/GS_h.pdf ). This rate does not include any locality adjustment as applicable.
The processing time estimates above are based on the actual amount of time employees of each grade level spend to process to completion a claim received on this form. The within-grade step (3) of each employee represents the average experience of employees within each grade.
Explain the reason for any program changes or adjustments reported in Items 13 or 14 of OMB 83-I.
Burden increase due to an increase in the number of requests for issuance of a burial flag.
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.
This information is collected for insurance purposes only and there are no plans for publication.
If seeking approval to omit the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
We are not seeking to omit the expiration date for OMB approval.
Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB 83-I.
There are no exceptions to the certification statement identified in Item 19 of OMB Form 83-1
The Veterans Benefits Administration does not collect information employing statistical methods.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | BO SURVEY |
| Author | issrfore |
| File Modified | 0000-00-00 |
| File Created | 2021-03-12 |