OMB SUPPORTING STATEMENT
RI 20-7 – Representative Payee Application
RI 30-3 – Information Necessary for a Competency Determination
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, Sections 8345(e) and 8466(c) provide that payment due a minor, or an individual mentally incompetent or under legal disability, may be made to the person who is constituted guardian or other fiduciary by the law of the State of residence of the claimant or is otherwise vested with the care of the claimant or his estate.
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 20-7 is used by the Civil Service Retirement System (CSRS) and the Federal Employees Retirement System (FERS) to collect information from persons who apply to be fiduciaries for annuitants or survivor annuitants who appear to be incapable of handling their own funds or for minor children. The scope of the information requested includes items relating to the capability and the suitability of the applicant to assume responsibility for the annuitant’s benefit, as well as identifying information from the applicant. RI 30-3 is an enclosure to RI 20-7 and is needed for adult annuitants who are alleged to be incompetent. RI 30-3 collects medical information regarding the annuitant’s competency for OPM’s use in evaluating the annuitant’s condition. Failure to collect this information would make it impossible for OPM to make a determination as to whom to pay and thus could deny payment provided by title 5, U.S. Code, Chapters 83 and 84. The Privacy Act Statement (PAS) is current due to a systematic review by our Privacy Officer. The Public Burden Statement meets the requirement of 5 CFR 1320.8(b)(3). We have revised this Information Collection Request (ICR) in the following manner: (1) the display of the OMB control number and (2) minor edits to the Privacy Act Statements.
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.
The information collected is detailed and can only be obtained from the respondents. New methods of information technology would do little to reduce the burden on the respondents; they must sign the application attesting to its truth, under penalty of law, to the best of their knowledge. However, the forms are available in a PDF format on our website and meet 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.
Applications are filed individually. Duplication is minimized.
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.
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 only when OPM must determine whether a person properly should be responsible for handling benefits for an incompetent annuitant. Less frequent collections would be to the disadvantage of the incompetent annuitant.
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 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 is 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.
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
On April 13, 2020, a 60 Day Federal Register Notice was published at 85 FR 20532. No comments were received.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No gifts or payments of any kind have been provided to any individuals who are connected to this collection.
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 regulations (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, effective April 21, 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 includes questions about the annuitant’s medical condition; this information is considered private and is protected by OPM as described in item 10 above. The information must be collected, if there is no court-appointed guardian, in order for OPM to determine whether the annuitant is incompetent. The submission of this information is voluntary. However, if it is not submitted, OPM cannot determine whether the annuitant needs a representative payee.
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.
The number of respondents to RI 20-7 is 12,480; we estimate that it
takes 30 minutes to fill out the form. The annual burden is 6,240
hours. The number of respondents to RI 30-3 is 250; we estimate it
takes 60 minutes to fill out the form. The annual burden is 250
hours. The total burden is 6,490 hours. This burden is not expected
to vary substantially.
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 |
Representative Payee |
RI 20-7 |
12,480 |
1 |
30 minutes |
6,240 |
$10.75 |
$167,700 |
Information Necessary for a Competency Determination |
RI 30-3 |
250 |
1 |
1 hour |
250 |
$21.50 |
$6,718.75 |
Although recent physicians’ reports may be required so that we can make a competency determination, there is no way to estimate the cost to the annuitants because they are paying for their continuing medical care anyway. They do not necessarily have to get a special medical evaluation to fulfill the OPM requirements.
The Total Annual Respondent Cost for this information collection request is $174,418.75.
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.
We have revised this Information Collection Request (ICR) in the
following manner:
(1) the display of the OMB control number and
(2) minor edits to the Privacy Act Statements.
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 annualized cost to the Federal government is $198,850. 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.
No information collected from the form will be 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.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | OMB SUPPORTING STATEMENT |
| Author | MEMOORE |
| File Modified | 0000-00-00 |
| File Created | 2021-02-04 |