Supporting Statement - 0015 (Final)

Supporting Statement for Form SSA-521

Request for Withdrawal of Application

20 CFR 404.640

OMB No. 0960-0015

A. Justification

1. Introduction/Authoring Laws and Regulations

20 CFR 404.640 of the Code of Federal Regulations provides an individual with the option to withdraw their application for benefits before or after the Social Security Administration (SSA) makes a determination of eligibility.

Form SSA-521, Request for Withdrawal of Application, allows claimants to specify which application they want to withdraw and the reason for the withdrawal.

2. Description of Collection

SSA employees collect Form SSA-521, which documents the information SSA needs to process the withdrawal of an application for benefits. Form SSA-521 is our preferred instrument for a withdrawal request; however, any written request for withdrawal signed by the claimant or a proper applicant on the claimant’s behalf will suffice. Each time individuals wish to withdraw an application for benefits, they complete and sign Form SSA-521. Typically, respondents complete the form themselves and do not need information from someone else to complete the form. SSA uses the information from the SSA-521 to process the request for withdrawal. The respondents are beneficiaries or applicants for Retirement, Survivors, Disability, and Health Insurance benefits.

2. Use of Information Technology to Collect the Information

SSA created an online Fillable PDF version of Form SSA-521 for individuals to complete, print, and mail to SSA for processing. This collection does not currently have a fully public-facing Internet version, as we prioritized other information collections for full electronic conversions. Given that IT Mod programming is an ongoing, dynamic project, we cannot provide specific timelines for when we will be able to make any particular ICR available via Internet web-based application. We will ultimately convert most existing ICRs to full electronic versions depending on how they fall within our overall IT Mod schema, but this may be unconnected to the PRA approval lifecycle.

In the interim, we evaluated this collection for conversion to a submittable PDF. Given the high volume of conversions we are coordinating and the more urgent nature of some of the other conversions, we ultimately decided not to prioritize this ICR for conversion to fully submittable PDF at this time. When we are able to schedule this form for conversion to a submittable PDF, we will submit a Change Request to OMB to request prior approval.

2. Why We Cannot Use Duplicate Information

The nature of the information we collect and the manner in which we collect it precludes duplication. SSA does not use another collection instrument to obtain similar data.

5. Minimizing Burden on Small Respondents

This collection does not affect small businesses or other small entities.

6. Consequence of Not Collecting Information or Collecting it Less Frequently If we did not use Form SSA-521, claimants would not be able to withdraw their application for benefits. Because we only collect the information on an as needed basis, we cannot collect it less frequently. There are no technical or legal obstacles to burden reduction.

7. 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.

8. Solicitation of Public Comment and Other Consultations with the Public

The 60-day advance Federal Register Notice published on July 2, 2021 at 86 FR 35371, and we received no public comments.  The 30-day FRN published on September 2, 2021 at 86 FR 49403.  If we receive any comments in response to this Notice, we will forward them to OMB.

8. Payment or Gifts to Respondents

SSA does not provide payments or gifts to the respondents.

8. 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.

8. Justification for Sensitive Questions

The information collection does not contain any questions of a sensitive nature.

8. 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)*	Total Annual Opportunity Cost (dollars)**
Respondents applying for or receiving Retirement, Survivors, or Health Insurance benefits.	60,753	1	5	5,063	$10.95*	$55,440**
Respondents applying for or receiving Disability benefits.	14,374	1	5	1,198	$10.95*	$13,118**
Totals	75,127			6,261		$68,558**

* We based this figure on the average DI payments based on SSA's current FY 2021 data (https://www.ssa.gov/legislation/2021FactSheet.pdf).

** 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.

The total burden for this ICR is 6,261 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $68,558. SSA does not charge respondents to complete our applications. We base our burden estimates on current management information data, which includes data from years of conducting this information collection via USPS mail. Per our management information data, we believe that the 5 minutes accurately shows the average burden per response for reading the instructions, gathering the facts, and answering the questions. Based on our current management information data, the current burden information we provided is accurate.

13. Annual Cost to the Respondents (Other)

This collection does not impose a known cost burden on the respondents.

14. Annual Cost To Federal Government

The annual cost to the Federal Government is approximately $649,097. 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	$308
Distributing, Shipping, and Material Costs for the Form	Distribution + Shipping + Material Cost	$0*
SSA Employee (e.g., field office, program service center staff) Information Collection and Processing Time	GS-9 employee x # of responses x processing time	$641,169
Full-Time Equivalent Costs	Out of pocket costs + Other expenses for providing this service (locally printing the form)	$4,200
Systems Development, Updating, and Maintenance	GS-9 employee x man hours for development, updating, maintenance	$3,420
Quantifiable IT Costs	Any additional IT costs	$0*
Total		$649,097

* 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.  It is difficult for us to break down the cost for processing a single form, because so many employees have a hand in each aspect of our forms; therefore, 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.

15. Program Changes or Adjustments to the Information Collection Request

When we last cleared this IC in 2018, the burden was 2,652 hours. However, we are currently reporting a burden of 6,261 hours. This change stems from an increase in the number of responses from 31,827 to 75,127. There is no change to the burden time per response. Although the number of responses changed, SSA did not take any actions to cause this change. The current figures represent the latest Management Information data.

16. Plans for Publication Information Collection Results

SSA will not publish the results of the information collection.

17. 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.

18. 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).

B. Collections of Information Employing Statistical Methods

SSA does not use statistical methods for this information collection.