OMB SUPPORTING STATEMENT
RI 25-37 – Evidence to Prove Dependency of a Child
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 8341(a)(3) and 8441(3) state that benefits are payable to dependent children. OPM must determine that the children are eligible. RI 25-37 is designed to inform the person applying on behalf of the child of the needed documentation to establish eligibility. RI 25-37 is mailed to the applicants along with a cover letter to explain why OPM is requesting the information.
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.
Based on the evidence provided, OPM determines whether the child is eligible for survivor benefits. If the child is eligible, annuity payments are made. If this information were not collected, payments could not be authorized. This ICR does not require a Privacy Act Statement. This Information Collection Request (ICR) has been revised to update the display of the OMB control number.
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.
New methods of information technology would do little to reduce the burden on the respondents. They must provide a copy of a State court order or affidavits stating specific information about the child. This form is available in a PDF format on our website at www.opm.gov/forms and meets 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.
Documentation is submitted individually. There is no duplication because the respondents initiate the collection.
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.
The collection of this information is performed as needed to determine entitlement and to authorize payment on individual survivor annuity claims. Less frequent collection would deny payments to children of deceased Federal employees and annuitants. This collection is consistent with the guidelines of 5 CFR 1320.6.
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 a 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 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 2, 2021, a 60 Day Federal Register Notice was published at 86 FR 17418. 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 does not include questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.
Provide estimates of the hour burden of the collection of information. The statement
should:
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.
Approximately 250 dependency determinations are made annually. It
takes about one
hour to assemble the needed
documentation. The annual burden is 250 hours.
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 |
Evidence to Prove Dependency of a Child |
RI 25-37 |
250 |
1 |
1 hour |
250 |
$21.50 |
$6,718.75 |
The Total Annual Respondent Cost is $6,718.75.
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.
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 $5,350. 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.
This Information Collection Request (ICR) has been revised to update the display of the
OMB control number.
There is no change in the hour or cost burden.
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 | 2021-07-01 |