RI 34-001_OMB_Supporting_Stmt_Final

OMB SUPPORTING STATEMENT

RI 34-1 Financial Resources Questionnaire

RI 34-3 Notice of Amount Due Because of Annuity Overpayment

RI 34-17 Financial Resources Questionnaire (FEGLI Premiums Underpaid)

RI 34-18 Financial Resources Questionnaire (FEHB Premiums Underpaid)

RI 34-19 Notice of Amount Due Because of FEGLI Premium Underpayment

RI 34-20 Notice of Amount Due Because of FEHB Premium Underpayment

1. Justification

1. 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 31, Section 3716, requires aggressive agency action to collect all claims of the United States for money or property arising out of the agency’s internal activity or referred to the agency for action under the Uniform Federal Claims Collection Standards (FCCS) [4 CFR Parts 101 through 105].
Under FCCS, the Office of Personnel Management (OPM) is required to pursue overpayments through every available mechanism, after providing due process, in order to satisfy the Government’s interest in collecting money owed the Civil Service Retirement and Disability Fund. In making decisions regarding these collections, OPM is governed by 5 CFR, Part 831, Subparts M and N, Part 845,
Part 870, Subpart D, and Part 890, which discuss recovery of overpayments and standards for waiver. Prior to commencement of collection activity, OPM must inform the annuitant of the overpayment or failure to pay premiums and establish that the money is owed and that the amount owed is mathematically correct. OPM must give the annuitant the opportunity to request waiver, compromise, termination, or suspension of collection, etc. The annuitant may want to pay the sum rather than have it collected. OPM must decide how to handle the transaction based on the annuitant’s response and the personal financial information provided by the annuitant. In order to make a final decision in these matters and to meet the requirement of the current law and regulation, OPM must request and review information about the person’s current financial circumstances. This information is necessary so that OPM can make a rational decision regarding the appropriate course of action.

2. 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.

The Notice of Amount Due Because of Annuity Overpayment (RI 34-3); the Notice of Amount Due Because of FEGLI Premium Underpayment (RI 34-19); and the Notice of Amount Due Because of FEHB Premium Underpayment (RI 34-20) are used to notify individuals about overpaid benefits and the intent of OPM to collect the overpayment. The Financial Resources Questionnaire forms (RI 34-1,
RI 34-17, and RI 34-18) are used to collect financial data from overpaid individuals. The information collected is used by OPM to determine their ability to repay the debt owed to the Civil Service Retirement and Disability Fund, the Federal Employees’ Group Life Insurance Trust Fund, and the Federal Employees Health Benefits Trust Fund, respectively. Based on this information and other material information, OPM may agree to a waiver, compromise, or adjustment of the collection schedule.

The information requested on RI 34-1 is collected by OPM from persons who owe the United States because of erroneous payments from the Civil Service Retirement and Disability Fund. After discovery of the erroneous payment, OPM uses RI 34-3 to notify the person who received the payment that the overpayment exists. The form provides the amount and cause of the overpayment, gives information about the right to request reconsideration, waiver, and/or compromise, as well as to request an adjustment in the collection schedule if (1) the person cannot repay in a lump sum and/or (2) the proposed installment collection schedule would cause financial hardship. RI 34-1 is an enclosure to
RI 34-3. The person uses part 2 of RI 34-3 to inform OPM of his or her request for disposition of the overpayment. RI 34-1 is used by those wanting to be considered for waiver or compromise, write-off of the overpayment because of an inability to repay the debt because of financial hardship, or an adjustment in the proposed collection schedule. OPM needs the detailed information from the RI 34-1 to make an informed decision to waive, accept a compromise, write-off or adjust the collection schedule.

RI 34-17 performs the same function as the RI 34-1 and is used for underpayment of life insurance premiums. Similarly, RI 34-18 performs the same function as RI 34-1 and is used for the underpayment of health benefit premiums.

RI 34-19 performs the same function as RI 34-3 and is used for the underpayment of life insurance premiums. RI 34-20 performs the same function as RI 34-3 and is used for the underpayment of health insurance premiums. This Information Collection Request (ICR) has been revised to update the display of the OMB control number.

3. 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 collection is detailed and can only be obtained from the respondents. New methods of information collection technology would do little to reduce the burden on the respondents. Under penalty of law, respondents must sign the questionnaire attesting to its truthfulness. However, RI 34-1 and RI 34-17 are available in a PDF fillable format on our website and meet our GPEA requirements.

TERMS OF CLEARANCE: OPM should consider if this collection of forms should be converted to a

common form. OPM has determined that the following forms should not be converted to common
forms: RI 34-1 (This form is used by OPM to determine eligibility to waive, compromise, lower installments or voluntary repay a debt to OPM.); RI 34-3 (This form is used by OPM to notify an annuitant of an upcoming debt collection is scheduled for an annuity overpayment.); RI 34-17 (This form is used by OPM to determine eligibility to waive, compromise, lower, or voluntary repay underpaid FEGLI premiums.); RI 34-18 (This form is used by OPM to determine eligibility to waive, compromise, lower, or voluntary repay underpaid FEHB premiums.); RI 34-19 (This form is used by OPM to notify an annuitant of an upcoming debt collection due to underpaying their FEGLI premiums.); and RI 34-20 (This form is used by OPM to notify an annuitant of an upcoming debt collection due to underpaying their FEHB premiums.).

4. 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.

Duplication of this information is minimized. However, up-to-date, similar information certified by the applicant is not available elsewhere.

5. 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.

6. 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.

If OPM could not collect this information, it would prevent OPM from carrying out the intent of the Federal Claims Collection Act.

7. 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 that would cause an information collection to be collected in the aforementioned manner. This information collection is consistent with the guidelines in 5 CFR 1320.6, except that a response is requested within 30 days in order to prevent the continuation of payments to which the respondent may not be entitled.

8. Federal Register Notice: Provide a copy and identify the date and page number of the publication in the Federal Register of the agency’s notice soliciting comments on the information collection prior to submission to OMB.

On June 8, 2021, a 60 Day Federal Register Notice was published at 86 FR 30503. No comments were received.

No gift or payment is awarded respondents based on return of this form.

9. 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).

10. 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. However, detailed financial information is collected so that OPM can make a reasonable decision about the debtor’s ability to repay.

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.

Approximately 450 RI 34-1 forms are completed each year; approximately 70 forms each of RI 34-

17 and RI 34-18 are completed each year. Approximately 1,351 forms of RI 34-3 are completed

annually; approximately 210 forms of RI 34-19 and RI 34-20 are completed annually. A response time

of one hour is estimated for each form. Burden of 450 hours for RI 34-1; 70 hours each for RI 34-17 and

RI 34-18; 1,351 hours for RI 34-3; and 210 hours for RI 34-19 and RI 34-20 equals 2,361 hours and 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
Financial Resources Questionnaire; Notice of Amount Due Because…	RI 34-1 RI 34-17 RI 34-18 RI 34-3 RI 34-19 RI 34-20	450 70 70 1,351 210 210	1 1 1 1 1 1	60 mins 60 mins 60 mins 60 mins 60 mins 60 mins	450 70 70 1,351 210 210	$21.50 $21.50 $21.50 $21.50 $21.50 $21.50	$12,093.75 $1,881.25 $1,881.25 $36,308.13 $5,643.75 $5,643.75
Aggregated Annual Respondent Cost Total: $63,451.88

The Total Annual Respondent Cost is $63,451.88

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 cost to the respondents.

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.

Annualized cost to the Federal Government is approximately $126,000. This cost is derived from

employee salaries, staff hours required to process the forms and the cost of printing, storing and

shipping forms.

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.

The results of this information collection are not 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.