Supporting Statement - 0960-0061 (Final)

Supporting Statement for Form SSA-7156

Farm Self-Employment Questionnaire

20 CFR 404.1082(c) & 20 CFR 404.1095

OMB No. 0960-0061

1. Justification

1. Introduction/Authoring Laws and Regulations

Section 211(a) of the Social Security Act states the existence of a trade or business is a prerequisite for determining whether an individual or partnership may have "net earnings from self-employment." Section 20 CFR 404.1095 of the Code of Federal Regulations further defines an agricultural trade or business, and 20 CFR 404.1082(c) establishes the rules for farm rental income. The Social Security Administration (SSA) collects this information to determine the existence of an agricultural trade or business. This determination of coverage may affect an individual's insured status for receipt of monthly Social Security benefits, or it may affect the amount of the monthly payments.

2. Description of Collection

SSA collects the information on Form SSA-7156 on a voluntary and as-needed basis to determine the existence of an agriculture trade or business that may affect the monthly benefit or insured status of the applicant. SSA requires the existence of a trade or business as a prerequisite for determining whether an individual or partnership may have net earnings from self-employment. When an applicant indicates self-employment as a farmer, SSA uses Form SSA-7156 to elicit the information we need to determine the existence of an agricultural trade or business, and subsequent covered earnings for Social Security entitlement purposes. Generally SSA employees collect this information one time, through a personal interview, either face-to-face or via telephone. We made this form available on the Intranet and Internet, where respondents can fill it out electronically and print it for signature. The respondents are applicants for Social Security benefits, whose entitlement depends on whether the worker has covered earnings from self-employment as a farmer.

3. Use of Information Technology to Collect the Information

SSA created a fillable PDF version of this form for respondents to download, complete, print, and submit to SSA. Per our recent risk assessment, we are not currently able to make the signature line on this form fillable.

Form SSA-7156 SSA is available on SSA's website for individuals to print, complete, and mail to SSA or take into the local field office (FO) 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. 

4. Why We Cannot Use Duplicate Information

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

5. Minimizing Burden on Small Respondents

This collection of information does not involve small businesses or other small entities.

6. Consequence of Not Collecting Information or Collecting it Less Frequently

SSA only collects the information in cases where we need to determine the existence of a covered agricultural trade or business, because the earnings may affect the monthly benefit or insured status of the claimant. If we did not collect the information, or collected this information less frequently, it may disadvantage some claimants. There are no technical or legal obstacles to the burden reduction.

7. Payment or Gifts to Respondents

SSA does not provide payments or gifts to the respondents

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

The 60-day advance Federal Register Notice published on January 3, 2022, at 87 FR 139, and we received no public comments. The 30-day FRN published on March 30, 2022 at 87 FR 18456. If we receive any comments in response to this Notice, we will forward them to OMB. We did not consult with the public on the revision of this form.

9. Payment or Gifts to Respondents

SSA does not provide payments or gifts to the respondents

10. Assurances of Confidentiality

SSA protects and holds confidential the information we collect 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.

11. Justification for Sensitive Questions

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

12. Estimates of Public Reporting Burden

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)*	Average wait time in field office or for teleservice centers (minutes) **	Total Annual Opportunity Cost (dollars)**
SSA-7156	1,000	1	10	167	$14.49*	21**	$7,491***

* We based this figure on average Farmworkers and Laborers, Crop, Nursery, and Greenhouse salaries as reported by Bureau of Labor Statistics data (https://www.bls.gov/oes/current/oes452092.htm)

** We based this figure on averaging both the average FY 2021 wait times for field offices and teleservice centers, based on SSA’s current management information

data.

*** 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.

In addition, OMB’s Office of Information and Regulatory Affairs (OIRA) is requiring SSA to use a rough estimate of a 30-minute, one-way, drive time in our calculations of the time burden for this collection. OIRA based their estimation on a spatial analysis of SSA’s current field office locations and the location of the average population centers based on census tract information, which likely represents a 13.97 mile driving distance for one-way travel. We depict this on the chart below:

Total Number of Respondents Who Visit a Field Office	Frequency of Response	Average One-Way Travel Time to a Field Office (minutes)	Estimated Total Travel Time to a Field Office (hours)	Total Annual Opportunity Cost for Travel Time (dollars)****
1,000	1	30	500	$7,245

****We based this dollar amount on the Average Theoretical Hourly Cost Amount in dollars shown on the burden chart above.

Per OIRA, we include this travel time burden estimate under the 5 CFR 1320.8(a)(4), which requires us to provide “time, effort, or financial resources expended by persons [for]…transmitting, or otherwise disclosing the information,” as well as 5 CFR 1320.8(b)(3)(iii) which requires us to estimate “the average burden collection…to the extent practicable.” SSA notes that we do not obtain or maintain any data on travel times to a field office, nor do we have any data which shows that the average respondent drives to a field office, rather than using any other mode of transport. SSA also acknowledges that respondents’ mode of travel and, therefore, travel times vary widely dependent on region, mode of travel, and actual proximity to a field office.

NOTE: We included the total opportunity cost estimate from this chart in our calculations when showing the total time and opportunity cost estimates in the paragraph below.

We base our burden estimates on current management information data, which includes data from actual interviews, as well as from years of conducting this information collection. Per our management information data, we believe that 10 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. The total burden for this ICR is 1,000 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $14,736. SSA does not charge respondents to complete our applications.

13. Annual Cost Burden to the Respondents (Other)

The collection does not impose a known cost burden to the respondents

14. The annual cost to the Federal Government is approximately $8,603. 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	$350
Distributing, Shipping, and Material Costs for the Form	Distribution + Shipping + Material Cost	$0*
SSA Employee (e.g., field office, 800 number, DDS staff) Information Collection and Processing Time	GS-9 employee x # of responses x processing time	$4,833
Full-Time Equivalent Costs	Out of pocket costs + Other expenses for providing this service	$0*
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		$8,603

* 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.

In addition, it is difficult for us to break down the cost for processing a single form, as field office and State Disability Determination Services staff often help respondents fill out several forms at once, and the time it takes to do so can vary greatly per respondent.  As well, because so many employees have a hand in each aspect of our forms, 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 2019, the burden was 7,917 hours. However, we are currently reporting a burden of 167 hours. This change stems a decrease in the number of responses from 47,500 to 1,000. 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. These figures represent current Management Information data.

* Note: The total burden reflected in ROCIS is 1,017, while the burden cited in #12 above is 167.  This discrepancy is because the ROCIS burden reflects the following components:  field office waiting time + telephone call system wait times + a rough estimate of a 30-minute, one-way, drive burden.  In contrast, the chart in #12 above reflects actual burden.

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 usable forms with expired OMB approval dates, avoiding Government waste.

18. Exception 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).

1. B. Collections of Information Employing Statistical Methods

SSA does not use statistical methods for this information collection.

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