Supporting Statement - 0310 (Final)

Supporting Statement for Form SSA-199 and Accompanying Regulations

Vocational Rehabilitation Provider Claim

20 CFR 404.2101(a); 404.2108(b); 404.2117(c)(1)&(2); 404.2121(a); 416.2208(b); 416.2217(c)(1)&(2); 416.2201(a); and 416.2221(a)

OMB No. 0960-0310

1. Justification

1. Introduction/Authoring Laws and Regulations

Section 205(a) of the Social Security Act (Act) allows the Commissioner of the Social Security Administration (SSA) to make rules and regulations and to institute procedures to collect information from the public, which establish the right to the following benefits:

1. Claiming Reimbursement for Vocational Rehabilitation (VR) Services Provided

Sections 222(d)(1), (4)&(5) and 1615(d) of the Act authorize the Commissioner to determine the amount SSA reimburses for VR services. SSA’s regulations at 20 CFR 404.2108(b) and 416.2208(b) of the Code of Federal Regulations (Code) require the state VR agencies to make claims for reimbursement of the cost incurred for providing VR services on Form SSA‑199, Vocational Rehabilitation Provider Claim form, provided by SSA.

2. Certifying Adherence to Cost Containment Policies and Procedures

Section 222(d)(1) and 1615(d) of the Act authorize the Commissioner to reimburse state VR Agencies for the reasonable and necessary costs of VR services to disabled beneficiaries. 20 CFR 404.2117(c)(1) and 416.2217(c)(1) of the Code require SSA to pay reasonable and necessary costs, complying with the written cost containment policies of the state VR agencies established under 34 CFR 361 of the Code. In addition, 20 CFR 404.2117(c)(2) and 416.2217(c)(2) of the Code require state VR agencies to submit written certification (before the end of the first calendar quarter of each year) to SSA, explaining their adherence to established cost containment policies when providing goods and services for which they claim payment from SSA. When SSA deems it necessary, the state VR agencies also submit copies of their specific written policies and procedures to carry out SSA programs (e.g., any guidelines and fee schedules for a given year).

3. Preparing Causality Statements

Sections 222(d)(1) and 1615(d) of the Act authorize the Commissioner to reimburse state VR agencies for the reasonable and necessary costs of VR services to disabled beneficiaries. 20 CFR 404.2121(a) and 416.2201(a) of the Code require state VR agencies to submit a clear explanation or existing documentation of the causal relationship between each service they provide and its impact upon the attainment of a continuous 9-month period of substantial gainful activity. In addition, claims described in 404.2101(a) and 416.2221(a) of the Code require state VR agencies to submit a clear explanation or existing documentation of how they expect the services they provide to motivate or assist the individual to attain substantial gainful activity.

2. Description of Collection

SSA requires respondents to provide the information listed on Form SSA-199 to obtain reimbursement of costs incurred for providing VR services. The respondents provide the information requested through a web-based Secure Ticket Portal, in lieu of submitting paper forms. This Portal allows VRs to retrieve reports and enter and submit information electronically, eliminating the use of the paper form. SSA requires VR agencies to submit claims for reimbursement for the following categories:

1. Claiming Reimbursement for VR Services Provided:

We require VR agencies to submit each claim for reimbursement in a format SSA prescribes containing (1) a description of each service provided; (2) the date when the State VR agency provided the service, and (3) the cost of the service they provided. SSA needs this information to determine whether to pay under our vocational rehabilitation programs.

2. Certifying Adherence to Cost Containment Policies and Procedures:

SSA needs the information each state VR agency provides about their cost containment policies to permit us to make sure the costs we reimburse are in accordance with the cost-containment policies described in #1 above.

3. Preparing Causality Statements:

The information the state VR agencies present for validation review enables SSA to assess the appropriateness of its reimbursement policies. The information also helps SSA determine when and where we should consider changes to ensure we secure maximum benefits from VR services at the appropriate level of cost.

State VR agencies submit this information voluntarily to ensure SSA reimburses them for services. SSA collects the information on an on-going basis as VRAs submit claims for reimbursement. The respondents are State VR agencies offering vocational and employment services for SSA disability recipients.

3. Use of Information Technology to Collect the Information

We have a secure Ticket Portal, which allows state VR agencies to electronically complete actions and report to SSA. We include the OMB approval (and public reporting burden) for the Ticket Portal approval under OMB Control No. 0960‑0644. State VR agencies use the Ticket Portal to perform all of their actions and data sharing activities. This collection only covers the burden for use of the paper Form SSA-199.

4. 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 business or other small entities.

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

If we collected this information less frequently, it would create insufficient oversight of costs claims; potentially lead to inaccurate payment of claims; and unnecessarily delay reimbursement to state VR agencies for reasonable and necessary costs they incurred and for which they paid. We would also be unaware of State VR agency modifications affecting policies that could affect appropriate cost of VR services. Since we only collect this 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 March 10, 2022 at 87 FR 13783, and we received no public comments. The 30-day FRN published on May 24, 2022 at 87 FR 31598. If we receive any comments in response to this Notice, we will forward them to OMB.

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 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.

11. Justification for Sensitive Questions

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

12. Estimates of Public Reporting Burden

The following chart summarizes the public reporting burden for the 77 state VR agencies in regard to the three types of responses SSA requests:

Modality of Completion	Number of Respondents	Frequency of Response	Number of Responses	Average Burden per Response (minutes)	Estimated Total Annual Burden (hours)	Average Theoretical Hourly Cost Amount (dollars)*	Total Annual Opportunity Cost (dollars)**
a. Claiming Reimbursement on SSA-199 – 20 CFR 404.2108(b) & 416.2208(b)	77	303	23,331	23	8,944	$16.02*	$143,283**
b. Certifying Adherence to Cost Containment Policy and Procedures – 20 CFR 404.2117(c)(1)&(2), 416.2217(c)(1)&(2) & 34 CFR 361	77	1	77	60	77	$16.02*	$1,234**
c. Preparing Causality Statements – 20 CFR 404.2121(a), 404.2101(a), 416.2201(a), & 416.2221(a)	77	2.5	193	100	322	$16.02*	$5,158**
Totals	231		23,601		9,343		$149,675**

* We based this figure on the average Healthcare Support Occupations, as reported by Bureau of Labor Statistics data (https://www.bls.gov/oes/current/oes310000.htm).

** 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.

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 the 23, 60, and 100 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 9,343 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $149,675. SSA does not charge respondents to complete our applications.

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 $252,750. 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	$2,500
Distributing, Shipping, and Material Costs for the Form	Distribution + Shipping + Material Cost	$250
SSA Employee (e.g., field office, 800 number, DDS staff) Information Collection and Processing Time	GS-9 employee x # of responses x processing time	$250,000
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	$0*
Quantifiable IT Costs	Any additional IT costs	$0*
Total		$252,750

* 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, as field office 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 5,320 hours. However, we are currently reporting a burden of 9,342 hours. This change stems from an increase in the total number of responses from 13,080 to 23,601. 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.

16. Plans for Publication Information Collection Results

SSA does 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.