SF2800_SF2800A_OMBSupportingStatement_2021_08_31

OMB SUPPORTING STATEMENT

SF 2800 Application for Death Benefits (CSRS)

SF 2800A Documentation and Elections in Support of Application for Death Benefits

When Deceased Was an Employee at the Time of Death

SF 2800-1 Applying for Death Benefits under the Civil Service Retirement System

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 5, U. S. Code, Chapter 83, Sections 8341 and 8342 provide for two types of death benefits: survivor benefits and lump-sum payments. Survivor annuities may be payable to a spouse, former spouse, and eligible dependent children upon the death of an employee or annuitant. A lump-sum benefit may be payable upon the death of an employee, former employee, or annuitant if no spouse, former spouse, or eligible dependent children are entitled to survivor annuity or, if a survivor annuity is payable, after the right of the last person entitled thereto has terminated. These benefits cannot be paid unless application for the benefits is made to the Office of Personnel Management (OPM). Title 5, U. S. Code, Section 8347(b) authorizes OPM to prescribe the application formats needed.

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 information collected by these applications is used by the Civil Service Retirement System to authorize payment of benefits in the event of the death of an employee, a former employee, or an annuitant. SF 2800 collects information from the survivors of deceased employees and deceased annuitants. SF 2800A collects information needed from survivors of employees who die in service. This information is already available if the deceased is an annuitant. Every applicant who uses SF 2800 should read SF 2800-1, Applying for Death Benefits under CSRS. This brief booklet provides the general information applicants need to understand what they are applying for. The Privacy Act Statement (PAS) is current due to a systematic review by our Privacy Officer. The Public Burden Statement meets the requirements of 5 CFR 1320.8(b)(3). This Information Collection Request (ICR) has been revised to update the display of the OMB control number and there are editorial changes to the instructions and forms regarding contacting OPM etc.

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 collected is detailed and can only be obtained from the respondents. New methods of information technology would do little to reduce the burden on the respondents; they must sign the application attesting to its truth, under penalty of law, to the best of their knowledge. This form is available in PDF fillable format on our website at www.opm.gov/forms and meets the GPEA requirements.

TERMS OF CLEARANCE: OPM should consider if the forms in this ICR should be

submitted as common forms.

OPM has determined that these forms: SF 2800 (Application for Death Benefits: CSRS) and SF 2800A (Documentation & Elections in Support of Applications for Death Benefits When the Deceased was an Employee at the Time of Death) are candidates to be categorized as common forms.

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.

Applications are filed individually. There is no similar information available. Duplication is minimized.

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.

Information collection is required upon the death of an employee, a former employee, or an annuitant. Less frequent collections would delay the award of benefits authorized by title 5, U. S. Code, Chapter 83. This collection is consistent with the guidelines of 5 CFR 1320.6.

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 involved in the collection of this information.

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 February 10, 2021, a 60 Day Federal Register Notice was published at 86 FR 8930. Two comments were received however, they have no relation to this Information Collection Request (ICR).

9. 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.

10. 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).

11. 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.

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 40,000 SF 2800s are processed annually. This form requires
approximately forty-five minutes for completion including the time required to verify
the information requested. A burden of 30,000 hours is estimated.

Approximately 400 applicants will use SF 2800A annually. This form also requires approximately forty-five minutes for completion giving a burden of 300 hours.

The total burden for these forms is 30,300 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
Application for Death Benefits Under CSRS	SF 2800	40,000	1	45 minutes	30,000	$16.13	$806,500
Documentation and Elections in Support of Application for Death Benefits When Deceased Was an Employee at the Time of Death (CSRS)	SF 2800A	400	1	45 minutes	300	$16.13	$8,065

The Total Annual Respondent Cost is $814,565.00.

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 $1,325,300. This cost was determined
by 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 and there are editorial changes to the instructions and forms regarding contacting OPM and etc.

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.