Addendum - 0585

Addendum to the Supporting Statement for Form SSA-437-BK

Complaint Form for Allegations of Discrimination in Programs or Activities

Conducted by the Social Security Administration

OMB No. 0960-0585

Minor Revisions to the Collection Instrument

SSA is making the following revisions:

• Change #1: We are removing the OGC fax number on the form.

Justification #1: OGC receives few, if any, complaints via fax because this technology is generally obsolete. Of course, OGC will continue accepting complaints sent to its fax number posted on the previous version of the form, and any OGC fax number available to the public, as well as anything redirected from another component. Additionally, removing the fax number from the form would eliminate the need to further assess privacy/records-related risks and burdens posed by fax-based collection.

• Change #2: We will direct customers who use mail (for the form or questions about the form) to use a specific OGC address at HQ instead of asking customers to pick among ten OGC regional office addresses. As a result, we are removing the list of regional OGC offices (Page 8).

Justification #2: As part of OGC’s reorganization in FY22, we determined it is more efficient to centralize our incoming physical mail at HQ. Also, mail centralization eliminates common user errors in identifying the appropriate regional address. The HQ address also carries weight, which should eliminate duplicative copies being sent to HQ and the Commissioner.

• Change #3: We will no longer ask for the SSN of the complainant.

Justification #3: Following consultation with OGC’s experts in privacy, disclosure, and data storage compliance, we have determined that is it unnecessary for SSA to request that complainants provide their SSN on this form. To the extent we later need an SSN to conduct a full investigation, it can be obtained otherwise. Eliminating the SSN will help the agency better align with policy to avoid non-essential collection of SSNs. Also, for complaints that require referral, the receiving component may confirm the SSN via its own investigation.

• Change #4: We are revising the instructions on page 2 of the form to:

FILING A COMPLAINT BY MAIL OR EMAIL: To file a complaint of discrimination, you or someone helping or representing you, should complete a signed and dated copy of this form (or a letter stating the same information required by this form). If your complaint of discrimination is incomplete or unsigned, we will send it back to you for correction which will delay our consideration of your complaint. Save a copy of your completed complaint of discrimination. Mail the original to:

Social Security Administration

Office of the General Counsel

Attn: Civil Rights Complaints

6401 Security Boulevard

Room G401, West High Rise

Baltimore, Maryland 21235-6401

You may choose to email your complaint of discrimination as an attachment to [email protected]. Please note that this email mailbox is not a secure means of communication with us. It is possible that information you include in an email, including any attachments, can be intercepted by others outside of SSA and used by those third parties for purposes you did not intend. For this reason, please limit personal information about both yourself and others when transmitting complaints to us via email. Please include only the minimal information that is necessary to convey your complaint. Do not include any Social Security numbers with the complaint.

QUESTIONS. For questions about or assistance with the civil rights discrimination complaint process, you or someone helping or representing you may reach us by mail or email as described above or by telephone, toll-free, at (866) 574-0374.

Justification #4: Following consultation with OGC’s experts in privacy, disclosure, and data storage compliance, we believe that the instructions better reflect current guidelines to increase public awareness of risks posed by unsecured email communications.

• Change #5: We are revising the PRA statement on this form.

Justification #5: We are revising the PRA statement to reflect our current boilerplate language. The current language, which dates back to the last reprint of the form, is now outdated.

• Change #6: We are revising the Privacy Act Statement on this form.

Justification #6: SSA’s Office of the General Counsel is conducting a systematic review of SSA’s Privacy Act Statements on agency forms. As a result, SSA is updating the Privacy Act Statement on this form.