A. Justification
Introduction/Authoring Laws and Regulations
Sections 1612(b)(4)(A), 1612(b)(4)(B) and 1613(a)(4) of the Social Security Act (Act) authorize the Commissioner of the Social Security Administration (SSA) to exclude income or resources determined necessary to fulfill a Plan to Achieve Self-Support (PASS). The PASS provision encourages individuals to use available income or resources (such as business equipment, education, or specialized training) to pay for goods and services they would need to enter (or re-enter) the workforce and become self-supporting. Section 1631(e) of the Act permits SSA to collect this information. In addition, the regulations 20 CFR 416.1180-416.1182 and 416.1225-416.1227 of the Code of Federal Regulations specify the requirements for such plans.
Description of Collection
The Supplemental Security Income (SSI) program encourages recipients to return to work. One of the program objectives is to provide incentives and opportunities that help recipients toward employment. The Plan to Achieve Self-Support (PASS) provision allows individuals to use available income or resources (such as business equipment, education, or specialized training) to enter (or re-enter) the workforce and become self-supporting. In turn, SSA does not count the income or resources recipients use to fund a PASS when determining an individual's SSI eligibility or payment amount. An SSI recipient who wants to use available income and resources to obtain education or training to become self-supporting completes Form SSA-545. SSA uses the information from Form SSA-545 to evaluate the recipient's plan for achieving self-support, and to determine eligibility under the provisions of the SSI program. The respondents are SSI recipients who want to develop a return-to-work plan.
Use of Information Technology to Collect the Information
Form SSA-545 is available as a print-only, fillable PDF on SSA’s website and Intranet. If the recipient is not able to access the form from SSA’s website, we mail the form to them to complete. 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.
In the interim, we evaluated this collection for conversion to a submittable PDF. Given the high volume of conversions we are coordinating and the more urgent nature of some of the other conversions, we ultimately decided not to prioritize this ICR for conversion to fully submittable PDF at this time. When we are able to schedule this form for conversion to a submittable PDF, we will submit a Change Request to OMB to request prior approval.
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 obtain similar data.
Minimizing Burden on Small Respondents
This collection does not affect small businesses or other small entities.
6. Consequence of Not Collecting Information or Collecting it Less Frequently
If we did not use Form SSA-545, we would not have the information necessary to determine whether an individual's PASS is feasible, and whether the expenditures under the PASS are necessary and reasonably priced. Because we only collect this information once, we cannot collect it less frequently. There are no technical or legal obstacles that prevent 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.
Solicitation of Public Comment and Other Consultations with the Public
The 60-day advance Federal Register Notice published on August 9, 2022 at 87 FR 48548, and we received no public comments. The 30-day FRN published on October 27, 2022 at 87 FR 65112. If we receive any comments in response to this Notice, we will forward them to OMB.
Payment or Gifts to Respondents
SSA does not provide payments or gifts to the respondents.
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.
Justification for Sensitive Questions
To determine whether to approve a PASS, we need to collect certain information of a personal nature, which may have a bearing on the feasibility of the PASS. For example, we need information about the person's disability, and how the PASS will help with overcoming any resulting limitations which might otherwise hinder employment (e.g., through the purchase of adaptive equipment or specialized training). Similarly, information pertaining to the individual's educational and vocational background is critical for the SSA evaluator to determine the feasibility of the plan and the need for the proposed expenditures. Since we collect some information of a sensitive nature, SSA will keep the information secure and only necessary personnel will review it.
Estimates
of Public Reporting Burden
The
following chart shows the estimated public reporting burden for this
information collection:
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 (minutes)** |
Total Annual Opportunity Cost (dollars)*** |
SSA-545 |
7,000 |
1 |
120 |
14,000 |
$11.70* |
24** |
$196,500*** |
* We based this figure on the average DI payments based on SSA's current FY 2022 data (https://www.ssa.gov/legislation/2022factsheet.pdf).
** We based this figure on the average the FY 2022 wait time for field offices, 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)**** |
7,000 |
1 |
30 |
3,500 |
$40,950 |
****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 120 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 14,000 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $237,450. 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.
Annual Cost To Federal Government
The annual cost to the Federal Government is approximately $732,771. 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 |
$3,643 |
Distributing, Shipping, and Material Costs for the Form |
Distribution + Shipping + Material Cost |
$221 |
SSA Employee (e.g., field office, 800 number, DDS staff) Information Collection and Processing Time |
GS-9 employee x # of responses x processing time |
$725,487 |
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 |
|
$732,771 |
* 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. First, since we work with almost every US citizen, we often do bulk mailings, and cannot track the cost for a single mailing. 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
There are no changes to the public reporting burden.
* Note: The total burden reflected in ROCIS is 20,300, while the burden cited in #12 of the Supporting Statement is 14,000. This discrepancy is because the ROCIS burden reflects the following components: field office waiting time + a rough estimate of a 30-minute, one-way, drive burden. In contrast, the chart in #12 of the Supporting Statement 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 useable forms with expired OMB approval dates, avoiding Government waste.
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.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Title of Information Collection and Form Number(s) |
| Author | Naomi |
| File Modified | 0000-00-00 |
| File Created | 2023-09-01 |