Justification for the Non-Substantive Changes for 0960-0029

Justification for Non-Substantive Changes for SSA-7008

Online Request for Correction of Earnings Record

20 CFR 404.820 & 422.125

OMB No. 0960-0029

Background

SSA offers an alternative to the paper process of requesting a correction to an earnings record and provide a service that enables our users to make similar requests electronically through the online my Social Security portal. As a result, we are obsoleting the clearance process for the information collection Changes for Online Request for Correction of Earnings Record (OMB No 0960-0819), and combing the clearance package to legally continue collection of this information under OMB No. 0960-0029. The information SSA collects from the public on the Internet screens, will not exceed the information we request on the paper Form SSA-7008, Request for Correction of Earnings Record. (OMB No. 0960-0029)

Individuals alleging inaccurate earnings records in SSA’s files submits Form SSA-7008 to SSA, or a SSA employee conducts a personal interview with the respondents, and enters the respondent’s responses into our electronic Earnings Modernization Item Correction (ICOR) system, to provide the information SSA needs to check earnings posted, and, as necessary, initiate development to resolve any inaccuracies. The respondents are individuals who request correction of earnings posted to their Social Security earning records.

If an individual alleges an inaccurate earnings record in SSA’s files, they can submit earnings correction requests electronically on the Online Request for Correction of Earnings Record screens, through the agency’s online secure web platform my Social Security portal. These Internet screens collect information, which supports an earnings correction action, such as employer names; addresses; wage amounts; and pertinent details about the nature of employment. This information collection is not mandatory for requesting an earnings correction action. However, SSA encourages respondents to submit supporting evidence, as determined by the Commissioner of Social Security, to support the earnings correction action. SSA collects information from individuals only. The earnings correction request does not include private businesses, farms, non-profits, or state or local governments. The respondents are authorized, authenticated individuals accessing the earnings correction process from their personal my Social Security account.

Revisions to the Information Collection

• Change #1:

We are combining the two information collection packages OMB number 0960-0819: Online Request for Correction of Earnings Record and OMB No. 0960-0029: Request for Correction of Earnings Record under one OMB number 0960-0029.

Justification #1:

We are combining these two information collections under one OMB number

0960-0029 as per OMB’s Terms of Clearance. 

• Change #2:

We are updating the Estimates of Public Reporting Burden chart in the OMB No. 0960-0029 to include the burden estimates for 0960-0819.

Justification #2:

We are removing the Estimates of Public Reporting Burden information from OMB No. 0960-0819 and adding them to Estimates of Public Reporting Burden chart in OMB No. 0960-0029 to combine the two modalities.

The chart below, shows the updated burden estimates for 0960-0029 combined with the burden estimates from 0960-0819:

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-7008	28,734	1	28	13,409	$28.01*	24**	$697,533***
In-person or telephone interview	337,500	1	20	112,500	$28.01*	24**	$6,932,475***
Online Request for Correction of Earnings Record	76,047	1	15	19,012	$28.01*	0*	$532,526***
Totals	442,281			144,921			$8,162,264***

* We based this figure on average U.S. worker’s hourly wages, as reported by

Bureau of Labor Statistics data(https://www.bls.gov/oes/current/oes_nat.htm).

** We based this figure on the average FY 2023 wait times 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.

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)****
442,281	1	30	221,141	$6,914,059****

****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 the average times of 15, 20 and 28 minutes shown in our chart above 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 442,281 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $15,076,323. SSA does not charge respondents to complete our applications.

Terms of Clearance

OMB placed the following Terms of Clearance on this Information Collection when they approved it on May 3, 2023:

The agency modified the supporting statement to provide additional details regarding this

collection and to update its burden estimates.

Prior to its next renewal, the agency will consider merging this information collection with 0960-0819.

SSA Response: In response to the Terms of Clearance we modified the Supporting Statement to provide additional details and updated the burden estimates. In addition, as per the Terms of Clearance, we are also submitting this Change Request to merge this information collection with 0960-0819 (as per the revisions mentioned above).