Addendum to the Supporting Statement for 0960-NEW (PA Household NPRM)

Addendum to the Supporting Statement for Regulatory Changes to

Expand the Definition of a Public Assistance Household

20 CFR 416.1101, 416.1102, 416.1130-416.1148, 416.1160, 416.1201

OMB No. 0960-NEW

In the Notice of Proposed Rule Making for this rule, we included the following PRA Statement:

Paperwork Reduction Act

These rules do not create any new collections, or require revisions to existing collections, and, therefore, do not require Office of Management and Budget approval under the Paperwork Reduction Act. However, the application of the revisions to these rules may cause burden changes to the collection instruments for the following information collection requests: 0960‑0174, the SSA-8006, Statement of Living Arrangements, In-Kind Support and Maintenance; 0960-0456, the SSA-8011, Statement of Household Expense and Contributions; and 0960-0529, the SSA-5062, Claimant Statement about Loan of Food or Shelter, and the SSA‑L5063-F3, Statement about Food or Shelter Provided to Another. We anticipate a small burden reduction per response for the SSA-8006 (0960-0174) as respondents will not need to develop the responses about their household. In addition, we anticipate a 50% reduction in the number of respondents based on those who indicate they are part of a Public Assistance Household and who may not need to complete the follow-up forms SSA-5062, SSA‑L5063, SSA-8006, and SSA-8011.

The following chart shows the reduction in time burden information associated with the proposed rule:

OMB #; Form #; CFR Citations	Number of Respondents	Frequency of Response	Current Average Burden Per Response (minutes)	Current Estimated Total Burden (hours)	Anticipated New Number of Respondents Under Regulation	Anticipated New Burden Per Response Under Regulation (minutes)	Anticipated Estimated Total Burden Under Regulation (hours)	Estimated Burden Savings (hours)
0960-0174 SSA-8006 (Paper Form)	12,160	1	7	1,419	12,160	6	1,216	203
0960-0174 SSA-8006 (SSI Claims System)	109,436	1	7	12,768	109,436	6	10,944	1,824
0960-0456 SSA-8011-F3 (Paper Form)	21,000	1	15	5,250	10,500		2,625	2,625
0960-0456 Personal Interview (SSI Claims System)	398,759	1	15	99,690	199,380		49,845	49,845
0960-0529 SSA-5062 (Paper version)	29,026	1	30	14,513	14,513		7,257	7,256
096-0529 SSA-5062 (SSI claim system)	29,026	1	20	9,675	14,513		4,838	4,837
0960-0529 SSA-L5063 (Paper version)	29,026	1	30	14,513	14,513		7,257	7,256
0960-0529 SSA-L5063 (SSI claim system)	29,026	1	20	9,675	14,513		4,838	4,837
Totals	657,459			167,503	389,528		88,820	78,693

The following chart shows the reduction in theoretical cost burdens associated with the proposed rule:

OMB #; Form #; CFR Citations	Anticipated New Number of Respondents	Estimated Burden Per Response from Chart Above (minutes)	Average Theoretical Hourly Cost Amount (dollars)*	Average Combined Wait Time in Field Office and/or Teleservice Centers (minutes)**	Anticipated Annual Opportunity Cost (dollars)***
0960-0529 SSA-5062 (Paper version)	14,513	30	$21.29*	24**	$432,506***
0960-0529 SSA-5062 (SSI claim system)	9,675	20	$21.29*	24**	$288,373***
0960-0529 SSA-L5063 (Paper version)	14,513	30	$21.29*	24**	$432,506***
0960-0529 SSA-L5063 (SSI claim system)	14,513	20	$21.29*	24**	$288,373***
0960-0174 SSA-8006 (Paper Form)	6,080	6	$12.81*	24**	$109,039***
0960-0174 SSA-8006 (SSI Claims System)	54,718	6	$12.81*	24**	$981,310***
0960-0456 SSA-8011-F3 (Paper Form)	10,500	15	$29.76	21**	$421,846***
0960-0456 Personal Interview (SSI Claims System)	199,380	15	$29.76	21**	$8,010,291***
Totals	323,892				$10,964,244***

* We based this figure on the average DI payments based on SSA's current FY 2023 data (https://www.ssa.gov/legislation/2023factsheet.pdf); on the average U.S. citizen’s hourly salary, 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 and hearings office, as well as by averaging both the average FY 2023 wait times for field offices and teleservice centers, 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.

SSA submitted a single new Information Collection Request which encompasses revisions to information collections currently under OMB Numbers 0960-0174, 0960-0456, and 0960-0529) to OMB for the approval of the changes due to the proposed rule. After approval at the final rule stage, we will adjust the figures associated with the current OMB numbers for these forms to reflect the new burden.  We are soliciting comments on the burden estimate; the need for the information; its practical utility; ways to enhance its quality, utility, and clarity; and ways to minimize the burden on respondents, including the use of automated techniques or other forms of information technology. 

As per the above PRA Statement from the NPRM, we are not making any revisions to the forms associated with this rulemaking (0960‑0174, the SSA-8006; 0960-0456, the SSA-8011; and 0960-0529, the SSA-5062, and the SSA‑L5063-F3), as the current forms do not specifically require the respondents to discuss their household situation. Rather, we expect a burden reduction for the respondents of these forms, as we will not require follow up contact with the respondents to further develop the information regarding their households, if they respond on these forms that they receive some kind of public assistance.

Therefore, we are making no changes to the forms themselves; however, we are estimating a reduction in the burden for the SSA-8006 (0960-0174) since respondents will not need to further develop their household situation, if they indicate on the form that they receive public assistance. In addition, we also estimate that approximately 50% fewer respondents will need to complete the follow up forms, SSA-8011 (0960-0456) and SSA-5062, with the cover letter SSA-L5063 (0960-0529) since those respondents will not need to submit further development regarding their households.

We indicated these estimated reductions in the NPRM (chart above), as well as in the Supporting Statement for this rule making.