SUPPORTING STATEMENT - PART A
Income and Asset Statement in Support of Claim for Pension or Parent's Dependency and Indemnity Compensation (D.I.C.) – 2900-0829
Summary of Changes from Previously Approved Collection
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1. Need for the Information Collection
The Department of Veterans Affairs (VA) through its Veterans Benefits Administration (VBA) administers an integrated program of benefits and services, established by law, for Veterans, service personnel, and their dependents and/or beneficiaries. Title 38 U.S.C. 5101(a) provides that a specific claim in the form provided by the Secretary must be filed in order for benefits to be paid to any individual under the laws administered by the Secretary. Information requested by this form is authorized under the authority of 38 U.S.C. 1503, Determinations with respect to annual income, 38 U.S.C. 1315, Dependency and indemnity compensation to parents, and 38 U.S.C. 1543, Net worth limitation.
2. Use of the Information
VA Form 21P-0969 will be used by claimants for VA Pension or Parents' Dependency and Indemnity Compensation (DIC) to provide information pertaining to income and assets to establish entitlement to Pension or Parents' DIC. This form will be completed only by those claimants who had income other than Social Security benefits during the calendar year before claiming benefits or who disposed of assets or have significant assets which may affect their entitlement to needs-based benefits.
3. Use of Information Technology
For the information collected on VA Form 21P-0969, VA does not currently use automated, electronic, mechanical, or other technological collection techniques. The form modifications are designed to be inclusive of these types of changes in the future.
VA Form 21P-0969 is available on the benefits.va.gov website in a fillable electronic format.
VBA is currently working on putting the technology in place to allow for the electronic submission and processing of the form. To ease the burden on respondents, VBA plans to develop and deploy functionality enabling electronic submission of this information. VBA cannot estimate the date this functionality will be deployed.
4. Non-duplication
The information obtained through this collection is unique and is not already available for use or adaptation from another cleared source.
5. Burden on Small Businesses
This information collection does not impose a significant economic impact on a substantial number of small businesses or entities.
6. Less Frequent Collection
VBA would be unable to properly administer needs-based benefits without this collection of information. The information is collected on an ad hoc basis, and, therefore, cannot be collected less frequently. The form is designed to collect the minimum amount of information which will allow VBA to properly administer the program.
7. Paperwork Reduction Act Guidelines
This collection of information does not require collection to be conducted in a manner inconsistent with the guidelines delineated in 5 CFR 1320.5(d)(2).
8. Consultation and Public Comments
Part A: PUBLIC NOTICE
A 60-Day Federal Register Notice (FRN) for the collection published on Thursday, July 6, 2023. The 60-Day FRN citation is Volume 88 FRN 43171-43172.
1 comment was received during the 60-Day Comment Period. They are included below in the order they were received, as well as our Agency’s response to the comment.
COMMENT 1: |
Can I get a copy of the proposed form? Is there a list I could be on to always receive a copy of the forms related to proposed Pension changes? |
RESPONSE 1: |
Thank you for your inquiry as it pertains to these form changes.
The draft forms currently under public comment from Pension and Fiduciary Service (P&FS) are attached for your review: 1) VA Form 21P-0969 and 2) VA Form 21P-8416.
The drafts should be reviewed only for the purpose of making public comments. There is no centralized means to receive draft copies of forms prior to their approval by OMB. Forms may change at any time in response to public comments, and there is no guarantee that the draft copies provided will be the final version of the form. P&FS will respond to requests to review draft forms on a case-by-case basis. |
A 30-Day Federal Register Notice for the collection published on Wednesday, October 4, 2023. The 30-Day FRN citation is 88 FRN 68906.
Part B: CONSULTATION
No additional consultation apart from soliciting public comments through the Federal Register was conducted for this submission.
9. Gifts or Payment
No payments or gifts are being offered to respondents as an incentive to participate in the collection.
10. Confidentiality
The records are maintained in the appropriate Privacy Act System of Records identified as “Compensation, Pension, Education, and Vocational Rehabilitation and Employment Records-VA (58VA21/22/28),” published at 74 FR 29275 on June 19, 2009, and last amended at 84 FR 4138 (February 14, 2019).
11. Sensitive Questions
No questions considered sensitive are being asked in this collection.
12. Respondent Burden and its Labor Costs
Part A: ESTIMATION OF RESPONDENT BURDEN
Collection Instrument(s)
Income and Asset Statement in Support of Claim for Pension or Parent's Dependency and Indemnity Compensation (D.I.C.)
Number of Respondents: 55,000
Number of Responses Per Respondent: One time
Number of Total Annual Responses: 55,000
Response Time: 25 minutes
Respondent Burden Hours (C multiplied by D, computed into hours): 22,917 hours
Total Submission Burden (Summation or average based on collection)
Total Number of Respondents: 55,000
Total Number of Annual Responses: 55,000
Total Respondent Burden Hours (P: add all “e’s” in this section): 22,917 hours
Part B: LABOR COST OF RESPONDENT BURDEN
(P): OMB believes that everyone’s time is worth money. In this section, we’re determining that if the respondent was working at their job, how much would they make in the time it takes them to respond to the collection instrument?
If respondents are salaried, and not hourly wage-earners, approximate the hourly wage as best as possible. For a good estimate, divide respondent salary by 52 weeks, then divide again by 40 hours to come up with a respondent hourly wage.
Collection Instrument(s)
Income and Asset Statement in Support of Claim for Pension or Parent's Dependency and Indemnity Compensation (D.I.C.)
Number of Total Annual Responses: 55,000
Response Time: 25 minutes
Respondent Hourly Wage: $29.76
Labor Burden per Response: $12.40
Total Labor Burden: $682,000.00
Overall Labor Burden
Total Number of Annual Responses: 55,000
Total Labor Burden: $682,000.00.
The Respondent hourly wage was determined by using the Department of Labor Wage Website ([http://www.dol.gov/dol/topic/wages/index.htm])
13. Respondent Costs Other Than Burden Hour Costs
There are no annualized costs to respondents other than the labor burden costs addressed in Section 12 of this document to complete this collection.
14. Cost to the Federal Government
Part A: LABOR COST TO THE FEDERAL GOVERNMENT
Collection Instrument(s)
Income and Asset Statement in Support of Claim for Pension or Parent's Dependency and Indemnity Compensation (D.I.C.)
Grade |
Step |
Burden Time |
Fraction of Hour |
Hourly Rate |
Cost Per Response |
Total Responses |
Total |
|
7 |
3 |
25 |
0.42 |
$20.49 |
$8.60 |
55,000 |
$ |
473,000.00 |
9 |
3 |
20 |
0.33 |
$25.06 |
$8.27 |
55,000 |
$ |
454,850.00 |
11 |
3 |
20 |
0.33 |
$30.32 |
$10.01 |
55,000 |
$ |
550,550.00 |
Processing / Analyzing Costs per response |
$26.88 |
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Total Cost to Government |
$ |
1,478,400.00 |
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Overall Labor Burden
Total Number of Annual Responses: 55,000
Total Labor Burden: $1,478,400.00.
Part B: OPERATIONAL AND MAINTENANCE COSTS
(P): To determine Operational and Maintenance Costs, think of the incidental or miscellaneous costs to owning this collection. How much does equipment, printing, or postage for this collection cost? Are there any overhead costs for purchasing or licensing software? If a database or system is involved, how much money does it take to maintain the system?
If you do have incur any Operational and Maintenance costs through this collection, please put “$0” next to each category.
Cost Categories
Equipment: $0
Printing: $32,853.33
Postage: $0
Software Purchases: $0
Licensing Costs: $0
Other: $0
Total Operational and Maintenance Cost: $32,853.33
Part C: TOTAL COST TO THE FEDERAL GOVERNMENT
Total Labor Cost to the Federal Government: $1,478,400.00
Total Operational and Maintenance Costs: $32,853.33
Total Cost to the Federal Government: $1,511,253.33.
15. Reasons for Change in Burden
The burden has decreased since the previous approval due to actual receipts of the form.
16. Publication of Results
The results of this information collection will not be published.
17. Non-Display of OMB Expiration Date
We are not seeking approval to omit the display of the expiration date of the OMB approval on the collection instrument.
18. Exceptions to “Certification for Paperwork Reduction Submissions”
We are not requesting any exemptions to the provisions stated in 5 CFR 1320.9.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Kaitlin Chiarelli |
| File Modified | 0000-00-00 |
| File Created | 2023-10-05 |