Supporting Statement - 0665 (Final)

Supporting Statement for Request for Form SSA-711

Deceased Individual’s Social Security Records

20 CFR 402.130

OMB No. 0960-0665

1. Justification

1. Introduction/Authoring Laws and Regulations

The Freedom of Information Act (FOIA) at 5 USC 552(a)(3) of the United States Code is a law that provides instructions for members of the public to request records from Federal agencies. FOIA requires Federal agencies to provide full or partial disclosure of previously unreleased information and documents controlled by the United States government upon request. In addition, FOIA gives any person access, with certain exemptions, to information about the functions, procedures, policies, decisions, and operations of federal agencies. 20 CFR 402.130 of the Code of Federal Regulations describes how to request a record from the Social Security Administration (SSA) through providing a name, address, and description of the request. While respondents may submit these requests in writing, SSA also allows for the use of Form SSA-711, Deceased Individual’s Social Security Records, for FOIA requests for a deceased individual’s records for genealogical research, family estate matters, and other reasons.

2. Description of Collection

When a member of the public requests a Social Security record, SSA needs the name and address of the requestor as well as a description of the requested record to process the request. SSA uses the information the respondent provides on Form SSA-711, or via an Internet request through SSA’s electronic Freedom of Information Act Xpress (FOIAXpress) website, to: (1) verify the wage earner is deceased; and (2) access the correct Social Security record. Respondents learn of the possibility for these requests via Agency mailers; multi-media commercials and advertising; SSA’s general website; a link from the mySocial Security landing page; as well as from other individuals. SSA is constantly reviewing our outreach tactics to assure maximum exposure and accessibility to all individuals who need this service. Our website and mailers list the information respondents need to apply for requests.

We identified the following psychological costs based on the requirements for this information collection:

• Psychological Cost:

• Requirement for the Program: The SSA-711 application process asks individuals to provide some personal information about themselves so SSA can determine whether they are eligible for this program.

• Psychological Cost: The respondent may perceive these questions as unduly invasive, and these factors can lead to individuals choosing to delay or abandon completing this form.

We understand these psychological costs may cause respondents to delay their completion of the information collection or cause them to abandon the information collection entirely. However, we require full completion of this collection to receive the information requested. Therefore, we have taken this potential psychological cost into account when calculating our burden in #12 below.

Respondents are members of the public requesting deceased individuals’ Social Security Records.

3. Use of Information Technology to Collect the Information

Form SSA-711 is currently available on the Internet as a fillable PDF, which the respondent can complete, print, and send to SSA for processing. In addition, SSA’s electronic Freedom of Information Act Xpress (FOIAXpress) system allows the public to fill out Form SSA-711 electronically through the Internet. In accordance with the agency’s Government Paperwork Elimination Act plan, SSA created the FOIAXpress, Internet version of Form SSA-711. We estimate that 99% percent of the respondents use the Internet version to submit this information.

4. Why We Cannot Use Duplicate Information

The nature of the information we collect and the manner in which we collect it precludes duplication. SSA does not use another collection instrument to obtain similar data.

5. 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-711, the public would have no way to obtain genealogical data and would not be able to use records for actions such as estate settlements, legal claims, and other court-related cases. We would also be unable to respond to the public’s FOIA requests, which is mandated by Congress. Because we only collect the information once, we cannot collect it less frequently. There are no technical or legal obstacles to 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.

8. Solicitation of Public Comment and Other Consultations with the Public

The 60-day advance Federal Register Notice published on July 5, 2024, at 89 FR 55666, and we received no public comments. The 30-day FRN published on November 6, 2024, at 89 FR 88105. If we receive any comments in response to this Notice, we will forward them to OMB.

9. Payment or Gifts to Respondents

SSA does not provide payments or gifts to the respondents.

10. 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.

11. Justification for Sensitive Questions

The information collection does not contain any questions of a sensitive nature.

12. Estimates of Public Reporting Burden

Please see the burden chart below:

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 or for Teleservice Centers (minutes) **	Total Annual Opportunity Cost (dollars)***
Internet Request through FOIAXpress	49,800	1	7	5,810	$31.48*		$182,899***
SSA-711 (paper)	200	1	7	23	$31.48*	21**	$2,928***
Total	50,000			5,833			$185,827***

* 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 averaging both the average FY 2024 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.

In addition, OMB’s Office of Information and Regulatory Affairs 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)****
200	1	30	100	$3,148****

**** 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 opportunity cost estimates in the paragraph below.

The total burden for this ICR is 5,833 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $188,975. SSA does not charge respondents to complete our applications. 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 7 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.

13. Annual Cost to the Respondents (Other)

SSA charges the public varying amounts depending on how much information they provide and how they request to receive the information. Since the cost to the respondents varies so much from year-to-year, we cannot calculate a separate annual cost burden. Current fiscal year costs are as follows:

• $28 if SSN of decedent is not provided (photocopy)

• $28 if SSN of decedent is provided (photocopy)

• $30 if SSN of decedent is not provided (computer extracted SS-5)

• $30 if SSN of decedent is provided (computer extracted SS-5)

Based on an average of the above amounts, we calculated an average cost per response of $29, for a total estimated cost to the respondents of $1,450,000.

14. Annual Cost To Federal Government

The annual cost to the Federal Government is approximately $143,420. 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	$0*
Distributing, Shipping, and Material Costs for the Form	Distribution + Shipping + Material Cost	$0*
SSA Employee (e.g., field office, 800 number, DDS staff) Information Collection and Processing Time	GS-9 employee x # of responses x processing time	$140,000
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		$143,420

* 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.  It is difficult for us to break down the cost for processing a single form, as field office 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 6,003, while the burden cited in #12 of the Supporting Statement is 5,833. 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.

We are also showing a decrease in the total burden in ROCIS due to revisions to the wait time and one-way drive burdens for our information collections (we needed to remove the wait time and drive time which we inadvertently included for the Internet submissions and add them to the paper submissions. This caused an overall burden reduction of 24,830 hours, as respondents who use the Internet to submit their requests do not need to drive to a field office or wait for help from field office staff.

16. Plans for Publication Information Collection Results

SSA will not publish the results of the information collection.

17. Displaying the OMB Approval Expiration Date

For the paper version, Form SSA-711, we will not publish 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.

For the Internet version, FOIAXpress, SSA is not requesting an exception to the requirement to display the OMB approval expiration date.

18. Exceptions to the 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).

2. Collections of Information Employing Statistical Methods

SSA does not use statistical methods for this information collection.