2900-0003 (530) Supporting Statement with AR69(P) information_2023

Supporting Statement – Part A

Application for Burial Benefits (Under 38 U.S.C. Chapter 23)

Control #2900-0003

Summary of Changes from Currently Approved Collection

• Some changes have been made to the form, as noted below.

• The respondent burden has increased since the previous approval due to an expanded burial transportation benefit, which now includes covered Veterans’ cemeteries.

• The ICR is associated with AR69(F) – Expanded Monetary Burial Benefits.

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. Under the authority of 38 U.S.C. 2302, 2303, 2304, 2307, and 2308, the VA will pay burial benefits upon the death of a Veteran to certain eligible claimants. Regulatory authority is found in 38 C.F.R. 3.1700 through 3.1712.

VA Form 21P-530EZ was updated to include the following:

• Updated instructions to reflect the regulation change and updates to the form

• Split Section I into Section I – Veteran’s Information and Section II - Claimant’s Information

• Moved Veteran’s Information Questions to Section I

• Changed Section Titles to Section III - Veteran’s Service Information; Section IV – Information Regarding Final Resting Place; Section V – Claim for Burial Allowance; Section VI - Claim for Plot and/or Transportation Allowance

• Question 18 – added Tribal trust land, name of cemetery or tribal trust land and zip code

• Question 20A – removed VA Hospitalization Death / Amount paid from (now covered under non-service-connected burial allowance)

• Moved Question 20A to Section VI (now question 23)

2. Use of the Information

VA Form 21P-530EZ is used to gather the necessary information to determine eligibility for VA burial benefits including the burial allowance, plot or interment allowance, and transportation reimbursement.

3. Use of Information Technology

VA Form 21P-530 is available on the benefits.va.gov website in a fillable electronic format.

VBA does not currently have the technology in place to allow for the direct electronic submission 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

VA Form 21P-530EZ is used to gather the necessary information to determine eligibility for monetary burial benefits, including the burial allowance, plot or interment allowance, and transportation reimbursement. VBA would be unable to properly administer burial benefits program 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

The notice of Proposed Information Collection Activity was included in the proposed rule for AR69 published in the Federal Register on Monday, September 25, 2023 at 88 FR 65641.

VA did not receive comments in response to this notice.

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 Veteran Readiness and Employment Records-VA (58VA21/22/28),” published at 74 FR 29275 on June 19, 2009, and last amended at 87 FR 8740 (February 16, 2022).

11. Sensitive Questions

No questions considered sensitive are being asked in this collection.

12. Respondent Burden and its Labor Costs

1. Number of Respondents is estimated at 132,055 per year.

2. Frequency of Response is one time.

3. Annual burden hours are 66,028 hours.

4. The estimated completion time for this form is 30 minutes.

5. VA cannot make further assumptions about the population of respondents because of the variability of factors such as the educational background and wage potential of respondents. Therefore, VBA used general wage data to estimate the respondents’ costs associated with completing the information collection.

The Bureau of Labor Statistics (BLS) gathers information on full-time wage and salary workers.  According to the latest available BLS data, the mean hourly wage is $31.48 based on the BLS wage code – “00-0000 All Occupations.”  This information was taken from the following website: https://www.bls.gov/oes/current/oes_nat.htm.

Legally, respondents may not pay a person or business for assistance in completing the information collection. Therefore, there are no expected overhead costs for completing the information collection. VBA estimates the total cost to all respondents to be $2,078,561.44 (66,028 burden hours x $31.48 per hour).

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

Grade	Step	Burden Time	Fraction of Hour	Hourly Rate	Cost Per Response	Total Responses	Total
9	3	30	0.50	$26.24	13.120	132,055	$ 1,732,561.60
Overhead at 100% Salary							$ 1,732,561.60
12	3	15	0.25	$38.05	9.513	132,055	$ 1,256,173.19
Overhead at 100% Salary							$ 1,256,173.19
Processing / Analyzing Costs							$ 5,977,469.58
Printing and Production Cost							$ 66,416.33
Total Cost to Government							$ 6,043,885.90

Overhead costs are 100% of salary and are the same as the wage listed above and the amounts are included in the total. 

Printing and production costs approximates the cost of printing this information collection per year. (Processing/Analyzing Cost total divided by $90).

Note: The hourly wage information above is based on the hourly 2024 General Schedule (Base) Pay (Pay & Leave : Salaries & Wages - OPM.gov). This rate does not include any locality adjustment as applicable.

The processing time estimates above are based on the actual amount of time employees of each grade level spend to process to completion a claim received on this form. The within-grade step (3) of each employee represents the average experience of employees within each grade.

15. Reasons for Change in Burden

The burden has increased since the previous approval due to an expanded burial transportation benefit, which now includes covered Veterans’ cemeteries.

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.