RI20-120_Supporting_Statement_2025

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Request for Change to Unreduced Annuity, OMB #3206-0245; (RI 20-120)

A. JUSTIFICATION

1. Explain the circumstances of this collection, why this collection is necessary. and the legal statutes that allow it.

Title 5, U. S. Code, Sections 8339(j)(5)(A) and (B) and 8419(b) provide that Civil Service annuity reductions
for the purpose of providing a survivor annuity terminate after the death of the spouse or former spouse. The reduction also terminates after the dissolution of the spouse’s marriage to the annuitant, unless a court order requires that the reduction continue.

2. Describe how, by whom, and for what purpose the information is to be used. Except for a new collection, describe how the agency has made use of the information received from the current collection.

RI 20-120 is used by the annuitant to request that OPM re-compute the annuity without the reduction and to give us all the information we need to accomplish this. This form is accompanied by a cover letter to the annuitant. This form is unique to OPM because we request specific evidence such as a death certificate, court certified copy of a divorce decree or annulment from the annuitant to change a reduced annuity to provide a survivor benefit to an unreduced annuity rate.

3. How are the respondents expected to complete the collection? Can this collection be completed electronically (e.g., through a website or application)?

Respondents can complete the RI 20-120 by completing the fillable version at: www.opm.gov/forms. Print and mail the completed form to: Retirement Operations Center, Post Retirement, Attention: Y- Adjustment, PO Box 45, Boyers PA 16017-0045.

Alternatively, a copy of the form may be mailed to the annuitant for completion and return mailing to the above address.

3. Does this collection duplicate any other collection of information? Describe why the agency doesn’t already have this information within their systems.

While OPM must give the annuitant the opportunity to initiate a change in their election, OPM is continuing its momentum from FY 2023 investments to pilot a fully digital retirement case processing method. Additionally, OPM will continue building on pilot initiatives to improve the annuitant experience like the online retirement guide and chatbot. Retirement Services will use data-driven evaluations of these pilots to inform additional ways to better answer annuitant questions and reduce their burden.

3. Describe any impacts on small business. If applicable, describe any methods used to minimize those impacts.

This information collection request has no impact on small businesses and organizations.

3. What are consequences to the Federal program or policy goals if this collection is not done or the information is collected less frequently? Describe any technical or legal obstacles to reducing burden.

This information collection is made when OPM needs to re-compute the annuity without the reduction. This information collection is consistent with the guidelines in 5 CFR 1320.8(b)(3). If this information were not collected, annuitants could be paid less than the law provides.

3. Do any of the following special circumstances apply?

• requiring respondents to report information to the agency more often than quarterly;

•requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

•requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

There are no special circumstances involved in the collection of this information.

3. Cite the Federal Register publication for a request for public comments and address any comments received.

On December 20, 2024, a 60-Day Federal Register Notice was published at 89 FR 104243,
requesting comments. No comments were received.

On April 8, 2025, a 30-Day Federal Register Notice was published at 90 FR 15166 requesting comments.

3. Are payments or gifts given to the respondents?

No gifts or payments of any kind have been provided to any individuals who are connected to
this collection.

3. Describe any assurances of privacy/confidentiality. Cite specific privacy laws, relevant OPM regulations, and SORNs.

This information collection is protected by the Privacy Act of 1974 and OPM regulations
(5 CFR 831.106). The routine uses of disclosure appear in the Federal Register for OPM/Central-1
(87 FR 5874, published February 2, 2022).

3. Are any questions of a sensitive nature asked, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private? If yes, provide justification. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

The information collection does not include questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The submission of this information is voluntary. However, if it is not collected, annuitants could be paid less than the law provides.

3. Describe the hour time burden and the hour cost burden on the respondent needed to complete this collection. Please specify hourly salary for your respondent audience by referencing Bureau of Labor Statistics Occupational Employment and Wage Estimates or other alternative wage site, when applicable.

Type of Respondent	Form Name	No. of Respondents	Total No. of Responses	Average Burden per Response (in hours)	Hourly Wage Rate	Total Respondent Cost
Federal Annuitant	Request for Change to Unreduced Annuity	5,000	1	.5	$29.57	$73,925

Approximately 5,000 forms will be processed annually. The form requires approximately
30 minutes each to complete. The annual burden of 2,500 hours is estimated.

The Total Annual Respondent Cost is $73,925.

3. Describe the non-hourly monetary burden to respondents needed to complete this collection. This is defined as out-of-pocket costs such as application fees for the collection, document fees (birth/death certificates, school transcripts), mailing costs (printing, postage, and/or mileage), or anything else respondents may need to pay to complete and/or implement the collection.
   
   

Form Name	No. of Respondents	No. of Respondents	Mileage at $0.70 a mile	Total Mileage	Average Cost of a Vital Record	Total Vital Records Cost	Total Non-Hourly Cost
Request for Change to Unreduced Annuity	5,000	5,000	9	$31,500	$20	$100,000	$131,500

Based on an article from the U.S. Census Bureau, we are assuming 39% of respondents will need a divorce decree with their form. As annulments are rarely granted, we will assume a 1% rate for forms that use that documentation, leaving 60% remaining using death certificates. While the cost of vital records can vary wildly from state to state, OPM estimates on average the cost will be $20.

While OPM provides postage for the return of the form, there is still the cost of mileage for mailing the form back to OPM. USPS estimates that the average driving distance between post offices is around 9 miles. The IRS announced that the 2025 mileage rates is $0.70 per mile.

Therefore, the estimated total non-hourly cost is $131,500.

3. Describe the cost incurred by the Federal Government to complete this collection.

Annualized cost to the Federal Government is approximately $148,750. This cost is derived
from employee salaries, staff hours required to process the forms and the cost of printing
and shipping forms.

3. Explain any changes/adjustments to this collection since the previous submission, if applicable. Describe whether these changes impact the hour or cost burden. If yes, describe if the impact is the result of deliberate Federal government action (“program change”) or something else (“adjustment”).

Since the previous submission, the cost burden has increased. The adjustment reflects an increase of the respondent’s hourly cost burden to complete this form.

3. Specify if the data gathered by this collection will be published. This could include Congressional reporting, using respondent numbers in budget justification, or other broad reporting.

The details of this ICR are not published. However, there may occasionally be aggregate data reported, as needed, including in Congressional reporting, budget justifications, or other broad reporting

3. If applicable, explain the reason(s) for seeking approval to not display the OMB expiration date.

We seek approval to not display the OMB clearance expiration date on the forms and to communicate version changes to the public via the revision date. OPM has modified our Paperwork Reduction Act notice to ensure respondents can verify the validity of the OMB control number and collection.

3. Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

There are no exceptions to the certification statement.

B. Collection of Information Employing Statistical Methods

This collection does not employ statistical methods.