Document
Supporting Statement A
ICR 202507-3220-006 · OMB 3220-0155 · Object 169325600.
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| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
|---|---|
| File Title | Supporting Statement A |
| Author | Mary Prosser |
| Last Modified By | Writer |
| File Modified | 2026-05-28 |
| File Created | 2026-06-04 |
| Conversion State | complete |
Extracted Text
Justification
Supplement to Claim of Person Outside the United States
RRB Form G-45
1. Circumstances of information collection - Under the Social Security Amendments of 1983 (Public Law 98-21), which amends Section 202(t) of the Social Security Act, effective January 1, 1985, the Tier I or the overall minimum (O/M) portion of an annuity, and Medicare benefits payable under the Railroad Retirement Act to certain beneficiaries living outside the United States, may be withheld.
The benefit withholding provision of P.L. 98-21 applies to divorced spouses, spouses, minor or disabled children, students and survivors of railroad employees who (1) initially became eligible for Tier I amounts, O/M shares, and Medicare benefits after December 31, 1984; (2) are not U.S. citizens or U.S. nationals; and (3) have resided outside the U.S. for more than six consecutive months starting with the annuity beginning date. The benefit withholding provision does not apply, however, to a beneficiary who is exempt under either a treaty prior to August 1, 1956, or a totalization agreement between the U.S. and the country in which the beneficiary resides or an individual who is exempt under other criteria specified in P.L. 98-21.
2. Purposes of collecting/consequences of not collecting the information
Form G-45, Supplement to Claim of Person Outside the United States, is used by the Railroad Retirement Board (RRB) to obtain the information needed to determine applicability of the withholding provision of P.L. 98-21.
The form is used:
as a supplement to a benefit application from a non-U.S. citizen to whom the non-payment provision may apply, or
as an independent vehicle when a beneficiary informs the RRB of a change in country of residence, which may involve applying the benefit withholding provision of P.L. 98-21.
Completion of Form G-45 is self-explanatory. The identifying information requested in the upper right-hand corner of the form is pre-filled before the form is released. When mailed to an applicant or beneficiary, the RRB includes a pre-addressed return envelope.
Form G-45 is patterned after the Social Security Administration's Form SSA-21, Supplement to Claim of Person Outside the United States, OMB No. 0960-0051.
The RRB proposes the following changes to Form G-45:
• Changed last sentence of the Paperwork Reduction Act Notice to “Railroad Retirement Board, ATTN: Bureau of Information Services/Policy & Compliance, 844 N. Rush St., Chicago, IL 60611-1275.”
• Question 9 (d) and (e): Replaced “checks” with “correspondence” and other minor editorial changes to comply with Executive Order 14247, Modernizing Payments To and From America’s Bank Account.
3. Planned use of improved information technology or technical/legal impediments to further burden reduction - Due to agency technology limitations, this information collection does not allow for electronic submission as described in the Government Paperwork Elimination Act (GPEA). However, we will reevaluate electronic signatures after the completion of our IT Modernization project.
4. Efforts to identify duplication - To our knowledge, no other agency uses a form similar to Form G-45 and this information collection does not duplicate any other RRB information collection.
5. Small business respondents - N.A.
6. Consequences of less frequent collection - Not applicable since the information is requested only once for each incident involving a change in the country of residence by an applicant or beneficiary.
7. Special circumstances - None
8. Public comments/consultations outside the agency - In accordance with 5 CFR 1320.8(d), comments were invited from the public regarding the information collection. The notice to the public was published on page 13869 of the Federal Register dated March 23, 2026. No comments or requests for additional information were received.
9. Payments or gifts to respondents - None.
10. Confidentiality - Privacy Act System of Records, RRB-22, Railroad Retirement, Survivor and Pensioner Benefit System. In accordance with OMB Circular M-03-22, a Privacy Impact Assessment for this information collection was completed and can be found at https://www.rrb.gov/sites/default/files/2017-06/PIA-BPO.pdf.
11. Sensitive questions - N.A.
12. Estimate of respondent burden - The estimated annual burden for the collection remains unchanged.
Current Burden
Form Number
Annual Responses
Time (Minutes)
Burden (Hours)
G-45
50
10
8
Proposed Burden
Form Number
Annual Responses
Time (Minutes)1/
Burden (Hours)
G-45
24
10
4
1/The RRB has been collecting the information on this form since OMB approved the information collection. Based on a sampling done when the form was originally created, the office calculated the estimated time, which includes time for getting the needed data and reviewing the completed form
Responses
Hours
Total Response/Burden Change
24
4
Adjustment Change
-26
-4
13. Estimated annual cost to respondents or record keepers - N.A.
14. Estimate of cost to Federal Government - N.A.
15. Explanation for change in burden – The overall burden estimated for the collection has been decreased by 26, from 50 to 24 and the burden hours have been decreased by 4, from 8 to 4. The decrease is due to an agency’s adjustment to the number of annuitants residing abroad.
16. Time schedule for publication - The results of this collection will not be published.
17. Request not to display OMB expiration date - The RRB started an extensive multi-year IT
Modernization Initiative at the beginning of Fiscal Year 2019 to transform our operations into the 21st Century using multiple contractor services to improve mission performance, expand service capabilities, and strengthen cybersecurity and modernization is still in progress. The RRB hired a new CIO on November 4, 2024, and was briefed on the modernization initiative status. If requested, the RRB will provide OMB with any updates to the consolidated project timeline.
Given that the form in this collection is seldom revised; the costs associated with redrafting, reprinting, and distributing forms to keep the appropriate OMB expiration date in place; and our desire to reevaluate after the completion of the modernization project, the RRB requests the authority to not display the expiration date on the forms.
18. Exceptions to Certification Statement - None