Supporting Statement A

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Supporting Statement for Paperwork Reduction Act Submissions

OMB Control Number: 3206-0138, RI 30-9 – Reinstatement of Disability Annuity Previously Terminated Because of Restoration to Earning Capacity

    A. Justification

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

Sections 8337 and 8455 of title 5, United States Code, provide for the restoration of a disability annuity that has been terminated because the annuitant has been restored to earning capacity (i.e., the annuitant’s earnings exceeded 80 percent of the current rate of pay for the position occupied immediately before retirement).  A disability annuity may be reinstated if the annuitant again falls below the earnings threshold.  The annuity will not be restored if the person (1) has been reemployed in a position subject to a Federal retirement system; (2) has recovered from the disability; or (3) has reached age 62.

    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 30-9 informs affected disability annuitants of their right to request restoration if their earnings again fall below the earnings threshold.  It also specifies the conditions annuitants must meet and the documentation they must submit to OPM with a request for reinstatement. If this collection of information were not conducted, OPM would be unable to determine whether a disability annuity should be reinstated as required by law. 

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

This form is available on the OPM website at https://www.opm.gov/retirement-center/publications-forms. This form is electronically available to print. A separate written request should be mailed to: OPM, Retirement Surveys and Students, 1900 E Street, NW, Washington, DC 20415-0001.

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

There is no duplication because the terminated annuitant’s request for restoration to the disability annuity roll must be evaluated based upon their current disabling condition/status as it relates to: (1) the terminated annuitant’s reemployment in Federal Service covered by CSRS or FERS, (2) recovery from disability and (3) has not reached age 62.    



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

Information is not collected from nor has any impact on small businesses or organizations.

    6. 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 initiated by disabled annuitants who wish to be restored to the disability annuity rolls after termination due to excess earnings.  Less frequent collection would delay the restoration of benefits authorized by law.

    7. 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. 

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

On February 24, 2026, a 60 Day Federal Register Notice was published at 91 FR 8922 requesting comments. No comments were received.

    9. Are payments or gifts given to the respondent?

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

    10. 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; revised 88 FR 56058 August 17, 2023).  


    11. 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. 
This collection includes medical and financial information from the respondents.  This information is commonly considered private and is protected by OPM as described in item 10 above. The information must be collected for purposes of allowing OPM to determine whether the respondent continues to be disabled and if the respondent’s earnings have again fallen below the 80 percent earnings limitation to determine if the respondent is entitled to restoration. The respondent is not required to submit this information; however, without such information OPM is unable to reinstate the disability annuity.

    12. 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.  
Approximately 200 forms will be processed annually.  The form requires approximately 60 minutes for completion.  A burden of 200 hours is estimated. The Total Respondent Cost is $6,532.

Form Name
Form Number
No. of Respondents
No. of Responses per Respondent
Average Burden per Response (in hours)
Total Annual Burden (in hours)
Average Hourly Wage Rate
Total Annual Respondent Cost
Reinstatement of Disability Annuity Previously Terminated Because of Restoration to Earning Capacity
RI 30-9
200
1
60 minutes
200
$32.66
$6,532

  13. 	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.

 There is a postage and mileage cost to send the letter to OPM. USPS estimates that the average driving distance between post offices is around 9 miles. The cost for first class postage in 2026 is $.73 totaling a cost of $146.00. Mileage cost in 2026 at a rate of $.0725 totals $130.50.

OPM estimates the printing cost of employment and tax documents at $.26 per page.
We estimate a total cost of $1,093. 

Therefore, the estimated total non-hourly cost is $1,369.50.

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

The annualized cost to the Federal government is $10,500.  

15. 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”). 

There are no adjustments or change in the hour burden that is not based on updates on economic data. Therefore, any changes noted would be categorized as “adjustments.”
However, the form has been completely reformatted to allow the respondent to answer directly in questions and answer format rather than submit via a written statement. The Privacy Act and Public Burden Statements have also been updated.

16.  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.

No information collected from the form will be published.

17. 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. The results of this collection are not published.

18. 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.