ARS Privacy Impact Assessment

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Privacy Impact Assessment for

Annuity Roll System (ARS)
December 21, 2017
Contact Point
Nicholas Ashenden
System Owner
Deputy Associate Director, RS/RO
Reviewing Official
Kellie Cosgrove Riley
Chief Privacy Officer

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Abstract
The United States Office of Personnel Management’s (OPM) Annuity Roll
System (ARS) is a centralized retirement and benefit system that supports
the OPM’s Retirement Services (RS) and interoperability with other RS
systems. ARS serves as one of the primary systems supporting RS
retirement and benefit operations under Civil Service Retirement System
(CSRS) and the Federal Employees Retirement System (FERS). This PIA is
being conducted because ARS contains personally identifiable information
(PII) about federal annuitants, their dependents and survivors.

Overview
The Federal government’s Annuity Roll, the active roster of individuals
qualified to receive an annuity benefit, collects and maintains information
related to eligibility for and the computation of Federal retirement, health,
and life insurance benefits. The information is used to determine
qualification and pay benefits for retired Federal employees and their
survivors. ARS, used to manage the Annuity Roll, is the OPM core retirement
and benefit management system supporting the majority of retirement
functions for OPM’s Retirement Services (RS). It is used to perform key
federal retirement benefit management functions including processing the
annuity roll in daily, monthly and yearly cycles, court orders, voluntary
allotments, health benefit/insurance providers’ modifications, lump sum
payouts, pay history, service history, and agency matching validations.
ARS supports distributed RS information technologies (IT) and applications
which enable the office to serve millions of active federal annuitants and
survivors. This system contains the vast majority of retirement customer
transactions for OPM, and includes data from all Federal agencies (Executive,
Legislative, Judicial branches, U.S. Postal Service, and Intelligence
Agencies). Specifically, it contains information on annuitants and their
survivors and is the backbone for maintaining accurate retirement records
for proper disbursement of retirement benefits processed through OPM’s
Office of the Chief Financial Officer.
ARS interfaces with multiple systems such as the Federal Annuity Claims
Expert System (FACES), an information technology tool that assists RS in
calculating annuities based on former employees’ records of federal service,
Services Online (SOL), which provides federal retirees and survivor
annuitants the ability to access their monthly annuity payment information
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online, and the Annuitant Health Benefit Online Support System (AHBOSS),
an application that annuitants use to make health benefit enrollment
changes and/or to request brochure information for plans participating in the
Federal Employees Health Benefits (FEHB) program. These interfaces use
batch-file transfer technologies that are machine based in their
authentication and authorization mechanisms as well as technology that
encrypts sensitive information and ensures that it is communicated securely.
Through the FACES interface, ARS obtains annuity calculations for further
processing and adjudication. Through the SOL interface, ARS obtains
annuitant and survivor change requests to modify personal information, such
as federal and state tax withholdings, mailing address, direct deposit
information, and allotment details. Through the AHBOSS interface, ARS
obtains annuitant and survivor change requests for health insurance
providers during the annual FEHB open season.
ARS also receives data files for processing from systems at the Social
Security Administration (SSA), the Department of Labor (DOL) and the
Railroad Retirement Board (RRB). It interfaces with systems at SSA for a
series of individual matching validations including for the FEHB program,
prescription drug subsidy under Medicare, cost of living adjustment impacts,
disability benefits checks for annuitants and survivors, and death
notifications of annuitants. ARS interfaces with DOL’s Office of Workers’
Compensation program (OWCP) to identify individuals receiving prohibited
concurrent benefits under CSRS and FERS. ARS interfaces with RRB to
identify employees and spouses that are subject to Non-Covered Service
Pensions.

Section 1.0. Authorities and Other Requirements
1.1. What specific legal authorities and/or agreements permit and
define the collection of information by the project in question?
The Civil Service Retirement System (CSRS) is administered pursuant to 5
U.S.C. chapter 83 and the Federal Employee Retirement System (FERS) is
administered pursuant to 5 U.S.C. chapter 84. In addition, the following
authorities are relevant to the information in ARS: 5 U.S.C. § 3301 and
chapters 87, 89 and 90; Pub. L. 83-598, 84-356, 86-724, 94-455, and 106265; and Executive Order 9397, as amended by Executive Order 13478.

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1.2. What Privacy Act System of Records Notice(s) (SORN(s)) apply
to the information?
The records in ARS are covered by the OPM/CENTRAL 1 Civil Service
Retirements and Benefits SORN.
1.3. Has a system security plan been completed for the information
system(s) supporting the project?
Yes. A System Security Plan was completed in conjunction with the
Authority to Operate that was granted to ARS on October 16, 2016.
1.4. Does a records retention schedule approved by the National
Archives and Records Administration (NARA) exist?
A records schedule is under review by NARA. In accordance with NARA
regulations, these records are considered permanent until the schedule has
been approved.
1.5. If the information is covered by the Paperwork Reduction Act
(PRA), provide the OMB Control number and the agency number for
the collection. If there are multiple forms, include a list in an
appendix.
The information in ARS is obtained from a variety of forms, some of which
are subject to the PRA and others that are not. Please see appendix A,
which identifies the forms and, where applicable, the corresponding OMB
control number.

Section 2.0. Characterization of the Information
2.1. Identify the information the project collects, uses, disseminates,
or maintains.
ARS collects, uses, disseminates, or maintains the following information:
name, claim number, date of birth, social security number, address, marital
status, financial and banking information and key values to compute an
annuity, and health care insurance information (plan and carrier details).
2.2. What are the sources of the information and how is the
information collected for the project?
The information in ARS is obtained directly from the individual annuitant,
who provides it via the various forms referenced in section 1.5. Data in ARS
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originates primarily from the annuitant’s paper application for benefits and
employment records submitted by that annuitant’s former agency. ARS also
receives data from the internal OPM systems FACES, SOL and AHBOSS; and
from external agencies via secure, encrypted connections.
2.3. Does the project use information from commercial sources or
publicly available data? If so, explain why and how this information
is used.
Yes. ARS uses software for zip code verification prior to monthly annuity roll
processing. The software validates, corrects and standardizes customer
address data, and is certified by the United States Postal Service. Its address
data solutions help provide accurate, on-time delivery of correspondence,
goods, and services, while minimizing costs of undelivered mail.
2.4. Discuss how accuracy of the data is ensured.
A review of the annuity computation is conducted by Legal Administrative
Specialists employed by OPM and checked against information in paperbased records. In addition, OPM has matching agreements with other
benefits-paying Federal agencies to ensure correctness of
employment/employee information and benefit computations. Individuals
are also afforded opportunities to review the accuracy of the data as
described in Section 7.0.
2.5. Privacy Impact Analysis: Related to Characterization of the
Information
Privacy Risk

Mitigation

There is a risk of collecting
extraneous information.

This risk is mitigated through expert
analysis of data elements required
to determine the proper type of
annuity. The forms listed in Section
1.5 are crafted to request only those
data elements required to process a
claim.

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Privacy Risk

Mitigation

There is a risk that the information
in ARS is not accurate.

This risk is mitigated by the detailed
procedures ARS has in place,
described in Section 2.4, to ensure
that the information is as accurate
as possible. OPM also assumes that
information regarding the Federal
employees that comes directly from
other agencies is correct and has
been validated by the employing
agency then submitted
appropriately.

Section 3.0. Uses of the Information
3.1. Describe how and why the project uses the information.
The information in ARS is used for the computation of Federal retirement,
health, and life insurance benefits, and to determine qualification regarding
pay benefits.
ARS supports Retirement Services’ management of retirement benefits for
Federal annuitants, and their survivors and dependents, across the
government. The information in ARS is used for the computation of CSRS
and FERS benefits, CSRS and FERS and survivors' benefits, FEHBP and
enrollments, and FEGLI benefits, and to withhold State income taxes from
annuitant payments. The information may also be used to compute CSRS
and FERS benefit estimates.
ARS uses first, last, and middle initial of name for employee identification;
Social Security number for an alternate unique identifier if the claim number
is not available; date of birth, in combination with other data elements, to
search annuitants; claim number as a unique identifier for the annuitant
case file; marital status to calculate any survivor benefits elected at
retirement; and health insurance carrier information as part of the annuity
benefit package and key values to compute annuity payments.

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3.2. Does the project use technology to conduct electronic searches,
queries, or analyses in an electronic database to discover or locate a
predictive pattern or an anomaly? If so, state how OPM plans to use
such results.
No. ARS does not use technology to conduct electronic searches, queries, or
analyses for the purpose of discovering or locating a predictive pattern or
anomaly. Only simple searches by claim number based on specific criteria
manually input by the users are allowed.
3.3. Are there other programs or offices with assigned roles and
responsibilities within the system?
Yes, there are other program offices within OPM with assigned roles and
responsibilities within ARS. These include Healthcare and Insurance, the
Chief Financial Officer’s staff, and the Office of the Chief Information Officer.
Healthcare and Insurance requires access to process healthcare enrollments,
the Chief Financial Officer requires access to process financial statements
and dispense benefits, and the Chief Information Officer requires access for
IT system development and maintenance.
3.4. Privacy Impact Analysis: Related to the Uses of Information
Privacy Risk

Mitigation

There is a risk that the information
in ARS could be used for a purpose
other than that for which it was
initially collected.

This risk is mitigated by user roles
established by the ARS
Administrator. Only those with a
function related to managing the
Annuity Roll will be granted access
and only authorized users may
access or modify the data in ARS.

There is a risk that an unauthorized
user might access the information in
the system.

This risk is mitigated through role
based access control and following a
strict IT access provisioning policy.

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Section 4.0. Notice
4.1. How does the project provide individuals notice prior to the
collection of information? If notice is not provided, explain why not.
Individuals will not typically have access to ARS; therefore notice is not
given by the system. However, though no notice is given directly from the
ARS system, a statement regarding a retiring employee’s coverage and
Privacy Act statements are on each paper application for retirement benefits
given to employees by their employing agency. This PIA as well as the
published SORN referenced in Section 1.2 also provide notice to individuals.
4.2. What opportunities are available for individuals to consent to
uses, decline to provide information, or opt out of the project?
Individuals may opt to exclude required information as requested on the
paper application; however it will impact the processing of their retirement
application and subsequent annuity/benefit calculation and distribution.
Federal employees cannot opt-out of the benefit since it is given as part of
the employment.
4.3. Privacy Impact Analysis: Related to Notice
Privacy Risk

Mitigation

There is a risk that individuals are
not aware that ARS contains their
information.

This PIA provides notice that ARS
uses and shares data with internal
OPM source systems and external
Federal agencies for purposes of
data matching related to retirement
benefits. Notice is also provided
that individual information may be
shared outside of OPM through the
Routine Use sections of the
applicable SORN. In addition,
retiring employees receive notice
when they complete the retirement
application.

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Section 5.0. Data Retention by the Project
5.1. Explain how long and for what reason the information is
retained.
Until the replacement for records schedule number NC1-146-84-03 is
approved, we are retaining the records in ARS permanently, as required by
law. The new schedule will have the retention mandated by 5 U.S.C. §
8345(i): We will destroy the records 30 years after the date of the
employee’s death or 115 years after the date of the employee’s birth,
whichever is sooner.
5.2. Privacy Impact Analysis: Related to Retention
Privacy Risk

Mitigation

There is a risk that the length of the
retention period will impact data
quality due to media age.

This risk is mitigated by testing and
verification of ARS backups.

There is a risk that information will
be kept longer than is necessary to
achieve the necessary business
purpose.

This risk is currently not mitigated
as the records must be treated as
permanent until a records schedule
in place. OPM is working through
the process required to establish a
new records schedule in order to
mitigate this risk as soon as
possible.

Section 6.0. Information Sharing
6.1. Is information shared outside of OPM as part of the normal
agency operations? If so, identify the organization(s) and how the
information is accessed and how it is to be used.
Information in ARS is shared externally primarily with other Federal agencies
in accordance with Computer Matching Agreements, memoranda of
understanding, or information exchange agreements. The information is
disclosed for a series of individual matching validations to ensure correctness
and completeness of information and for retirement benefit distribution and
fraud prevention. In addition, OPM contractors are provided with access to
ARS pursuant to contracts for the development and maintenance of ARS.

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6.2. Describe how the external sharing noted in 6.1 is compatible
with the SORN noted in 1.2.
The information sharing described above is conducted in accordance
primarily with the following routine uses in the OPM/CENTRAL 1 SORN:
k. For Non-Federal Personnel--To disclose information to private
organizations, contractors, grantees, volunteers, or other non-Federal
personnel performing or working on a project, contract, service, grant,
cooperative agreement, or job for, to the benefit of, or consistent with the
interests of the Federal Government when OPM has determined that the use
of that information is compatible with proper disclosure and will benefit
Federal employees, annuitants or their dependents, survivors, and
beneficiaries. To disclose information to contractors, grantees, or volunteers
performing or working on a contract, service, grant, cooperative agreement,
or job for the Federal Government.
l. To disclose, to the following recipients, information needed to adjudicate a
claim for benefits under OPM's or the recipient's benefits program(s), or
information needed to conduct an analytical study of benefits being paid
under such programs: Office of Workers' Compensation Programs;
Department of Veterans Affairs Pension Benefit Program; Social Security
Administration's Old Age, Survivor and Disability Insurance and Medical
Programs and Supplemental Security Income Program; Center for Medicare
and Medicaid Services; Department of Defense; Railroad Retirement Board;
military retired pay programs; Federal civilian employee retirement
programs (other than the CSRS or FERS); or other national, State, county,
municipal, or other publicly recognized charitable or social security
administrative agencies;
m. To disclose to the Office of Federal Employees Group Life Insurance
(OFEGLI) information necessary to verify the election, declination, or waiver
of regular and/or optional life insurance coverage or eligibility for payment of
a claim for life insurance.
n. To disclose to health insurance carriers contracting with OPM to provide a
health benefits plan under the FEHB, SSN, and other information necessary
to identify enrollment in a plan, to verify eligibility for payment of a claim for
health benefits, or to carry out the coordination for benefits provisions of
such contracts.

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z. To disclose to an allottee, as defined in 5 CFR 831.1501, the name,
address, and the amount withheld from an annuitant's benefits, pursuant to
5 CFR 831.1501 et seq. as an allotment to that allottee to implement the
program of voluntary allotments authorized by 5 U.S.C. 8345(h) or 8465.
bb. To disclose to the Social Security Administration the SSN of civil service
annuitants
6.3. Does the project place limitations on re-dissemination?
Yes, re-dissemination of ARS information is subject to the terms stated in
signed computer matching agreements and information exchange
agreements.
6.4. Describe how the project maintains a record of any disclosures
outside of OPM.
The ARS application captures information in audit records to establish what
events occurred, the sources of the events, and the outcome of the events.
Audit record content includes: (i) date and time of the event; (ii) the
component of the information system where the event occurred; (iii) type of
event; (iv) subject identity; and (v) outcome of the event (success or
failure) of the event. Records disclosed outside of OPM are maintained
through interface logs (e.g., batch files) upon distribution as outlined in
section 6.1.
6.5. Privacy Impact Analysis: Related to Information Sharing
Privacy Risk

Mitigation

There is a risk that information from
ARS could be inappropriately
disclosed for a purpose that is not
consistent with the purpose for
which it was collected.

This risk is mitigated be entering
into agreements with information
sharing partners that clearly define
the purpose for the sharing,
consistent with the purpose stated
in the applicable SORN. In addition,
OPM technical personnel review and
analyze application audit records to
ensure that information is accessed
appropriately.

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Privacy Risk

Mitigation

There is a risk that information,
once shared appropriately, will be
further shared or used in a manner
that is inconsistent with the original
purpose for which it was collected
and/or shared.

This risk is mitigated be ensuring
that the sharing is subject to written
agreements that define the
purposes for which information is
shared, prohibits additional uses,
and appropriately limits any onward
sharing with third parties.

Section 7.0. Redress
7.1. What are the procedures that allow individuals to access their
information?
Individuals do not have direct access to ARS. However, benefits information
is provided to annuitants/survivors annually via mail or electronically and is
also available for review on Services Online (SOL). A Summary of Benefits
booklet is prepared upon benefit adjudication and mailed to the annuitant.
In addition, individuals may request access to their records by contacting the
system owner identified in the OPM/CENTRAL 1 SORN and providing the
following information: name, including all former names; date of birth;
Social Security number; the name and address of the office in which he or
she is currently or was formerly employed in the Federal service; and
annuity, service credit, or voluntary contributions account number, if
assigned. Individuals requesting access must also follow OPM's Privacy Act
regulations, 5 C.F.R. part 297, regarding verification of identity and access
to records.
7.2. What procedures are in place to allow the subject individual to
correct inaccurate or erroneous information?
Individuals do not have direct access to ARS but can access and update their
information through the web-based Services Online (SOL). Alternatively,
individuals may contact Retirement Services directly to notify the agency of
changes to personal information. Based on the type of change, RS may
require the individual submit evidence to prove identity and/or the validity of
change.
In addition, individuals may request that their records be corrected by
contacting the system owner identified in the OPM/CENTRAL 1 SORN and

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providing the following information: name, including all former names; date
of birth; Social Security number; the name and address of the office in
which he or she is currently or was formerly employed in the Federal
service; and annuity, service credit, or voluntary contributions account
number, if assigned. Individuals requesting access must also follow OPM's
Privacy Act regulations, 5 C.F.R. part 297, regarding verification of identity
and access to records.
7.3. How does the project notify individuals about the procedures for
correcting their information?
Individuals are notified at the time of retirement and through subsequent
notifications via mail about the availability of the SOL website as a
mechanism for accessing and correcting their information. In addition, the
OPM/CENTRAL 1 SORN provides notification concerning correcting records,
as does this PIA.
7.4. Privacy Impact Analysis: Related to Redress
Privacy Risk

Mitigation

There is a risk that individuals may
not be able to access information
that is contained in ARS nor be
afforded adequate opportunity to
correct that information.

This risk is mitigated by providing
individuals with access to their
information via the SOL website, as
well as through the procedures
outlined in the OPM/CENTRAL 1
SORN.

There is a risk that individuals will
not be notified concerning their
ability to access and amend their
records.

This risk is mitigated through
notification that is provided to
individuals at the time of retirement,
as well as through subsequent
mailings. In addition, the
OPM/CENTRAL 1 SORN provides
notice regarding the procedures for
accessing and correcting
information.

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Section 8.0. Auditing and Accountability
8.1. How does the project ensure that the information is used in
accordance with stated practices in the PIA?
ARS maintains access roles for OPM personnel and contractors that restrict
and grant access to information and functionality based on the user’s role in
supporting the business process need. ARS captures sufficient information in
audit records to establish what events occurred, the sources of the events,
and the outcomes of the events.
OPM personnel review and analyze application audit records for indications
of inappropriate or unusual activity, investigate suspicious activity or
suspected violations, report findings to appropriate officials, and take
necessary actions
8.2. Describe what privacy training is provided to users either
generally or specifically relevant to the project.
All OPM employees are required to complete annual IT Security and Privacy
Awareness Training. In addition, end-users receive applicable ARS content
training specific to their work responsibilities, which covers the appropriate
use of the information in ARS and individual user responsibility.
8.3. What procedures are in place to determine which users may
access the information and how does the project determined who
has access?
ARS administrators grant access based on approval from the user’s Federal
supervisor. Each user is assigned a unique user account and assigned a
defined set of privileges based on the least privilege principle. The ARS
administrator is responsible for ensuring the appropriate authorization has
been granted for the access and the privileges requested, and for the
removal of the user’s privileges once that authorization has ceased.
Contractors serve as system developers and maintain the retirement
systems at OPM. A contractor’s access to ARS is based on the length of the
contract and on the work the contractor is obligated to perform to support
ARS and OPM. Before a contractor is granted access to ARS, the ARS
administrator confirms that there is a valid contract in place, the contractor
has a successfully adjudicated background investigation, and the contractor
has completed IT Security and Privacy Awareness training. ARS program
staff receive a list of all users that have left OPM each month from OPM
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Human Resources. OPM network staff will terminate access of any contractor
or OPM employee that no longer requires access. In addition, the OPM
network administrators will suspend/remove access from contract personnel
when the contract has expired.
8.4. How does the project review and approve information sharing
agreements, MOUs, new uses of the information, new access to the
system by organizations within OPM and outside?
ARS program managers coordinate with the Office of the Chief Information
Officer and with the Chief Privacy Officer, as needed, to review and assess
new uses of information contained in ARS. ARS program managers, the CPO,
and CIO also routinely review information sharing agreements, including
Memoranda` of Understanding (MOUs), computer matching agreements and
information exchange agreements to ensure that appropriate privacy and
security provisions are included to safeguard PII.

Responsible Officials
Nicholas Ashenden
Deputy Associate Director
Retirement Operations
Office of Personnel Management

Approval Signature

KELLIE RILEY

Digitally signed by KELLIE
RILEY
Date: 2017.12.21 10:27:12
-05'00'

Kellie Cosgrove Riley
Chief Privacy Officer
Office of Personnel Management

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Appendix A
(*PRA not applicable)
Standard Forms:
SF-2800, Application for Death Benefits (Civil Service Retirement System),
OMB No. 3206-0156
SF-2801, Application for Immediate Retirement (CSRS) *
SF-2802, Application for Refund of Retirement Deductions (CSRS), OMB No.
3206-0128
SF-2803, Application to Make Deposit or Redeposit, OMB No. 3206-0134
SF-2804 and SF 2804-A, Application to Make Voluntary Contributions
(CSRS)*
SF-2805, Request for Recovery of Debt due the United States *
SF-2806, Individual Retirement Record *
SF-2807, Register of Separations and Transfers (CSRS) *
SF-2809, Employee Health Benefits Registration Form, OMB No. 3206-0160
SF-2810, Notice of Change in Health Benefits Enrollment *
SF-2817, Life Insurance Election: Federal Employees' Group Life Insurance
Program, OMB No. 3206- 0230
SF-2818, Continuation of Life Insurance Coverage as an Annuitant or
Compensationer*
SF-2821, Agency Certification of Insurance Status*
SF-3101, Notice of Correction of Individual Retirement Record*
SF- 3100, Individual Retirement Record (FERS) *

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SF-3104 and SF-3114, Application for Death Benefit (FERS), OMB No. 32060172
SF-3106, Application for Refund of Retirement Deductions (Federal
Employees Retirement System) (SF 3106A, Current/Fonner Spouse's
Notification for Refund Retirement Deductions is included with this form.),
OMB No.3206-0170
SF-3107 and SF 3113, Application for Immediate Retirement (Federal
Employees Retirement System) *
SF-3109, Election of Coverage (Federal Employees Retirement System)
OPM Forms:
OPM 1482, Agency Certification of Status of Reemployed Annuitant - Federal
Employees' Group Life Insurance Program*
OPM 1496A, Application for Deferred Retirement, Civil Service Retirement
System (Separations on or after October 1, 1956), OMB No. 3206-0121
OPM 1522, Request for Offset for Health Benefits Premiums from Monies
Payable Under the Civil Service Retirement System or the Federal Employees
Retirement System (in lieu of SF 2805)*
Retirement Forms:
RI 10-125, Federal Employee Retirement Coverage Corrections Act
(FERCCA) Election Form*
RI 16-28, Authorization for Direct Payments
RI 20-7, Representative Payee Application, OMB No. 3206-0140
RI 20-64, Letter Reply to Request for Information, OMB No. 3206-0235
RI 20-120, Request for Change to Unreduced Annuity, OMB No. 3206-0245
RI 20-122 Certification for Physicians Comparability Allowances (PCA)*

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RI 25-14, Self-Certification of Full-Time School Attendance for the School
Year, OMB No. 3206-0032
RI 25-15, Notice of Change in Student's Status, OMB No. 3206-0042
RI 25-41, Initial Certification of Full-Time School Attendance, OMB No. 32060099
RI 25-49 Verification of Full-Time School Attendance, OMB No. 3206-0215
RI 30-1, Request for Information, OMB No. 3206-0143
RI 30-10, Disabled Dependent Questionnaire, OMB No. 3206-0179
RI 38-45, We Need the Social Security Number of the Person Named Below,
OMB No. 3206-0144
RI 38-107, URGENT - Reply Required Within 30 Days to Avoid Interruption of
Your Payments, OMB No.3206-0197
RI 38-122, Alternative Annuity and Rollover Election*
RI 38-124, Voluntary Contributions Election*
RI 38-128, It's Time to Sign-up for Direct Deposit, OMB 3206-0226
RI 76-10, Assignment of Federal Employee's Group Life Insurance*
RI 79-9, Health Benefits Cancellation/Suspension Confirmation*
RI 92-19 Application for Deferred or Postponed Retirement - Federal
Employees Retirement System (FERS), OMB No. 3206-0190
RI 92-22, Annuity Supplement Earnings Report, OMB No. 3206-0194

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