Public Comments

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PUBLIC SUBMISSION

As of: 10/27/26, 8:39 AM
Received: October 26, 2026
Status: Draft
Tracking No. mvq-51v4-6kzh
Comments Due: October 26, 2026
Submission Type: Web

Docket: SSA-2026-0991
Agency Information Collection Activities: Proposed Request
Comment On: SSA-2026-0991-0001
Agency Information Collection Activities: Proposed Request
Document: SSA-2026-0991-DRAFT-0002
Comment from Anonymous

Submitter Information
Name: Anonymous Anonymous

General Comment
Under 44 U.S.C. § 3506(c) and 5 C.F.R. § 1320.8, SSA must support its burden estimates with an
objectively defensible methodology, establish the practical utility of the information collected, and
consider whether the collection can be improved or its burden reduced.
First, SSA should explain its valuation methodology. Several collections use average disability benefit
payments as an hourly proxy for the opportunity cost of respondents' time, while another averages
disability payments and worker wages. A benefit amount is not itself an hourly wage. SSA should disclose
the calculations and explain why these figures reasonably measure the opportunity cost of time for the
populations concerned.
Second, SSA should explain its treatment of waiting time. In the Marital Relationship Questionnaire
collection, SSA includes 21 minutes of field-office waiting time for all paper-form respondents, while
acknowledging that individuals who mail or drop off completed forms experience no such wait. SSA
should disclose the assumptions underlying this estimate and distinguish actual in-person burden from
burden attributable to other completion methods.
Third, SSA should clarify the burden and respondent totals for the Georgia SOAR evaluation. The table
reports 165 respondents across three instruments despite a project population of 90 individuals. Although
respondents may participate in multiple collections, SSA should distinguish unique individuals from
instrument-specific respondent counts to avoid ambiguity in the reported totals.
Fourth, SSA should substantiate the five-minute burden estimate for Form HA-4608, which documents a
claimant's waiver of a personal appearance before a judge. SSA should explain whether this estimate
includes reading the form, understanding the consequences of waiving an appearance, and making an
informed decision. The agency should also confirm that the form adequately explains the right being
waived and that the process protects voluntary and informed choice.

These issues are directly relevant to the accuracy of the burden estimates and the adequacy of SSA's PRA
submission. I request that SSA provide the underlying calculations, clarify its assumptions, and revise any
estimates that cannot be supported by the administrative record before requesting OMB approval.