SUPPORTING STATEMENT
CLAIM FOR REIMBURSEMENT – FORM CA-278
OMB NO. 1215-0202
1. The Office of Workers’ Compensation Programs (OWCP) is the federal agency responsible for administration of the War Hazards Compensation Act (WHCA), 42 U.S.C. 1701 et seq., http://nt5.scbbs.com/cgi-bin/om_isapi.dll?clientID=371055&infobase=whca-act.nfo&softpage=PL_frame Under section 1704(a) of the WHCA, an insurance carrier or self-insured who has paid workers’ compensation benefits to or on account of any person for a war-risk hazard may seek reimbursement for benefits paid (plus expenses) out of the Employees Compensation Fund for the Federal Employees’ Compensation Act (FECA) at 5 U.S.C. 8147. http://nt5.scbbs.com/cgi-bin/om_isapi.dll?clientID=371046&infobase=feca-act.nfo&softpage=PL_frame
Form CA‑278 is used by insurance carriers and the self-insured to request reimbursement. The regulations that implement the WHCA permit OWCP to collect the information needed to consider an insurance carrier’s or self-insured’s reimbursement request at 20 CFR 61.101 and 61.104. http://nt5.scbbs.com/cgi-bin/om_isapi.dll?clientID=250127&infobase=whca-reg.nfo&jump=sec%2061.101&softpage=PL_frame#JUMPDEST_sec%206101
2. The information collected is used by OWCP staff to process requests for reimbursement of WHCA benefit payments and claims expenses submitted by insurance carriers and self-insureds. The information is also used by OWCP to decide whether it should opt to pay ongoing WHCA benefits directly to the injured worker.
3. Form CA-278 is currently posted on the internet at http://www.dol.gov/esa/regs/compliance/owcp/ca-278.pdf for downloading by insurance carriers and self-insured. However, since Form CA-278 must be accompanied by documentation in support of the request for reimbursement, providing for the submission of this information electronically is not considered to be practicable.
4. The information collected on this form is not duplicative of any information available elsewhere. The respondent is the only source of the benefit payment and claims expenses data that is needed to process the request for reimbursement.
5. This information collection has been streamlined to obtain the minimum information needed for OWCP to process a request for reimbursement while imposing the minimum burden on respondents, and does not have a significant economic impact on a substantial number of small entities.
6. Please refer to Nos. 1 and 2 on page 1. The information collected from both insurance carriers and self-insureds is the minimum needed to evaluate whether a reimbursement request meets the statutory requirements in the WHCA. Reimbursement requests cannot be processed by OWCP without the information collected.
7. There are no special circumstances for conducting this information collection.
8. No outside consultations have been conducted concerning the use of Form CA-278. However, reimbursement for benefit payments and claims expense has been available since the WHCA was passed in 1942, and OWCP has received a sufficient number of requests for reimbursement to develop the proposed collection instrument.
A notice inviting public comment on this information collection was published in the Federal Register on January 10, 2007. No comments were received.
9. Respondents do not receive any gifts or payments to furnish the requested information.
10. All information collected by and submitted with Form CA-278 will be protected under the Privacy Act http://www.usdoj.gov/oip/privstat.htm in the system of records entitled DOL/GOVT-1. http://www.dol.gov/sol/privacy/dol-govt-1.htm
11. There are no questions of a sensitive nature on this form.
12. OWCP receives an average of 140 new WHCA reimbursement claims annually, of which approximately 140 are opened when an insurance carrier or self-insured submits a request for reimbursement to OWCP. These 140 responses are submitted by seven respondents through attorney firms (twenty responses per year per respondent, since each reimbursement request is for a single beneficiary). It is estimated that each Form CA-278 will take approximately 30 minutes to prepare, for an annual hour burden of 70 hours (140 responses annually x 0.5 = 70 hours). Using the current median hourly wage for insurance claims and policy processing clerks (reported by the Bureau of Labor Statistics) http://www.bls.gov/oes/current/oes439041.htm of $14.49 per hour, the respondent annualized cost estimate for this collection is $1014 (70 x 14.49 = 1014.3). The rate of submission of new claims has increased as the result of the conflict in Iraq. The increase is likely to continue in the next few years as additional injuries or deaths occur.
13. There are no startup costs for this information collection. Operation and maintenance costs consist solely of mailing costs. An estimated annual total of 140 mailed responses at $1.71 per response (based on $1.56 in postage for 4 ounces to accommodate attachments + $.15 for large size envelope) = annual operation and maintenance costs of $239 (140 x 1.71) = 239.4).
14. The estimated costs to the Federal government of collecting the information on Form CA-278 are set out below:
Printing costs: Due to the small number of respondents that OWCP contemplates will submit a Form CA-278; there are no plans to print the form in bulk for distribution.
Mailing/Developmental costs: Insurance carriers and self-insureds who wish to request reimbursement from OWCP will be able to download Form CA-278 directly from the Internet once it has been approved by OMB and for that reason, no mailing costs for the form will be incurred. There are also no developmental costs associated with this collection of information.
Processing/Reviewing Costs: Reimbursement requests made under the WHCA are processed by a “special claims” unit located in the FECA program’s district office in Cleveland, Ohio that includes 5 GS-12 claims examiners, 2 GS-12 senior claims examiners and 1 GS-13 supervisor; they spend about 10% of their time processing WHCA reimbursement requests.
Claims Examiners Grade/Step Salary Cost
2 GS-12/4 $70,279 $140,558
2 GS-12/6 $74,538 $149,076
2 GS-12/7 $76,667 $153,334
1 GS-12/8 $78,796 $ 78,796
1 GS-13/10 $98,766 $ 98,766
Total Cost $620,530
$620,530 x 10% of the salaries listed above = $62,053 for the Estimated Federal cost.
The Salary Table 2006-CLE, www.opm.gov/oca/06tables/html/cle.asp was used to arrive at the estimated Federal Cost.
15. There is an adjustment of 40 burden hours to 70 which is an increase of 30 burden hours as a result of the number of claims being submitted due to the conflict in Iraq. There has been a change in the operation and maintenance cost due to an increase in postage from $97 to $239.
16. There are no plans to publish any data collected by Form CA-278.
17. This information collection request does not seek a waiver from the requirement to display the expiration date.
18. There are no exceptions to the certification statement.
| File Type | application/msword |
| Author | U.S. DOL |
| Last Modified By | U.S. Department of Labor |
| File Modified | 2007-01-10 |
| File Created | 2007-01-10 |