2900-0510 justification

Supporting Statement for VA Form 21-0571

Application for Exclusion of Children’s Income

(2900-0510)

A. Justification

1. The Department of Veterans Affairs (VA), through its Veterans Benefits Administration (VBA), administers an integrated program of benefits and services established by law for veterans, service personnel, and their dependents and/or beneficiaries, including the Improved Pension program. A veteran’s or surviving spouse’s rate of Improved Pension is determined by family income. Normally, income of children who are members of the household is included in this determination. However, children’s income may be excluded if it is unavailable or if consideration of that income would cause hardship. 38 U.S.C. 1521(h) and 1541(g) provide the authority for the exclusion of children’s income based on unavailability or hardship.

2. VA Form 21-0571 is used for the sole purpose of collecting the information needed to determine whether children’s income is available to the beneficiary, and if it would cause hardship to consider their income.

3. VA From 21-0571 is available on the One-VA web site in a fillable electronic format. VBA is currently hosting this form on a secure server and does not have the technology in place to allow for the complete submission of the form. Validation edits are performed to assure data integrity. Efforts within VA are underway to provide a mechanism to allow the information to be submitted electronically with a recognized signature technology. There currently is no utility process in place that will allow the data submitted on the forms to be incorporated with an existing centralized legacy database. Veterans Online Applications (VONAPP) allows applicants to view, print, and submit applications electronically to VBA. However, VA Form 21-0571 is not one of the forms scheduled to be added to VONAPP because estimated total usage of this form is low. The Department will reconsider adding this form to VONAPP when the resources become available or if usage of this form becomes greater.

4. Program reviews were conducted to identify potential areas of duplication; however, none were found to exist. There is no known Department or Agency which maintains the necessary information, nor is it available from other sources within our Department.

5. The collection of information does not involve small businesses or entities.

6. 38 CFR 3.23(d) provides the criteria for determining whether children’s income is available to the beneficiary, and if it would cause hardship to consider their income. VA Form 21-0571 solicits information needed to make these determinations. Without this information, VA would be unable to determine whether a child’s income should be excluded, and pension benefits would not be properly paid.

7. There is no special circumstance requiring collection in a manner inconsistent with 5 CFR 1320.6 guidelines.

8. The Department notice was published in the Federal Register on January 22, 2008, Volume 73, Number 14, pages 3807-3808. No comments were received.

9. No payments or gifts to respondents have been made under this collection of information.

10. The records are maintained in the appropriate Privacy Act System of Records identified as 58VA21/22, "Compensation, Pension, Education and Rehabilitation Records - VA" as set forth in Privacy Act Issuances, 1993 compilation found in 42 Fed. Reg. 49726 (9/27/1977).

11. There are no questions of a sensitive nature.

12. Estimate of Information Collection Burden.

a. Number of Respondents is estimated at 2,700 per year.

b. Frequency of Response is one time for most beneficiaries.

c. Annual burden is 2,025 hours.

d. The estimated completion time of 45 minutes is based on review by staff personnel and previous usage of this form.

e. The total estimated cost to respondents is $30,375 (2,025 hours x $15 per hour).

13. This submission does not involve any recordkeeping costs.

14. Estimated Costs to the Federal Government:

a. Processing/Analyzing costs $83,971

(GS-12/5 @ $36.26 2,700 x 15/60 minutes = $24,476)

(GS-9/5 @ $25.00 x 2,700 x 45/60 minutes = $50,625)

(GS-3/5 @ $13.14 x 2,700 x 15/60 minutes = $ 8,870)

b. Printing and production cost $150

c. Total cost to government $84,121

15. The reporting burden has not changed.

16. The information collection is not for publication or tabulation use.

17. The collection instrument, VA Form 21-0571, may be reproduced and/or stocked by the respondents and veterans service organizations. This VA form does not display an expiration date, and if required to do so would result in unnecessary waste of existing stocks of this form. This form is submitted to OMB every 3 years. As such, this date requirement would also result in an unnecessary burden on the respondents and would delay Department action on the benefit being sought. VA also seeks to minimize its cost to itself of collecting, processing and using the information by not displaying the expiration date. For the reasons stated, VA continues to seek an exemption that waives the displaying of the expiration date on VA Form 21-0571.

18. This submission does not contain any exceptions to the certification statement.

B. Collection of Information Employing Statistical Methods

The Veterans Benefits Administration does not collect information employing statistical methods.