2900-0017 justification

Justification for VA Form 21-4706, 21-4706b, 21-4706c, 21-4718 and 21-4718a,

Federal Fiduciary Account

(2900-0017)

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. Information is requested by this form under the authority of Title V of the Veterans Benefits Improvement Act of 2004 (Public Law No. 108-454).

2. VA Form 21-4706, 21-4706b, 21-4706c, 21-4718 and 21-4718a will be completed by VA appointed and recognized fiduciaries of VA beneficiaries. The information will be used by VA field examiners to determine whether an individual is an appropriate fiduciary and properly using and maintaining an accounting of the VA beneficiaries compensation or pension payments.

3. VA Form 21-4706b and 21-4718a are available on the One-VA web site in a fillable electronic format. VA Form 21-4706 and 21-4706c require a sworn signature, therefore it is not available in the fillable electronic format. VBA is currently hosting forms on a secure server and does not currently have the technology in place to allow for the complete submission of the form. Validation edits are performed to assure data 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 form 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 21-4706, 21-4706b, 21-4706c, 21-4718 and 21-4718a are not scheduled to be added to VONAPP. The Department will reconsider adding the form to VONAPP when the resources become available.

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. These forms are used to collect the information that is necessary to appoint the appropriate fiduciary for a VA beneficiary. Public Law 108-454 requires VA to consider a potential fiduciary’s credit and criminal background in evaluating his or her qualifications to become a VA fiduciary. Without this collection of information, VA may be negligent by appointing an inappropriate fiduciary. Consequently, VA would be required to re-issue misused benefit payments which would cause addition.

7. There are no special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines of 5 CFR 1320.6.

8. The Department notice was published in the Federal Register on June 29, 2009, pages 31111-31112. No comments were received in response to this notice.

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 "VA Compensation, Pension, Education, and Vocational Rehabilitation and Employment Records - VA (58 VA 21/22/28)," republished in its entirety at 74 FR 14865 (April 1, 2009).   

11. There are no questions of a sensitive nature.

12. Estimate of Information Collection Burden.

a. Number of Respondents is estimated at 31,512 per year for all forms.

VA Form 21-4706 is estimated at 2,200 per year

VA Form 21-4706b is estimated at 14,000 per year

VA Form 21-4706c is estimated at 4,000 per year

VA Form 21-4718 is estimated at 8,000 per year

VA Form 21-4718a is estimated at 3,312 per year

b. Frequency of Response can be semi-annual or annually depending on the findings of the VA field examiner.

c. Annual burden is 29,566 hours.

VA Form 21-4706 is estimated at 1,100

VA Form 21-4706b is estimated at 6,300

VA Form 21-4706c is estimated at 2,000

VA Form 21-4718 is estimated at 20,000

VA Form 21-4718a is estimated at 166

d. The estimated completion time of each form is as follows:

VA Form 21-4706 is 30 minutes

VA Form 21-4706b is 27 minutes

VA Form 21-4706c is 30 minutes

VA Form 21-4718 is 2½ hours

VA Form 21-4718a is 3 minutes

These estimates are based on review by staff personnel and previous usage of this form.

e. The total estimated cost to respondents is $472,680 (31,512 x $15 an hour).

13. This submission does not involve any recordkeeping costs.

14. Estimated Costs to the Federal Government:

a. Processing/Analyzing costs $885,818

GS-10/5 @ $30.15 x 31,512x 30 minutes = $475,043

GS-9/5 @$27.37 x 31,512x 27 minutes = $388,118

GS-3/5 @$14.38 x 31,512 x 3 minutes = $22,657

b. Printing and production cost $750

c. Total cost to government $886,568

15. There is no program change or adjustment to the burden hours.

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

17. The collection instrument, VA Form 21-4706, 21-4706b, 21-4706c, 21-4718, and 21-4718a 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 21-4706, 21-4706b, 21-4706c, 21-4718, and 21-4718a.

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

B. Collection of Information Employing Statistical Methods

The data collection does not employ statistical methods.