2900-0500

Supporting Statement for VA Form 21-0538

Status of Dependents Questionnaire

(2900-0500)

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. 38 C.F.R. 3.652 provides that veterans are required to certify entitlement factors when requested, so VA can determine continued entitlement to the benefits being paid. Statutory authority is found in 38 U.S.C. 501, Veteran’s Benefits.

2. VA Form 21-0538 is used to request certification of the status of dependents for whom additional compensation is being paid to veterans. Without the information, continued entitlement to the benefits for dependents could not be determined.

3. The collection of information does not involve the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology. VA Form 21-0538 is partially completed by VA with veteran-specific information before it is mailed to certain veterans. Veterans who are receiving compensation with additional compensation for dependents are sent this form approximately once every eight years. To avoid improper use by veterans who are not required to submit this form or are not due to submit the form, the form is not available on the VBA website for downloading. A faxed copy of a properly signed VA Form 21-0538 may be accepted if there are no questions as to its validity. Currently, there has been no consideration of using other information technology. The Department will reconsider using other information technology 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. If the collection were not conducted, VA would have no means of determining continued eligibility for benefits for dependents. Benefits would not be properly paid, and overpayments could result.

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 October 12, 2010 at pages 62636-62637. There were no comments 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 ‘‘Compensation, Pension, Education, and Rehabilitation Records—VA (58VA21/22/28)’’as set forth in Privacy Act Issuances, 1993 compilation found in 74 Fed. Reg. 117 (June 19, 2009).

11. There are no questions of a sensitive nature.

12. Estimate of Information Collection Burden.

a. Number of Respondents is estimated at 84,500 per year.

b. Frequency of Response is approximately once every eight years for most beneficiaries.

c. Annual burden is 14,083 hours.

d. The estimated completion time of 10 minutes is based on review by staff personnel and previous usage of this form.

e. The total estimated cost to respondents is $211,245 (14,083 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 $2,713,295.00

(GS-9/5 @ $28.04 x 84,500 x 55 minutes = $2,171,931.67)

(GS-5/4 @ $17.96 x 84,500 x 5 minutes = $ 126,468.33)

(GS-3/5 @ $14.73 x 84,500 x 20 minutes = $ 414,895.00)

b. Printing and production cost $1,521

c. Total cost to government $2,714,816.00

15. There is no change in the reporting burden.

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

17. The collection instrument, VA Form 21-0538, 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 21-0538.

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.