2900-0068 justification

SUPPORTING STATEMENT

VA FORMS 29-4364, 29-4364C & 29-0151

APPLICATION FOR SERVICE-DISABLED VETERANS INSURANCE

2900-0068

JUSTIFICATION:

1. These forms are used by veterans to apply for Service Disabled Veterans Insurance, to designate a beneficiary and to select an optional settlement. The information is required by law, 38 USC, Section 1922.

2. The data collected on these forms are used by Department of Veterans Affairs (VA) to determine the veteran’s eligibility for insurance. VA Form 29-4364C is being added for veterans who have been rated individually unemployable or have been rated for certain severely disabling conditions. These veterans do not need to provide medical information to qualify for the insurance. VA Form 29-4364 and VA Form 29-0151 are being revised to delete certain medical questions, which will lessen the respondent burden to 20 minutes.

3. VA Form 29-4364 is available on the One-VA web site in a fillable electronic format and the VA Insurance website. VBA is currently hosting this form on a secure server and does not currently have the technology in place to allow for the complete submission of the form. VA Form 29-0151 is released to the veteran when he/she is first notified of their disability rating. This form is not available to the general public. VA Form 29-4364C also is not available to the general public. The Department of Veterans Affairs will release this form to the appropriate individuals. 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.

4. The information is not contained in any other VA records. Similar information is not available elsewhere.

5. The information does not involve any small businesses.

6. These forms are designed for use by the insured to apply for Service Disabled Veterans Insurance, to designate a beneficiary and to select an optional settlement.

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

8. The Department notice was published in the Federal Register on November 4, 2010, Volume 75, Number 213, Pages 68036-68037. There were no comments received in response to this notice.

9. The information collected is supplied by the respondent. No remuneration is made.

10. The information collection conforms with the Privacy Act of 1974 and is subject to the conditions of disclosure contained therein. The records are maintained in the system identified as 36VA00, “Veterans and Armed Forces Personnel United States Government Life Insurance Records - VA” as contained in the Privacy Act Issuances, 1993 Compilation.

11. There are no questions of a sensitive nature.

12. We estimate that approximately 25,000 forms a year will be received. We also estimate that it will take approximately 20 minutes to complete these forms. We arrived at this estimate by initiating a trial with a VA staff member unfamiliar with the forms. The annual burden will now be 8,333 hours. Cost to reporting public is $124,995 (8,333 hours X $15/hour).

13. This submission does not involve any record keeping costs.

14. Cost to Government:

$ 12,925.00 Estimated mailing cost (25,000 X 2 minutes per

form X $15.51/hour (average salary for station

mail personnel)

$ 11,650.00 Estimated cost for collections (25,000 X 2 minutes

per X $13.98/hour (average salary of station collections

personnel)).

$ 991,500.00 Estimated cost for processing (25,000 forms X 120

minutes per form X $19.83/hour (average salary

for reviewers)).

$ 750.00 Estimated printing costs (25,000 X $30/1,000 forms).

$1,016,825.00 Total cost to the Government.

15. There is a change in respondent burden due to the fact certain medical questions have been removed from the forms. Also, the increase in the burden hours is due to more veterans becoming eligible for this type of insurance, therefore more applications are received and the inclusion of VA Form 29-4364c.

16. The information is collected for insurance purposes only and there are no plans for publication.

17. The collection instruments, VA Form 29-4364, VA Form 29-4364C and 29-0151, may be reproduced and/or stocked by the respondents and veteran service organizations. These VA forms do not display an expiration date, and if required to do so would result in unnecessary waste of existing stock of these forms. These forms are submitted to OMB for approval every three 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 these VA forms.

18. There are no exceptions to the certification statement identified in Item 19 of

OMB Form 83-I.

Statistical Methods

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