SUPPORTING STATEMENT FOR
QUESTIONNAIRE FOR CHILDREN CLAIMING SSI BENEFITS
Form SSA-3881
20 CFR 416.912(a)
A. Justification
Introduction/Authoring Laws and Regulations
When 1) child claimants for Supplemental Security Income (SSI) receive an unfavorable disability eligibility decision from the Social Security Administration (SSA), and the people applying on their behalf want to appeal the decision; or 2) when children who are currently receiving Disabled Child (DC) payments and SSA is reviewing their continued eligiblity, these applicants and recipients need a mechanism to submit relevant evidence about the child’s functioning. SSA uses form SSA-3881, the Questionnaire for Children Claiming SSI Benefits, for that purpose.
Section 1631(d)(2) of the Social Security Act gives the agency the authority to collect the information we need to determine the validity of an applicant’s claim for SSI payments. Public Law 104-193, the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, gives the definitions and eligibility rules for disabled children. Section 20 CFR 416.912(a) of the Code of Federal Regulations states that an applicant must furnish medical and other evidence that SSA can use to reach conclusions about a child’s medical condition.
Description of Collection
The purpose for the information collection is for program evaluation. The respondents are typically parents or legal guardians of children seeking to obtain or retain SSI payments. The respondents provide information about the child’s school history, testing/evaluation history, types of therapy received, vocational rehabilitation, medical conditions, and names and addresses of other people or organizations (such as schools, counselors, agencies, and therapists) who are familiar with the child and could provide useful informaiton to SSA for program evaluation purposes. SSA includes this information in the child applicant’s disability claims file. In turn, SSA shares this information with State Disability Determination Services’ offices, who use the sources provided as resources for collecting more information about the child. Overall, SSA uses the information to determine if 1) its initial rejection of a child SSI applicant was incorrect or 2) if a current recipient of DC payments should continue to receive them.
This collection is mandatory if the child claimant receives an unfavorable disability determination and the people applying on their behalf want to appeal the decision. They are not required to complete the collection if they do not wish to appeal SSA’s unfavorable disability determination. The portion of the form inquiring about the child’s court involvement is a voluntary section.
Use of Information Technology to Collect the Information
Currently, the agency does not have an Internet version of form SSA-3881 under its Government Paperwork Elimination Act plan. However, form SSA-3881 is available electronically to the public on SSA’s website (www.ssa.gov) in a portable document formant (PDF). For those individuals who appeal childhood disability decisions online, we have provided an electronic link directly from the appeals form to the SSA-3881.
In addition, we have taken the first of several steps required to develop the electronic information collection tools necessary to implement an Internet electronic application continuing disability review (eCDR) process. Various aspects of the eCDR process were phased in during 2009 and will continue through 2012. The eCDR collection tool will encompass the questions on the current form SSA-3881, and is expected to extend eventually to appeals.
Why We Cannot Use Duplicate Information
The nature of the information we are collecting and the manner in which we are collecting it preclude duplication. SSA does not use any other collection instrument to collect similar data.
Minimizing Burden on Small Respondents
This collection does not affect small businesses or other small entities.
Consequence of Not Collecting Information or Collecting it Less Frequently
If SSA did not conduct this information collection, we would have no means of ensuring that 1) our initial denials of child applicants for SSI were correct or 2) that our determinations for continuing eligiblity for child SSI payments are accurate. Since respondents only complete this form when one of these situations arises, we cannot collect the information less frequently. There are no technical or legal obstacles to burden reduction.
Special Circumstances
There are no special circumstances that would cause SSA to conduct this information collection in a manner inconsistent with 5 CFR 1320.5.
Solicitation of Public Comment and Other Consultations with the Public
SSA published the 60-day advance Federal Register Notice on January 28, 2010 at 76 FR 5233, and SSA received no public comments. We published the 30-day Notice on April 1, 2011 at 76 FR 18290. If we receive any comments on the second Notice, we will forward them to OMB. We did not consult with members of the public.
Payment or Gifts to Respondents
SSA provides no payment or gifts to the respondents .
Assurances of Confidentiality
SSA protects and holds confidential the information in accordance with 42 U.S.C. 1306, 20 CFR 401 and 402, 5 U.S.C. 552 (Freedom of Information Act), 5 U.S.C. 552a (Privacy Act of 1974), and OMB Circular No. A-130.
Justification for Sensitive Questions
The information collection does not contain any questions of a sensitive nature.
Estimates of Public Reporting Burden
Approximately 152,000 respondents take 30 minutes each to complete Form SSA-3881. The resulting total is 76,000 hours and reflects burden hours. SSA did not calculate a separate cost burden.
Reporting |
Number of Respondents |
Frequency of Response |
Average Burden per Response (minutes) |
Total Annual Burden (hours) |
Appeals Cases |
60,000 |
1 |
30 |
30,000 |
Disability Review Cases |
92,000 |
1 |
30 |
46,000 |
Total |
152,000 |
|
|
76,000 |
Annual Cost to the Respondents (Other)
There is no cost burden to the respondents.
Annual Cost To Federal Government
The annual cost to the Federal Government for form SSA-3881 is approximately $1,558,480. This estimate is a projection of the costs for printing and distributing the collection instrument and for collecting the information.
Program Changes or Adjustments to the Information Collection Request
Due to budgetary constraints, SSA has been conducting fewer disaiblity reviews; thus the decrease in the overall reporting burden.
Plans for Publication Information Collection Results
SSA will not publish the results of this information collection.
Displaying the OMB Approval Expiration Date
OMB granted SSA an exemption from the requirement that we print the expiration date for OMB approval on its program forms. SSA produces millions of public-use forms, many of which have a life cycle longer than that of an OMB clearance. SSA does not periodically revise and reprint its public-use forms, (e.g., on an annual basis). OMB granted this exemption so that otherwise useable editions of forms would not be taken out of circulation because the expiration date had been reached. In addition, we are avoiding Government waste because we will not have to destroy and reprint stocks of forms. SSA is not requesting an exception to the requirement to display the OMB approval expiration date.
Exceptions to Certification Statement
SSA is not requesting an exception to the certification requirements at 5 CFR 1320.9 and related provisions at 5 CFR 1320.8(b)(3).
B. Collections of Information Employing Statistical Methods
SSA does not use statistical methods for this information collection.
0960-0499 (SSA-3881)
| File Type | application/msword |
| File Title | October 1997 |
| Author | 505969 |
| Last Modified By | 889123 |
| File Modified | 2011-04-08 |
| File Created | 2011-02-01 |