2900-0665 justification

SUPPORTING STATEMENT

VA FORM 29-0309_

DIRECT DEPOSIT ENROLLMENT FORM

2900-0665

JUSTIFICATION:

1. This form is used by the insured or beneficiary to apply for direct deposit of a Treasury check. The information on the form is required by Public Law 104-134.

2. The data collected on the form is used by the Department of Veteran Affairs (VA) to initiate direct deposit of an insurance benefit. VA Form 29-0309 is not only used by VA beneficiaries but by living veterans for their active VA life insurance.

3. VA Form 29-0309 will be 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 currently have the technology in place to allow for the complete submission of this 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 this form 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. This form is designed for use by the insured or beneficiary to establish his/her eligibility for direct deposit.

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 May 18, 2011, page 28852-28853. No comments were received.

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

10. The information collection conforms to 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 30,000 applications a year will be received. We also estimate that it will take approximately 20 minutes to complete this form. We arrived at this estimate by initiating a trial with a VA staff member unfamiliar with this form. The annual burden is 10,000. Cost to reporting public is $150,000.00 (10,000 hours X $15/hour).

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

14. Cost to Government:

$26,970.00 Estimated mailing cost (30,000 X 2 minutes per

form X $15.51/hour (average salary for station

mail personnel) plus 30,000 X 38.2 cents each

(presort discount)).

$13,980.00 Estimated cost for collections (30,000 X 2 minutes

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

personnel)).

$99,150.00 Estimated cost for processing (30,000 forms X 10

minutes per form X $19.83/hour (average salary

for reviewers)).

$900.00 Estimated printing costs (30,000 X $30/1,000 forms).

$141,000.00 Total cost to the Government.

15. There is no change in burden.

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

17. The collection instrument, VA Form 29-0309, may be reproduced and/or stocked by the respondents and veteran service organizations. This VA form does not display an expiration date, and if required to do so would result in unnecessary waste of existing stock of this form. This form is 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 this VA form.

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

OMB Form 83-I.

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