2900-0052 justification

Supporting Statement for VA Form 21-2545

Report of Medical Examination for Disability Evaluation

(2900-0052)

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 U.S.C. 501 (a) authorizes VA to prescribe all rules and regulations which are necessary or appropriate to carry out the laws administered by the Department, including the methods of making medical examinations. 38 CFR 3.326 authorizes a VA examination where the reasonable probability of a valid claim is indicated in any claim for disability compensation or pension, including claims for benefits set forth under 38 C.F.R. 3.351(d) and (e), benefits based on the need of a veteran, surviving spouse, or parent for regular aid and attendance, and benefits based on a child’s incapacity for self-support.

2. VA Form 21-2545 is used to gather the necessary information from a claimant prior to undergoing a VA examination and to record the findings of the examining physician.

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. Veterans Online Applications (VONAPP) allows applicants to view, print and submit applications electronically to VBA; however, the Department is not planning to add VA Form 21-2545 to VONAPP as it is completed by three different parties. After VBA schedules a VA examination, VA Form 21-2545 is partially completed by VBA before it is mailed to the veteran. The veteran completes sections A and B, signs the form, and brings it to the scheduled VA examination. The VA examiner then completes section C during or after examination. 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. The VA compensation and pension programs require current information to determine initial and continuing eligibility for benefits. This form solicits the information needed to determine the level of disability. Without this information, benefits could not be administered effectively.

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 May 22, 2011, page 27380-2738. 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 58VA21/22/28,‘‘Compensation, Pension, Education, and Rehabilitation Records—VA ’’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 180,000 per year.

b. Frequency of Response is on occasion for most beneficiaries.

c. Annual burden is 45,000 hours.

d. The estimated completion time of 15 minutes is based on review by staff personnel and previous usage of this form.

e. The total estimated cost to respondents is $675,000 (45,000 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 $ 13,870,050

(GS-12/5 @ $40.66 x 180,000 x 60/60 minutes = $7,318,800)

(GS- 9/5 @ $28.04 x 180,000 x 70/60 minutes = $5,888,400)

(GS- 3/5 @ $14.73 x 180,000 x 15/60 minutes = $ 662,850)

b. Printing and production cost $9,000

c. Total cost to government $ 13,879,050

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 21-2545, 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 21-2545.

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

B. Collection of Information Employing Statistical Methods

The submission does not employ statistical methods.