2900-0594 justification

SUPPORTING STATEMENT FOR OMB NUMBER 2900-0594

Election to Apply Selected Reserve Service to Either Montgomery GI Bill-Active Duty or to the Montgomery GI Bill-Selected Reserve

A. Justification.

1. The Department of Veterans Affairs (VA) is authorized to pay educational benefits to veterans and other eligible persons pursuing approved programs of education under chapter 30, title 38 U.S.C. and chapter 1606, title 10, U.S.C. This information collection relates to elections between chapter 30 and chapter 1606 benefits. A member of the Selected Reserve can elect to have his or her service credited toward either chapter 30 (Montgomery GI Bill-Active Duty) or chapter 1606 (Montgomery GI Bill-Selected Reserve) education benefits. The reservist must make this election in writing.

The following administrative and legal requirements necessitate the collection:

1. 38 U.S.C. 3033(c) and 10 U.S.C. 16132

B. 38 CFR 21.7042 and 21.7540

2. VA uses the election to determine which benefit is payable based on the individuals reserve service. Without this information, VA would not be able to determine under which education benefit the individual wishes to be paid.

 

3. Information technology cannot be used to reduce the burden. This election must be in writing and must be signed by the individual. At the present time, electronic signatures and authentication technologies are being evaluated and tested within the Department and will be deployed when possible. Until the technology is in place, however, the form cannot be submitted electronically.

4. VA is not aware of any duplication of this information collection.

5. Members of the Selected Reserve are the only sources for this information. The information collection does not have any impact on small businesses or other small entities.

6. Information is only collected once, when the individual applies for education benefits.

7. The collection of this information does not require any special circumstances.

8. The public was informed of the right to submit comments on this information collection. The notice is contained on page 33416 of the Federal Register dated June 8, 2011. No comments were received in response to this notice.

9. VA does not provide any payments or gifts to respondents.

10. The claimant’s election is retained permanently in the claimant’s electronic file. Our assurance of confidentially is covered by our System of Records, Compensation, Pension, Education and Rehabilitation Records – VA (58VA21/22/28) which are contained in the Privacy Act Issuances, 2001 Compilation.

11. None of the information collected is considered to be of a sensitive nature.

12. The estimated annual burden for the collection of the information is 2,667 hours. To arrive at this figure we estimate that the number of reservists who will qualify to elect either benefit due to being called up to active duty from the reserves is approximately 8,000 annually. We estimate that it will take a reservist 20 minutes, or one-third of an hour, to make this election. 8,000 respondents divided by 3 equals the estimated annual burden of 2,667.

The annual cost to the public is $40,005 based on 2,667 at $15.00 per hour.

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

14. The estimated cost to the government is zero.

15. There is no change in burden.

16. VA does not publish this information or make it available for publication.

17. This VA form does not display an expiration date. As these forms are submitted to OMB for approval every three years, this date requirement would result in an unnecessary burden on the public and would delay VA action processing claims for benefits. VA also seeks to minimize the cost to itself of collection, processing, and using the information, by not displaying the expiration date

18. This information collection fully complies with all the requirements of

5 CFR 1320.8(b)(3).

B. Collection of Information Employing Statistical Methods.

This collection of information does not employ statistical methods.