2900-0747_justification 08-11

Supporting Statement for

VA Form 21-526EZ, Fully Developed Claim (Application for Compensation), VA Form 21-527EZ, Fully Developed Claim (Application for Pension), VA Form 21-534EZ, Fully Developed Claim (Application for DIC, Death Pension, and Accrued Benefits)

OMB Control Number 2900-0747

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. Public Law 110-389, Section 221 (a) required that VBA carry out the pilot study “Expedited Treatment of Fully Developed Claims” for a period of one-year. VBA subsequently decided to expand a modified version of the program to all 57 regional offices under the title “Fully Developed Claim Program” or “FDC Program.” Currently in use are the prescribed forms for the FDC Program: the VA Form 21-526EZ (Compensation) and VA Form 21-527EZ (Pension).

2. VA Form 21-526EZ, Fully Developed Claim (Application for Compensation), and VA Form 21-527EZ, Fully Developed Claim (Application for Pension), will replace the current VA Form 21-526EZ and 21-527EZ and become the prescribed forms for disability compensation and pension claims, respectively, claimed under the FDC Program. The VA Form 21-534EZ will serve as the prescribed form for DIC, death pension, and accrued benefit claims claimed under the FDC Program. These forms are required as part of the FDC Program Transformation Initiative.

The particular nature of the changes made to these forms is to satisfy the requirements under 38 U.S.C 5103 for claims upon application. VA Forms 21-526EZ, 21-527EZ, and 21-534EZ will each be appended to the FDC Notice. For claims filed on the appropriate, claimant-signed form, the FDC Notice will satisfy the requirements under 38 U.S.C 5103. A claimant-signed VA Forms 21-526EZ, 21-527EZ, or 21-534EZ received at VBA will also, if all other FDC criteria are met, permit the claim to undergo special expeditious processing.

The revised forms simplify the process for claimants submitting benefit claims in that they provide notice of the information and evidence necessary to substantiate a benefit claim upfront, upon application, rather than through VA’s traditional process post-VBA claim receipt. By providing the claimant notice of the information and evidence necessary to substantiate a benefit claim upon application, the claimant is aware of such necessary information and evidence and is able to submit it with his or her application, rather than wait for VBA to later notify the claimant of the information needed. The revised forms also simplify the process for claimants submitting benefit claims into the FDC Program by incorporating the certification statement, required for participation in the FDC Program, into the application, rather than as a separate page as was seen in the original VA Forms 21-526EZ and 21-527EZ.

3. VA Forms 21-526EZ, 21-527EZ, and 21-534EZ will be available on the VBA website for downloading by claimants. Claimants may print and submit applications non-electronically. The Department is in process of adding VA Forms to the eBenefits website. The eBenefits website will allow applicants to view, print, and submit applications electronically to VBA. The eBenefits website will also auto-populate into an application information of record in the VBA systems, reducing a claimant’s burden in completing an application for benefits. VA Forms 21-526EZ, 21-527EZ, and 21-534EZ are forms VA plans to add to the eBenefits website.

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. This form was redesigned into a “user friendly” form, incorporating plain English, to comply with the President’s Memorandum of June 1, 1998, Plain Language in Government Writing.

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 June 15, 2011, page 35086. 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 ‘‘Compensation, Pension, Education, and Rehabilitation Records—VA (58VA21/22/28)’’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 104,440 per year.

b. Frequency of Response is one time for most beneficiaries.

c. Annual burden is 43,516 hours.

d. The estimated completion time of 25 minutes is based on review by staff personnel.

e. The total estimated cost to respondents is $652,740 (15.00 x 43,516).

13. This submission does not involve any recordkeeping costs.

14. Estimated Costs to the Federal Government:

a. Processing/Analyzing costs $3,500,988

VA Form 21-526EZ

(GS-11/5@ $33.92 x 34,813 x 25/60 minutes = $492,023)

(GS-9/5 @ $28.04 x 34,813 x 25/60 minutes = $406,666)

(GS-5/5 @ $18.50 x 34,813 x 25/60 minutes = $268,307)

VA Form 21-527EZ

GS-11/5@ $33.92 x 34,813 x 25/60 minutes = $492,023)

(GS-9/5 @ $28.04 x 34,813 x 25/60 minutes = $406,666)

(GS-5/5 @ $18.50 x 34,813 x 25/60 minutes = $268,307)

VA Form 21-534EZ

(GS-11/5@ $33.92 x 34,813 x 25/60 minutes = $492,023)

(GS-9/5 @ $28.04 x 34,813 x 25/60 minutes = $406,666)

(GS-5/5 @ $18.50 x 34,813 x 25/60 minutes = $268,307)

b. Printing and production cost $5,222

c. Total cost to government $3,506,210

15. There is no change in burden. The primary reason for the revision is the inclusion of the VA Form 21-534EZ. The VA Form 21-534EZ along with the revised VA Forms 21-526EZ and 21-527EZ will allow VA to expeditiously process all compensation and pension claims considered fully developed.   Generally, a claim is considered fully developed when the claimant has certified he or she has no other information to submit and requires no additional VA assistance with it, except for obtaining certain federal records and ordering medical examinations.

16. The information collection is not for publication or tabulation use.

17. The collection instruments, VA Forms 21-526EZ, 21-527EZ, and 21-534EZ, may be reproduced and/or stocked by the respondents and Veterans Service Organizations. These VA forms do not display an expiration date, and if required to do so would result in unnecessary waste of existing stocks of the forms. These forms are 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 Forms 21-526EZ, 21-527EZ, and 21-534EZ.

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

B. Collection of Information Employing Statistical Methods

The data collection does not collect information employing statistical methods.