Application
Requirement to Receive VA Dental Insurance Plan Benefit
Under 38
CFR 17.169
RIN 2900-0789
1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.
Department of Veteran Affairs Dental Insurance Reauthorization Act of 2016 (Public Law 114-218) requires VA to establish and administer a dental insurance plan for Veterans enrolled in VA health care and survivors and dependents of Veterans eligible for VA’s Civilian Health and Medical Program (CHAMPVA). Public Law 114-218 requires VA to contract with a private insurer (using the Federal contracting process) to offer dental insurance, and the private insurer will be responsible for virtually all aspects of the administration of the dental insurance program. VA’s role will primarily be to form the contract with the private insurer and verify eligibility of veterans and certain survivors and dependents. Enrolled veterans and certain survivors and dependents of veterans will be required to complete an application to be enrolled in this dental insurance program, and will be required to submit certain documentation/information for certain types of disenrollment requests and for appeals of claims decisions. VA will not prescribe the form these collections are to take, but is prescribing regulations that nonetheless require these collections. These collections are required to fulfill VA’s obligations under Public Law 114-218.
2. Indicate how, by whom, and for what purposes the information is to be used; indicate actual use the agency has made of the information received from current collection.
The information in the application will be used by private insurers to evaluate basic eligibility criteria under Public Law 114-218, and to gather other information necessary to administer the private insurer programs under Public Law 114-218. VA will merely confirm eligibility of the veterans and certain survivors and dependents that apply to receive dental insurance from the private insurers. The information that will be collected for certain types of disenrollment requests and for appeals of disenrollment decisions is minimally prescribed by VA in regulations, as required to fulfill VA obligations under Public Law 114-218. VA will not prescribe the specific form that these collections will take, but is requiring that certain information will be collected by the private insurers. Such information on the application will include an enrollee’s name (last, middle initial, first); full social security number, date of birth, gender, home address, home phone number, and e-mail address. Such information on the disenrollment requests and for appeals of disenrollment requests will include: insured’s name, policy number /insured identifier, and reason for disenrollment.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
This collection will use automated, electronic collection techniques in the form of an online application and submission process that is controlled by the private insurers. Decisions for disenrollment and appeals of claims may or may not use automated electronic collection techniques, based on how the private insurers will administer that portion of their dental insurance policy. The electronic application completion and submission process will ease the burden for those applying for this dental insurance as well as the private insurers, and for VA in verifying eligibility under Public Law 114-218.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
VA does not have a similar collection of information because the requirement to provide this information is created by the proposed rulemaking.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
VA does not expect this collection to impact small businesses or other small entities, because none of the potential private insurers that will contract with VA to provide the dental insurance are considered small entities.
6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently as well as any technical or legal obstacles to reducing burden.
This collection of information is required to ensure that enrollment in the dental insurance program is considered “voluntary” as required by Public Law 114-218. Without this information, VA would not be able to provide private, premium-based dental insurance through private insurers as required by Public Law 114-218.
7. Explain any special circumstances that would cause an information collection to be conducted more often than quarterly or require respondents to prepare written responses to a collection of information in fewer than 30 days after receipt of it; submit more than an original and two copies of any document; retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years; in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study and require the use of a statistical data classification that has not been reviewed and approved by OMB.
There are no such special circumstances.
8. a. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the sponsor’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the sponsor in responses to these comments. Specifically address comments received on cost and hour burden.
The notice of Proposed Information Collection Activity was published in the Federal Register on October 31, 2016 (Volume 81, Number 75491, page 75491-75492). We did not receive any comments related to this notice.
b. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, clarity of instructions and recordkeeping, disclosure or reporting format, and on the data elements to be recorded, disclosed or reported. Explain any circumstances which preclude consultation every three years with representatives of those from whom information is to be obtained.
Outside consultation is conducted with the public through the 60-day Federal Register notice.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payment or gift is provided to respondents.
10. Describe any assurance of privacy, to the extent permitted by law, provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
This information may include Protected Health Information (PHI) or Individually Identifiable Health Information (IIHI). VA will ensure that private insurers provide assurances of privacy to the extent permitted by law through the use of an existing VA contractor for electronic data interchange, Change Healthcare. By conducting the exchange of information through this approved VA contractor, VA security requirements will be maintained.
11. Provide additional justification for any questions of a sensitive nature (Information that, with a reasonable degree of medical certainty, is likely to have a serious adverse effect on an individual's mental or physical health if revealed to him or her), such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private; include specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
There are no questions of a sensitive nature.
12. Estimate of the hour burden of the collection of information: 40,750
a. The number of respondents, frequency of responses, annual hour burden, and explanation for each form is reported as follows:
Form |
No. of respondents |
x No. of responses |
x No. of minutes |
÷ by 60=
|
Number of Hours |
Application |
150,000 |
1 |
15 |
37,500 |
|
Form |
No. of respondents |
x No. of responses |
x No. of minutes |
÷ by 60=
|
Number of Hours |
Eligibility verification |
150,000 |
1 |
1 |
2500 |
|
Form |
No. of respondents |
x No. of responses |
x No. of minutes |
÷ by 60=
|
Number of Hours |
Disenrollment request |
1000 |
1 |
30 |
500 |
|
Form |
No. of respondents |
x No. of responses |
x No. of minutes |
÷ by 60=
|
Number of Hours |
Appeal of disenrollment request |
500 |
1 |
30 |
250 |
|
Total |
301,500 |
1 |
76 |
|
40,750 |
b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB 83-I.
This request covers mechanisms for collecting information; however, VA is not prescribing the form of the collections, and is not aware if these collections will be issued via specific forms.
c. Provide estimates of annual cost to respondents for the hour burdens for collections of information. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.
Legally, respondents may not pay a person or business for assistance in completing the information collection and a person or business may not accept payment for assisting a respondent in completing the information collection. Therefore, there are no expected overhead costs for completing the information collection. VHA estimates the total cost to all respondents to be $578,242.50 (40,750 burden hours x $14.19 per hour).
May 2015 National Occupational Employment and Wage Estimates United States:
http://www.bls.gov/oes/current/oes_nat.htm
31-0000 |
major |
3,989,910 |
0.4% |
28.934 |
$13.00 |
$14.19 |
$29,520 |
0.2% |
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).
There is no anticipated recordkeeping burden.
14. Provide estimates of annual cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
There is no anticipated recordkeeping burden, or any annual cost to the Federal Government associated with these collections. VA will have no interactions with the insurers regarding disenrollment requests or appeals of disenrollment requests, and will only be verifying eligibility of potential VADIP enrollees when requested of the insurers. To verify eligibility of potential VADIP enrollees, the insurers must establish a contractual relationship for electronic transactions with VA's Electronic Data Interchange (EDI) clearinghouse contractor prior to enrollment. All EDI transactions to confirm VADIP eligibility have to go through this clearinghouse and responses from VA will be returned through this clearinghouse. All costs associated with EDI transactions to confirm VADIP eligibility between the insurer and the EDI contractor is the responsibility of the contracted insurer.
15. Explain the reason for any burden hour changes or adjustments reported in items 13 or 14 of the OMB form 83-1.
This is an established collection and all burden hours are considered a program increase.
16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
VA does not intend to publish this data.
17. If seeking approval to omit the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
VA is not seeking approval to omit the expiration. There is no applicable VA form from which to omit the expiration date for OMB approval of the information collection.
18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB 83-I.
There are no exceptions.
No statistical methods are used in this data collection.
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| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Bold black = OMB questions |
| Author | vhacobickoa |
| File Modified | 0000-00-00 |
| File Created | 2021-01-23 |