3220-0156

OMB No. 3220-0156

Justification

Employer’s Deemed Service Month Questionnaire

RRB Form GL-99

1. Circumstances of information collection – Under Section 3(h) of the Railroad Retirement Act (RRA), service performed for a covered railroad employer or as an employee representative is creditable toward an annuity under the RRA. Such annuities are based on an employee’s earnings credits and months of service. Section 3(i) of the Act, as amended by the Railroad Retirement Solvency Act of 1983 (P.L. 98-76) provides that after 1984, the Railroad Retirement Board (RRB) under certain circumstances, may deem additional months of service for an employee who has worked less than 12 months in a calendar year and who also satisfies certain eligibility requirements, including the existence of an employment relation between the employee and his or her employer.

The procedures pertaining to the deeming of additional months of service are contained in the RRB’s regulations 20 CFR 210, Creditable Railroad Service.

2. Purposes of collecting/consequences of not collecting the information - The RRB uses Form GL-99, Employer’s Deemed Service Months Questionnaire, to obtain needed information from railroad employers to determine whether an employee had an employment relationship with a covered railroad employer or was an employee representative during a month not worked.

Form GL-99 is generated and released by the RRB when an employer reports less than 12 months of service, additional employment relationship information is needed, and:

• there are six or more potential deemed months; or

• the employee has more than one employer in the calendar year; or

• the employee has no service months reported in the following calendar year.

The Railroad Retirement Board proposes the following non-burden impacting editorial change to Form GL-99:

• Changed title in second paragraph of Paperwork Reduction Act from Chief of Information Resource Management to Associate Chief Information Officer for Policy and Compliance.

To our knowledge no other agency uses a form similar to GL-99.

3. Planned use of improved information technology or technical/legal impediments to further burden reduction – Budgetary and technology constraints prevent us from making further technological improvements. However, the RRB will reevaluate after the completion of the RRB IT Modernization project.

4. Efforts to identify duplication – This information collection does not duplicate any other information collection.

5. Small business respondents – N.A.

6. Consequences of less frequent collection – Not applicable since the deeming actions are part of the annual update of railroad employees’ service and compensation records.

7. Special Circumstances – None.

8. Public comments/consultations outside the agency – In accordance with 5 CFR 1320.8(d), comments were invited from the public regarding this information collection. The notice to the public was published on page 5736 of the February 22, 2019, Federal Register. No comments or requests for additional information were received from the public.

9. Payments or Gifts to respondents – N.A.

10. Confidentiality – Privacy Act System of Records, RRB-5, Master File of Railroad Employees’ Creditable Compensation. In accordance with OMB Circular M-03-22, a Privacy Impact Assessment for this information collection was completed and can be found at https://www.rrb.gov/sites/default/files/2017-06/PIA-BPO.pdf

11. Sensitive questions – N.A.

12. Estimate of respondent burden – The current and proposed estimated burdens for this collection are as follows:

Current Burden

Form Number	Annual Responses	Time (Minutes)1/	Burden (Hours)
GL-99	2,000	2	67

1/ The RRB has been collecting the information on these forms since OMB approved the information collection. Based on a sampling done when the form was originally created, the office calculated the estimated time, which includes time for getting the need data and reviewing the completed form.

13. Estimate of annual cost to respondents or record keepers – N.A

13. Estimate of cost to Federal Government – N.A.

13. Explanation for changes in burden – N.A

13. Time schedule for data collection and publication – The results of this collection will not be published.

13. Request to not display OMB expiration date – The RRB just started an IT Modernization Project Initiative and recently awarded a contract to replatform (transition) our legacy mainframe environment to an open server-based environment. The RRB also plans to enter into a separate contract within the second or third quarter of this fiscal year to assess and re-engineer our business processes with cloud-fist in mind. Both project will be a multi-year effort spanning 5 – 7 years with different contractors. Given the GL-99 is seldom revised, the extensive modernization efforts over the next 5 – 7 years and the competing IT priority projects and limited staffing resources, the RRB requests authorization to not display the OMB expiration date.

13. Exceptions to the Certification Statement – None

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