Supporting Statement, 2019

SUPPORTING STATEMENT

FOR:

Dependents’ Request for Change of Program or Place of Training

(OMB Control Number 2900–0099)

Justification.

1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.

Spouses, surviving spouses, and children who are eligible for Survivor’s and Dependent’s Educational Assistance (DEA) benefits under chapter 35, and children eligible for the Marine Gunnery Sergeant John David Fry Scholarship (Fry Scholarship) under chapter 33, title 38, U.S. Code, may not make any changes in their education program unless the new program is suitable to their abilities, aptitudes, and interests. Beneficiaries may change their education program the first time solely at their option; however, these beneficiaries may not change their education program a second (or subsequent) time unless the new program is suitable to their abilities, aptitudes, and interests. In addition to changing their education program, these claimants may also change their school upon application to the Department of Veterans Affairs (VA). VA Form 22-5495 serves as the procedural requirement for claimants to request a different education program or place of training. The form has been revised to remove the statement that chapter 35 recipients could not use the Electronic Funds Transfer (EFT) option.

The following administrative and legal requirements necessitate the collection:

a. 38 United States Code 3034(a), 3034(b), 3323(a), 3323(b), 3471, 3513, 3521, and 3691

b. 38 Code of Federal Regulations 21.4234

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.

VA has used the current information collection to determine (1) if the claimant continues to qualify for education benefits when taking a different program of training and (2) to verify that a new place of training is approved for benefits. The information on the form can be obtained only from the individual claimant. VA cannot make an eligibility determination without this information.

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.

Information is collected when an eligible dependent of a veteran applies for a new program of education or place of training. Information technology is being used to reduce this burden.

We have converted this form into an electronic fillable format available on the Internet. Additionally, this form is available on the va.gov computer system. The va.gov version is identical to the printed form, except claimants are guided past questions that do not pertain to them. Va.gov applies information technology and reduces the burden on the public. VA estimates that 20% of claimants submit the form via va.gov.

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.

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. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The information collection only affects eligible dependents of veterans. There is no impact on education institutions or small businesses.

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 information is collected only when a dependent of a veteran request a change of educational program or place of training. If this information is not collected, VA would not have any basis to make eligibility determinations regarding requests for benefits involving a change of program or place of training. There are no technical or legal obstacles to reducing the burden of this information collection.

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.

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

8. If applicable, provide a copy and identify the date and page number of publications 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 Department notice was published in the Federal Register on August 12, 2019, Volume 84, Number 155, page 39894.  No comments were received.

9. Explain any decision to provide any payment or gift to respondents, other

than remuneration of contractors or grantees.

VA does not provide any payment or gift to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

VA Form 22-XXXX is retained permanently in the student’s education file. Our assurance of confidentiality is covered by our System of Records, Compensation, Pension, Education, Vocational Rehabilitation and Employment Records — VA (58VA21/22/28) which are contained in the Privacy Act Issuances, 2012 Compilation.

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.

None of the questions on the application are of a sensitive nature.

12. Estimate of the hour burden of the collection of information:

The estimated annual burden hours, as indicated below, for the collection of this information is 27,440 burden hours, calculated based on the 2020 Presidential Budget Submission, of the actual total of 109,760 responses received for years 2016, 2017 and 2018. This number represents the number of respondents for Chapter 35 Son’s and Daughter’s, and Chapter 35 Spouses and Widow(ers), at 90,263 and 19,497, respectively.

1. Number of Respondents: 109,760

2. Frequency of Response: On occasion

3. Annual Burden Hours: 27,440 (109,760 X 15 / 60 = 27,440)

4. Estimated Completion Time: 15 minutes

e. The respondent population for VA Form 22-5495 is composed of individuals who are Veterans and their dependent student. VBA cannot make further assumptions about the population of respondents because of the variability of factors such as the educational background and wage potential of respondents.  Therefore, VBA used general wage data to estimate the respondents’ costs associated with completing the information collection.

The Bureau of Labor Statistics gathers information on full-time wage and salary workers. Accordingly, the median weekly earnings of full-time wage and salary workers is $999.20. Assuming a forty (40) hour work week, the median hourly wage is $24.98.

The general wage code of 00-000-0000 for “All Occupations” may be found by clicking this link: https://www.bls.gov/oes/current/oes_nat.htm#00-0000 

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. VBA estimates the total cost to all respondents to be $685,451 (27,440 burden hours X $24.98 per hour).

13. Provide estimates 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).

This submission does not involve any record keeping costs.

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.

Estimated Costs to the Federal Government are accessible through this link: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2018/general-schedule/

Grade	Step	Processing Burden Time -Employee	Hourly Wage Rate	Cost for Response	Number of Responses	Gov. Cost
VCE GS 9	5	15min	$27.93	N/A	109,760	$766,399 109,760 X $27.93 X 15 / 60)
	Overhead at 100%. Overhead costs are 100% of salary and are the same as the wage listed above; and the amount is included in the total.					N/A
	Processing / Analyzing Cost					N/A
	Printing and Production Cost					N/A
Total Cost to Government for Processing All Applications (Paper-Electronic) $766,399

The processing time above is based on the actual amount of time employees of the grade level spend to process to completion a claim received on this form.

15. Explain the reason for any burden hour changes since the last submission.

There is a decrease in burden hours due to a decrease in the actual number of applications/responses received for 2016, 2017 and 2018, as is based on the 2020 Presidential Budget Submission for Chapter 35 sons, daughters, spouses and widows.

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 publish this information or make it available for publication.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

We are not seeking approval to omit the expiration date for OMB approval.

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB 83-I.

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 by the Veterans Benefits Administration does not employ statistical methods.