Supporting Statement 6553d-6553d-1 (updated)

SUPPORTING STATEMENT

A. Justification

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

The Department of Veterans Affairs (VA) is authorized to pay education benefits to Veterans and other eligible persons pursuing approved programs of on-the-job training or apprenticeship training under chapters 30, 32, 33 and 35, of title 38, U. S. C.; chapters 1606 and 1607 of title 10, U. S. C.; and Section 903 of Public Law 96-342.

The following administrative and legal requirements necessitate the collection:

1. Public Law 115-89 “Veterans Apprenticeship and Labor Opportunity Reform Act” 38 U.S.C. 3002(3)(C), 3032(c), 3233, 3313(g), 3484, 3534(a), 3680(c), 3687, and 10 U.S.C. 16131.

2. 38 CFR 21.3131(a), 21.3132(c), 21.4135(e)(3)(iii), 21.4203(f)(3), 21.4262, 21.5130, 21.5138, 21.7139(g), and 21.7639(f), 21.9561(c), 21.9641(g).

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 provides the collection instrument to training establishments to assist them to promptly report the recent training status of individuals as required by law. The information collected informs VA whether or not a claimant’s education benefits are to be continued without changes, amendments, or terminations. The form also provides an effective date if any adjustments are required.

Benefits are authorized monthly based on the number of hours worked by the trainee as verified by the training establishment. Unscheduled terminations result in the termination of benefits. If hours are reduced to less than a full-time work schedule, a reduction of benefits will occur.

Public Law 115-89 “Veterans Apprenticeship and Labor Opportunity Reform Act” (VALOR Act) was signed into law on November 21, 2017. Section 3 of this law amended 38 U.S.C. 3680(c) to eliminate the trainee’s certification requirement. As a result, this form is only completed by the training establishment to report the trainee’s number of hours worked and/or to report the trainee’s date of termination. The form is then sent to the regional processing office (RPO) for processing.

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 technology is helping to reduce the burden. The online electronic collection will be made via the Vets.gov portal which has been implemented using algorithms that help guide the respondent toward completing the form based on their responses to the questions being asked. The implementation and use of Vets.gov then helps to reduce the time burden to the respondent while still enabling respondent to submit the application directly to the Regional Processing Office (RPO) with jurisdiction over the claim, thus reducing potential errors and expediting the processing of the information provided.

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 is required to be collected by every training establishment approved to receive VA Education benefits regardless of the size of the training establishment as prescribed by statute. The form must be submitted for any students receiving VA educational benefits when training in “on-the-job training” establishments or apprenticeships. For that reason, the information collection cannot be reduced for small establishments.

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.

Collecting this information at the end of each month of training allows VA to pay all benefits due to trainees timely, while preventing the overpayment of benefits for any extended period

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 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 Department notice was published in the Federal Register on February 27, 2020, Volume No. 85, Page Number 11454. One comment was received in response to this notice. The commenter agrees with the form’s revision but suggests that a format change would make the form more user friendly; and the commenter suggests that the respondent’s time to complete the form should be expanded. VA acknowledges this comment; however, VA will not make any changes to the form based on this comment, since the form's format and respondent time is sufficient for the respondents to promptly report the OJT and Apprenticeship training status of individuals.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

VA does not provide any payments or gifts 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.

If VA Form 22-6553d (or 22-6553d-1) reports continued training, the form is retained in the Finance Activity in the regional processing office. If the form reports termination of training, the form is retained in the claimant's education folder. VA assurance of confidentiality is covered by System of Records, Compensation, Pension, Education and Vocational Rehabilitation and Employment Records - VA (58VA21/22/28) 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 information collected is considered to be of a sensitive nature.

12. Estimate of the hour burden of the collection of information. Please show mathematical calculations:

The estimated burden to the public for this information collection is 5,693 hours.

1. Estimated Number of Respondents: 3,795 (34,155 responses annually)

2. Estimated Frequency of Response: 9 responses per respondent annually

3. Annual Burden Hours: 5,693 hours [3,795 X 9 X 10 / 60 = 5,693 annual burden hours].

4. Estimated Completion Time for Respondent: 10 minutes

5. The respondent population is composed of training establishments offering on-the-job training and apprenticeships who complete the form for Veterans who are enrolled in and pursuing this training. 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 are $999.20. Assuming a forty (40) hour work week, the median hourly wage is $24.98. 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 $142,211 (5,693 burden hours x $24.98 per hour).

13. Provide an estimate of the total annual cost burden to respondents or recordkeeping 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. Estimated Costs to the Federal Government:

The annual cost to the Government for administering the form is estimated to be $141,060 based on 34,155 responses annually. This cost is determined as follows:

a. The processing cost of $141,060 is based on an estimate that a GS 9/5 employee will have to review each application. The salary for such an employee is $24.78 per hour. We estimate it will take 10 minutes to review each claim. (34,155 claims x $24.78 x 10 min /60 min = $141,060)

b. There are no administrative costs associated with this information collection.

Note: The hourly wage information above is based on the hourly 2020 General Schedule (Base) Pay https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2020/GS_h.pdf. This rate does not include any locality adjustment as applicable.

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

There is a reduction in the annual burden due to the decrease in the number of respondents since the certifying officials at VA approved training establishments are now the only respondents.

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

OMB83-1.

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

B. Collection of Information Employing Statistical Methods.

This collection of information does not employ statistical methods. If statistical methods are employed, Part B must be completed.