Supporting Statement (3-9-20)

SUPPORTING STATEMENT
VA FORMS 29-0188 and 29-0189,
APPLICATION FOR SUPPLEMENTAL SERVICE
DISABLED VETERANS INSURANCE
2900-0539
A. Justification
1.
Explain the circumstances that make the collection of information
necessary. Identify legal or administrative requirements that necessitate the
collection of information.
These forms are used by eligible insureds to apply for Supplemental Service Disabled
Veterans Insurance. Collection of the requested information is required to implement the
provisions of Public Law 102-568 which expanded the insurance coverage available
under 38 USC Section 1922.
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 collected on these forms is used by the Department of Veterans
Affairs (VA) to establish the insured’s eligibility for coverage under the
Supplemental Service Disabled Veterans Insurance program.
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.
VA Forms 29-0188 and 29-0189 are available on the One-VA web site in a
fillable electronic format. VBA is currently hosting these forms on a secure server
and does not currently have the technology in place to allow for the complete
submission of the forms. Validation edits are performed to assure data integrity.
Efforts within VA are underway to provide a mechanism to allow the information
to be submitted electronically with a recognized signature technology. There
currently is no utility process in place that will allow the data submitted on the
forms to be incorporated with an existing centralized legacy database.

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4.
Describe efforts to identify duplication. Show specifically why all similar
information already available cannot be used or modified for use for the purposes
described in Item 2 above.
The information is not contained in any other VA records. Similar information is not
available elsewhere.
5.
If the collection of information impacts small businesses or other small
entities, describe any methods used to minimize burden.
The information does not involve any 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.
These forms are designed for use by VA to determine the insured’s eligibility for
insurance coverage.
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 special circumstances requiring that the collection of information be
conducted in a manner inconsistent with the guidelines in 5 CFR Section 1320.6.
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 sponsor in response to these comments. Specifically address
comments received on cost and hour burden.
The Department notice was published in the Federal Register on March 30, 2020,
Volume 85, No. 61, Page(s) 17620 to 17621. The information does not involve
obtaining information from any state or local Government. There is no person or
organization other than VA that will collect the information which is submitted by the
insured. No comments were received in response to this notice.

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9.

Explain any decision to provide any payment or gift to respondents.

The information collected is supplied by the respondent. No remuneration is made.
10.
Describe any assurance of confidentiality provided to respondents and the
basis for the assurance in statue, regulation, or agency policy.
The information collection conforms with the Privacy Act of 1974 and is subject to the
conditions of disclosure contained therein. The records are maintained in the system
identified as 36VA29, “Veterans of Uniformed Services Personnel Programs of U.S.
Government” as contained in the Privacy Act Issuances, 1993 Compilation.
11.
Provide additional justification for any questions of a sensitive nature, 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:
a. Number of Respondents: 10,000
b. Frequency of Response: On occasion
c. Annual Burden Hours: 3,333 hours
d. Estimated Completion Time: 20 minutes
e. The Bureau of Labor Statistics (B:S) gathers information on full-time
wage and salary workers. According to the latest available BLS data, the
mean weakly earnings of full-time wage and salary workers are $999.20.
Assuming a forty (40) hour work week, the mean hourly wage is $24.98
based on the BLS wage code – “00-0000 All Occupations.” This
information was taken from the following website:
(https://www.bls.gov/oes/current/oes_nat.htm, May 2018).
Legally, respondents may not pay a person or business for assistance 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 $83,258.34 (3,333 burden hours x
$24.98 per hour).

13.
Provide an estimate of the total annual cost burden to respondents or record
keepers resulting from the collection of information.
This submission does not involve any record keeping costs.
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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.
Estimated Costs to the Federal Government:
Grade

Step

Burden
Time

Fraction of
Hour

9
3
20
.33
Overhead at 100% Salary
5
3
2
0.03
Overhead at 100% Salary
4
3
2
0.03
Overhead at 100% Salary

Hourly Rate

Cost Per
Response

$15.39

.54

10,000

$13.76

.49

10,000

$23.32

Processing / Analyzing Costs
Printing and Production Cost
Total Cost to Government

7.69

Total
Responses

10,000

Total

$76,900.00
$76,900.00
$5,400.00
$5,400.00
$4,900.00
$4,900.00
$174,400.00
$54.00
$174,454.00

Note: The hourly wage information above is based on the hourly 2020 General
Schedule (Base) Pay (https://www.opm.gov/policy-data-oversight/payleave/salaries-wages/salary-tables/pdf/2020/GS_h.pdf). This rate does not include
any locality adjustment as applicable.
The processing time estimates above are based on the actual amount of time
employees of each grade level spend to process to completion a claim received on
this form. The within-grade step (3) of each employee represents the average
experience of employees within each grade.

15.
Explain the reason for any program changes or adjustments reported in
Items 13 or 14 of OMB 83-I.
There is no change in respondent burden.
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.
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The information is collected for insurance purposes only and there are no plans for
publication.
17.
If seeking approval to omit 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 submission does not contain any exceptions to the certification statement.
PART B
B. Collection of Information Employing Statistical Methods
This collection of information does not employ statistical methods.

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