A. Justification
Introduction/Authoring Laws and Regulations
SSA uses Sheltered Workshop Wage Reporting to collect wage information for SSI recipients directly from sheltered workshops. Section 1631(e)(1) requires SSA to obtain proof, as necessary, to assure that we pay benefits to eligible individuals only. Section 1612(1)(C) of the Social Security Act (Act) and 42 USC 1382a of the U.S. Code define remuneration received for services performed in a sheltered workshop as earned income for the Supplemental Security Income (SSI) program. The amount of monthly wages determines an individual’s SSI payment amount.
Description of Collection
Sheltered workshops are private non-profit organizations or institutions that implement a recognized program of rehabilitation for handicapped workers, or provide such workers with remunerative employment or other occupational rehabilitative activity of an educational or therapeutic nature. Sheltered workshops perform a service for their clients by reporting monthly wages directly to SSA. SSA uses the information these workshops provide to verify and post monthly wages to the SSI recipient’s record. Most workshops report monthly wage totals to their local SSA office, so we can adjust the client’s SSI payment amount in a timely manner and prevent overpayments. Sheltered workshops are motivated to report wages voluntarily as a service to their clients. Respondents are sheltered workshops that report monthly wages for services performed in the workshop.
Use of Information Technology to Collect the Information
In accordance with the agency’s Government Paperwork Elimination Act plan, SSA created an Internet version of the Sheltered Workshop Wage Reporting System. SSA offers an electronic option for reporting sheltered workshop wages through Government-to-Government Services Online. Clearance Package OMB No. 0960-0757 (Form SSA-159, Government to Government Services Online (GSO) Website Registration; Form SSA-160, Government to Government Services Online Website Account Modification/Deletion) clears the registration process for the Government-to-Government Service Online. Based on our data, 100% of respondents under this OMB number use the electronic version.
Why We Cannot Use Duplicate Information
The nature of the information we collect and the manner in which we collect it preclude duplication. SSA does not use another collection instrument to obtain similar data.
Minimizing Burden on Small Respondents
This collection does not significantly affect small businesses or other small entities.
Consequence of Not Collecting Information or Collecting it Less Frequently If we did not collect this information, we would risk increased instances of improper payments. Sheltered Workshop reporting reduces the number of overpayments SSI recipients incur by providing SSA with timely and accurate wage reports. Processing these wage reports electronically reduces the cost of administering the program. Because we collect the information on an as needed basis, we cannot collect it less frequently. There are no technical or legal obstacles to burden reduction.
Special Circumstances
There are no special circumstances that would cause SSA to conduct this information collection in a manner inconsistent with 5 CFR 1320.5.
Solicitation of Public Comment and Other Consultations with the Public
The 60-day advance Federal Register Notice published on June 5, 2020 at 85 FR 34703, and we received no public comments. The 30-day FRN published on August 20, 2020 at 85 FR 51540. If we receive any comments in response to this Notice, we will forward them to OMB.
9. Payment or Gifts to Respondents
SSA does not provide payments or gifts to the respondents.
10. Assurances of Confidentiality
SSA protects and holds confidential the information it collects in accordance with 42 U.S.C. 1306, 20 CFR 401 and 402, 5 U.S.C. 552 (Freedom of Information Act), 5 U.S.C. 552a (Privacy Act of 1974), and OMB Circular No. A-130.
11. Justification for Sensitive Questions
The information collection does not contain any questions of a sensitive nature.
12. Estimates of Public
Reporting Burden
Please
see the burden chart below:
Modality of Completion |
Number of Respondents |
Frequency of Response |
Total Number of Responses |
Average Burden per Response (minutes) |
Estimated Total Annual Burden (hours) |
Average Theoretical Hourly Cost Amount (dollars)* |
Total Annual Opportunity Cost (dollars)** |
Sheltered Workshop Wage Reporting |
800 |
12 |
9,600 |
15 |
2,400 |
$19.31* |
$46,344** |
* We based this figure on average Rehabilitation Counselors hourly salary, as reported by Bureau of Labor Statistics data (https://www.bls.gov/oes/current/oes211015.htm).
** This figure does not represent actual costs that SSA is imposing on recipients of Social Security payments to complete this application; rather, these are theoretical opportunity costs for the additional time respondents will spend to complete the application. There is no actual charge to respondents to complete the application.
The total burden for this ICR is 2,400 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $46,344. SSA does not charge respondents to complete our applications.
13. Annual Cost to the Respondents (Other)
This collection does not impose a known cost burden on the respondents.
Annual Cost To Federal Government
The annual cost to the Federal Government is approximately $71,952. This estimate accounts for costs from the following areas:
Description of Cost Factor |
Methodology for Estimating Cost |
Cost in Dollars* |
Designing, Printing, and Distributing the Form |
Design Cost + Printing Cost + Distribution Cost |
$0 |
SSA Employee (e.g., field office, 800 number, DDS staff) Information Collection and Processing Time |
GS-9 employee x # of responses x processing time |
$68,532 |
Systems Development, Updating, and Maintenance |
GS-9 employee x man hours for development, updating, maintenance |
$3,420 |
Total |
|
$71,952 |
* We have inserted a $0 amount for cost factors that do not apply to this collection.
SSA is unable to break down the costs to the Federal government further than we already have. First, since we work with almost every US citizen, we often do bulk mailings, and cannot track the cost for a single mailing. We do not track design costs or upkeep costs (as these are based on employee time and may vary from collection to collection). In addition, it is difficult for us to break down the cost for processing a single form, as field office and State Disability Determination Services staff often help respondents fill out several forms at once, and the time it takes to do so can vary greatly per respondent. As well, because so many employees have a hand in each aspect of our forms, we use an estimated average hourly wage, based on the wage of our average field office employee (GS-9) for these calculations. Finally, SSA prefers not to provide breakdowns of estimated payment to employees who process these items for a variety of reasons (only one of which is that it is not possible to do this entirely accurately).
Program Changes or Adjustments to the Information Collection Request
There are no changes to the public reporting burden.
Plans for Publication Information Collection Results
SSA will not publish the results of the information collection
17. Displaying the OMB Approval Expiration Date
SSA is not requesting an exception to the requirement to display an expiration date.
18. Exceptions to Certification Statement
SSA is not requesting an exception to the certification requirements at
5 CFR 1320.9 and related provisions at 5 CFR 1320.8(b)(3).
B. Collections of Information Employing Statistical Methods
SSA does not use statistical methods for this information collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Supporting Statement for Title of Information Collection (and Form Number(s) if applicable) |
| Author | 075903 |
| File Modified | 0000-00-00 |
| File Created | 2021-01-14 |