Supporting Statement for:
OMB #2900-0659
VA Form # |
Title |
21-0781 |
Statement in Support of Claim for Service Connection for Post-Traumatic Stress Disorder (PTSD) |
21-0781a |
Statement in Support of Claim for Service Connection for Post-Traumatic Stress Disorder (PTSD) Secondary to Personal Assault |
A. JUSTIFICATION:
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), through its Veterans Benefits Administration (VBA), administers an integrated program of benefits and services established by law for veterans, service personnel, and their dependents and/or beneficiaries. 38 U.S.C. 5103(a) provides that VA has a duty to assist claimants in obtaining evidence that is necessary to substantiate their claims, including relevant records when claimants have given VA enough information to locate such records. 38 U.S.C. 5107(a) provides that claimants have a responsibility to support a claim for benefits. 38 CFR 3.304(f) provides that service connection for post-traumatic stress disorder (PTSD) requires a medical diagnosis; a link, established by medical evidence, between current symptoms and an in-service stressor; and credible supporting evidence that the claimed in-service stressor occurred. When a veteran who did not serve in combat or was not a prisoner of war claims PTSD due to in-service stressors, there must be credible supporting evidence that the claimed stressors occurred. This collection includes both VA Form 21-0781, Statement in Support of Claim for Service Connection for Post-Traumatic Stress Disorder (PTSD), and VA Form 21-0781a, Statement in Support of Claim for Service Connection for Post-Traumatic Stress Disorder (PTSD) Secondary to Personal Assault.
The respondent burden has increased due to the estimated number of receivables averaged over the past year.
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 Forms 21-0781 and 21-0781a are used to gather specific information about in-service stressors, so VA can assist claimants in obtaining credible supporting evidence that the claimed stressors occurred. In-service stressors reported by veterans must be verifiable. VA cannot thoroughly research military records and other sources of information for credible supporting evidence unless the veteran provides VA with specific information about the in-service stressors. The forms request information that is necessary to conduct meaningful research of records.
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 21-0781 and 21-0781a 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. There currently is a utility process in place that will allow the data submitted on the form to be incorporated with an existing centralized legacy database. Also, there are several electronic portals available that expedite processing; including www.va.gov, Stakeholder Enterprise Portal, Digits-to-Digits, and Enterprise Veterans Self Service.
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.
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
The collection of information does not involve small businesses or entities.
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.
VA Forms 21-0781 and 21-0781a are used to gather specific information about in-service stressors, so VA can assist claimants in obtaining credible supporting evidence that the claimed stressors occurred. In-service stressors reported by veterans must be verifiable. VA cannot thoroughly research military records and other sources of information for credible supporting evidence unless the veteran provides VA with specific information about the in-service stressors. The forms request information that is necessary to conduct meaningful research of records.
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 is no special circumstance requiring collection in a manner inconsistent with 5 CFR 1320.6 guidelines.
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 November 6, 2020, Volume 85, No. 216, pages 71139 and 71140. No comments were received in response to this notice.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payments or gifts to respondents have been made under this collection of information.
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.
The records are maintained in the appropriate Privacy Act System of Records identified as “Compensation, Pension, Education, and Vocational Rehabilitation and Employment Records-VA (58VA21/22/28),” published at 74 FR 29275 on June 19, 2009, and last amended at 84 FR 4138 (February 14, 2019).
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.
There are no questions of a sensitive nature.
Estimate of the hour burden of the collection of information:
Total Number of Respondents is estimated to 20,374 per year.
Estimated number of respondents for VA Form 21-0781 is 15,499.
Estimated number of respondents for VA Form 21-0781a is 4875.
Note: These numbers were derived from the previous year total receivables through our centralized mail portal for the two forms.
Frequency of Response is one time.
Annual burden hours are 23,770 hours.
The total estimated completion time is 70 minutes.
Estimated completion time for VA Form 21-0781 is 70 minutes.
Estimated completion time for VA Form 21-0781a is 70 minutes.
The respondent population for VA Forms 21-0781 and 21-0781a is composed of individuals who are claiming in-service stressors. VA 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 (BLS) gathers information on full-time wage and salary workers. According to the latest available BLS data, the mean hourly wage is $25.72 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.
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 $524,019.28 (20,374 burden hours x $25.72 per hour).
Provide an estimate 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 recordkeeping costs.
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:
Grade |
Step |
Burden Time |
Fraction of Hour |
Hourly Rate |
Cost Per Response |
Total Responses |
Total |
7 |
3 |
30 |
0.50 |
$19.26 |
9.630 |
20,374 |
$ 196,201.62 |
Overhead at 100% Salary |
$ 196,201.62 |
||||||
10 |
3 |
30 |
0.50 |
$25.94 |
12.970 |
20,374 |
$ 264,250.78 |
Overhead at 100% Salary |
$ 264,250.78 |
||||||
12 |
3 |
15 |
0.25 |
$34.16 |
8.540 |
20,374 |
$ 173,993.96 |
Overhead at 100% Salary |
$ 173,993.96 |
||||||
|
|
||||||
Processing / Analyzing Costs |
$ 1,268,892.72 |
||||||
Printing and Production Cost |
$ 14,098.81 |
||||||
Total Cost to Government |
$ 1,282,991.53 |
||||||
Overhead costs are 100% of salary and are the same as the wage listed above and the amounts are included in the total.
Printing and production costs approximates the cost of printing this information collection per year. (Processing/Analyzing Cost total divided by $90).
Note: The hourly wage information above is based on the hourly 2021 General Schedule (Base) Pay (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2021/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.
Explain the reason for any burden hour changes since the last submission.
The respondent burden has increased due to the estimated number of receivables averaged over the past year.
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.
The information collection is not for publication or tabulation use.
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.
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.
B. Collection of Information Employing Statistical Methods
No statistical methods are used in this data collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 2021-04-11 |