SUPPORTING STATEMENT 0839 and 10275 06-22-2022

SUPPORTING STATEMENT

VA Form 22-0839, VA Form 22-10275

Renewal Submission of Yellow Ribbon Program Agreement (2900-0718)

A. Justification

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

Public Law 110-252 authorizes the Department of Veterans Affairs (VA) to administer an education benefit program known as the Post–9/11 GI Bill. Section 3317 of title 38, United States Code, establishes the Yellow Ribbon G.I. Enhancement Program, referred to as the “Yellow Ribbon Program.” The Yellow Ribbon Program allows institutions of higher learning (IHLs) to voluntarily enter into an agreement with VA to waive a portion of the outstanding amount of established charges not otherwise covered under the Post-9/11 GI Bill. VA will match the amount waived by the IHL; however, VA’s portion will not exceed fifty percent of the total outstanding amount of established charges.

IHLs wishing to participate in the Yellow Ribbon Program are required to submit the Yellow Ribbon Program Agreement (VA Form 22-0839) indicating the maximum number of students that will receive benefits under the program, the maximum dollar amount of outstanding established charges that will be waived for each student based on student status (i.e., undergraduate, graduate, doctoral) or sub-element (i.e., college or professional school), and the way in which the contribution will be given (i.e., direct grant, scholarship, or other).

The Principles of Excellence were established in 2012 and allow schools to publicly proclaim their adherence to the guidelines therein that promote transparency and student success.

Title 38 U.S.C. 3317 necessitates this collection of information, along with Executive Order 13607.

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 will use the information collected from VA Form 22-0839 to determine which IHLs will be participating in the Yellow Ribbon Program, the maximum number of individuals for whom the IHL will make contributions in any given academic year, the maximum dollar amount of outstanding established charges that will be waived for each student based on student status (i.e., undergraduate, graduate, doctoral) or sub-element (i.e., college or professional school).

VA will use the information collected from VA Form 22-10275 to determine which schools have voluntarily elected to participate in the Principles of Excellence.

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.

At this time, information technology cannot be used to reduce the burden. VA does not have the technology to obtain signatures electronically and cannot require all schools to use information technology to submit this information.

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.

Collection of this information will not have a significant impact on small businesses or small entities. Small entities represent a very small share of the total number of institutions that participate in the program. The majority of entities that would voluntarily elect to participate in the Yellow Ribbon (YR) program are predominately the larger entities due to their larger tuition and fees costs. Therefore, the larger entities are the most significantly impacted by the collection of the YR information requested in the agreement. The same is true for prospective participants of the Principles of Excellence, since it requires programs approved for VA Education Benefits and/or the military’s Federal Tuition Assistance Program.

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.

A respondent need only file a Yellow Ribbon Agreement once therefore the burden cannot be decreased further. If the information is not collected, VA will not be able to administer the provisions of the Yellow Ribbon Program as mandated by statute. Similarly, a respondent needs only a single form to elect to participate in the Principles of Excellence.

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 is no special circumstance requiring collection in a manner inconsistent with 5 CFR 1320.6 guidelines:

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 notices were published in the Federal Register on June 30, 2022, Volume 87, Number 125, Pages 39161 and 39162. No comments were received from the public in response to this notice.

9. 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.

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.

Our assurance of confidentiality is covered by 38 U.S.C. 5701.

VA published a System of Records Notice on July 19, 2012, covering our System of Records, Compensation, Pension, Education and Veteran Readiness and Employment Records – VA (58VA21/22/28), 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 of a sensitive nature.

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

The total estimated burden to the public for this information collection is 25,928 hours, with submissions by 1,852 respondents over 2018, 2019 and 2020.

a. Number of Respondents: 1,852

b. Frequency of Response: Once

c. Annual Burden Hours: 25,928 hours (1,852 X 840min/60min) VAF 22-0839

d. Estimated Completion Time: 14 hours or 840 minutes

e. The respondent population for the VA Form 22-0839 and the new VA Form 22-10275 consists of school administrators seeking to participate in one or both voluntary programs. VBA cannot make further assumptions about the population of respondents because of the variability of factors such as educational background and wage potential of respondents. Therefore, VBA used general wage data for “All Occupations” 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 weekly earnings of full-time wage and salary workers are $1,120.40. Assuming a forty (40) hour work week, the mean hourly wage is $28.01 based on the BLS wage code – “00-0000 All Occupations.” ($28.01 X 40 hours). This information was taken from the following website: https://www.bls.gov/oes/current/oes_nat.htm May 2021.

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 $726,243.28 (25,928 burden hours X $28.01 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 entail 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:

Grade	Step	Burden Time	Hourly Rate	Cost Per Response	Total Responses	Total
13	05	840 minutes or 25,465 hrs.	$51.25	$717.50	1,852	$1,328,810.00
--	--	--	--	--	--
Overhead at 100% Salary						$1,328,810.00
Overhead costs are 100% of salary and are the same as the wage listed above; and the amount is included in the total.
Processing / Analyzing Costs)						$1,328,810.00
Printing and Production Cost						$0
Total Cost to Government						$1,328,810.00

Note: The hourly wage information above is based on the hourly 2022 General Schedule (Base) Pay. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2022/RUS_h.pdf

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

REPORTING FEE INFORMATION: There is no cost to schools because VA pays each school that furnishes training under the various VA education programs a fee for processing all required VA reports or certifications for each veteran or other claimant. VA refers to these fees as "school reporting fees" which help schools to defray the costs of processing paperwork required to be submitted to VA. The reporting fee is in lieu of any other compensation or reimbursement. Reporting fees were established by Public Law 90-77 effective August 31, 1967 and are in 38 U. S. C. 3684

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

The decrease in the annual reporting burden is due the decrease in the number of schools submitting the Yellow Ribbon Program Agreement. The number of approved Institutions of Higher Learning is fairly stable and each participant need only apply once.

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 will post the Yellow Ribbon Agreement Form to the GI Bill website by the second week of March in each calendar year. The deadline for completed agreements to be received by VA is May 15th of each calendar year (or the next business day if the 15th is a Saturday or Sunday). VA will publish the terms of the agreement via a link at www.GIBILL.gov.

VA will post the Principles of Excellence Form on the GI Bill website Find A VA Form | Veterans Affairs along with all other publicly available forms. The 22-10275 form will be available year-round. Participating schools are indicated in their school profile on the GI Bill Comparison Tool.

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 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.