SUPPORTING STATEMENT - PART A
Involuntary Allotment Application–OMB Control Number 0704-0367
Summary of Changes from Previously Approved Collection
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Need for the Information Collection
The Hatch Act Reform Amendments of 1993 (hereinafter referred to as the “Act”) exempted members of the uniformed services from the Federal garnishment provisions contained therein. However, the Act provided for the involuntary allotment of the pay of a member of the uniformed services for indebtedness owed a third party as determined by the final judgment of a court of competent jurisdiction, competent military or executive authority. Competent military or executive authority must also determine that all the procedural requirements of the Service Members Civil Relief Act (SCRA) have been met. Furthermore, the Act provided that regulations shall include provisions for consideration for the absence of a member of the uniformed service from an appearance in a judicial proceeding resulting from the exigencies of military duty.
DoD needs a program under the law, 5 U.S.C. 5520a(k), which responds to requests for involuntary allotments. Before responding to a request, the responsible government official must have information that identifies both the applicant and the member against whom the involuntary allotment is sought; proves that the request is based on a valid court judgment; shows that the judgment comports with the provision of the SCRA; and enables consideration for whether exigencies of military duty caused the absence of the member from a judicial proceeding upon which the judgment is based. With the exception of information concerning exigencies of military duty, an applicant for an involuntary allotment must provide required information before a government official can act on the applicant’s request.
Use of the Information
The respondents for this information collection are individuals seeking an involuntary allotment from the pay of a member of the Armed Forces. Respondents complete the DD Form 2653, “Involuntary Allotment Application” and send the form and a copy of the court judgment to the Defense Finance and Accounting Service (DFAS) for processing. The information from the DD Form 2653 is used by DFAS officials to determine whether an involuntary allotment should be established against the pay of a member of the Armed Forces. The information is used to provide government reviewing officials with necessary information to ensure that both the law and due process considerations are accounted for, including information sufficient for a decision maker to determine that the request is based on a valid judgment and that the SCRA has been complied with.
The information collected from the DD Form 2653 has been used to permit direct assistance in the collection of debt provided the strict criteria of the Act are complied with.
Use of Information Technology
Respondents are able to obtain the DD Form 2653 from the DFAS web page at https://www.dfas.mil/Garnishment/Forms. The DD Form 2653 can be downloaded electronically but the form with an original signature must be submitted to DFAS. It is estimated that an annual average of 90% of respondents use an electronically-generated form. Full compliance with the Government Paperwork Reduction Act is not possible. A signed certification statement is required from each respondent that indicates the information provided is true and that the respondent has full knowledge of the penalties involved for willfully making a false statement. This requires an original signature. Also, the respondent must also attach certified copies of the court-ordered judgment. Certified copies of the court-ordered judgment is required so that DFAS can verify the validity of the document. Civilian courts are still at the initial development stage of incorporating electronic signatures and internet technology in their day-to-day business. As a result, the application of internet technology to incorporate supporting documentation is just not feasible at this time. Because the certification originates with the respondent and the requirement to have a hard copy certification document with any supporting documentation, there is no practical or cost effective way to apply any other form of current information technology to this collection process.
Non-duplication
The information obtained through this collection is unique and is not already available for use or adaptation from another cleared source.
Burden on Small Businesses
This information collection does not impose a significant economic impact on a substantial number of small businesses or entities.
Less Frequent Collection
This information is collected from the respondent on occasion. If this information were not collected or collected less frequently, the respondents would be unable to establish an involuntary allotment executing a judgment for payment of a debt. Without this collection of information, DoD would be unable to comply with the law.
Paperwork Reduction Act Guidelines
This collection of information does not require collection to be conducted in a manner inconsistent with the guidelines delineated in 5 CFR 1320.5(d)(2).
8. Consultation and Public Comments
Part A: PUBLIC NOTICE
A 60-Day Federal Register Notice (FRN) for the collection published on Friday, June 25, 2021. The 60-Day FRN citation is 86 FR 33694 FRN 33694.
No comments were received during the 60-Day Comment Period.
A 30-Day Federal Register Notice for the collection published on Thursday, September 16, 2021. The 30-Day FRN citation is 86 FR 51658 FRN 51658-51659.
Part B: CONSULTATION
No additional consultation apart from soliciting public comments through the Federal Register was conducted for this submission.
Gifts or Payment
No payments or gifts are being offered to respondents as an incentive to participate in the collection.
Confidentiality
A Privacy Act Statement is located at the top of DD Form 2653.
SORNs are published at https://dpcld.defense.gov/Privacy/SORNs/ for DFAS and Marine Corps Total Force System (MCTFS), at the following URLs:
https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-Component-Notices/DFAS-Article-List/
https://dpcld.defense.gov/Privacy/SORNsIndex/DOD-Component-Notices/NavyUSMC-Article-List/
A Privacy Impact Assessment is published, Integrated Garnishment System (IGS) DFAS accessed at https://media.defense.gov/2020/Feb/29/2002257217/-1/-1/0/INTEGRATED%20GARNISHMENT%20SYSTEM%20(IGS).PDF
System retention and disposal: Destroy 6 years and 3 months after cutoff.
Records retention and disposal: Destroy 10 years after cutoff.
11. Sensitive Questions
The Department's finance system, managed by the DFAS, currently uses the Service member's social security number (SSN) in the 5.8 million pay accounts they manage. The SSN is the unique identifier used by DFAS to identify the individual Service member internally and to the Internal Revenue Service. Without the SSN, DFAS would not be able to determine if they have the correct individual's financial record, which could result in garnishing the wrong Service member's pay.
12. Respondent Burden and its Labor Costs
Part A: ESTIMATION OF RESPONDENT BURDEN
Collection Instrument
[DD2653]
Number of Respondents: 2,783
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 2,783
Response Time: 30 minutes
Respondent Burden Hours: 1,391.5 hours
Total Submission Burden
Total Number of Respondents: 2,783
Total Number of Annual Responses: 2,783
Total Respondent Burden Hours: 1,391.5 hours
Part B: LABOR COST OF RESPONDENT BURDEN
Collection Instrument(s)
[DD2653]
Number of Total Annual Responses: 2,783
Response Time: 30 minutes
Respondent Hourly Wage: $18.32
Labor Burden per Response: $9.16
Total Labor Burden: $25,492.28
Overall Labor Burden
Total Number of Annual Responses: 2,783
Total Labor Burden: $25,492.28
The Respondent hourly wage was determined by using the Bureau of Labor Statistics Website (Occupational Employment and Wages, May 2020) ([https://www.bls.gov/oes/current/oes433011.htm]) for a bill and account collector. The site indicates the mean hourly wage rate is $18.32. The 30-minute per form response time was determined by having a DFAS garnishment section employee complete the DD Form 2653.
13. Respondent Costs Other Than Burden Hour Costs
There are no annualized costs to respondents other than the labor burden costs addressed in Section 12 of this document to complete this collection.
14. Cost to the Federal Government
Part A: LABOR COST TO THE FEDERAL GOVERNMENT
Collection Instrument(s)
[DD2653]
Number of Total Annual Responses: 2,783
Processing Time per Response: 30 minutes
Hourly Wage of Worker(s) Processing Responses: $30.24
Cost to Process Each Response: $15.12
Total Cost to Process Responses: $42,078.96
The workers who process these applications are paralegals journeyman whose grade is a GS-9. The pay rate was based on a GS-9/Step 5 in DFAS’ locality, which is $30.24 per hour.
Overall Labor Burden to the Federal Government
Total Number of Annual Responses: 2,783
Total Labor Burden: $42,078.96
Part B: OPERATIONAL AND MAINTENANCE COSTS
Cost Categories
Equipment: N/A
Printing: $542.08
Postage: $406.56
Software Purchases: N/A
Licensing Costs: N/A
Other: N/A
Total Operational and Maintenance Cost: $948.64
Printing
costs – approximately 8 pages are printed per accepted
application which are then mailed to the commander. It is estimated
that printing costs approximately $0.11 per page. Additionally,
larger envelops are used but we estimate the package would not exceed
3.5 ounces, which costs $0.66 to mail.
Part C: TOTAL COST TO THE FEDERAL GOVERNMENT
Total Labor Cost to the Federal Government: $42,078.96
Total Operational and Maintenance Costs: $948.64
Total Cost to the Federal Government: $42,027.60
15. Reasons for Change in Burden
The burden has increased since the previous approval due to an increase to the respondents’ hourly wage.
16. Publication of Results
The results of this information collection will not be published.
17. Non-Display of OMB Expiration Date
We are not seeking approval to omit the display of the expiration date of the OMB approval on the collection instrument.
18. Exceptions to “Certification for Paperwork Reduction Submissions”
We are not requesting any exemptions to the provisions stated in 5 CFR 1320.9.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Kaitlin Chiarelli |
| File Modified | 0000-00-00 |
| File Created | 2021-10-16 |