Supporting Statement - 0688 (Final)

Supporting Statement for

Certification of Prisoner Identity Information

20 CFR 422.107

OMB No. 0960-0688

1. Justification

1. Introduction/Authorizing Laws and Regulations

Section 205(c)(2)(B) of the Social Security Act (Act) authorizes the assignment of Social Security numbers (SSN). The Social Security Administration (SSA) regulations at 20 CFR 422.107 of the Code of Federal Regulations specify an applicant must provide documentary evidence of identity when applying for an original or replacement Social Security card. Section 702 of the Act authorizes SSA to establish rules and regulations appropriate to carry out the functions of the administration.

2. Description of Collection

SSA collects information needed to assign an SSN, as well as issue an original, duplicate, or corrected SSN card. SSA uses the SSN to keep an accurate record of an individual’s earnings, and to accurately pay benefits under the Social Security program. Inmates of Federal, State, or local prisons, either public or private (third party contracted by local, State, or Federal Government agency), may need an SSN card as verification of their SSN for school or work programs, or as proof of employment eligibility upon release from prison. Before SSA can issue a replacement Social Security card, applicants must show SSA proof of their identity. People who are in prison for an extended period typically do not have current identity documents. Therefore, under formal written agreement with the correctional institution, SSA contacts prison officials, and allows them to verify the identity of certain incarcerated U.S. citizens who need replacement Social Security cards. Inmates complete and sign Form SS-5 (OMB No. 0960-0066), Application for a Social Security Card, and a prison official certifies the inmate's identity using information found in the inmate's official file. Information prison officials provide comes from the official prison files sent on correctional facility letterhead; there is no standardized form used for this information collection. SSA uses this information to establish the applicant’s identity in the replacement Social Security card process. The respondents are prison officials who certify the identity of prisoners applying for replacement Social Security cards.

3. Use of Information Technology to Collect the Information

We do not currently allow for the transmission of this data via email, due to the sensitivity of the information we are requesting from the prison officials. As we are requesting the prison officials send us verification of personally identifying information for the prisoners, we cannot allow for the transmission of this information via email, as email is not a secure means to transmit this data electronically. In addition, this collection does not currently have a fully public‑facing Internet version, as we prioritized other information collections for full electronic conversions.  Given that IT Mod programming is an ongoing, dynamic project, we cannot provide specific timelines for when we will be able to make any particular ICR available via Internet web-based application.  We will ultimately convert most existing ICRs to full electronic versions depending on how they fall within our overall IT Mod schema, but this may be unconnected to the PRA approval lifecycle.  Finally, as there is no standardized form for this collection, we are unable to create a submittable PDF version of this information collection.

4. 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.

5. Minimizing Burden on Small Respondents

This collection does not affect small businesses or other small entities.

6. Consequence of Not Collecting Information or Collecting it Less Frequently

If we did not collect the information, we would have no means to prove the identity of the prisoner applicants who request a replacement SSN card. This could create a hardship for prisoners who do not typically have the current documents we require as proof of identity. Because we request this information on an as needed basis, we cannot collect it less frequently. There are no technical or legal obstacles to burden reduction.

7. 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.

8. Solicitation of Public Comment and Other Consultations with the Public

The 60-day advance Federal Register Notice published on August 20, 2021, at

86 FR 46897, and we received no public comments. The 30-day FRN published on October 26, 2021 at 86 FR 59262. If we receive any comments in response to this Notice, and we received no public comments.

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

Modality of Completion	Number of Respondents	Frequency of Response	Number of Responses	Average Burden per Response (minutes)	Estimated Total Annual Burden (hours)	Average Theoretical Hourly Cost Amount (dollars)*	Total Annual Opportunity Cost (dollars)**
Verification of Prisoner Identity Statements	1000	200	200,000	3	10,000	$28.80*	$288,000**

* We based this figure on average Probation Officers and Correctional Treatment Specialists hourly salary, as reported by Bureau of Labor Statistics data (https://www.bls.gov/oes/current/oes211092.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.

We base our burden estimates on current management information data, which includes data from actual interviews, as well as from years of conducting this information collection. Per our management information data, we believe that 15 minutes accurately shows the average burden per response for reading the instructions, gathering the facts, and answering the questions. Based on our current management information data, the current burden information we provided is accurate. The total burden for this collection instrument is 10,000 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $288,000. SSA does not charge respondents to complete our applications.

Additionally, since this process does not involve respondents visiting SSA Field Offices, we do not need to include a rough estimate of a 30-minute, one-way, drive time in our calculations of the time burden for this collection.

13. Annual Cost to the Respondents (Other)

This collection does not impose a known cost burden on the respondents.

14. Annual Cost To Federal Government

The annual cost to the Federal Government is approximately $170,000. This estimate accounts for costs from the following areas:

Description of Cost Factor	Methodology for Estimating Cost	Cost in Dollars*
Designing and Printing the Form	Design Cost + Printing Cost	$0*
Distributing, Shipping, and Material Costs for the Form	Distribution + Shipping + Material 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	$170,000
Full-Time Equivalent Costs	Out of pocket costs + Other expenses for providing this service	$0*
Systems Development, Updating, and Maintenance	GS-9 employee x man hours for development, updating, maintenance	$0*
Quantifiable IT Costs	Any additional IT costs	$0*
Other	[Component may add as needed]	$0*
Total		$170,000

* 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.  Since there is not standard form for this collection, we have no design, printing, or distribution costs. In addition, since we contact the prison officials when we need to obtain this information, we do not maintain online instructions as to how to submit this information to SSA, rather, we inform the prison officials when we request the information.  Finally, 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.  However, we have calculated these costs as accurately as possible based on the information we collect for creating, updating, and maintaining these information collections.

15. Program Changes or Adjustments to the Information Collection Request

There are no changes in the public reporting burden.

16. 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.