RI38-115_OMB_Supporting_Stmt_2025

RI38-115_OMB_Supporting_Stmt_2025.docx

Representative Payee Survey

OMB: 3206-0208

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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

RI 38-115 – Representative Payee Survey


A. JUSTIFICATION

  1. Explain the circumstances of this collection, why this collection is necessary. and the legal statutes that allow it.

Title 5, U. S. Code, Chapter 83, Section 8345(e) and Chapter 84, Section 8466(c) provide for the payment of benefits to the representative payee of an incompetent annuitant. Title 5, U. S. Code, Chapter 83, Section 8347(a) and Chapter 84, Section 8461(g) provide that the Office of Personnel Management (OPM) shall administer the provisions of the law and regulations relating to the payment of retirement benefits. RI 38-115 is designed to collect information about how the monies OPM has paid to a representative payee have been used or conserved for the benefit of the incompetent annuitant.


  1. Describe how, by whom, and for what purpose the information is to be used. Except for a new collection, describe how the agency has made use of the information received from the current collection.


RI 38-115 is used to determine whether representative payees are using the benefit to support the annuitant. This information collection is needed in order to avoid paying persons who are misusing the annuities, are no longer acting as payee for the annuitant, or have failed to report an event (such as the death of the annuitant) which would terminate the annuity. The survey is not mailed to court-appointed fiduciaries. The form collects the social security number of the representative payee and the email address where the payee can be reached.


  1. How are the respondents expected to complete the collection? Can this collection be completed electronically (e.g., through a website or application)?


RI 38-115 is mailed to representative payees for completion and return to: U.S. Office of Personnel Management, Retirement Surveys & Students Branch, 1900 E Street, NW - Room 2416, Washington, DC 20415-0001. The form must be returned within 30 days after the date of the survey.


The survey can also be completed electronically at www.opm.gov/forms, printed and mailed to the

address above.


  1. Does this collection duplicate any other collection of information? Describe why the agency doesn’t already have this information within their systems.


While OPM must give the annuitant the opportunity to initiate a change in their election, OPM is

continuing its momentum from FY 2023 investments to pilot a fully digital retirement case

processing method. Additionally, OPM will continue building on pilot initiatives to improve the annuitant experience like the online retirement guide and chatbot. Retirement Services will use data-driven evaluations of these pilots to inform additional ways to better answer annuitant questions and reduce their burden.  If the collection of information impacts small businesses or other small entities.


  1. Describe any impacts on small business. If applicable, describe any methods used to minimize those impacts.

Information is not collected from small businesses and organizations.


  1. What are consequences to the Federal program or policy goals if this collection is not done or the information is collected less frequently? Describe any technical or legal obstacles to reducing burden.


Less frequent collection would hamper OPM efforts to oversee the payment of annuities to persons who are charged with using the money for the benefit of someone else.


  1. Do any of the following special circumstances apply?

requiring respondents to report information to the agency more often than quarterly;

requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

requiring respondents to submit more than an original and two copies of any document;

requiring respondents to 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;

requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law


This information collection is consistent with the guidelines in 5 CFR 1320.6, except 1320.6(b). A response is required within 30 days in order to prevent payment to those who are no longer eligible.


  1. Cite the Federal Register publication for a request for public comments and address any comments received.


On March 10, 2025, a 60 Day Federal Register Notice was published at 90 FR 11633.
No comments were received.

On September 16, 2025, a 30 Day Federal Register Notice was published at 90 FR 44727.

No comments were received.


  1. Are payments or gifts given to the respondents?

No gifts or payments of any kind have been provided to any individuals who are connected to this collection.


10. Describe any assurances of privacy/confidentiality. Cite specific privacy laws, relevant OPM regulations, and SORNs.


This information collection is protected by the Privacy Act of 1974 and OPM regulations
(5 CFR 831.106). The routine uses of disclosure appear in the Federal Register for OPM/Central-1 (87 FR 5874, published February 2, 2022).


  1. Are any questions of a sensitive nature asked, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private? If yes, provide justification. This justification should include the reasons why the agency considers the questions necessary, the 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.


The information collection does not include questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The submission of this information is voluntary. However, if it is not collected, annuitants could be paid less than the law provides.


  1. Type of Respondent

    Form Name

    No. of Respondents

    Total No. of Responses

    Average Burden per Response (in hours)

    Hourly Wage Rate

    Total Respondent Cost

    Representative Payee

    Representative Payee Survey

    11,000

    1

    .333

    $32.66

    $119,634



    Describe the hour time burden and the hour cost burden on the respondent needed to complete this collection. Please specify hourly salary for your respondent audience by referencing Bureau of Labor Statistics Occupational Employment and Wage Estimates or other alternative wage site, when applicable.


Approximately 11,000 forms will be processed annually. The form requires
approximately 20 minutes each to complete. The annual burden of 3,667 hours is
estimated.








The Total Annual Respondent Cost is $119,634.


13.Describe the non-hourly monetary burden to respondents needed to complete this collection. This is defined as out-of-pocket costs such as application fees for the collection, document fees (birth/death certificates, school transcripts), mailing costs (printing, postage, and/or mileage), or anything else respondents may need to pay to complete and/or implement the collection.

Form Name



No. of Respondents


No. of Respondents

Mileage at $0.70 a mile

Total Mileage

Total Non-Hourly Cost

Representative Payee Survey

11,000


11,000

9

$69,300

$69,300










While OPM provides postage for the return of the form, there is still the cost of mileage for mailing the form back to OPM. USPS estimates that the average driving distance between post offices is around 9 miles. The IRS announced that the 2025 mileage rates is $0.70 per mile.


Therefore, the estimated total non-hourly cost is $69,300.


14. Describe the cost incurred by the Federal Government to complete this collection


The annualized cost to the Government is $104,100. This cost is derived from employee’s
salaries, staff hours required to process the forms and the cost of printing, storing and

shipping forms.


  1. Explain any changes/adjustments to this collection since the previous submission, if applicable. Describe whether these changes impact the hour or cost burden. If yes, describe if the impact is the result of deliberate Federal government action (“program change”) or something else (“adjustment”).


This Information Collection Request (ICR) has been revised to update the display of the

OMB control number.


There is no change in the hour or cost burden other than what would be inflationary changes.


16. Specify if the data gathered by this collection will be published. This could include Congressional
reporting, using respondent numbers in budget justification, or other broad reporting
.

The results of this information collection are not published.


17. If applicable, explain the reason(s) for seeking approval to not display the OMB expiration date.


We seek approval to not display the OMB clearance expiration date on the forms and to communicate version changes to the public via the revision date. OPM has modified our Paperwork Reduction Act notice to ensure respondents can verify the validity of the OMB control number and collection.

  1. Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”


There are no exceptions to the certification statement.


B. Collection of Information Employing Statistical Methods

This collection does not employ statistical methods.





File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleOMB SUPPORTING STATEMENT
AuthorIkpe, Yvonne R.
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File Created2025-12-18

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