Justification for Non-Substantive Changes
Consent Based Social Security Number Verification (CBSV)
20 CFR 41.100
OMB No. 0960-0760
Background:
The CBSV is a fee-based Social Security Number (SSN) verification service private business and other requesting parties use to obtain SSA’s validation of SSNs of consenting number holders. After signing a user agreement and completing a registration process, the requesting party submits a file to SSA through either the CBSV internet or web service applications. SSA matches the information against our Master File, using SSN, name, date of birth, and gender code (if available). The results file SSA returns to the requesting party over the Internet or web service shows only a match/no match indicator (and an indicator if our records show that the individual issued the SSN is deceased).
We are requesting OMB approval to make the following non-substantive, nonmaterial changes to the collection instrument, user agreement, to incorporate the Commissioner of Social Security’s goals of promoting plain language in Government as expressed under the Plain Writing Act of 2010. The following changes to the user agreement will improve clarity and readability for the user, and will not increase the public burden.
Justification for Non-Substantive Changes to the Collection or Resubmission of the Collection within One Year of OMB Approval
Section I. Purpose and Definitions (page 4)
New Agreement: We modified client definition to align with SSA’s standard operating procedure for client signatory authority for minors and persons who are legally incompetent. The old agreement was silent concerning this procedure.
Section IV. Responsibilities (page 6)
New Agreement: A.8.a – At the completion of the registration process, SSA will issue a unique access code to the Responsible Company Official.
Justification – This is a clarification of the business process. The old agreement implied this action.
Section V. Consent (page 8)
New Agreement: If a parent or legal guardian signs the Consent Form (SSA-89), the parent or legal guardian must provide proof of relationship, e.g., a copy of the birth certificate or court documentation proving the relationship. The Requesting Party must retain proof of the relationship.
Justification - This is a new requirement for the agreement, but standard operating procedures for all SSA business with the public. At the recommendation of SSA’s legal counsel, we are requiring proof of relationship. The burden is on the business (i.e., Requesting Party) to ensure the client provides proof of relationship in this situation.
Section VI. Technical Specifications and Systems Security and Related Business Process Requirements (page 9)
New Agreement: Clarification of encryption protocols for data exchanges between SSA and the Requesting Party.
Justification: Due to security issues related to the use of web services, SSA cannot process all verifications using the web services method. In the case of CBSV, we offer both web service and online. For online data entry, SSA provides an interface where users enter the data into fields on a screen. For the web service, the user creates an application that sends the data and programming instructions to the CBSV application resources. This section clarifies the data exchange protocols the Requesting Party should use.
Section IX. Duration of Agreement, Suspension of Services, and Annual Renewal (page 11)
New Agreement: A.1 – Notification in writing of requesting party to terminate agreement…
The old agreement simply stated “…gives notice of its decision to cancel its Agreement.”
Justification - This is a clarification of the old agreement. The agreement implied this action; we are clarifying the language to state the request should be in writing.
Section IX. Duration of Agreement, Suspension of Services, and Annual Renewal (page 13)
New Agreement: C. Annual Renewal (paragraph 4) – Based on a requirement from the Department of Transportation, beginning fiscal year 2013, SSA must issue payments to contractors conducting business with us via electronic fund transfer (EFT).
Justification - We are bringing the process in line with regulation edicts. The old agreement did not require EFT.
Section X. Compliance Reviews, Initiating the Compliance Review (page 14)
New Agreement: C.2 – CPA must send certification documentation to SSA within 30 days of receiving Engagement Letter.
Justification - This is a clarification of the old agreement. This is standard operating procedures for such agreements.
User Agreement throughout – Agreement sections are in a different order from the old or original version.
Justification – The rearrangement of sections is to improve clarity and readability for the user (i.e., Requesting Party).
We will implement upon OMB approval.
| File Type | application/msword |
| File Title | ADDENDUM TO SUPPORTING STATEMENT |
| Author | Naomi |
| Last Modified By | 889123 |
| File Modified | 2012-06-27 |
| File Created | 2012-06-27 |