Supporting Statement
Request for Accommodation in Communication Method
Form SSA-9000-F6
45 CFR 85.51
OMB No. 0960-0777
A. Justification
Introduction/Authoring Laws and Regulations
In American Council of the Blind, et al v. Michael Astrue and Social Security Administration, the U.S. District Court for the Northern District of California ordered the Social Security Administration (SSA) to give blind or visually impaired Social Security applicants, beneficiaries, recipients, and representative payees the opportunity to elect one of five alternative formats to receive notices about program benefits. Those five alternative formats are as follows: (1) a standard print notice by first-class mail; (2) a standard print notice by first-class mail with a follow-up telephone call; (3) certified mail; (4) Braille; and (5) Microsoft Word files (on data compact discs). In addition, the Court ordered SSA to consider requests from blind or visually impaired individuals for notices in other formats if none of the alternative formats SSA offered provided effective communication. SSA began processing accommodation requests on April 15, 2010. SSA also offers two additional alternative formats to receive notices: (1) large print (18-point font), and (2) audio CD.
To meet the Court’s mandates, SSA developed Form SSA-9000, Request for Accommodation, in agreement with 45 CFR 85.51 of the Code of Federal Regulations, to gather information from blind or visually impaired individuals about why they require a particular accommodation, other than the accommodations already offered, to have effective communication with SSA.
Description of Collection
SSA allows blind or visually impaired Social Security applicants, beneficiaries, recipients, and representative payees to call or visit SSA to tell us which method of communication they want SSA to use when it sends them benefit notices and other related communications. As mentioned above, the seven alternative methods we offer are as follows: (1) standard print notice by first class mail, (2) standard print mail with a follow-up telephone call, (3) certified mail, (4) Braille, (5) Microsoft Word file on data compact disk (CD), (6) large print (18-point font), or (7) audio CD. However, respondents who want to receive notices from SSA through a communication method other than these seven methods must use Form SSA-9000 to: (1) describe the type of accommodation they want, (2) disclose their condition necessitating the need for a different type of accommodation, and (3) explain why none of the seven methods described above are sufficient for their needs.
SSA uses Form SSA-9000 to determine, based on applicable law and regulation, whether to grant an individual’s request for an accommodation based on their blindness, other visual impairment, and as applicable, another disabling condition. SSA collects this information electronically through either an in-person interview or a telephone interview during which the SSA employee keys in the information on Intranet screens. The respondents are Social Security applicants, beneficiaries, recipients, and representative payees who are blind or visually impaired and who ask SSA to send notices and other communications in an alternative method besides the seven modalities we currently offer.
Use of Information Technology to Collect the Information
Respondents can complete Form SSA-9000 during a field office visit or telephone interview, which allows them to avoid completing a paper form. We have not developed an Internet-based version of the form under SSA’s Government Paperwork Elimination Act plan because of the low volume of use (fewer than 50,000 respondents).
Why We Cannot Use Duplicate Information
The nature of the information we are collecting and the manner in which we are collecting it preclude duplication. SSA does not use another collection instrument to obtain similar data.
Minimizing Burden on Small Respondents
This collection does not affect small businesses or other small entities.
Consequences of Not Conducting Information or Collecting it Less Frequently
A court order requires SSA to collect this information from blind or visually impaired individuals who will not have meaningful communication with SSA unless their benefits notices are in a format other than the alternatives SSA currently offers. Without this information collection, SSA has no adequate means of determining whether to grant an individual’s request for an additional accommodation. Since we only collect the information when an individual wishes to request an alternative accommodation, we cannot collect it less frequently. There are no technical or legal obstacles to burden reduction.
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.
Solicitation of Public Comment and Other Consultations with the Public
The 60-day advance Federal Register Notice published on June 17, 2013, at 78 FR 36291, and we received no public comments. SSA published the second Notice on September 3, 2013, at 78 FR 54363. If we receive comments in response to the 30-day Notice, we will forward them to OMB. We did not consult with the public in the revision of this form.
SSA published a correction notice on 6/17/13, at 78 FR 36291 which we are using as our official 60-day Notice. Our originally published 60-day Notice, published on 6/3/13 at 78 FR 33142, showed incorrect burden information. We republished on 6/17/13 to correct the burden information. We also show the corrected burden information in #12 below.
Payment or Gifts to the Respondents
SSA does not provide payments or gifts to the respondents.
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.
Justification for Questions of a Sensitive Nature
The information collection does not contain any questions of a sensitive nature.
Estimates of Public Reporting Burden
We estimate 1,417 requests for a special accommodation annually, which we will complete during a face-to-face or telephone interview. We estimate it takes 20 minutes to collect the information requested by the SSA-9000 for a total burden of 472 hours. This figure represents burden hours, and we did not calculate a separate cost burden.
Annual Cost to the Respondents (Other)
This collection does not impose a known cost burden on the respondents.
Cost to the Federal Government
The annual cost to the Federal Government for this collection is approximately $60,000. This estimate is a projection of the costs for processing the information collection.
Changes to the Public Reporting Burden
We based our previous burden estimate on our projection of respondents who may want to use the new form. However, after the initial implementation of the form, the number of respondents dropped considerably. Therefore, we based our new estimate on actual usage for 2012. In addition, while we offer a paper version of the SSA-9000, none of the respondents used it. Rather, since implementing this process, the respondents have only used the telephone or in-person interview option. Therefore, we are no longer showing burden for the paper version, but we will keep the paper version available in case respondents choose to use it. Finally, we increased our time estimate for completing the interview from 10 minutes to 20 minutes, as we found it takes a bit longer for respondents to answer the questions than we initially anticipated in 2010.
Publication of the Results of the Information Collection
SSA will not publish the results of the information collection.
Displaying the OMB Expiration Date
SSA is not requesting an exception to the requirement to display the OMB approval expiration date for the in-person or telephone interview; however, for the paper form, OMB granted SSA an exemption from the requirement to print the OMB expiration date on its program forms. SSA produces millions of public-use forms with life cycles exceeding those of an OMB approval. Since SSA does not periodically revise and reprint its public-use forms (e.g., on an annual basis), OMB granted this exemption so SSA would not have to destroy stocks of otherwise useable forms with expired OMB approval dates, avoiding Government waste.
OMB Certification Requirements
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 will not use statistical methods for this information collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | 072230 |
| File Modified | 0000-00-00 |
| File Created | 2021-01-29 |