Supporting Statement
Application for the Review of
Discharge or Dismissal
from the Armed Forces of the United
States
A. JUSTIFICATION.
1. Need for Information Collection
Under 10 U.S.C. § 1553 and DoD Directive 1332.41, “Boards for the Correction of Military Records (BCMRs) and Discharge Review Board (DRBs),” former Service members who received an administrative discharge have the right to appeal the characterization or reason for separation, provided they do so within 15 years from the date of separation. Accordingly, each Military Department has established a Board of Review to review appeals of former members of the Armed Forces. The DD Form 293, “Application for Review of Discharge from the Armed Forces of the United States” provides the respondent a vehicle to present to the DRB their reasons and justifications for a discharge upgrade as well as providing the Services the essential data needed to process the appeal. This information collection is needed to provide Service members a method to present to their respective Military Department Discharge Review Boards their reason/justification for a discharge upgrade, as well as, providing the Military Departments with the basic data need to process the appeal. The data collected is covered by the Systems of Record Notices correction of discharge review board and official military records maintained by each of the Military Departments (available http://dpclo.defense.gov/Privacy/SORNs.aspx).
2. Use of Information
The primary purpose of this information is to identify the arguments of the respondents and justifications for requested relief, and secure their Official Military Personnel Files from the National Records Center, and it allows the respondent to explain the reasons for the alleged error or injustice, designate counsel of choice, select the method of hearing desired, and request a records review or personal hearing. This information is also used to correspond with the respondent and counsel regarding his or her appeal, to provide further clarification as needed, and updates on the status of the case. The respondents for this information collection are former members of the Military Departments requesting a change in the characterization of their discharge or the reason for their separation. Service members submit to their respective Service Discharge Review Board a DD Form 293. The respective Service Discharge Review Board (DRB) uses the information from the DD Form 293 in processing the respondent’s discharge appeal authorized under 10 U.S.C. § 1553 and DoD Directive 1332.41. While in Service custody, this information is privileged and restricted to individuals who have a need for the record in the performance of their official duties.
Over the past three years, the information collected from the DD Form 293 has been used by the respective Service Discharge Review Boards to examine the propriety and equity of the respondents’ discharge and to recommend any changes, if warranted.
3. Improved Information Technology
The DD Form 293 is available on Department of Defense forms website,
http://www.dtic.mil/whs/directives/infomgt/forms/eforms/dd0293.pdf.
For respondents who have access to computerized information technology, the DD Form 293 can be completed on-line before printing for signature. A signed DD Form 293 is required from each respondent that indicates the information provided is true and that the respondent has full knowledge of penalties involved for willfully making a false statement.
At this time, there is no practical or cost-effective way to completely implement the requirements of the Government Paperwork Elimination Act. It does not appear that the electronic signature is practical to use for the respondent’s limited submission of a DD Form 293. There is an ongoing initiative within the Department of Defense to provide the capability to deploy public key infrastructure (PKI) for its issuance of certificate-based digital signatures. In the future, based on the outcome and requirements of the DoD PKI initiative, electronic signatures may be considered for use with the DD Form 293 if the burden and cost to the respondent is minimal.
4. Non-Duplication
There is no duplication. The DD Form 293 is used by all the Services for identical purposes. No similar information is readily available from which an individual appeal could be processed. The respondent must initiate the request and must provide personal information, including his or her name, address, social security number, branch of Service at discharge, discharge date, discharge characterization, unit and location at the time of discharge, change requested in and justification for change in discharge characterization or reason for discharge, whether he or she desires to appear before the Board, and supporting documentation for a discharge upgrade.
5. Burden on Small Business
Small business and other small entities are not involved.
6. Less Frequent Collection
The respondent initiates a request for review and upgrade of his or her discharge by completing the requested information on the DD Form 293 and submitting it to the respective Service Discharge Review Board. The form, which implements Congressional intent under 10 U.S.C. §1553, is essential. If the form was not used, or if the information was not collected, the respondents would be unable to appeal to their respective Discharge Review Boards to request a change in their characterization of discharge or reason for separation. Without this collection of information, the Department of Defense would be unable to comply with the current law, Congressional intent would be frustrated, and former Service members and the public would lose confidence in the fairness of the military’s administration of it personnel system.
7. Paperwork Reduction Act Guidelines
There are no special circumstances. The data collections will be conducted in a manner consistent with guidelines in 5 C.F.R. 1320.5(d)(2).
8. Consultation and Public Comments
A notice has been made in Volume 79, No. 161, page 49288, of the Federal Register, August 20, 2014. No public comments were received.
A 30-day Federal Register Notice has been published on 10/27/14 in Volume 79, page 63906.
The Military Department Discharge Review Boards are primary users of the information collected on the DD Form 293. Minor administrative changes were recommended by the board. Boxes on the form have been renumbered, and the addresses and contact information for the Discharge Review Boards have been updated.
DD Form 293 has been in use and tested for years. Less than 1% are questioned or mis-routed.
9. Gifts or Payment
No payments or gifts will be made to respondents.
10. Confidentiality
The collected information is used to process a respondent’s appeal. During the processing, records are maintained in areas accessible only to authorized personnel. All data are protected by the Privacy Act of 1974 and are protected according to the regulations therein, and by related DoD directives and instructions.
Applicable SORNs:
Army http://dpclo.defense.gov/Privacy/SORNsIndex/DODComponentArticleView/tabid/7489/Article/6000/a0015-185-sfmr.aspx
Navy and Marine Corps http://dpclo.defense.gov/Privacy/SORNsIndex/DODwideSORNArticleView/tabid/6797/Article/6510/nm01000-1.aspx
Coast Guard
http://www.gpo.gov/fdsys/pkg/FR-2011-10-28/html/2011-27881.htm
PIA:
The PIA URL is http://ciog6.army.mil/Portals/1/PIA/2012/ACTS_PIA.pdf (specific PDF) or http://ciog6.army.mil/PrivacyIm-pactAssessments/tabid/71/Default.aspx (for the Army's CIO/G-6 PIA webpage).
Sensitive questions
No sensitive questions are asked in the collection. Respondents furnish only that information relevant and necessary to process their request.
Social Security Number (SSN): Is requested to ensure accuracy of data involving the specified individual applicant. The form states this information is voluntary; however, failure of the applicant to provide their SSN may delay the processing of the application.
Personal Identifying Information (PII): Respondents are advised that their data is for Official Use Only and will be maintained and used in strict confidence in accordance with Federal law and regulations and that the procedures are in place to protect the confidentiality of the information. The erroneous release of PII might cause legal action from individuals against DoD and/or the government. All personal information provided by the subject falls under the Privacy Act of 1974 and OMB Circular A-108.
12. Response Burden, and its Labor Costs
a. Estimation of Respondent Burden
(1) DD Form 293
Total annual respondents: 10,000
Frequency of response: One-time
Total annual responses: 10,000
Burden per response: 45 minutes
Total burden hours: 7,500 hours
b. Labor Cost of Respondent Burden
The 45 minutes per form response time was based on the time it took an Army Review Board Agency employee to complete an application.
c. Labor Cost to Respondent.
$7.25/hour (Federal minimum wage) x 7,500 hours = $54,375.
13. Respondent Costs Other than Burden Hour Costs
a. Total Capital and Start-up Cost.
There are no capital or start-up costs associated with this information collection. Respondents will not need to purchase equipment or services to respond to this collection.
b. Operation and Maintenance Cost.
(1) Photocopy of supporting documentation (average number per submission):
4 pages at $.10 per page = $0.40 x 10,000 applications = $4,000.00
(2) Mailing of DD Form 293 and supporting documents:
10,000 x $1.39 (postage) per application = $13,900.00
10,000 x $0.10 (envelope) per application = $ 1000.00
TOTAL ANNUAL RESPONDENT O&M COST= $18,900.00
14. Cost to the Federal Government
a. Printing individual forms on Federal Government computer printers:
10,000 forms x $0.42 cents per form (4 sides) = $4200.00
b. Photocopying and word processing (paper, toner, machines) of form, supporting documentation, and decisional documents for mailing and archiving:
10,000 forms x $4.94 per decision = $49,400.00
c. Mailing between offices and records repositories of form, records, advisory opinions, and decisional documents:
10,000 x $2.21 per applicant = $22,100.00
d. Mailing decisional documents to respondents:
10,000 x $ .44 (postage) per decision = $4,420.00
10,000 x $ .10 (envelope) per decision = $1000.00
TOTAL ANNUAL MATERIALS COST = $146,000.00
e. Labor Costs:
The following estimate involving labor costs is based on the personnel structure at the Army Discharge Review Board, which is similar to the other Military Department Boards. Additionally, for each category, an average salary for the personnel was used to determine the hourly rate.
Examiner Staff:
4 staff at average $33.65/hr x 7 hrs = $ 942.20
Support Staff:
Screening and Processing
6 personnel at average $15.65/hr x 6 hrs = $ 563.40
Archiving and Promulgating
2 personnel at average $19.51/hr x 1 hr = $ 39.02
Mail Handling
2 personnel at average $17.67 x ¼ hr = $ 8.84
IT Technical Support
2 personnel at average $28.29/hr x ¼ hr = $ 14.15
Board Members:
5 board members at average $70.00/hr x ¾hr = $ 262.50
Total Labor Cost Per Case = $1830.11
TOTAL COST TO THE GOVERNMENT $18,466,000
15. Reasons for Change in Burden.
There has been an increase of approximately 2,000 annual applications since 2011 (an increase of approximately 4,300 annual applications since 2006). The increase in the number of individuals seeking to correct their military records is likely due to the effects of increased recruitment of individuals to join military forces and the higher operations tempo of the armed forces.
16. Publication of Results
Information is not tabulated or published. This collection of information does not employ statistical methods.
17. Non-Display of OMB Expiration Date
DoD is not seeking an exception to displaying the expiration date of this information collection.
18. Exceptions to “Certification for Paperwork Reduction Submissions”
No exceptions to the certification statement are being requested..
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | SUPPORTING STATEMENT |
| Author | gingrasm |
| File Modified | 0000-00-00 |
| File Created | 2021-01-26 |