SUPPORTING STATEMENT A
Application for Correction of Military Records
Under the Provisions of Title 10, U.S. Code, Section 1552,
OMB 0704-0003
Need for the Information Collection
Under Title 10 United States Code § 1552, Active Duty and Reserve Component Service members, Coast Guard, former Service members, their lawful or legal representatives, spouses of former Service members on issues of Survivor Benefit Program (SBP) benefits, and civilian employees with respect to military records other than those related to civilian employment, who feel that they have suffered an injustice as a result of error or injustice in military records (hereafter referred to as respondents) may apply to their respective Boards for Correction of Military Records (BCMR) for a correction of their military records. These Boards are the highest level of administrative review authority regarding official personnel records in the Military Departments. The information collected is needed to provide the Boards the basic data needed to process and act on the request.
Use of the Information
The respondents submit to the respective BCMR review Boards a DD Form 149, “Application for Correction of Military Record under the Provisions of Title 10, U.S. Code, Section 1552.” The information from the DD Form 149 is used by the respective Service Review Boards in processing the respondent’s request authorized under 10 USC § 1552. The DD Form 149 was devised to standardize application to these Boards. This information is used to identify and secure the appropriate official military and medical records from the records storage facilities. Information on the form is also used to determine current status, to allow respondents to designate counsel of choice, to identify the issues involved, and to determine if the request was filed within the three-year statute of limitations established by Congress.
The information collected from the DD Form 149 has been used by the respective Military Department correction Boards to determine if an error or injustice has occurred in an individual’s military record and to promulgate a correction based on justice, equity, and compassion.
Use of Information Technology
Approximately 75% of respondents submit the DD Form 149 electronically. The DD Form 149 is available to the public electronically on-line from the Department of Defense forms website http://www.dtic.mil/whs/directives/infomgt/forms/eforms/dd0149.pdf.
Non-duplication
The information obtained through this collection is unique and is not already available for use or adaptation from another cleared source. The DD Form 149 is used by all the Services for identical purposes.
Burden on Small Business
This information collection does not impose a significant economic impact on a substantial number of small businesses or entities.
Less Frequent Collection
This information is collected from the respondent on occasion. If this information was not collected or collected less frequently, respondents would be unable to apply to their respective BCMRs to request correction of alleged error contained in their military records and/or a correction of an injustice. Without this collection of information, DoD would be unable to comply with the current law.
Paperwork Reduction Act Guidelines
This collection of information does not require collection to be conducted in a manner inconsistent with the guidelines delineated in 5 CFR 1320.5(d)(2).
Consultation and Public Comments
Part A: PUBLIC NOTICE
A 60-Day Federal Register Notice for the collection published on Friday, July 12, 2019. The 60-Day FRN citation is 84 FRN 33243.
No comments were received during the 60-Day Comment Period.
A 30-Day Federal Register Notice for the collection published on Monday, September 16, 2019. The 30-Day FRN citation is 84 FRN 48602.
Part B: CONSULTATION
No additional consultation apart from soliciting public comments through the 60-Day Federal Register Notice was conducted for this submission.
Gifts or Payment
No payments or gifts are being offered to respondents as an incentive to participate in the collection.
Confidentiality
A Privacy Act Statement has been included on the DD Form 149 to inform respondents of their privacy rights. 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.
Applicable SORNs:
Army
http://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/569931/a0015-185-sfmr.aspx
Navy and Marine Corps
http://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570411/nm01000-1
Air Force
http://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/569838/f036-safpc-d/
Coast Guard
https://www.gpo.gov/fdsys/pkg/FR-2013-10-02/html/2013-23991.htm
PIA:
The PIA URL is http://ciog6.army.mil/Portals/1/PIA/2012/ACTS_PIA.pdf (specific PDF) or http://ciog6.army.mil/PrivacyImpactAssessments/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.
Respondent Burden and its Labor Costs
Respondent for Collection of Information. Please note that this number has been adjusted based on Military Department annual reports.
Estimation of Respondent Burden
DD Form 149
Total annual respondents: 36,110
Frequency of response: 1
Total annual responses: 36,110
Burden per response: 30 minutes
Labor Cost of Respondent Burden
The 30 minute per form response time was determined by having an Army Review Board Agency employee sit down and fill out the DD Form 149.
$7.25/hour (Federal minimum wage) x 18,055 hours = $130,898.75.
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. Total Operation and Maintenance Cost.
(1) Photo copy of supporting documentation (average number per submission)
5 pages at $ .10 per page = $ .50 x 36,110 applications = $18,055
(2) Mailing of DD Form 149 and supporting documents:
36,110 x $ 1.39 (postage) per application = $50,192.90
36,110 x $ .10 (envelope) per application = $3,611
TOTAL ANNUAL RESPONDENT O&M COST = $71,858.90
Cost to the Federal Government
(a) Printing individual forms on Federal Government computer
printers: 12,000 forms @ 20 cents per form (2 sided) = $ 2,400
(This cost is based upon a substantial number of written requests that are sent to the Boards from retirees or inmates requesting forms. These individuals often do not have ready access to electronic versions of the form. This figure should eventually go down in the future as more senior citizens and inmates obtain the form online).
(b) Photo copying and word processing (paper, toner, machines) of form, supporting documentation, and decisional documents for mailing and archiving:
36,110 x $5.11 per decision = $184,522.10
(c) Mailing between offices and records repositories of form, records, advisory opinions, and decisional documents:
36,110 x $2.28 per applicant = $82,330.80
(d) Mailing decisional documents to respondents:
36,110 x $ .39 (postage) per decision = $14,082.90
36,110 x $ .05 (envelope) per decision = $1805.50
(e) Labor Costs:
The following estimate involving labor costs is based on the personnel structure at the Army Board for the Correction of Military Records, which is similar to the other Services boards. Additionally, for each category, an average salary for the personnel was used to determine the hourly rate.
Examiner Staff: 4 staff at average $9.60/hr x 7 hrs = $ 268.80
Support Staff:
Screening and Processing
6 personnel at average $4.10/hr x 6 hrs = $ 147.60
Archiving and Promulgating
2 personnel at average $12.60/hr x 1 hr = $ 25.20
Mail Handling
2 personnel at average $7 x ¼ hr = $ 3.50
2 personnel at average $12/hr x ¼ hr = $ 6.00
Board Members:
3 board members at average $15.33/hr x ½ hr = $ 23.00
Board Approval by Secretarial Representative:
$56.00/hr x ½ hr = $ 28.00 Total Labor Cost Per Case = $ 502.10
TOTAL COST TO THE GOVERNMENT $16,923,945.20
Reasons for Change in Burden
There is no change in burden.
Publication of Results
The results of this information collection will not be published.
Non-Display of OMB Expiration Date
We are not seeking approval to omit the display of the expiration date of the OMB approval on the collection instrument.
Exceptions to “Certification for Paperwork Reduction Submissions”
We are not requesting any exemptions to the provisions stated in 5 CFR 1320.9.
| File Type | application/msword |
| File Title | Supporting Statement |
| Author | Crystal Mall 4 |
| Last Modified By | SYSTEM |
| File Modified | 2019-09-20 |
| File Created | 2019-09-20 |