A. Justification
Introduction/Authoring Laws and Regulations
If individuals want to become official representatives for Social Security claimants, the Social Security Administration (SSA) requires collection of certain information to register or appoint them as representatives. SSA uses Form SSA‑1699, Registration for Appointed Representative Services and Direct Payment, for this purpose. Sections 206(a) and 1631(d) of the Social Security Act give SSA the authority to collect the information we request on Form SSA-1699.
To comply with the Internal Revenue Code Sections 6041(a) and 6045(f), and the Debt Collection Improvement Act of 1996, as Codified at 31 U.S.C. 325 and 7701, SSA requires appointed representatives to provide taxpayer identification information as a prerequisite for receiving direct payment. SSA is required to issue IRS Forms INS-1099-NEC, or INS-1099-MISC for each representative who received fees above $600 in a calendar year.
Description of Collection
SSA uses Form SSA-1699 to register appointed representatives of claimants before SSA who:
Want to register for direct payment of fees;
Registered for direct payment of fees prior to 10/31/09, but need to update their information;
Registered as appointed representatives on or after 10/31/09, but need to update their information; or
Received a notice from SSA instructing them to complete this form.
By
registering these individuals, SSA: (1) authenticates and authorizes
them to do business with us; (2) allows them
to access our
records for the claimants they represent; (3) facilitates direct
payment of authorized fees to appointed representatives; and (4)
collects the information we need to meet Internal Revenue Service
(IRS) requirements to issue specific IRS forms if we pay an appointed
representative in excess of a specific amount ($600). The
respondents are appointed representatives who need to use Form
SSA-1699 for any of the purposes cited above.
Use of Information Technology to Collect the Information
Respondents can use a fillable PDF format available on the Internet or complete the paper form. They may submit the form to the nearest field office via mail or fax. This collection does not currently have a fully public-facing Internet version, as we prioritized other information collections for full electronic conversions. Given that IT Mod programming is an ongoing, dynamic project, we cannot provide specific timelines for when we will be able to make any particular ICR available via Internet web-based application. We will ultimately convert most existing ICRs to full electronic versions depending on how they fall within our overall IT Mod schema, but this may be unconnected to the PRA approval lifecycle. In the interim, we evaluated this collection for conversion to a submittable PDF and intend to make this conversion within the next 3-6 years. Once we have the submittable PDF ready for implementation, we will submit a Change Request to OMB for prior approval.
Why We Cannot Use Duplicate Information
The nature of the information we collect and the manner in which we collect it precludes duplication. SSA does not use another collection instrument to obtain these data.
Minimizing Burden on Small Respondents
This collection does not significantly affect small businesses or other small entities.
Consequence of Not Collecting Information or Collecting it Less Frequently
If we did not collect this information, SSA would have no means of authenticating representatives; allowing them direct access to beneficiary records; facilitating direct payment of authorized fees to representatives; or issuing the necessary IRS forms. Since we collect the information on an as-needed basis, we cannot collect it less frequently. There are no technical or legal obstacles to burden reduction.
7. 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 August 20, 2021, at
86 FR 46897, and we received no public comments. The 30-day FRN published on November 18, 2021 at 86 FR 64585. If we receive any comments in response to this Notice, we will forward them to OMB. We did not consult with the public in the revision of this form.
Payment or Gifts to 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 Sensitive Questions
The information collection does not contain any questions of a sensitive nature.
Estimates of Public Reporting Burden
Modality of Completion |
Number of Respondents |
Frequency of Response |
Average Burden per Response (minutes) |
Estimated Total Annual Burden (hours) |
Average Theoretical Hourly Cost Amount (dollars)* |
Total Annual Opportunity Cost (dollars)** |
SSA-1699 |
10,382 |
1 |
20 |
3,461 |
$ 73.86* |
$255,629** |
* We based this figure on average Lawyers hourly wages, as reported by Bureau of Labor Statistics data (www.bls.gov/oes/current/oes231011.htm ).
** This figure does not represent actual costs that SSA is imposing on recipients of Social Security payments to complete this application; rather, these are theoretical opportunity costs for the additional time respondents will spend to complete the application. There is no actual charge to respondents to complete the application.
We base our burden estimates on current management information data, which includes data from actual interviews, as well as from years of conducting this information collection. Per our management information data, we believe that the average time in minutes listed in the chart above accurately shows the average burden per response for reading the instructions, gathering the facts, and answering the questions. Based on our current management information data, the current burden information we provided is accurate. The total burden for this ICR is 3,461 burden hours (reflecting SSA management information data), which results in an associated theoretical (not actual) opportunity cost financial burden of $255,629. SSA does not charge respondents to complete our applications.
Annual Cost To Federal Government
The annual cost to the Federal Government is approximately $3,409,178. This estimate accounts for costs from the following areas:
Description of Cost Factor |
Methodology for Estimating Cost |
Cost in Dollars* |
Designing and Printing the Form |
Design Cost + Printing Cost |
$1,500 |
Distributing, Shipping, and Material Costs for the Form |
Distribution + Shipping + Material Cost |
$0* |
SSA Employee (e.g., field office, 800 number, DDS staff) Information Collection and Processing Time |
GS-9 employee x # of responses x processing time |
$3,404,258 |
Full-Time Equivalent Costs |
Out of pocket costs + Other expenses for providing this service |
$0* |
Systems Development, Updating, and Maintenance |
GS-9 employee x man hours for development, updating, maintenance |
3,420 |
Quantifiable IT Costs |
Any additional IT costs |
$0* |
Total |
|
$3,409,178 |
* We have inserted a $0 amount for cost factors that do not apply to this collection.
SSA is unable to break down the costs to the Federal government further than we already have. First, since we work with almost every US citizen, we often do bulk mailings, and cannot track the cost for a single mailing. In addition, it is difficult for us to break down the cost for processing a single form, as field office and State Disability Determination Services staff often help respondents fill out several forms at once, and the time it takes to do so can vary greatly per respondent. As well, because so many employees have a hand in each aspect of our forms, we use an estimated average hourly wage, based on the wage of our average field office employee (GS-9) for these calculations. However, we have calculated these costs as accurately as possible based on the information we collect for creating, updating, and maintaining these information collections.
15. Program Changes or Adjustments to the Information Collection Request
When we last cleared this IC in 2019, the burden was 5,900 hours. However, we are currently reporting a burden of 3,460 hours. This change stems from a decrease in the number of average responses from 17,700 to 10,382. There is no change to the burden time per response. Although the number of responses changed, SSA did not take any actions to cause this change.
16. Plans for Publication Information Collection Results
SSA will not publish the results of the information collection.
17. Displaying the OMB Approval Expiration Date
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.
Exceptions to Certification Statement
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 does not use statistical methods for this information collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Title of Information Collection and Form Number(s) |
| Author | Naomi |
| File Modified | 0000-00-00 |
| File Created | 2021-11-21 |