Electronic Protective Filing Tool

Forms and Documents

Document Name	Status
Emergency Justification Letter - 0960-NEW (ePFT) (2-28-22).docx Supplementary Document	2022-02-28
SSA Emergency Addendum - 0960-NEW (ePFT) (2-28-22).docx Supplementary Document	2022-02-28
SSA Emergency Supporting Statement - 0960-NEW (ePFT) (2-28-22).docx Supporting Statement A	2022-02-28

IC Document Collections

IC ID	Document Title	Status
251889	ePFT - Respondent Type 3 (ex: Attorney Representatives) Other-Internet and Mobile App Screens	New
251888	ePFT - Respondent Type 2 (ex: Professional Assistors) Other-Internet and Mobile App Screens	New
251887	ePFT - Respondent Type 1 (ex: Potential Applicants) Other-Internet and Mobile App Screens	New

ICR Details

OMB Control No:	ICR Reference No: 202202-0960-008
Status: Received in OIRA	Previous ICR Reference No:
Agency/Subagency: SSA	Agency Tracking No:
Title: Electronic Protective Filing Tool
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 03/16/2022
Date Submitted to OIRA: 02/28/2022

	Requested	Previously Approved
Expiration Date	6 Months From Approved
Responses	42,500	0
Time Burden (Hours)	4,675	0
Cost Burden (Dollars)	0	0

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Abstract: The COVID-19 pandemic limited the public’s access to Social Security Administration (SSA) Field Offices (FOs), requiring SSA to rapidly modernize and improve online services available to the public. Since the beginning of the pandemic, underserved populations who have historically relied on in-office appointments and service decreased their submissions of Supplemental Security Income (SSI) claims. SSA uses the term “People facing barriers” to refer to these vulnerable populations, which include low-income individuals (especially those over age 65), the homeless, people with limited English proficiency, and disabled children. Historically, individuals contact SSA by phone, in person, or by mail to express interest in filing for benefits. Because same-day service to file an application is not always possible or individuals prefer to have an appointment, SSA technicians use eLAS (OMB No. 0960-0822) to set up appointments and record the protective filing date for potential claimants. This process ensures that potential claimants do not miss out on possible benefits due to the lack of same-day service. Protective filing is the precursor to filing an application for benefits. Protective filing refers to the date by which SSA receives an individual’s intent to file for Social Security benefits, Medicare Part A (Health Insurance), or SSI payments, which SSA then uses as the application date provided the individual files an application within a specific amount of time after that date. For instance, if an individual files an application for SSI payments within 60 days of the protective filing date, or an application for Social Security benefits within 6 months of the protective filing date, SSA uses the protective filing date as the application filing date. Thus, it is as if the application was filed on the day the individual contacted SSA to express interest in filing, which often results in SSA processing the application faster for that individual. SSA developed an online tool to allow Internet users to request an appointment to file an application for benefits and to establish a protective filing date with SSA. The electronic protective filing tool will allow individuals to submit information for the appointment request using a computing device, such as a personal computer or handheld (mobile) device instead of calling SSA by phone or visiting an FO. The tool will be available to potential claimants, as well as those individuals assisting them. The respondents are individuals requesting an appointment with an intent to file for Social Security benefits, Medicare Part A (Health Insurance), or SSI payments, or other third-party individuals helping claimants with the filing process.

Emergency Justfication: The Social Security Administration (SSA) is seeking emergency approval from OMB under the Paperwork Reduction Act (PRA) to implement an online tool that enables members of the public to request an appointment to file an application for benefits and establish a protective filing date. Need for Emergency Clearance: Emergency approval of this Information Collection Request (ICR) will enable individuals to express interest in filing for SSI payment and Social Security benefits, while we continue to resolve telephone capacity challenges and begin to reopen our field offices while still protecting the health and safety of the public and our employees. Advocacy groups representing the interests of Social Security claimants and professional organizations from the representative community requested that the agency implement online tools to enable individuals to express interest in filing for SSI without the burden of visiting an office or the delays accompanying a phone or mailed request. This effort also aligns with the recent Executive Order on Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government, and other federal guidance on enabling electronic services. As the agency prepares to reopen to walk-in visitors, we expect many offices will experience a surge in demand for SSI appointments. The new online electronic protective filing tool expands our capacity to serve customers who have Internet access and are able to use our online services, while maximizing in-office appointments for those without access and other people facing barriers. To expand access to the SSI program and ensure we protect individuals at the earliest date possible for benefits while maintaining the health and safety of the public and our employees, SSA needs the new online electronic protective filing tool in place as soon as possible. The length of the standard Paperwork Reduction Act (PRA) process would hinder our ability to increase our service immediately to aid the vulnerable populations that need this service. Therefore, we are requesting emergency clearance with approval to be granted no later than 03/16/2022. We will publish the requisite Federal Register Notice to invite the public to submit comments if they wish to do so. Given the nature of this information collection request (ICR), our OMB desk officer conveyed to us that PRA approval does not depend on resolution of or response to public comments. See our attached Emergency Justification Letter for more information.

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Authorizing Statute(s): None

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	87 FR 11111	02/28/2022
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 3

IC Title	Form No.	Form Name
ePFT - Respondent Type 1 (ex: Potential Applicants)
ePFT - Respondent Type 2 (ex: Professional Assistors)
ePFT - Respondent Type 3 (ex: Attorney Representatives)

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ICR Summary of Burden

	Total Request	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	42,500	0	0	42,500	0	0
Annual Time Burden (Hours)	4,675	0	0	4,675	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: This is a new Internet-based tool that increases the public reporting burden. See the chart above for updated burden figures.

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Annual Cost to Federal Government: $2,895,350

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     Yes

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     Yes

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Yes

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 02/28/2022

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