Supporting Statement 8-26-25

Supporting Statement 8-26-25.docx

APPLICATION FOR VETERANS AFFAIRS LIFE INSURANCE (VALife) (VA Form 29-10277)

OMB: 2900-0906

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SUPPORTING STATEMENT – PART A

VA FORM 29-10277

APPLICATION FOR VETERANS AFFAIRS LIFE INSURANCE (VALife)

2900-0906



Summary of Changes:


  • This ICR is being submitted as an “Extension” of a currently approved collection.

  • The changes made to the VA Form 29-10277 do not affect the burden for this collection.

  • Title: Application For Veterans Affairs Life Insurance (VALife).

  • 1 comment received during the comment period.



  1. Need for the Information Collection


This form is used by authorized agents (POA, Guardian, or VA Fiduciary) to apply on behalf of incompetent Veterans for Veterans Affairs Life Insurance (VALife) and to designate a beneficiary. The information is required by law, 38 USC, Section 1922.


  1. Use of the Information


The data collected on this form is used by Department of Veterans Affairs (VA) to determine the Veteran’s eligibility for VA Life Insurance (VALife) and to obtain required information from applicants for VALife.


  1. Use of the Information Technology


VA Form 29-10277 is available as a DocuSign form through the Insurance web site. While most VALife applicants will apply through a VALife web application, this form is for authorized agents (POA, Guardian, or VA Fiduciary) to apply on behalf of incompetent Veterans who are unable to apply on their own behalf. Agents applying on behalf of a Veteran will be directed to the DocuSign version of the form to complete and submit through a secure DocuSign portal.


  1. Non-duplication


The information is not contained in any other VA records. Similar information is not available elsewhere.


  1. Burden on Small Businesses


The information does not involve any small businesses.





  1. Less Frequent Collection


These forms are designed for use by agents acting on behalf of incompetent Veterans to apply for VALife and to designate a beneficiary(ies). If we don’t provide this form, then agents won’t be able to apply for VALife coverage on behalf of incompetent Veterans.


  1. Paperwork Reduction Act Guidelines


There are no special circumstances requiring that the collection of information be conducted in a manner inconsistent with the guidelines in 5 CFR Section 1320.6.


  1. Consultation and Public Comments


Part A: PUBLIC NOTICE:

A 60-Day Federal Register Notice (FRN) for the collection published on Monday, June 23, 2025. The 60-Day FRN citation is 90 FRN 26681.


1 comment received during the comment period. VA is preparing a response.


A 30-Day Federal Register Notice for the collection published on Tuesday, August 26, 2025. The 30-Day FRN citation is 90 FRN 41634.


Part B: CONSULTATION:


No additional consultation apart from soliciting public comments through the Federal Register was conducted for this submission.


  1. Gifts or Payment


No payments or gifts are being offered to respondents as an incentive to participate in the collection.


  1. Confidentiality


The information collection conforms to the Privacy Act of 1974 and is subject to the conditions of disclosure contained therein. The records are maintained in the system identified as 36VA29 Veterans and Uniformed Services Personnel Program of U.S. Government Life Insurance – VA” as contained in the Privacy Act Issuances, 2011 Compilation.


  1. Sensitive Questions


There are no questions of a sensitive nature.





  1. Respondent Burden and its Labor Costs


    1. Number of Respondents: 25,000

    2. Frequency of Response: On occasion

    3. Annual Burden Hours: 8,333 hours

    4. Estimated Completion Time: 10 minutes

    5. VA cannot make further assumptions about the population of respondents because of the variability of factors such as the educational background and wage potential of respondents. Therefore, VBA used general wage data to estimate the respondents’ costs associated with completing the information collection.


The Bureau of Labor Statistics (B:S) gathers information on full-time wage and salary workers. According to the latest available BLS data, the mean weakly earnings of full-time wage and salary workers are $1,306.40. Assuming a forty (40) hour work week, the mean hourly wage is $32.66 based on the BLS wage code – “00-0000 All Occupations.” This information was taken from the following website: (https://www.bls.gov/oes/current/oes_nat.htm, May 2024). 


Legally, respondents may not pay a person or business for assistance in completing the information collection. Therefore, there are no expected overhead costs for completing the information collection.  VBA estimates the total cost to all respondents to be $272,156 (8,333 burden hours x $32.66 per hour).


  1. Respondent Costs Other Than Burden Hour Costs


This submission does not involve any record keeping costs.


  1. Costs to the Federal Government


Grade

Step

Burden Time

Fraction of Hour

Hourly Rate

Cost Per Response

Total Responses

Total

9

3

10

0.17

$26.68

$4.54

   25,000

$113,500.00

Overhead at 100% Salary

$113,500.00

5

3

2

0.03

$17.61

$0.53

   25,000

$13,250.00

Overhead at 100% Salary

$13,250.00

4

3

2

0.03

$15.74

$0.47

25,000

$11,750.00

Overhead at 100% Salary

$11,750.00

 


Processing / Analyzing Costs

$277,000.00

Printing and Production Cost

$54.00

Total Cost to Government

$277,054.00


Overhead costs are 100% of salary and are the same as the wage listed above and the amounts are included in the total.


Printing and production costs approximates the cost of printing this information collection per year. (Processing/Analyzing Cost total divided by $54).


Note: The hourly wage information above is based on the hourly 2025 General Schedule (Base) Pay (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/25Tables/html/GS_h.aspx).  This rate does not include any locality adjustment as applicable.


The processing time estimates above are based on the actual amount of time employees of each grade level spend to process to completion a claim received on this form. The within-grade step (3) of each employee represents the average experience of employees within each grade.


  1. Reason for Change in Burden


There is no change in respondent burden.


  1. Publication of Results


The information is collected for insurance purposes only and there are no plans for publication.


  1. 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.


  1. Exceptions to “Certification for Paperwork Reduction Submissions”


We are not requesting any exemptions to the provisions stated in 5 CFR 1320.9.

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