SUPPORTING STATEMENT A
Committal Services, Memorial Services, and Funeral Honors
(Certification
Requirements for Funeral Honors Providers)
OMB Control Number:
2900-0865
Summary of Changes from Previously Approved Collection
Title of the collection: Certification Requirements for Funeral Honors Providers
VA is making a small revision to the form to explicitly acknowledge 38 CFR 38.619.
Changes in burden: The burden has decreased since the previous approval due to a decrease in the number of respondents and responses. The cost to the Federal Government decreased due to the annual responses and printing cost declining since the previous approval.
NCA received one comment from the public.
Need for the Information Collection
The Department of Veterans Affairs (VA) requires this information to ensure that military funeral honors (“funeral honors”) activities performed on VA property maintain the honor and dignity of the national cemetery and do not negatively impact the safety of cemetery visitors. This collection is authorized by 38 U.S.C. 2402, 38 U.S.C. 2404, and 38 CFR 38.619. The regulatory requirement to complete the certification form applies to all funeral honors providers, including DoD-authorized details.
Use of the Information
VA is responsible for the safety of cemetery visitors and maintaining the honor and dignity of VA national cemeteries. Consequently, VA proposes certain requirements regarding conduct in the national cemeteries with which all funeral honors providers will certify their compliance. Funeral honors providers would be required to designate and provide contact information for a representative of their organization accountable for funeral honors activities. The designation of a funeral honors provider’s single point of contact would facilitate VA’s resource planning and cemetery administration and ensure that cemetery staff can quickly communicate information to, or obtain information from, an accountable representative from the organization.
All funeral honors providers be required to certify compliance with VA security, safety, and law enforcement regulations, published at 38 CFR 1.218, that protect cemetery visitors and employees. This certification raises awareness of VA standards and increases the accountability of these organizations performing activities on VA property. VA requires certification that equipment used by all funeral honors providers during a committal or memorial service be maintained and operated in a safe manner consistent with relevant VA policies and regulations, and if applicable, Department of Defense (DoD) policy.
In addition, all funeral honors providers would be required to certify that they will not solicit or accept donations on VA property, except as authorized under 38 CFR 1.218(a)(8). Funeral honors providers, like all members of the public, are prohibited from soliciting contributions, commercial solicitation, vending of all kinds, displaying, or distributing commercial advertising, or collecting private debts in or on VA property. Restricting solicitation helps maintain the dignity and solemnity of the national cemeteries and protects families from disturbances.
In addition to the requirements above, VA would require non-DoD funeral honors providers certify that they are conducting activities on federal property as an independent entity, not as an agent or employee of VA, unless they are registered as a VA volunteer. This certification is to ensure that non-DoD funeral honors providers understand that they may be liable for any injuries or damages that could occur while providing funeral honors on VA-property. Similarly, non-DoD funeral honors providers are required to certify that its members have completed training on assigned funeral honors tasks and the safe use of equipment. Funeral honors providers’ equipment and activities can cause harm to the user as well as the public, so it is necessary to require the training and safe use certification for anyone who uses such equipment or performs such tasks.
VA requires that non-DoD funeral honors providers certify that they will provide funeral honors services in accordance with the agreement between the provider and the personal representative. This certification is to ensure deference to the wishes of the personal representative in planning the content of a committal or memorial service.
NCA does not anticipate any psychological costs associated with this information collection outside of what may be expected and normal during routine form filling and document signing.
The certification from funeral honors providers will consist of a fillable form, that is available for download. The form can be electronically completed and printed but requires a written signature. The form cannot be submitted electronically. The further use of information technology would not the reduce burden.
Non-duplication
The information obtained through this collection is unique and is not already available for use or adaptation from another cleared source.
Burden on Small Businesses
The collection of information does not involve small businesses or entities.
Less Frequent Collection
VA would be unable to ensure the safe conduct of funeral honors activities in a national cemetery without this collection of information. The information is collected as needed and cannot be collected less frequently.
Paperwork Reduction Act Guidelines
There are no special circumstances that would cause this information collection to be conducted more often than quarterly.
Consultation and Public Comments
Part A: PUBLIC NOTICE
A 60-Day Federal Register Notice (FRN) for the collection published on Wednesday, April 9, 2025. The 60-Day FRN citation is 90 FRN 15298.
One comment was received during the 60-Day Comment Period.
A 30-Day Federal Register Notice for the collection published on Friday, June 13, 2025. The 30-Day FRN citation is 90 FRN 25119.
Part B: CONSULTATION
No additional consultation apart from soliciting public comments through the Federal Register was conducted for this submission.
Gifts or Payment
No payments or gifts to respondents will be made under this collection of information.
Confidentiality
All respondents will be informed that if the submitted material and information falls within the purview of the Privacy Act of 1974, it will be safeguarded in accordance with the applicable authorities.
Sensitive Questions
There are no questions of a sensitive nature.
Respondent Burden and its Labor Costs
Part A: ESTIMATION OF RESPONDENT BURDEN
Collection Instrument:
Funeral Honors providers Certification Form, VA Form 40-10190
Number of Respondents: 303 Respondents
Number of Responses per Respondent: 1
Number of Total Annual Responses: 303 responses
Response Time: 5 minutes1
Respondent Burden Hours: ((303 × 5 minutes) ÷ 60 minutes) = 25 hours
Total Submission Burden
Total Number of Respondents: 303 respondents
Total Number of Annual Responses: 303 responses
Total Respondent Burden Hours: 25 hours
The number of responses is 303 responses.
The total respondent time burden (hours) is 25 hours.
Part B: LABOR COST OF RESPONDENT BURDEN
Collection Instrument
Funeral Honors Providers Certification Form, VA Form 40-10190
Number of Total Annual Responses: 303 responses
Response Time: 5 minutes
Respondent Mean Hourly Wage: $31.48
Labor Burden per Response: 5 minutes (0.083) × $31.48 hourly wage = $2.623
Total Labor Burden: 303 × 5 minutes (0.083) × $31.48 = $794.87
Overall Labor Burden
Total Number of Annual Responses: = 303 annual responses
Total Labor Burden: $791.69 total labor burden
The Respondent hourly wage was determined by using the Bureau of Labor Statistics website.
Source: May 2023 Bureau of Labor Statistics, National Occupational Employment and Wage Estimates, Code 00-0000, All Occupations: https://www.bls.gov/oes/2023/may/oes_nat.htm#00-0000
Respondent Costs Other Than Burden Hour Costs
The respondent bears no costs, and this submission does not involve any recordkeeping costs.
Cost to the Federal Government
Part A: LABOR COST TO THE FEDERAL GOVERNMENT:
Collection Instrument
Funeral Honors Providers Certification Form, VA Form 40-10190
Number of Total Annual Responses: 303 responses
Processing Time per Response: 0.017 hours
Hourly Wage2 of Worker(s) Processing Responses: $20.45
Cost to Process Each Response 0.017 hours × $20.45 wage = $0.34 cost to process
Total Cost to Process Responses 303 responses × $0.34 cost = $103.27
VA estimates that submissions will be processed by a GS 7 Step 1. The hourly wage in item 1.c. above is taken from the 2025 General Schedule (GS) Locality Pay Tables published by the U.S. Office of Personnel Management and can be found here: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/25Tables/html/GS_h.aspx
Overall Labor Burden to the Federal Government
Total Number of Annual Responses: 303 annual responses
Total Labor Burden: $103.27 total labor burden
Part B: OPERATIONAL AND MAINTENANCE COSTS
1) Cost Categories
Equipment: $0
Printing: $15.15
Postage: $0
Software Purchases: $0
Licensing Costs: $0
Other: $0
Total Operational and Maintenance Cost: $0 Equipment Cost + ($0.05 × 303) $15.15 Printing Cost + $0 Postage + $0 Software Purchases + $0 licensing costs + $0 Other = $15.15 total maintenance cost
Part C: TOTAL COST TO THE FEDERAL GOVERNMENT
Total Labor Cost to the Federal Government: $103.27 total labor cost
Total Operational and Maintenance Costs: $15.15
Total Cost to the Federal Government: $103.27 + $15.15 = $118
Reasons for Change in Burden
NCA adjusted the burden estimates (such as the number of responses, mean hourly wage, total cost to respondents, hourly wage for cemetery administrative staff, and total cost to the Federal government) since the previously submitted information collection. For example, NCA adjusted the average hourly pay for 1 cemetery administrative staff GS-7 federal employee to reflect current general schedule pay rates set by the Office of Personnel Management (OPM).
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 Act Submissions
We are not requesting any exemptions to the provisions stated in 5 CFR 1320.9.
1 0.083333 hours = 5 minutes ÷ 60 minutes.
2 Grade 7 Step 1 hourly wage = $20.45. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/25Tables/html/GS_h.aspx.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 2025-06-15 |