RI92-022_OMBSupportingStmt_2024_03_21

Supporting Statement for Paperwork Reduction Act Submissions

RI 92-22 – Annuity Supplement Earnings Report

OMB Control Number: 3206-0194

1. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

Form RI 92-22 is used to annually obtain the earned income of Federal Employees Retirement System (FERS) annuitants receiving an annuity supplement. Title 5, U. S. Code, Chapter 84, Section 8421 and 5 CFR 842.504 provide for payment of an annuity supplement to non-disability retirees under FERS who meet the eligibility requirements. The annuity supplement is provided to eligible FERS employees who retire before age 62, approximating the portion of a full career Social Security benefit earned while under FERS and ending at age 62 when Social Security benefits become available. Like Social Security benefits, the annuity supplement is subject to an earnings limitation as specified in 5 USC 8421a. An earnings test based on an earnings-exempt amount established each year by the Social Security Administration (SSA) is required to determine the amount of and continued eligibility for the supplement. 5 CFR 842.505(c) states, “Earnings and estimated earnings for each test year will be furnished by retirees in a form prescribed by OPM.”

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

The information collected using RI 92-22 allows OPM to determine if the earnings from work performed while entitled to the annuity supplement have exceeded the earnings limitation established by SSA. Earnings that exceed the exempt amount reduce the annuity supplement by one dollar for every two dollars the exempt amount is exceeded. However, the reduction never exceeds the amount of the annuity supplement.
The earnings test applies only to the annuity supplement and is not used to reduce the basic FERS annuity. Only those whose annuities exceed the earnings limitation are asked to respond.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

The forms are available in a PDF format on our website: www.opm.gov/forms. Interested parties are able to go online and use the PDF fillable tool or print the form and fill it out by hand. They are then able to submit it back to OPM via mail only.

In OPM’s Congressional Budget Justification and Annual Performance Plan (FY 2025) OPM discusses the imperative to create a more modern retirement experience for Federal employees who earned these benefits over a career serving the American public. Essential to creating an excellent customer experience is digitizing OPM’s currently largely paper-centric process. OPM’s strategy involves creating a more streamlined Federal annuitant experience starting with a digital application that will make it easier for annuitants to apply and speed up the time they get their annuity. OPM projects that this will also reduce the need for annuitants to spend time following up on progress.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

Each RI 92-22 is prepared for the individual respondent who is asked to certify earnings information for the specified year. Duplication is minimized and respondents who did not earn more than the exempt amount are asked not to respond.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize.

Information is not collected from nor has any impact on small businesses or organizations.

6. Describe the consequence to Federal program or policy activities if the collection of information is not conducted, or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

This information collection is required to determine the correct amount of annuity supplements. Less frequent collections would result in incorrect annuity supplement payments. This information collection is consistent with the guidelines in 5 CFR 1320.6.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

•requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

•requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

There are no special circumstances involved in the collection of this information.
This information collection is consistent with the guidelines in 5 CFR 1320.8(b)(3).

8. Federal Register Notice: Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice soliciting comments on the information collection prior to submission to OMB.

On September 6, 2023, a 60 Day Federal Register Notice was published at 88 FR 60991 requesting comments. One comments was received generally supporting the collection saying “I support this collection of information and have myself supplied such information in the past.”

On April 30, 2025, the 30 Day Federal Register Notice was published at 89 FR 34288.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payment or gift is provided to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

This information collection is protected by the Privacy Act of 1974 and OPM regulations (5 CFR 831.106). The routine uses for disclosure appear in the Federal Register for OPM/Central-1 (73 FR 15013, published March 20, 2008), as amended (available at https://www.opm.gov/information-management/privacy-policy/sorn/opm-sorn-central-1-civil-service-retirement-and-insurance-records.pdf)..

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

This information collection does not include questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

12. Provide estimates of the hour burden of the collection of information. The statement

should:

a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desired. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.
c. Provide estimates of annualized cost to respondents for the hour burdens for collections
of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

Approximately 13,000 forms will be processed annually. The form requires approximately 15 minutes for completion. A burden of 3,250 hours is estimated.

Type of Respondent	Collection Name	No. of Respondents	No. of Responses per Respondent	Average Burden per Response (in hours)	Total Annual Burden (in hours)
FERS annuitants receiving an annuity supplement	RI 92-22 (Annuity Supplement Earnings Report)	13,000	1	.25 hours	3,250

13. Provide an estimate of the total annual cost burden to respondents or record keepers

resulting from the collection of information. (Do not include the cost of any hour burden

shown in Items 12 and 14.)

The cost estimate should be split into two components: (1) a total capital and start-up cost
component (annualized over its expected useful life); and (b) a total operation and
maintenance and purchase of services component. The estimates should take into account
costs associated with generating, maintaining, and disclosing or providing the information.
Include descriptions of methods used to estimate major cost factors including system and
technology acquisition, expected useful life of capital equipment, the discount rate(s), and
the time period over which costs will be incurred. Capital and start-up costs include, among
other items, preparations for collecting information such as purchasing computers and
software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

If cost estimates are expected to vary widely, agencies should present ranges of cost
burdens and explain the reasons for the variance. The cost of purchasing or contracting
out information collection services should be a part of this cost burden estimate.
In developing cost burden estimates, agencies may consult with a sample of respondents
(fewer than 10), utilize the 60-day pre-OMB submission public comment process and use
existing economic or regulatory impact analysis associated with the rulemaking containing
the information collection as appropriate.

Generally, estimates should not include purchases of equipment or services, or portions
thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with
requirements not associated with the information collection, (3) for reasons other than to
provide information to keep records for the government, or (4) as part of customary and
usual business or private practices.

Type of Respondent	Form Name	No. of Respondents	Total No. of Responses	Average Burden per Response (in hours)	Hourly Wage Rate	Total Respondent Cost
FERS annuitants receiving an annuity supplement	RI 92-22 (Annuity Supplement Earnings Report)	13,000	1	0.25 (15 minutes)	$23.11	$75,108

The Total Respondent Cost is $75,108. There is no change in the respondent burden.

14. Provide estimates of annualized cost to the Federal Government. Also, provide a description

of the method used to estimate cost, which should include quantification of hours,

operational expenses (such as equipment, overhead, printing and support staff), and any

other expense that would have been incurred without this collection of information.
You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.

The annualized cost to the Federal government is $525,460. This cost is calculated by processing the total forms (13,000) at a rate of $40.42 per form (GS-12, step 5 average hourly rate) for 30 minutes a total of $262,703 plus 100% overhead resulting in a total cost of $525,460 to the government.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of

the OMB Form 83-I. Changes in hour burden, i.e., program changes or adjustments made to

annual reporting and recordkeeping hour and cost burden. A program change is the result

of deliberate Federal government action. All new collections and any subsequent revisions

of existing collections (e.g., the addition or deletion of questions) are recorded as program

changes. An adjustment is a change that is not the result of a deliberate Federal government

action. These changes that result from new estimates or actions not controllable by the

The updates in the hour and cost burden described above are due to the latest statistics provided by government reporting and other resources. OPM therefore considers these updates “adjustments” and not the result of deliberate Federal government action.

16. For collections of information whose results will be published, outline plans for tabulation

and publication. Address any complex analytical techniques that will be used. Provide the

time schedule for the entire project, including beginning and ending dates of the collection

of information, completion of report, publication dates, and other actions.

The results of this information collection are not published.

17. If seeking approval to not display the expiration date for OMB approval of the information

collection, explain reasons that display would be inappropriate.

We seek approval to not display the OMB clearance expiration date on the forms and to communicate version changes to the public via the revision date. The results of this collection are not published.

18. Explain each exception to the certification statement identified in Item 19 “Certification for
Paperwork Reduction Act Submissions,” of OMB Form 83-I.

There are no exceptions to the certification statement.