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View ICR - OIRA Conclusion

OMB Control No: 0960-0809	ICR Reference No: 201704-0960-007
Status: Historical Active	Previous ICR Reference No:
Agency/Subagency: SSA	Agency Tracking No:
Title: Promoting Opportunity Project (POD)
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR: No
Type of Review Request: Regular
OIRA Conclusion Action: Approved with change	Conclusion Date: 11/09/2017
	Date Received in OIRA: 08/03/2017
Terms of Clearance: In accordance with 5 CFR 1320, the information collection approves this collection for three years. Office of Management and Budget (OMB) concurs with the Social Security Administration (SSA) that the information would be useful in providing insights and the conclusions drawn from the evaluation represent results only for the voluntary population of this study. Office of Management and Budget also recognizes that the data collection for this study will be beyond the 3-year approval for this ICR. OMB encourages SSA will engage in on-going dialogue about the implementation of the study. When SSA re-submits an ICR to continue to collect the data to complete the study, SSA is required to provide OMB information on the quality of the data already collected such as participation rate, and item non-response rate in a briefing. Once the study is completed at the end of the 5 year period, the agency should provide the results of the study to OMB.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	11/30/2020	36 Months From Approved
Responses	83,870	0	0
Time Burden (Hours)	20,699	0	0
Cost Burden (Dollars)	0	0	0

Abstract: Section 823 of the Bipartisan Budget Act of 2015 requires SSA to carry out the Promoting Opportunity Demonstration (POD) to test a new benefit offset formula for Social Security Disability Insurance (SSDI) beneficiaries. Therefore, SSA is undertaking POD, a demonstration to evaluate the affect the new policy will have on SSDI beneficiaries and their families in several critical areas: (1) employment, (2) benefits, (3) earnings, and (4) income (earnings plus benefits). Under current law, Social Security beneficiaries lose their SSDI benefit if they have earnings or work activity above the threshold of Substantial Gainful Activity (SGA). The POD evaluation will draw on previous lessons from related work incentive experiences, especially SSA’s Benefit Offset National Demonstration (BOND), 0960-0785, which tested a different offset formula. POD tests a different policy than BOND in two important ways: (1) A lower threshold at which point the offset is applied – increasing the likelihood of reducing benefit expenditures relative to current law expenditures; and (2) A more immediate adjustment to the benefits – to increase the salience and clarity of the offset policy for beneficiaries. The POD will test a benefit offset that will reduce benefits by $1 for every $2 in participants’ earnings above the POD threshold, gradually reducing benefits as earnings increase. The POD threshold will equal the greater of (1) an inflation adjusted trial work period level ($840 in 2017); or (2) the amount of the participant’s itemized impairment-related work expenses up to SGA. The new rules we will test in POD also simplify work incentives and we intend them to promote employment and reduce dependency on benefits. The design for POD will include implementation and evaluation activities designed to answer seven central research questions: • What are the impacts of the two POD benefit designs on beneficiaries’ earnings, SSDI benefits, and total earnings and benefit income? • Is POD attractive to beneficiaries? Do they remain engaged over time? • How were the POD offset policies implemented, and what operational, systemic, or contextual factors facilitated or posed challenges to administering the offset? • How successful were POD and SSA in making timely benefit adjustments, and what factors affected timeliness positively or negatively? • How do the impacts of the POD offset policies vary with beneficiary characteristics? • What are the costs and benefits of the POD benefit designs relative to current law, and what are the implications for the SSDI trust fund? • What are the implications of the POD findings for national policy proposals that would include a SSDI benefit offset? The public survey data collections have four components – a process analysis, a participation analysis, an impact analysis, and a cost-benefit analysis. The data collections are the primary source for data to measure the effects the benefit offset on SSDI beneficiaries’ work efforts and earnings. Ultimately, these data will benefit researchers, policy analysts, policy makers, SSA, and the state vocational rehabilitation agencies in a wide range of program areas. There are four targeted outcomes for SSDI beneficiaries under POD: (1) increased employment and earnings; (2) decreased benefits payments; (3) increased total income; and (4) impacts on other related outcomes (for example, health status and quality of life). Additionally, four outcomes of interest for system changes include: (1) reduction in overpayments; (2) enhanced program integrity; (3) stronger culture of self sufficiency; and (4) improved SSDI trust fund balance. Respondents are SSDI beneficiaries, who will provide written consent before agreeing to participate in the study and before we randomly assign them to one of the study treatment groups.

ICR Summary of Burden

	Total Approved	Change Due to Agency Discretion
Annual Number of Responses	83,870	83,870
Annual Time Burden (Hours)	20,699	20,699
Annual Cost Burden (Dollars)	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 new demonstration project increases the public reporting burden. See chart above for updated burden figures.

Annual Cost to Federal Government: $9,487,047

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? Uncollected

Agency Contact: Faye Lipsky 410 965-8783 faye.lipsky@ssa.gov

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