VA is updating the paperwork it uses to confirm that the dependents on a veteran's compensation award are still there: the spouse is still a spouse, the child is still in school, nobody has divorced or died. The form is VA Form 21-0538, Mandatory Verification of Dependents. On August 13, 2026, VA opened a 60 day public comment window on a revision of this collection, and the notice says the paperwork will take 138,197 veterans a combined 23,033 hours a year, at 10 minutes each.
We went into the OMB record to see where those numbers come from. The short answer: one of them is a head count. The other is that head count multiplied by 10 minutes. Here is what the record shows.
Three filings, one multiplication
Every information collection the federal government runs needs approval from the Office of Management and Budget under the Paperwork Reduction Act, and each approval records how many people respond and how long the agency says it takes them. For VA Form 21-0538 (OMB Control No. 2900-0500), the last three filings look like this:
| Filing | Responses per year | Hours per year | Minutes per response |
|---|---|---|---|
| 2021 approval | 175,400 | 29,233 | 10 |
| 2024 approval | 123,246 | 20,541 | 10 |
| 2026 notice | 138,197 | 23,033 | 10 |
In each filing, the reported annual burden is the number of responses multiplied by the same 10 minute estimate, with the result reported in whole hours. The response count is the only number that moves.
The same sentence explains a decrease and an increase
When the burden fell between the 2021 and 2024 approvals, by 52,154 responses and 8,692 hours, the supporting statement VA filed with OMB explained it in one line: "The burden has decreased since the previous approval due to the estimated number of receivables averaged over the past year." When the burden rose again in the 2026 notice, the explanation is the same phrase pointed the other way: the revision is "due to the burden increase since the previous approval resulting from the estimated number of receivables averaged over the past year."
The count moves in both directions. The 10 minutes stays put.
VA timed its own staff. The veteran's side is a fixed number.
The supporting statement behind the current approval states the veteran's side flatly: "The estimated completion time for each form is 10 minutes." No timing study. No test group. No split between easy cases and hard ones.
The government's side of the same form got a different standard. The same document budgets 20 minutes of staff time to process each response, split across three pay grades, and says those processing estimates are "based on the actual amount of time employees of each grade level spend to process to completion a claim received on this form." VA measured its employees. The veteran's number is a constant.
That one number has to cover a veteran checking a box to confirm an unchanged spouse. It also has to cover a veteran collecting school enrollment documentation for a dependent between 18 and 23, or working out the current status of a dependent they no longer live with.
Why the number matters
Burden estimates are not trivia. The Paperwork Reduction Act requires them to be supportable, OMB approves collections based on them, and they set the official price of the public's time. Using VA's own wage figure, the supporting statement values veterans' time on this one form at $611,300.16 a year. Running the collection costs the government another $2,001,323.32 a year, including $21,992.56 in printing, because, as VA told OMB, the form is posted in a fillable format but VBA "does not currently have the technology in place to allow for the complete submission of the form." The paper version goes out on a batch print cycle of roughly every eight years.
And the last time this collection went through review, the OMB record reports that no public comments were received at either the 60 day or the 30 day stage.
What we asked VA to do
The current comment window closes October 13, 2026. Our comment asks VA for four things: determine which verifications can be resolved from records the government already holds before asking the veteran to respond, the way VA replaced annual pension income reports with SSA and IRS data matching in 2012 (income verification is not the same as dependent status verification, but the precedent shows VA has replaced recurring self reporting when reliable records could do part of the work); support the 10 minute estimate with the same measurement discipline VA applies to its own staff processing time; make the purpose, deadline, and consequences of the request immediately clear on the form itself; and complete the electronic submission capability it told OMB it lacked, prepopulated with the dependents already on the award. A prepopulated digital option could reduce both respondent burden and VA processing costs.
Nothing about the form or the verification requirement changes while the notice is pending. A veteran who receives a 21-0538 today responds the same way as before.
Follow the docket
The record is public: the Federal Register notice, the OMB approval history for control number 2900-0500, and the supporting statement and burden tables. Anyone can submit a comment before October 13, 2026. We track every open VA comment window on our rule changes page.