SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

**A. 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.

> Section 102(c) of the Rehabilitation Act of 1973, as amended (Act)
> includes a specific requirement covering the procedures, under which
> an applicant or eligible individual can appeal an adverse action of
> the State vocational rehabilitation (VR) unit/agency. Subsection
> 102(c)(8)(A) of the Act requires the Commissioner of the
> Rehabilitation Services Administration (RSA) to report on appeal
> activities each year when the Annual Report required by Section 13 is
> sent to Congress. Subsection 102(c)(8)(B) of the Act specifies the
> data to be reported.
>
> Section 13 also requires the Commissioner to submit a full and
> complete report of the activities carried out under this Act. The 1998
> amendments specify two additional remedies for adverse actions,
> mediation and civil actions. In 1999, data elements were added to the
> current RSA-722 to collect information on these procedures.

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 collected information will continue to be used by RSA to fulfill
> the reporting mandate cited above. It has also been used to monitor
> whether appeals processes in the State agencies are operating
> according to each agency\'s State Plan.

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

> State VR agencies can electronically transmit RSA-722 data using
> electronic mail on the Internet. RSA is currently developing a
> management information system that agencies will be able to use to
> access the data collection directly through the Internet.

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

> There is no other reporting document required by RSA that covers the
> activities monitored by Form RSA-722. There is no information similar
> to that requested on Form RSA-722 in any existing RSA reporting
> system.

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 burden.

> Respondents are State VR agencies that do not qualify as \"small
> businesses or other small entities.\"

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

> Form RSA-722 is to be reported annually. A less frequent collection
> would put RSA in violation of the reporting mandate referred to in
> paragraph 1 above and shown in the attachment to this document.

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 than 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 is nothing in Form RSA-722 and its instructions that require the
> collection to be conducted in the manner listed above.

8.  If applicable, provide a copy and identify the date and page number
    of publication in the Federal Register of the agency's notice,
    required by 5 CFR 1320.8(d), soliciting comments on the information
    collection prior to submission to OMB. Summarize public comments
    received in response to that notice and describe actions taken by
    the agency in response to these comments. Specifically address
    comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain
their views on the availability of data, frequency of collection, the
clarity of instruction and record keeping, disclosure, or reporting
format (if any), and on the data elements to be recorded, disclosed, or
reported.

Consultation with representatives of those from whom information is to
be obtained or those who must compile records should occur at least once
every 3 years -- even if the collection of information activity is the
same as in prior periods. There may be circumstances that may preclude
consultation in a specific situation. These circumstances should be
explained.

> Revisions to the Form RSA-722 were shared with the Council of State
> Administrators for Vocational Rehabilitation (CSAVR), an organization
> representing the respondents (State VR agencies). The Management
> Services Committee of the CSAVR was given an opportunity to provide
> comments in June of 1999. There was general agreement on this
> collection as submitted. We have not sought comment on Form RSA-722 at
> this time, as no changes have been made to the current version.

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

> There is no decision to provide any payment or gift to respondents.

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

> Since Form RSA-722 contains aggregated data, none of the reported data
> can be used to identify individuals who are applicants or eligible
> individuals of these agencies. Therefore, confidentiality is assured.

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. The 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.

> There are no sensitive questions on Form RSA-722.

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

-   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 desirable. 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.

-   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.

-   Provide estimates of annualized cost to respondents of 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 not be included in
    Item 14.

> The 80 respondents will be asked to submit Form RSA-722 once a year.
> The annual burden is estimated at two hours per agency, or 160 hours
> altogether. One of the hours will be devoted to recording and checking
> the data on Form RSA-722. The other hour will be used to maintain the
> equivalent of a tally throughout the year as the basis or file from
> which to complete Form RSA-722. The number of applicants and eligible
> individuals who file appeals has proven to be rather small.

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: (a) 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 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 or keep records for the government,
    or (4) as part of customary and usual business or private practices.

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 not have been incurred without this collection of
information. Agencies also may aggregate cost estimates from Items 12,
13, and 14 in a single table.

> The record keeping/data reporting activities at the respondent level
> can be accomplished manually without reliance on computerization
> (respondents are, of course, not precluded from using automation). A
> very generous estimate for the hourly cost to respondents of the
> personnel required to maintain the information would be \$20/hour
> including overhead. The total annual cost to respondents would then be
> \$20 X 160 burden hours = \$3,200 per year. The total annual cost to
> the Federal government is estimated to be \$25 X 80 hours, or \$2,000
> per year.

15\. Explain the reasons for any program changes or adjustments reported
in Items 13 or 14 of the OMB Form 83-I.

> This request for extension does not include any program changes or
> adjustments to current OMB inventory.

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.

> Reports are due to RSA Central office no later than 30 days following
> the end of the fiscal year (approximately October 30 of each year).
>
> Data reported will be evaluated and transmitted to the President and
> Congress in the Annual Report prepared by the Commissioner.

17\. If seeking approval to not display the expiration date for OMB
approval of the information collection, explain the reasons that display
would be inappropriate.

> We are not seeking approval to not display the expiration date.

18\. Explain each exception to the certification statement identified in
Item 20, "Certification for Paperwork Reduction Act Submissions," of OMB
Form 83-I.

> There are no exceptions to the certification statement identified in
> Item 20, \"Certification for Paperwork Reduction Act Submission,\" of
> OMB Form 83-I.

**B. Collection of Information Employing Statistical Methods**

The agency should be prepared to justify its decision not to use
statistical methods in any case where such methods might reduce burden
or improve accuracy of results. When Item 17 on Form 83-I is checked
"Yes," the following documentation should be included in the Supporting
Statement to the extent that it applies to the methods proposed:

1.  Describe the potential respondent universe (including a numerical
    estimate) and any sampling or other respondent selection method to
    be used. Data on the number of entities (e.g., establishments, state
    and local government units, households, or persons) in the universe
    covered by the collection and in the corresponding sample are to be
    provided in tabular form for the universe as a whole and for each of
    the strata in the proposed sample. Indicate expected response rates
    for the proposed sample. Indicate expected response rates for the
    collection as a whole. If the collection had been conducted
    previously, include the actual response rate achieved during the
    last collection.

2.  Describe the procedures for the collection of information,
    including:

-   Statistical methodology for stratification and sample selection.

-   Estimation procedure.

-   Degree of accuracy needed for the purpose described in the
    justification.

-   Unusual problems requiring specialized sampling procedures, and

-   Any use of periodic (less frequent than annual) data collection
    cycles to reduce burden.

3.  Describe methods to maximize response and to deal with issues of
    non-response. The accuracy and reliability of information collected
    must be shown to be adequate for intended uses. For collections
    based on sampling, a special justification must be provided for any
    collection that will not yield "reliable" data that can be
    generalized to the universe studied.

4.  Describe any tests of procedures or methods to be undertaken.
    Testing is encouraged as an effective means of refining collections
    of information to minimize burden and improve utility. Tests must be
    approved if they call for answers to identical questions from 10 or
    more respondents. A proposed test or set of tests may be submitted
    for approval separately or in combination with the main collection
    of information.

5.  Provide the name and telephone number of individuals consulted on
    statistical aspects of the design and the name of the agency unit,
    contractor(s), grantee(s), or other persons who will actually
    collect and/or analyze the information for the agency.

> This collection of information does not employ any statistical
> methods.