OMB 83-1 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.

The basic data comprising the Case Service Report system (RSA-911) are
mandated by the Rehabilitation Act of 1973, as amended (the Act).
Attachment A shows the applicable portions of the Rehabilitation Act
which explicitly or implicitly require the recording and reporting of
specific data elements by state vocational rehabilitation (VR) agencies
to the Rehabilitation Services Administration (RSA).

Section 13 of the Act requires the Commissioner to collect and report
information specified in section 101(a)(10) to the Congress and the
President in the Annual Report. Section 626 requires the same
information to be reported for individuals who received supported
employment services. Data on persons served are needed, too, to satisfy
Section 131 calling for an exchange of data between RSA, the Social
Security Administration (SSA) and the Department of Labor (DOL).

Section 106 requires RSA to define performance indicators and establish
standards, which state VR agencies must achieve to retain program
benefits. A subset of data elements from this reporting instrument are
abstracted, aggregated, and applied according to prescribed formulae to
generate the performance indicators for each state VR agency. The
results of such calculations are then compared to the established
standards to determine agency performance.

Before the end of this Fiscal Year RSA will be awarding a contract to
revise the RSA-911 by adding or revising the data elements collected.
The revisions will improve RSA's ability to monitor and analyze grantee
(VR agencies') performance. In addition, the reporting form's
instructions will also need to be revised to make them more clear and
concise. RSA anticipates having a draft revised RSA-911 in summer 2009,
a final version entering clearance in winter 2009, and clearance
expected in July 2010. Following forms clearance, State agencies will
need time to re-program their data collection systems and conduct
systems testing. RSA may not be able to implement the revised form until
the 2011 reporting year. Data for the 2011 reporting year will be
reported to RSA in November 2012.

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.

In addition to the data the Commissioner must collect and include in the
Annual Report to the President and Congress (Sections 13 and 101(a)(10))
and the data exchange with SSA (Section 131), RSA-911 data support other
Rehabilitation Act responsibilities. Section 14 (a) calls for the
evaluation of Rehabilitation Act programs and an assessment of their
effectiveness in relation to cost. Through the years, many evaluation
studies have utilized RSA-911 data to varying degrees. The Commissioner
must also assure that each Individualized Plan for Employment (IPE)
meets the requirements of law, and, most particularly, that emphasis is
placed on the achievement of a vocational goal (Section 102). RSA‑911
data permit the Commissioner to monitor the degree to which vocational
goals are being achieved. Selected RSA-911 data are used to evaluate the
performance of state VR agencies using the standards and indicators
required by Section 106. In addition, these data are used during both
annual reviews and periodic onsite monitoring of state VR agencies
required by Section 107 in order to examine effectiveness of program
performance. Other important management activities, such as the
provision of technical assistance, program planning, and budget
preparation and development are greatly enhanced through the use of
RSA‑911 data.

The major consequence of the non‑collection of data would be that the
Department of Education and RSA would be operating the vocational
rehabilitation and supported employment programs in violation of the
law. A second consequence would be that RSA would lack indicators of
program impact and effectiveness, making it difficult to account for the
federal dollars allocated for these programs. The data exchange with SSA
could not take place, and insights into the long-term benefits of VR
services would be lost. Further, RSA could not adequately conduct
activities such as program planning, policy formulation, and technical
assistance.

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.

The system, devised in accordance with the Rehabilitation Act, is the
least burdensome one possible, because RSA requires that state VR
agencies provide only a portion of the data they typically collect for
their own purposes. Essentially, the RSA‑911 system is a \"dump\" of
selected state agency data with little additional processing burden on
the agencies. All data are submitted electronically either via email or
by compact disks. Data that are submitted via email must be compressed
and password protected.

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.

Duplication of data available in other reporting systems does not exist.
The RSA‑911 is the only system through which RSA requires data to be
reported for each individual who applied for or received VR services.

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 agencies of state governments that must keep
comprehensive records on individuals who apply for services to better
serve them and to fulfill the service record requirements of the
Rehabilitation Act. This is true even for the smallest VR agencies.
Section 102 defines the contents of the Individualized Plan for
Employment (IPE). State VR agencies, large and small, must also account
to their governments for the expenditure of state funds. The reporting
requirements of the RSA‑911, even without the explicit itemization of
data elements in Section 101(a)(10), involve but a segment of already
existing information that agencies must have at their disposal.
Nevertheless, to make reporting easier for small agencies, we have given
them the option of sending in data electronically via email or by
compact disks.

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.

It is not possible to collect RSA-911 data less frequently because
Section 13 of the Rehabilitation Act requires annual reporting.
Moreover, without this data collection, the Secretary would be
substantially hampered in complying with Section 106 of the Act.

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 are no special circumstances that require the collection to be
> conducted along the lines discussed in the bulleted items 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.

RSA regularly contacts the Council of State Administrators of Vocational
Rehabilitation (CSAVR) on developments affecting the RSA-911 system.
CSAVR is an umbrella organization, headquartered in suburban Washington,
DC, representing the 80 respondents (state VR agencies).

In addition, RSA has given state VR agencies the opportunity to
subscribe to the RSA-911 Listserv. This listserv is a mechanism used by
subscribers to discuss various issues pertaining to the RSA-911 system.
As a result, RSA has received input that has been used to modify,
clarify, or simplify instructions or other reporting requirements.

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

There has been no decision to provide any payment or gift to
respondents, other than remuneration of contractors or grantees.

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

The confidentiality of individual service record data has always been
RSA\'s policy. The only personal identifier in the RSA-911 system, the
Social Security Number, is used for record control purposes (e.g., to
cull out duplicates) and for the RSA‑SSA Data Exchange (Section 131 of
the Rehabilitation Act). For the latter, confidentiality rules apply.
Equally important, Section 13 of the Act reinforces RSA policy by
expressly stating that the Commissioner is to assure that the identity
of each person for whom information is supplied remains confidential.

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.

None of the items referred to in this question appears in the RSA‑911
system. Other items sometimes thought of as sensitive, such as race,
type of disability, and earnings are all required by law.

**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.**

Respondents in the RSA‑911 system are the 80 state VR agencies in the
United States and its territories. In these agencies, an estimated
600,000 individuals will have their service records closed annually. The
burden to submit RSA‑911 data would largely be the time it takes to
transfer already existing agency data to the RSA‑911 format. Because of
these considerations, we estimate that the information collection burden
imposed on a respondent averages 45 hours annually. Therefore, the total
annual burden hours requested is 3,600 (45 hours x 80 agencies).

**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.**

> Annualized Respondent Costs:
>
> Annual Operating Costs
>
> (45 hours x \$20 per hour X 80 agencies) \$ 72,000.00
>
> Estimated Equipment Costs [\$ 20,500.00]{.underline}
>
> Total Annualized Respondent Cost \$ 92,500.00

**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.**

> Annualized Federal Costs:
>
> Operating Personnel \$120,000.00
>
> Annual System Maintenance \$ 5,000.00
>
> Equipment Costs (CPU time) [\$ 5,000.00]{.underline}
>
> Total Annualized Federal Cost \$130,000.00

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

There are no program changes or adjustments associated with this
request.

**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.**

Tabulations are generated to describe personal and program‑related
characteristics by (a) state VR agency and by (b) specific target groups
(e.g., the type of disability, race, gender, etc.). There are 80 state
VR agencies and an unlimited number of target groups by which the data
can be displayed, by type of closure (e.g., with or without an
employment outcome).

Currently two automated programs are available and used by agencies to
monitor data quality. National and target group data, as well as data
derived for ad hoc purposes, are used for the many purposes described
earlier. As needed, the data will provide demographics, relationships
between variables, and program outcomes. Summaries of selected
characteristics for all persons served including those with significant
disabilities are published in the Annual Report.

RSA‑911 data are collected annually and are due 60 days after the fiscal
year of reference (November 30 of each year). All data are carefully
edited for legitimacy of codes, consistency across variables, and
completeness of reporting. In addition, the expected number of service
records for each state VR agency is closely monitored. The utilization
of the automated edit programs has shortened the time needed to produce
a national database.

**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.**

Approval is not being sought to not display the expiration date for OMB
approval of the information collection.

**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 of OMB Form 83-1.

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