**OMB 83-1 SUPPORTING STATEMENT**

**[Justification for the Quarterly Cumulative Caseload
Report:]{.underline}**

**[Form RSA-113]{.underline}**

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 13 of the Rehabilitation Act calls for the Commissioner to
submit a full and complete annual report to the President and Congress
within 180 days after a fiscal year on the activities carried out under
the Act. This annual report should include statistical data reflecting
services and activities provided to individuals during the preceding
fiscal year. Form RSA-113 fulfills a major role in helping the
Commissioner comply with the Annual Report requirement by providing
timely data on the overall dimensions of the state vocational
rehabilitation (VR) program.

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 Commissioner will use RSA-113 data for the purposes listed in
response to Question 1. Form RSA-113 data are also used to determine
trends in the acceptance and rehabilitation of applicants for
rehabilitation services. These data have been used for the generation of
outcome measures permitting assessment of state agency productivity. The
outcome measures, in turn, form the basis for monitoring and the timely
delivery of technical assistance to state agencies, when warranted. In
addition, RSA-113 data are employed in the budget development process
and are frequently requested by the Office of Management and Budget
(OMB), the Secretary and Assistant Secretary, and by the Congress and
its staff.

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.

RSA has developed a Management Information System that enables
respondents to enter data for the RSA-113 directly into RSA's database.
Currently many state VR agencies submit their data in this manner. Some
state VR agencies also submit their data by mail, by fax, and/or by
email.

While most respondents have the facility to submit their data
electronically, there are a few respondents that prefer the option of
submitting their data by hard copy.

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.

The information requested on Form RSA-113 represents a portion of
greater caseload detail already available in state rehabilitation
agencies. The agencies, therefore, have only to extract a limited amount
of caseload flow data from their own on-going data collection systems
when preparing Form RSA-113. The Form RSA-113 is the only RSA report
dealing with current and total state agency caseload flows. No similar
information is available from other sources.

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 only. There is no impact
on 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.

RSA-113 data are to be collected quarterly. These data provide current
perspectives and insights into caseload trends in individual state
agencies that permit early detection of questionable and undesirable
trends (e.g., reductions in the number of persons with significant
disabilities entering the caseloads, declines in acceptance rates and
rehabilitation rates, increasing backlogs of eligible individuals who
cannot be served, etc.). Using quarterly RSA-113 data, RSA staff can
perform their oversight functions more knowledgeably in their continuing
contacts with state agencies and provide expeditious technical
assistance, when needed. Without quarterly data, their monitoring and
technical assistance functions will be seriously limited. Further, the
availability of quarterly data permits informed judgments about trends
to be made for use in the budget development and preparation process.

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

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

There are no circumstances that require respondents to report
information 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;**

This collection has been in effect for several years and collects
information that the respondents maintain continuously. There are no
circumstances that require a written response in fewer than 30 days
after receipt.

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

Respondents are required to submit one copy to RSA in Washington, DC.

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

Respondents are not required to retain 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;**

This collection is not a statistical survey.

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

This collection is 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**

The RSA-113 is an aggregated report form of caseloads and does not
identify individual information.

-   **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.**

The RSA-113 report does not require proprietary trade secrets of other
confidential information.

**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.

The Department published a notice in the Federal Register: October 10,
2002 Volume 67, Number 197, Pages 63082-63083. This form has been
unchanged since this notice was published.

As a matter of policy, RSA consults with the Council of State
Administrators of Vocational Rehabilitation (CSAVR) on developments
affecting Form RSA-113. The CSAVR is the umbrella organization
representing all respondents (state VR agencies). The CSAVR Executive
Director is Mr. Carl Suter, telephone number 301-654-8414. The current
President of the CSAVR is Mr. Paul Leather, Director of the New
Hampshire Division of Adult Learning and Rehabilitation, telephone
number 603-271-3471. Representatives of CSAVR participated in
discussions related to Form RSA-113 in the Spring of 2002 and agreed
that the content of the form should not be changed. In addition, CSAVR
holds biannual meetings of its Management Services Committee; data
collections are always an agenda topic at these meetings.

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

There are no payments or gifts to respondents.

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

The RSA-113 is an aggregated report form of caseloads and does not
identify individual information. There are no assurances of
confidentiality provided to respondents.

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.

Data collected on Form RSA-113 is not of a sensitive nature.

**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 be included in Item
    14.**

Estimates of reporting burdens are based on the experience of many years
of caseload data collection as well as discussions with respondent
representatives. Estimates for both reporting and record-keeping
indicate minimal burden because the data called for by Form RSA-113 are
limited in scope and are maintained by respondents for their own needs
and use.

Burden estimates may vary slightly each year with the number of state VR
agencies, the designated respondents. Some states have a separate agency
for the blind and visually impaired, while other states have a single
state agency. The total number of agencies has varied between 80 and 84
over the last decade. Currently 80 agencies are required to respond to
the RSA-113.

Estimated time to edit, collect and submit summary data on RSA-113
Report -- 1 hour Number of respondents -- 80

Number of quarterly collections from each respondent annually -- 4

Total number of responses annually -- 320

Annual cost to respondents: 320 burden hours X \$20/hour = **\$6,400**

**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.**

This collection does not require capital cost, start-up costs,
maintenance costs or the purchase of services for the respondents. The
summary data required is already maintained for the purpose of
maintaining its federal grant. There are no additional costs for this
RSA-113 report.

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.

Annual cost to federal government: 50 hours X \$25/hour = \$3,750

Annual federal computer costs: = [\$ 500]{.underline}

**\$4,250**

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

Burden estimates may vary slightly each year with the number of state VR
agencies, the designated respondents. Some states have a separate agency
for the blind and visually impaired, while other states have a single
state agency. The total number of agencies has varied between 80 and 84
over the last decade. Currently 80 agencies are required to respond to
the RSA-113, a slight downward change in the burden estimate from the
previous submittal occurs because there are two fewer respondents.

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.

RSA-113 data are due 30 days after the first three quarters of the
fiscal year, and 60 days after the fourth quarter, or end of the fiscal
year. By the middle to the end of the succeeding month, reports for all
state rehabilitation agencies will be collected, edited, revised if
necessary, and tabulated. The tabulation comprises eight tables of data
displaying all RSA-113 data for state agencies. The tables contain a
variety of analytical measures and comparisons such as percent
distributions, percent changes from previous year, percent of caseload
composed of significantly disabled persons, acceptance rates and
rehabilitation rates. They are also shown by type of agency
(general/combined and agency for the blind).

Data for the fourth quarter represent annual totals that are published
as \"Caseload Statistics\" on RSA's website early in the succeeding
calendar year. The annual totals are also made available, along with an
accompanying analysis, for the Annual Report to the Congress required by
Section 13 of the Rehabilitation Act.

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.

The expiration date for OMB approval will be displayed.

**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.