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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX

Revised XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

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 hard 

copy of the appropriate section of each statute and regulation mandating or authorizing 

the collection of information, or you may provide a valid URL link or paste the 

applicable section. Please limit pasted text to no longer than 3 pages. Specify the review 

type of the collection (new, revision, extension, reinstatement with change, reinstatement 

without change). If revised, briefly specify the changes. If a rulemaking is involved, 

make note of the sections or changed sections, if applicable.

Pursuant to Section 106 of the Rehabilitation Act of 1973, as amended by the Workforce 

Innovation and Opportunity Act (WIOA), RSA is required to evaluate the performance of 

state vocational rehabilitation (VR) agencies on established standards and indicators. RSA is 

seeking a one year extension of this information collection as changes in statute stemming 

from WIOA may result in either a modification to the information collection or the 

development of a new collection which accommodates a broad set of provisions of the statute 

regarding performance measures. As agencies who have not met performance levels have 

developed PIPs and are reporting progress updates quarterly it is important that agencies 

continue to implement strategies to reach specified standards of performance and report on 

their achievements to RSA.

Until revised pursuant to changes under WIOA, current federal VR program regulations (34 

CFR 361.82 thru 34 CFR 361.86) establish standards and indicators by which RSA measures 

the performance of the state VR agencies. Evaluation Standard 1 measures employment 

outcomes using six indicators. To achieve successful performance on Standard 1, a VR 

agency must meet or exceed the performance levels for at least four of the six indicators. In 

addition, the agency must meet or exceed the performance level for two of the three primary

indicators. An agency that does not achieve the required minimum performance levels for 

Standard 1 during the fiscal year must submit a program improvement plan (PIP) for RSA 

approval pursuant to 34 CFR 361.89 (a). 

The PIP must contain goals established by the agency, including measurable targets, by 

which it will assess its progress toward meeting the required minimum performance levels, 

along with strategies for the achievement of the goals. In accordance with regulations at 34 

CFR 361.89(c), RSA reviews an agency’s progress toward achieving the goals established in 

the PIP. For this purpose, it requires that an agency report its progress on a quarterly basis. 

Should the agency fail to sustain a satisfactory level of performance on Standard 1 for two 
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consecutive fiscal years, RSA will request that the agency modify the PIP to achieve the 

required level of performance.

As explained in response to Question 3, to promote the consistency of the information 

contained in the PIPs and the ability of RSA to assess a VR agency’s completion of 

performance improvement goals and strategies therein, as well as to ease the burden on the 

VR agencies in the development of and reporting on the PIPs. In FY 2011 RSA developed a 

new form and web based submission and reporting process. Beginning in FY 2012, each of 

the VR agencies evaluated during the year that RSA found to be out of compliance with 

federal performance standards used this form located on the website to submit a PIP for RSA 

approval and reported progress on goals and strategies contained in the PIP on a quarterly 

basis, until the agency met the performance criteria for each indicator of the PIP.

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 PIP must contain goals established by the agency, including measurable targets, by

which it will assess its progress toward meeting the required minimum performance levels, 

along with strategies for the achievement of the goals. In accordance with regulations at 34 

CFR 361.89(c), RSA reviews an agency’s progress toward achieving the goals established in 

the PIP. Using this information for each VR agency required to submit a PIP, RSA will be 

able to track the agency’s progress on goals and strategies to improve performance and 

identify the need for technical assistance to enable it to carry out the strategies.

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 given to using technology to reduce burden.

Previously, RSA did not use a web-based system for the submission of the PIPs and the 

reporting of progress, though it did provide a Word format template that the agencies which

did not meet Standard 1 could (but were not required to) use to develop their PIPs. Since FY 

2011, VR agencies report their progress toward the achievement of the goals contained in the 

PIPs on a quarterly basis using a web based system. The use of a consistent form and webbased submission process allows the VR agencies to develop and report progress on the PIPs 

in a more efficient and timely manner, thus reducing the reporting burden they now 

experience.

4. Describe efforts to identify duplication. Show specifically why any similar information 

already available cannot be used or modified for use for the purposes described in Item 2

above.

An agency that does not achieve the required minimum performance levels for Standard 1 

during the fiscal year must submit a PIP for RSA approval pursuant to 34 CFR 361.89 (a). 
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The PIP must contain goals established by the agency, including measurable targets, by

which it will assess its progress toward meeting the required minimum performance levels, 

along with strategies for the achievement of the goals. No similar information is available to 

RSA through other information collections.

5. If the collection of information impacts small businesses or other small entities, describe 

any methods used to minimize burden. A small entity may be (1) a small business which 

is deemed to be one that is independently owned and operated and that is not dominant in 

its field of operation; (2) a small organization that is any not-for-profit enterprise that is 

independently owned and operated and is not dominant in its field; or (3) a small 

government jurisdiction, which is a government of a city, county, town, township, school 

district, or special district with a population of less than 50,000.

The collection of information does not impact 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.

In accordance with regulations at 34 CFR 361.89(c), RSA reviews an agency’s progress 

toward achieving the goals established in the PIP. For this purpose, it requires that an agency

report its progress on a quarterly basis. Should the agency fail to sustain a satisfactory level 

of performance on Standard 1 for two consecutive fiscal years, RSA will request that the 

agency modify the PIP to achieve the required level of performance. Because RSA uses the 

information contained in the PIPs in preparing its annual report to the President and 

Congress, current data of agencies on PIPs must be made available each year.

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 that unnecessarily impedes sharing of data with 

other agencies for compatible confidential use; or
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 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 this information collection to be 

conducted in any manner listed above.

8. As applicable, state that the Department has published the 60 and 30 Federal Register 

notices as 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. During FY 2011, RSA engaged VR state agency

representatives in a field testing process. 

During the first phase an electronic version of the PIP was made available to participants 

to enter existing PIPs. RSA solicited information via teleconference to gain input on ease 

of access, user interface, and ideas on improving the user experience. Field testing of the 

quarterly progress updates occurred during July, 2011. 

Public comment on this one-year extension of the PIP form will be obtained through 

responses to notices published in the Federal Register. A 60-and 30-day FRN was 

published with no public comments during the 60-day comment period. 

9. Explain any decision to provide any payment or gift to respondents, other than 

remuneration of contractors or grantees with meaningful justification.

RSA has made 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. If personally identifiable information 

(PII) is being collected, a Privacy Act statement should be included on the instrument. 

Please provide a citation for the Systems of Record Notice and the date a Privacy Impact 

Assessment was completed as indicated on the IC Data Form. A confidentiality statement 

with a legal citation that authorizes the pledge of confidentiality should be provided.

Requests for this information are in accordance with the following ED and OMB 

policies: Privacy Act of 1974, OMB Circular A-108 – Privacy Act Implementation –
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Guidelines and Responsibilities, OMB Circular A-130 Appendix I – Federal Agency

Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, 

OMB M-06-15 – Safeguarding Personally Identifiable Information, OM:6-104 – Privacy

Act of 1974 (Collection, Use and Protection of Personally Identifiable Information). If 

the collection is subject to the Privacy Act, the Privacy Act statement is deemed 

sufficient with respect to confidentiality. If there is no expectation of confidentiality, 

simply state that the Department makes no pledge about the confidentially of the data.

There is no assurance of confidentiality, because the collection instrument does not collect 

individual, personal, or sensitive data.

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.

This report contains no questions of a sensitive nature.

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

should:

 Indicate the number of respondents by affected public type (federal government, 

individuals or households, private sector – businesses or other for-profit, private 

sector – not-for-profit institutions, farms, state, local or tribal governments), 

frequency of response, annual hour burden, and an explanation of how the burden 

was estimated, including identification of burden type: recordkeeping, reporting or 

third party disclosure. All narrative should be included in item 12. 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 the ROCIS IC Burden 

Analysis Table. (The table should at minimum include Respondent types, IC activity, 

Respondent and Responses, Hours/Response, and Total Hours)

 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.
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PIP Development and MIS 

Submission

PIP Quarterly Response and 

MIS Submission

Total Annual 

Burden

Number of 

Respondents

5 5 5

Frequency of 

Response

Initial Quarterly

Total Annual 

Responses

5 15 20

Hours per 

Response

16 3 18

Total Hours 80 45 125

Cost per Hour $35.00 $35.00

Total Cost per 

Response

$560.00 $105.00 $665.00

Total Cost $2,800.00 $525.00 $3,325.00

*The number of agencies developing and reporting on a PIP will vary; however, RSA 

estimates that five VR agencies will be required to develop a PIP each year based on 

historical performance results on Standard 1. These five respondents will then report for 

the remaining three quarters of the year, for a total of 15 quarterly responses. 

RSA has estimated the time required for each respondent to develop the PIP and 

complete the form based on field testing of VR agencies. Based on the results from Phase 

1 of the field test, in which three agencies participated, RSA found that the PIP can be 

developed and submitted into the MIS in an average time of 16 hours. In addition, RSA 

estimates the hourly cost to respondents to be $35.00, and cost per development and 

submission for the PIP to average $560.00 per respondent. RSA further estimates that the 

5 respondents will require a total of 80 hours annually to develop and submit the PIP, for 

a total annual cost of $2,800.00.

Based on experience with this process in past years, RSA estimates that the 5 respondents 

will report progress on the PIP for the three remaining quarters of the fiscal year, for a 

total of 45 responses. RSA has determined that each respondent will require 

approximately 3 hours to complete and submit each quarterly update in the MIS, for a 

total of 15 hours over the three quarters. Again, based on an hourly rate of $35.00, RSA 

calculates that the cost to each respondent per quarterly report to be $105.00, for a total 

annual cost to the 5 respondents over the three quarters of reporting of $525.00.

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.)
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 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 acquiring and maintaining 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. Also, these estimates should 

not include the hourly costs (i.e., the monetization of the hours) captured above in 

Item 12

Total Annualized Capital/Startup Cost:

Total Annual Costs (O&M): 

Total Annualized Costs Requested:

States and territories incur no additional cost burden when submitting the PIP

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.
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PIP review and 

approval

Quarterly progress 

reports review and 

approval

Total Annual Cost 

Annual cost to the federal 

government

7.5 hours x $45/ hour 

= $337.50

11.25 hours x $45/ 

hour = $506.25

18.75 hours/ 

$843.75

Annual Federal computer 

cost

$500

Total cost to Federal 

Government

$1,343.75

 

RSA estimates that one GS-13 staff person will require 1.5 hours to review and approve each 

new PIP submission totaling 7.5 hours of review time (5 x 1.5). RSA estimates that one GS-13 

staff person will require .75 hours to review and approve each quarterly PIP submission; totaling 

11.25 hours (15 x .75). RSA is now using an hourly cost of $45.00 for each hour of review, 

based on an hourly rate of staff responsible for this activity. The annual cost burden for review 

and approval of the PIP and Quarterly Progress reports is estimated to be $1,343.75 and take 

18.75 hours.

15. Explain the reasons for any program changes or adjustments. Generally, adjustments in 

burden result from re-estimating burden and/or from economic phenomenon outside of an 

agency’s control (e.g., correcting a burden estimate or an organic increase in the size of 

the reporting universe). Program changes result from a deliberate action that materially 

changes a collection of information and generally are result of new statute or an agency

action (e.g., changing a form, revising regulations, redefining the respondent universe, 

etc.). Burden changes should be disaggregated by type of change (i.e., adjustment, 

program change due to new statute, and/or program change due to agency discretion), 

type of collection (new, revision, extension, reinstatement with change, reinstatement 

without change) and include totals for changes in burden hours, responses and costs (if 

applicable).

The submission requires no changes to the burden of hours and costs included in the current 

OMB inventory; there are no program changes or adjustments reported.

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.

PIPs are not published information.

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.

RSA is not seeking approval to not display the expiration date.
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18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

The collection of Information does not employ any statistical methods.