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

Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

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.

The Rehabilitation Services Administration (RSA) is requesting approval for an 

extension of a previously approved collection, the 704 Report (1820-0606).

Sections 704(m)(4)(D), 706(d), 721(b)(3) and 725(c) of the Rehabilitation Act of 1992, 

as amended, and the corresponding regulations at 34 CFR parts 364, 365, and 366 require 

centers for independent living (CILs), Statewide Independent Living Councils (SILCs) 

and designated State units (DSUs) to submit an annual performance report (704 Report) 

to the Commissioner of the Rehabilitation Services Administration (RSA) to receive 

funding under the SILS (IL Part B) and CIL (IL Part C) programs. RSA’s approval of 

grantees’ 704 Reports is the major prerequisite for the granting of annual IL Part B and 

IL Part C continuation funding. The Rehabilitation Act is available at the following web 

link: http://rsa.ed.gov/display.cfm?pageid=279. Corresponding regulations are available 

at http://cfr.regstoday.com/34cfr364.aspx, http://cfr.regstoday.com/34cfr365.aspx, and 

http://cfr.regstoday.com/34cfr366.aspx.

As provided in the previous Terms of Clearance, RSA has continued to monitor the 

implementation of the IL program’s Government Performance and Results Act (GPRA) 

performance measures. No implementation issues have arisen, as the accuracy of the 

collected performance data continues to improve as a result of ongoing RSA technical 

assistance to its grantees. RSA is monitoring stakeholder efforts to develop alternative 

performance measures. At this time RSA is not proposing any performance measure 

modifications because suitable alternatives have not yet been developed. Also, 

modifications to the performance measures would not be advisable this year given the 

uncertainties related to the pending reauthorization of the Rehabilitation Act.
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EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX

Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

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.

Part I of the 704 Report is submitted annually by the SILC and DSU in all states 

receiving Part B funds. Part II of the 704 Report is submitted annually by all CILs 

receiving IL Part C funds. The 704 Reports are used by RSA to assess grantees’ 

compliance with title VII of the Act, with sections 364, 365 and 366 of the Code of 

Federal Regulations and with applicable provisions of the Education Department General 

Administrative Regulations (EDGAR). The 704 Report serves as the primary basis for 

RSA’s monitoring activities in fulfillment of its responsibilities under sections 706 and 

722 of the Act. The 704 Report also enables RSA to track performance outcomes and 

efficiency measures of the SILS and CIL programs with respect to the annual and longterm performance targets established in compliance with GPRA. The 704 Report is also 

used by RSA to design CIL and SILC training and technical assistance programs 

authorized by section 721 of the Act. 

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.

RSA has endeavored to make the 704 Report easy for grantees to complete and submit. 

Beginning with the FY 2008 reporting period, grantees have completed and submitted the 

704 Report directly through the RSA Management Information System (MIS). The MIS 

has expanded RSA’s capacity to achieve its program improvement and public 

accountability goals for the IL programs. RSA is using MIS data to improve IL grantees’ 

program performance and accountability. The MIS produces detailed reports about IL 

grantee performance based on each of the 704 Report data elements. RSA analyzes 

individual and/or comparison data for grantees. The analysis allows RSA to identify

grantees that may require monitoring and/technical assistance. RSA uses this information 

during its on-site reviews of CILs and state agencies.

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.

The 704 Report is submitted annually and is a unified collection instrument covering a 

wide range of reporting requirements. It is the only data collection instrument used for 

this purpose.

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

Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

The current 704 Report was significantly simplified and streamlined in 2006. Though the 

instrument is unchanged from 2006, grantees’ actual burden has been reduced through 

RSA’s continual 704 Report training and technical assistance and customer-friendly 

improvements in the RSA MIS.

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.

Federal statute and regulations require the annual collection of this information. If the 

data collection were not conducted, RSA would not be authorized to fund the SILS or 

CIL programs authorized by title VII 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;

None.

 requiring respondents to prepare a written response to a collection of 

information in fewer than 30 days after receipt of it;

None.

 requiring respondents to submit more than an original and two copies of any 

document;

None.

 requiring respondents to retain records, other than health, medical, government 

contract, grant-in-aid, or tax records for more than three years;

None.

 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;

None.

 requiring the use of a statistical data classification that has not been reviewed 

and approved by OMB;

None.

 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

None.

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

Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

None.

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.

N/A

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 current 704 Report was developed and approved after extensive RSA outreach to IL 

stakeholders. RSA conducted a series of meetings and teleconferences involving CIL, 

DSU and SILC representatives as well as other interested parties to ensure that 

stakeholders understood the new performance measures. This outreach effort included 

nine state and regional teleconferences featuring the participation of SILC, CIL and state 

agency representatives, as well as the RSA IL unit supervisor’s participation at plenary

presentations/question & answer sessions at National Council on Independent Living 

(NCIL) board meetings, Association of Programs for Rural Independent Living (APRIL) 

national conference, and the SILC Congress. Participants at the teleconferences and 

conference sessions totaled over 650 people. In addition to these outreach activities, 

RSA convened a workgroup of CIL directors, DSU staff and SILC representatives to 

recommend further improvements in the 704 Report. 

The 704 Report was published in the Federal Register on May 12, 2008 with revisions to 

Subpart II, Section G to conform with the Final Guidance on Maintaining, Collecting, 

and Reporting Racial and Ethnic Data to the U.S. Department of Education. No 

comments were received during the ensuing public comment periods. In November of 

that year, RSA conducted two national 704 Report trainings providing additional 

opportunities for CIL, SILC and DSU representatives to comment on and ask technical 

questions about the 704 Report. The trainings and subsequent RSA technical assistance 

have significantly increased stakeholders’ understanding of the information collection’s 

reporting requirements. The trainings and ongoing technical assistance since then have 

also resulted in steady and significant increases in the completed 704 Reports’ accuracy, 

timeliness and reliability, and corresponding improvements in RSA’s ability to assess IL 

program effectiveness relative to its performance measures. 

No comments were received during the 60 and 30-day public comment periods for the 

preceding 704 Report extension in 2011.
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EDICS Tracking and OMB Number: (XXXX) XXXX-XXXX

Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

Stakeholder familiarity with and acceptance of the current 704 Report are demonstrated 

by the increasing percentage of reports submitted by the December 31 deadline, from 

under 50% in FY 2008 to 80% in FY 2009 to well over 90% in FY 2010 and succeeding 

years. 

RSA has decided to defer 704 Report revisions until the next renewal period, given the 

stakeholder familiarity with and data reliability in the current data collection instrument, 

as well as the uncertainties related to the pending reauthorization of the Rehabilitation 

Act. RSA has already begun organizing the process of eliciting stakeholder input for a 

comprehensive 704 Report revision and testing prior to the next data collection renewal 

period.

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

remuneration of contractors or grantees with meaningful justification.

None.

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 – Guidelines and Responsibilities, OMB Circular A130 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.

None.

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.

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

Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

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.

The 704 Report’s estimated hour burden per respondent each for the Part I (IL Part B) 

and Part II (IL Part C) in 2014 remain unchanged at 35 hours from 2011, because the 

current data collection instrument is identical to the one approved in 2011. 

The total estimated hour burden also remain the same because the number of respondents, 

412, has not changed since the 2011 approval. 

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)

The aggregate total hour burden for 412 Parts I and II 704 Report is estimated at 14,420, 

as follows:

704 Report, Part I

Fifty-six IL Part B grantees will spend an estimated 35 hours completing the 704 Report, 

Part I, for an estimated total of 1,960 hours per year.

704 Report, Part II

Three hundred and fifty-six IL Part C grantees will spend an estimated 35 hours 

completing the 704 Report, Part II, for an estimated total of 12,460 hours per year.

 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.

The cost during the year in which the 704 Report is submitted is estimated to be 14,420 

hours x $25/hour = $360,500. 

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

Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

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:

No additional costs are incurred by respondents other than those specified in #12.

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 average review and approval of a 704 Report takes approximately one half-hour. 

RSA staff reviewing the completed reports is paid at an average rate of $50 per hour. 

The cost of the review and approval process is estimated at 0.5 hour x $50 per hour x 412 

reports = $10,300 annually. No additional operational expenses are expected.

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

Revised: XX/XX/XXXX

RIN Number: XXXX-XXXX (if applicable)

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).

N/A

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.

Upon Office of Management and Budget approval, RSA plans to formally transmit the 

approved 704 Report with instructions to SILCs, DSUs and CILs by September 2014. 

RSA staff will review and approve all corresponding 704 Reports by March 31, 2015. 

(The submission due date is December 31, 2014.) The 704 Report data will be tabulated, 

verified for accuracy and published in the RSA MIS by May 1, 2015. 

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 OMB expiration date will be displayed.

18. Explain each exception to the certification statement identified in the Certification 

of Paperwork Reduction Act.

There are no exceptions to the certification statement.