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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 20 U.S.C. 107a(6)(a) directs the Secretary of Education, through the 

Commissioner of the Rehabilitation Services Administration (RSA), to conduct periodic 

evaluations of the programs authorized under the Randolph-Sheppard Act (the Act). In 

addition, section 107b(4) requires entities designated as the state licensing agency (SLA) 

to “make such reports in such form and containing such information as the Secretary may

from time to time require....” The information to be collected is a necessary component 

of the evaluation process and forms the basis for the RSA annual report section on this 

program and is used in monitoring the implementation of the program by the States.

The Code of Federal Regulations, at 34 CFR 395.8, specifies that vending machine 

income received by the state from federal property managers can be distributed to blind 

vendors in an amount not to exceed the national average income for blind vendors. This 

amount is determined through data collected using Form RSA-15. In addition, the 

collection of information ensures the provision and transparency of activities referenced 

in 34 CFR 395.12 related to disclosure of program and financial information and assists 

with the requirement in 34 CFR 395.11 regarding the provision of training. 

The changes in the instrument primarily relate to clarifying instructions and reformatting 

intended to make the form easier to access and enter data. However, substantive changes 

were made to the following entries. In Section VI – Vendor Training, Number of Sites 

Surveyed, a new line was added as line 1 for the “Number of Sites Surveyed During the 

Reporting Year.” Line 2 was reworded from “Accepted for Vending Facility Site” to 

“Number of Sites Accepted by the SLA” and five subcategories were added: (a) Number 

of Accepted Sites Added to Existing Vending Facilities, (b) Number of Accepted Sites 

Used to Create New Vending Facilities, (c) Number of Accepted Sites Pending 

Assignment to a Blind Vendor, and (d) Number of Accepted Sites Assigned to a Third 

Party. In addition, a new line 5 was added, “Number of Surveyed Sites with a Decision 

Pending.”

In Section VIII – State and Nominee Agency Personnel, subsection A, Agency Personnel, 

we added a subcategory under Line 1 for (a) “Number of Business Consultant/Counselor 

Staff (FTE).” The instructions were modified to indicate that, of the total vending facility

program staff, we are interested in the numbers who are business consultant/counselor 

staff.
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The Department believes the additional burden resulting from the above changes is offset 

by the following reductions in reporting burden. In Section II – Vending Facilities and 

Vendors, subsection A – Number at Beginning of Year, the data entries for “Beginning of 

the year” will be adjusted in the MIS so they are prepopulated with the “Number at End 

of Year” from the prior year’s report for subsections A, D, E, F, G and H. The same 

change is made in section V(1). These changes will eliminate the need for the SLAs to 

separately calculate and enter these figures. Similarly, in subsection E.4 – Facilities on 

Public Property, an automatic edit check was added to the “Number at End of Year” to 

make sure the figures under Line 4 for categories a, b, &c add to the total number at the 

end of the year for Line 4. These changes will reduce burden and improve accuracy.

In Section VIII – State and Nominee Agency Personnel, subsection A, Agency Personnel, 

we eliminated Line 1, “Vending Facility Program Budgeted FTE.” In addition, in 

subsection B, Training, there were separate lines for: (1) “Number Who Received InService Training Related to Blindness, Business Management, or Aspects of the 

Randolph-Sheppard Vending Facility Program” and (2) “Number Who Received 

Training through an External Source Related to Blindness, Business Management, or 

Aspects of the Randolph-Sheppard Vending Facility Program.” We eliminated both of 

these data entries and substituted one entry for “Number Who Received Training Related 

to Blindness, Business Management, or Aspects of the Randolph-Sheppard Vending 

Facility Program.” The SLA will no longer need to artificially divide training categories 

into in-service and external sources.

A detailed list of the changes is included as Appendix A.

 

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 information collected on Form RSA-15 has been utilized in reporting to the 

legislative and executive branches on the status of the Randolph-Sheppard vending 

facility program. The consistent collection of data has allowed RSA to observe trends in 

the program and to make year-to-year comparisons. This report is presently the only 

means of assessing the growth or decline of the program in individual states and 

nationally. 

This data is also used in determining what agencies serving the blind and Federal 

property managers need in terms of technical assistance. In addition, analysis of the 

reported information provides the basis for identifying training needs and assists in 

identifying at risk programs in need of on-site technical assistance or monitoring.

The information is also used to establish the regulatory limit of vending machine income 

that can be distributed to blind vendors. The data helps RSA and the SLA so understand 

the distribution type and profitability of vending facilities throughout the country. Such 

information is useful in providing assistance to SLAs and property managers and in 

monitoring the implementation of the program. 
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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.

In FY 2008, the RSA-15 form was converted from hard copy submission to electronic 

submission via the RSA management information system (MIS) at www.rsa.ed.gov. 

Most states prepare their submissions using a combination of their own management 

information systems and hard copy data. Information is then entered into the RSA MIS, 

which provides multiple automatic calculations previously done manually. In addition, 

the electronic submission includes checks and balances to ensure the correct submission 

of data before the report can be rendered complete. This assists the states in identifying 

errors or flags prior to completing their submissions. While 100 percent of submissions 

should be submitted electronically, reports may still be submitted via electronic mail if 

there are complicating factors. The information is then transferred to the MIS by RSA 

staff responsible for the Randolph-Sheppard program.

4. Describe the 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.

Information on the vending facility program administered through state licensing 

agencies is only collected on Form RSA-15. There is no other source for this information.

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

(Item 5 of OMB Form 83-1), describe any methods used to minimize burden.

The information is not collected from small businesses.

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.

If the data were not collected annually, the Commissioner of RSA could not meet his/her 

statutory reporting requirements. Also, without information collected using this form, it 

would not be possible to provide the national averages necessary for States to distribute 

money to blind vendors in accordance with Federal statutes and regulations. In addition, 

information would not be available to respond to inquiries from Federal government 

entities and program stakeholders. There also would not be available to determine 

problem areas and inform Federal staff who are required to monitor the implementation 

of the Act.

7. Explain any special circumstances that would cause an information collection to 

be conducted in a manner:
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 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 that 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 this information collection to be 

conducted in any 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.

A 60-day and 30-day Federal Register Notice were published inviting public comment.
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RSA formed a workgroup composed of representatives from all of the national consumer 

organizations interested in this program, including the National Association of Blind 

Merchants (NABM), Randolph-Sheppard Vendors of America (RSVA); National 

Council of State Agencies for the Blind (NCSAB) Randolph-Sheppard Subcommittee, a 

State Department for the Blind and Vision Impaired, the National Federation of the 

Blind’s Entrepreneurs Initiative, and three State Licensing Agency managers of Business 

Enterprise Programs. The SLA managers are responsible for collecting the data and 

completing the form. Program staff from RSA’s MIS and data unit also participated on 

the workgroup.

All of the changes in the data collection instruments were suggested and approved by this 

workgroup. The representatives expressed their agreement with the form being approved 

for continued use with the recommended revisions. The workgroup was asked to clarify

instructions, eliminate duplication, and attempt to minimize the burden on state agencies. 

RSA worked closely with the workgroup to assure that the data elements included are 

necessary and meaningful.

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

remuneration of contractors or grantees.

There are no arrangements for gifts.

10. Describe any assurance of confidentiality provided to respondents and the basis 

for the assurance in statute, regulation, or agency policy.

Data is aggregated at the State level and no individual vendor information is provided to 

the Department. Efforts are made to avoid the collection of personal, proprietary, or 

confidential data. Therefore there are no assurances of confidentiality. 

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.

We are not seeking any private information such as that described above.

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 
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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 83-1.

 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.

Fifty-two is the average number of respondents and responses received annually. The 

annual hour burden estimate is 13.5 hours per respondent. The hour burden estimate was 

verified by a telephone survey of four SLAs who confirmed that 13.5 hours continues to 

be a reasonable estimate of the time required for completion of the form within their 

agencies. Only one form is covered by this request.

Number of respondents 52

Frequency of response Annually

Total annual responses 52

Hours per response 13.5

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.

Total hours 702

Cost per hour $22.00

Total cost $15,444 (702 x $22.00)
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 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 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 item is not applicable. No additional or special equipment is needed to respond to 

the data collection. In addition, SLAs do not contract out this data collection.

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 $7,560 

$7,560 = 120 hours x $63 (hourly rate associated with program and senior staff review)

Annual Federal Computer costs $0

Total cost to Federal Government $7,560

The annual cost to the Federal government was increased to reflect the cost-of-living 

increase in the salary of the program specialist and supervisor who will review, analyze

and approve the data. The number of projected hours has been increased to reflect 

planned efforts to increase the analysis and distribution of the data.

15. Explain the reasons for any program changes or adjustments reported in Items 

13 or 14 of the OMB Form 83-1.

The changes in the revised RSA-15 Report of Randolph-Sheppard Vending Facility 

Program form and instructions do not result in additional reporting burden. There are no 

program changes or adjustments in burden. The additions to the form are offset by 

deletions and an increased use of pre-population and automatically calculated entries in 

the form. The annual cost to the Federal government was increased to reflect the cost-ofliving increase in the salary of the program specialist and supervisor who will review, 
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analyze and approve the data. The number of projected hours has been increased to 

reflect planned efforts to increase the analysis and distribution of the data. 

A detailed list of changes is included as Appendix A.

16. For collections of information whose results will be published, outline plans for 

tabulation and publication. Address any complex and 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.

Data will be published on the www.rsa.ed.gov website and may be accessed for ad hoc 

queries. All data must be submitted by the end of the first quarter of the Federal fiscal 

year after which it will be reviewed and approved by the RSA staff responsible for the 

Randolph-Sheppard program. Once this process is completed, the data will be published 

(generally within 120 days). 

The Department plans to increase the analysis and distribution of this data. The 

aggregated data, including an analysis of trends, will be published in an information 

memorandum that will be distributed through the Randolph-Sheppard listserv and

targeted distribution to national organizations involved with the program. RSA also 

plans to conduct a webinar explaining the changes in the data collection instrument.

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.

This item is not applicable.

18. Explain each exception to the certification statement identified in Item 20, 

“Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-1.

Item (c) is not checked because this information collection does not apply to small 

entities. It is submitted by State Licensing Agencies which are the State Vocational 

Rehabilitation agency that serves individuals who are blind.

Item (f) is not checked because there is no specified record retention required by the 

Randolph-Sheppard program. States will abide by their own record retention 

requirements. The individual state reports are retained annually by RSA on the RSA 

website.

Item (i) is not applicable.