REHABILITATION SERVICES ADMINISTRATION

ALTERNATIVE FINANCING PROGRAMS/TITLE III of the 

ASSISTIVE TECHNOLOGY ACT OF 1998

Annual Progress Report for the Title III Alternative Financing Program under the 

Assistive Technology Act of 1998

REQUEST FOR OMB APPROVAL

SUPPORTING STATEMENT REQUIRED UNDER

THE PAPERWORK REDUCTION ACT

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 Rehabilitation Services Administration (RSA) of the U.S. Department of Education 

(ED) requests clearance for the renewal of a data collection instrument, Office of 

Management and Budget (OMB) Control Number 1820-0662, to be completed by 

grantees under title III of the Assistive Technology Act of 1998 as in effect prior to the 

amendments of 2004 (Public Law 105-394) (AT Act of 1998).

Title III of the AT Act of 1998 authorized grants to public agencies to support the 

establishment and maintenance of alternative financing programs (AFPs) that feature 

one or more alternative financing mechanisms1to enable individuals with disabilities 

and their family members, guardians, advocates, and authorized representatives to 

purchase assistive technology (AT). AFPs must operate and provide progress reports 

in perpetuity.

Since 2000, grants have been awarded to 33 states to operate AFPs. The information 

collected through this data collection instrument is necessary for these grantees to 

comply with the reporting requirements of title III of the AT Act of 1998 and to satisfy 34 

CFR 75.720, which requires them to submit an annual performance report.

In addition, section 307 of the AT Act of 1998 requires that RSA submit to Congress an 

annual report on the activities conducted under title III. In order to make these possible, 

states must provide annual progress reports to RSA that fulfill the section 307 reporting 

requirements. This data collection instrument has been developed to ensure that states 

report data in a consistent manner in alignment with these requirements.

 

1

See Appendix A for a description of the alternative financing mechanisms.
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.

RSA will use the information collected via this instrument to:

1) Complete the annual report to Congress required by the AT Act of 1998;

2) Meet the Education Department Administrative Regulations (EDGAR) 

requirements; and

3) Comply with reporting requirements under the Government Performance and 

Results Act (GPRA) of 1993 (Public Law 103-62).

Data collected from the grantees will provide a national description of activities funded 

under title III of the AT Act of 1998 to increase the acquisition of AT devices and 

services through alternative financing mechanisms for individuals with disabilities. In 

addition, RSA will use this data to inform its program management, monitoring, and 

technical assistance efforts. States will be able to use the data for internal management 

and program improvement.

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.

A web-based data collection system is currently in place and the proposed renewal to 

the system will be implemented based upon the instrument submitted for review. The 

paper version of the instrument translates directly into a web-based format; throughout 

the document there are numerous references to how certain sections and items are 

used in the electronic system. Upon OMB approval of the paper version, the webbased application for use by the states will be implemented by staff through the RSA 

Management Information System (MIS). Once updated, the system will meet or exceed 

requirements for accessibility of Section 508 of the Rehabilitation Act of 1973, as 

amended (Rehabilitation Act), the Federal Information Security Management Act 

(FISMA), and other applicable statutes and regulations, and industry standards. This 

web-based system allows the title III AFPs to enter and submit their data electronically 

at their convenience on an ongoing basis. Where appropriate, the system automatically 

generates totals and does other automatic calculations, saving time and reducing the 

chance of mathematical errors.

RSA will have immediate access to the information submitted, allowing RSA to identify 

which grantees have submitted their data. This access will allow RSA to generate 

reports, even on partial data, as requested by Congress or others. States will have 

similar access to their data for management purposes.
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.

Data collected on state financing activities in OMB Control Number 1820-0572 is 

duplicative in some cases, because the state financing activities under section 4 of the 

AT Act of 1998, as amended in 2004 (Public Law 108-364) (AT Act of 2004) may 

include AFPs. However, this proposed renewal of OMB 1820-0662 aligns closely with 

the data collection system for section 4 of the AT Act of 2004, which is OMB 1820-0572. 

Many states have incorporated their existing title III AFP into their section 4 programs. 

However, a single data collection instrument cannot capture the entire universe of data, 

or entities that need to report that data, for both title III and section 4. The data 

collection requirements of section 4 and title III are similar but not the same,2therefore it 

is not possible to use one as a proxy for the other because:

 Title III AFPs are funded under a separate authority;

 Title III has its own data collection requirements that differ from those of section 

4; and

 Not all states have both title III and section 4 grants, and both grants do not 

always go to the same agency when a state does have both.

Appendix B contains a side-by-side comparison of the similarities and differences 

between the portions of OMB 1820-0662 and OMB 1820-0572 that apply to alternative 

financing mechanisms.

Otherwise, the activities, and data collected about those activities, are unique to title III 

of the AT Act of 1998 and do not duplicate other data collection efforts.

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

8b of IC Data Part 2), describe any methods used to minimize burden.

This information collection does not involve small businesses and will not have a 

significant impact on substantial numbers of 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.

If this information is not collected, neither RSA nor states can fulfill their reporting 

obligations under title III of the AT Act of 1998. Those obligations are annual, so the 

data collection cannot occur less frequently than annually.

 

2

See Appendix B for a side-by-side comparison of the title III and section 4 requirements related to AFPs.
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

 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 proposed data collection is consistent with guidelines set forth in 5 CFR 1320.5, 

and requires no special circumstances.

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 notice was published Month Day, 2014 on pages - in the Federal Register, Vol 

__ , No. __. The public is invited to submit comments on the renewal of the Annual 

Progress Report for the Title III Alternative Financing Program under the Assistive 

Technology Act of 1998. Interested persons are invited to submit comments on or 

before Month Day, 2014. A 30-day response to comments notice will follow the initial 

60-day Federal Register notice.

The process for developing the current title III data collection instrument began in 

January 2007. The National Information System for Assistive Technology (NISAT), the 

project responsible for AT Act data collection reporting at the time, established a 

workgroup comprised of representatives from AFPs of various types. NISAT was also 

responsible for the development of the instrument for data collection and reporting on 

state financing activities in OMB Number 1820-0572 through a cooperative agreement 

with RSA, as required under section 6(b)(5) of the AT Act of 2004. NISAT facilitated 

several teleconference meetings of the workgroup through December 2007. During 

these meetings, AFPs provided suggestions for the general principles and features of a 

data collection system. RSA staff participated in all meetings. The current OMB 1820-

0662 instrument takes the suggestions of the workgroup into account, as well as the 

lessons learned from the development of OMB 1820-0572.

The instrument submitted for review is a renewal of the current instrument. The RESNA 

Catalyst Project, the technical assistance grant funded under section 6 of the AT Act of 

2004 conducted several workgroup conference calls throughout fiscal year 2013 to 

discuss potential updates or changes to the 1820-0662 IC with AFP representatives. 

AFPs, RESNA, and RSA agreed that the current instrument captures the data reporting 

requirements of the states funded under title III of the AT Act of 1998 for those AFPs 

that do not report state financing data in the 1820-0572 IC. However, the group 

recommended the use of the anecdotes section in the current instrument to provide 

additional information about the programs, such as leveraged funding or other relevant 

activities, to better describe the individual state stories of the AFPs.

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

remuneration of contractors or grantees.

No payments or gifts are provided to respondents.

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

the assurance in statute, regulation, or agency policy.
Confidentiality for individual consumers receiving services from a title III AFP is assured, 

because the states will not report information that identifies individual consumers. 

States will provide anecdotes about the effect of their programs on individual 

consumers, but states are instructed to write anecdotes in a manner that ensures their 

anonymity. All other data provided is reported in the aggregate. 

The web-based system to be developed will not allow public access to the reporting 

instrument for data entry, and states will have access to their data only, so they will not 

be able to see or manipulate data of other states. Individual reports will be kept 

confidential until they have been finalized by the state and accepted by RSA.

Once a report has been finalized by the state and accepted by RSA, access to the data 

will be available to the public via the Internet, though the public will be able to view and 

not alter the data. States will be advised that their data will be available to the public in 

this manner. 

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.

No questions included in the data collection instrument are considered sensitive.

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 16 of IC 

Data Part 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 be included in 

Item 14.

Up to thirty-three grantees will have the ability to report using the web-based data 

collection system. It is estimated the average amount of time required to complete all

responses is approximately 27 hours. This equals 891 total hours for the 33 AFPs. The 

estimated response burden includes time to review the instructions, gather existing 

data, and complete and review the data entry. This estimate is derived from knowing 

the burden of the previous version.

Assuming an average hourly cost of $30 per hour for staff members who complete the 

instrument, the cost burden for individual grantees is estimated to be $810, and the total 

cost for the 33 grantees is estimated to be $26,730. The average hourly cost of $30 

represents the average, fully-loaded wage rate, i.e., includes pre-tax cash wages, fringe 

benefits and overhead support, for several different classes of labor ranging from 

clerical to managerial labor, and accounts for the amount of time different types of 

grantee personnel (i.e., clerical, technical, professional, and managerial) are expected 

to expend.

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 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.

Total Annualized Capital/Startup Cost : $ .00

Total Annual Costs (O&M) : .00

____________________

Total Annualized Costs Requested : $ .00

There are no capital costs, equipment purchases, or purchased services needed to 

collect this data.

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.

RSA also employs one management and program analyst at the GS-14 level and one 

program specialist at the GS-13 level with the responsibility for the administration of 

grants funded under the AT Act, including this data collection. These employees are 

housed in the Service Programs Unit, which is overseen by a Unit Chief and Director. 

RSA staff dedicates a small percentage of their time to this data collection, creating an 

additional cost. RSA also employs an information technology specialist in the Program 

Support Staff Unit, who built the current AFP data collection system in the MIS and will 

update the system upon OMB approval of this instrument. The development and limited 

maintenance of this instrument in the MIS is an additional cost associated with the AFP 

data collection. The estimated annualized cost to the Federal government for RSA staff 

time is $20,400.

15. Explain the reasons for any program changes or adjustments to #16f of the IC Data 

Part 1 Form.

The proposed AFP IC package is a renewal and is consistent with the IC Data Part 1 

Form. The data collection instrument was substantially revised during the past two 

renewals and burden levels were significantly reduced. We believe the existing form 

achieves the correct burden balance and are not requesting any changes. RSA met 

several times in FY 2013 with an AFP work group to discuss potential revisions to the 

current OMB-approved 1820-0662 and the consensus of the work group resulted in a 

decision to request a renewal of the IC without changes. Below is a summary of the 

changes and reductions in burden to the expiring 1820-0662 instruments during the 

past six years.

Six years ago, the renewal and revision of OMB 1820-0662 contained significant 

changes that resulted in a decrease in reporting burden. The estimated reporting 
burden for that expiring instrument was 34.5 hours per grantee, for a total of 1,067 

hours.3 The estimated reporting burden for the previous OMB 1820-0662 reduced the 

reporting burden to approximately 29.5 hours per state for a total of 974 hours for the 33 

states. Further, the estimated reporting burden for the current, revised OMB 1820-0662 

is approximately 27 hours per state for a total of 891 hours for the 33 states, a net 

reduction of 83 reporting hours. The proposed version is a renewal of the current 

version.

The OMB 1820-0662 version that expired June 30, 2008 was developed by the National 

Institute on Disability and Rehabilitation Research (NIDRR) using a participatory action 

research approach. NIDRR based estimates for the number of initial applicant surveys 

on FY 2003 data and prior rates of completion for the individual follow-up surveys for 

approved and denied applicants. RSA used these previous estimates as a starting 

point because use of the system over the years proved them to be fairly accurate. 

Burden was deducted from this estimate based on the following:

First, title III AFPs switched from reporting data on each individual loan application to 

reporting aggregate, year-end data. A title III grantee no longer reports an initial 

applicant survey for each loan applicant. The burden estimate of the data collection 

instrument developed by NIDRR, which expired in 2008, includes 0.50 hours to 

complete each initial applicant survey. The current instrument does not include this 

survey. Instead, grantees only enter the information in aggregate at the conclusion of 

the reporting cycle, and most of this information applies only to those who receive loans 

as opposed to all who apply for loans. As a result, less information is required about 

fewer individuals.

Second, the current data collection instrument no longer requires follow-up surveys. 

AFPs no longer submit either a follow-up approval survey or a follow-up denial survey 

for each loan applicant. The previous instrument estimates 0.50 hours to complete 

each survey for approved applicants and 0.33 hours to complete each survey for denied 

applicants. Instead, AFPs have the opportunity to submit an anecdote of an individual 

obtaining a loan to purchase needed AT for use at home, in the community, or at the 

workplace. 

Another significant reduction in reporting burden to the previous instrument was the 

elimination of an additional annual survey that AFP grantees submitted to the 

Rehabilitation Engineering and Assistive Technology Society of North America 

(RESNA). Previously, AFP grantees were required to submit a separate data collection 

survey on top of the four surveys entered into the web-based data collection system 

housed at the University of Illinois at Chicago (UIC) under a subcontract with RESNA. 

The current instrument no longer requires grantees to submit a survey directly to 

RESNA in addition to the four surveys into the UIC web-based system. Grantees also 

update program changes directly into the revised data collection instrument in the MIS 

housed at RSA rather than submitting them to RESNA as was past practice.

 

3 When 1820-0662 was first approved, only 31 state grantees existed. There now are 33 states.
The current instrument eliminated an entire section of optional information that is not 

required for submission by the title III AFP grantees, further reducing the burden from 

approximately 29.5 hours to 27 hours per state. Section C. AFP Optional Data 

Elements, which are not title III annual reporting requirements for the AFP grantees, 

was removal from the current instrument. The information collected in this optional data 

section includes: 1. Types of AFP (partnership loans or revolving loans), 2. Interest 

Rates (lowest and highest interest rates established by policy), 3. Loan Amounts (lowest 

and highest loan amounts established by policy), 4. Repayment Terms (shortest and 

longest repayment terms established by policy), and 5. Loan Guarantee Requirement, 

the percentage of the loans that must be repaid by the AFP to the lender in case of 

default as established by the agreement with the lender. The data reported under C. 

AFP Optional Data Elements of the current instrument is not required by title III of the 

AT Act of 1998, therefore grantees did not report this information uniformly across 

programs. If every grantee doesn’t report in this section, then the data can’t be reported 

in aggregate form. In fact, the data in this section is available in the annual report to 

Congress on the AT Act, as this optional section contains information about program 

features and descriptions that may or may not change on an annual basis. Since there 

is no utility to the annual reporting of this optional information, the decision was made to 

further reduce the burden to all grantees by eliminating this section from the current 

instrument in the MIS.

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.

Because states provided an assurance that the alternative financing program will 

continue on a permanent basis, there is no end date for the reporting requirements. 

States will remain on a set data collection reporting cycle, with the period beginning 

October 1 and ending September 30 each year. The due date for grantees to submit 

data to RSA is December 31 of each year.

The aggregate, national data derived from this collection will be used to create an 

annual report to Congress that is due December 31 in the year following the data 

collection reporting cycle.

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 will display the expiration date for OMB approval of the information collection. See 

the Paperwork Burden Statement document.
18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

There are no exceptions to the certification statement.