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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Annual Progress Reporting Form for the American Indian Vocational Rehabilitation 

Services Program 1820-0655 

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

information, or 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) of the U.S. Department of Education (ED) 

requests a revision to an information collection for which approval expires on September 30, 

2014. This is a web-based annual reporting form that is completed by grantees funded under the 

American Indian Vocational Rehabilitation Services (AIVRS) program, authorized under Section 

121 of the Rehabilitation Act of 1973, as amended (Public Law 93-112).

The form collects data on grantees’ program activities. RSA staff will use this information to 

meet the requirement for an annual report to Congress in the Rehabilitation Act and the 

Education Department General Administrative Regulations (EDGAR) requirements requiring 

annual progress reports from grantees, as well as to facilitate program planning efforts required 

under the Government Performance and Results Act (GPRA) of 1993 (Public Law 103-62).

This data collection supports: 1) The Rehabilitation Act, which requires AIVRS grantees to 

report on specific identified activities; and 2) EDGAR, which outlines annual reporting 

requirements that must be met by applicants and grantees. The regulatory requirements that 

apply to the RSA grant programs include 34 CFR Parts 75, 77, 80, 81, and 82. Specifically, 34 

CFR 75.590 requires grantees to submit an annual performance report, or, for the last year of a 

project, a final report. RSA will use the form to capture the most current performance and 

financial expenditure information of the grantee, in order to determine substantial progress for 

continuation funding, as required in EDGAR section 75.118.

Additionally, as part of ED’s performance reporting requirements under GPRA, RSA must 

collect information to support: (a) implementation of a comprehensive plan that includes goals 

and objectives for the program, (b) measurement of the program’s progress in meeting its goals 

and objectives, and (c) submission of an annual report on program performance, including plans 

for program improvement, as appropriate.
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The revised information collection for which RSA is requesting approval is designed to fulfill all 

of the above requirements and needs for the AIVRS program. 

Proposed changes to the existing form, which will improve user friendliness and the clarity and 

accuracy of data reported, are not of a substantial manner nor significantly different from the 

original collection, but are proposed to provide clarity and consistency. In many areas, the data 

element language has been modified using direct language instead of passive terminology.

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 and ED will use the information gathered annually to: (a) comply with reporting 

requirements under EDGAR and provide annual information to Congress on activities conducted 

under the program, (b) measure performance on the program's GPRA indicators, and (c) to 

collect information that is consistent with the common measures for federal job training 

programs.

(a) Comply with Reporting Requirements under EDGAR and Provide Annual Information To 

Congress

The data collected from the AIVRS grantees will provide a national description of the types of 

activities that tribal vocational rehabilitation (VR) programs conduct to serve the VR needs of 

American Indians with disabilities. RSA will also use the data collected in preparing its annual 

report to Congress, as required by the Rehabilitation Act. This data will be used by RSA staff in 

desk and on-site monitoring of grantees. The data collected will help policy makers better 

understand the barriers, opportunities, and outcomes involved in improving VR services for 

American Indians with disabilities. Further, grantees can use the data for their own purposes as 

they discuss, plan, generate support for, and implement VR programs and services for American 

Indians with disabilities.

In order to provide the most accurate and comprehensive documentation of AIVRS activities, the 

form will collect information from the AIVRS grantees in the following areas:

1. Budget and Narrative

2. Project Goals and Objectives

3. Serving American Indians with Disabilities 

4. VR Services

5. Educational Goals and Employment Outcomes

6. Job Training Common Measures

7. Interaction with State VR Agencies

8. Evaluation

9. Consumer Satisfaction

(b) Measure Performance on the AIVRS Program’s GPRA Indicators
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The indicators for AIVRS that this data collection will address include:

1. Percentage of all eligible individuals who exit the program after receiving services under 

an individualized plan for employment (IPE) that achieve an employment outcome

(calculated by dividing the number of individuals who ended their participation in the 

program after receiving services under an IPE that achieve an employment outcome by

the total number of individuals who ended their participation in the program after 

receiving services under an IPE).

2. Cost per Employment Outcome (calculated by dividing the total Federal grant funds by

the number of individuals that achieved an employment outcome after receiving services)

3. Number of American Indians with disabilities receiving services under an IPE.

(c) Collect Information Consistent with the Common Measures for Federal Job Training 

Programs.

One of the recommendations that resulted from the FY 2004 PART review of the AIVRS 

program was to revise the program’s measures to be comparable to other job training programs 

and develop a strategy for collecting data to support the Common Measures for Federal Job 

Training Programs developed by OMB. As a result of the recommendation, the form that 

expires on September 30, 2014 was implemented and incorporated data elements to collect the 

following data that address the common measures for adult job training programs:

 The number of participants that exit the program, including (a) individuals who have 

achieved an employment outcome after receiving VR services and (b) individuals who have 

not achieved an employment outcome but have received services from the project.

 The average weekly earnings of individuals whose employment outcome resulted in 

earnings.

 The number of individuals who had earnings at the time of eligibility determination.

 The average weekly earnings at the time of eligibility determination.

 The average weekly earnings at the time of achieving an employment outcome.

 The number of eligible individuals who were employed three months after achieving an 

employment outcome (“Status 26”).

 The number of eligible individuals who were employed six months after achieving an 

employment outcome (“Status 26”).

 The number of individuals who exited after achieving an employment outcome and who have 

received post-employment services.
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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 given 

to using technology to reduce burden.

The entire submission is done electronically. The use of this web-based data collection form 

significantly reduces grantee burden in the following ways:

 The format is user friendly and requires minimal narrative.

 During year one of a grant, a grantee will enter all relevant project information. In

subsequent years, the system provides grantees with previously entered data, allowing 

them to make the necessary edits to this previously entered data. Grantees will not have 

to re-enter data from year to year, as was required in past years when paper forms were in 

use.

 The web system permits grantees to enter information on an ongoing basis during the 

reporting period, thereby giving grantees the option to use the system for their internal 

management purposes without having to spend their own resources to develop such a 

tool.

 The system will total all numeric entries for an end-of-the year report.

The system uses ColdFusion and Microsoft SQL Server software. Advantages to RSA staff in 

using this type of dynamic database software are as follows: (a) immediate access to information 

submitted by grantees; (b) the ability to identify which grantees submitted completed forms (via 

the Internet); (c) generate reports, even from partial data, as requested by Congress or ED; (d) 

ability to send emails to all grantees prior to the due date of performance reports; and (e) ability

to send emails to grantees that do not submit performance reports by the due date.

The System complies with Federal Accessibility standards implementing Section 508 for Internet 

Applications, Part 36 CFR 1194.22, thus assuring full access to users with disabilities. 

The Management Information System (MIS) complies with all the U.S. Department of 

Education’s security procedures. It has been previously certified and accredited and is currently 

in the process of being re-accredited in FY 2014.

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 data is not otherwise available, and the form does not duplicate items from any other federal 

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. 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-
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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.

No small businesses or other small entities will be part of this data collection.

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.

The proposed data collection supports the following activities: a report to Congress that is 

required to be submitted on an annual basis and GPRA data that is required to be collected from 

RSA American Indian grantees. If the information is not collected, data on key aspects of these 

programs for American Indians with disabilities will not be available. Consequently, RSA 

would be unable to meet statutory and regulatory requirements for collecting and reporting of 

data on grantees’ activities and outcomes.

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.
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The proposed revised data collection does not require any of these special circumstances.

8. If 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.

The proposed revised data collection is consistent with guidelines set forth in 5 CFR 1320.8(d).

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 AIVRS grantees have been included in the development and revision of the form. 

Since FY 2011, RSA Program staff has provided technical assistance to grantees regarding the 

submittal of data and grantees have provided comments and feedback regarding the functionality

of the MIS database which houses the AIVRS reporting form.

In preparation for revising the form that expires on September 30, 2014, RSA shared the draft 

form with the current grantees and held a teleconference on March 27, 2014 to update and 

receive input from the project directors on the proposed revisions being considered to the AIVRS 

reporting form. The project directors raised a number of questions and provided feedback that

was used to improve the language in some data elements to ensure the clarity and consistency of 

data reported.

A 60-day and 30-day Federal Register Notice was published inviting public comment. 

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

remuneration of contractors or grantees with meaningful justification.

No payments or gifts have been or are to be provided 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 
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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 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 are no assurances of confidentiality, only aggregate data will be collected. With no 

personally identifiable data collected and no questions of a personal nature regarding individual 

program participants.

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.

The data collection does not include 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.)
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 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 number of grantees funded under the AIVRS Program varies from year to year, with an 

estimate of 85 grantees currently reporting. The respondents will need 12.5 hours estimated to 

complete for a total annual burden of 1,062.5 hours. Based on reporting from previous years, 

grantees needed an average of 13 hours to complete the reporting form that expires September 

2014. The decrease in response burden is due to some of the fields being automatically

populated. The system performs auto calculations, and there is a reduction in data entry. The 

past cost to respondents was estimated to be $30 per hour for the instrument expiring September 

2014, but due to increases in the cost of living, this estimate for the revised instrument is 

increased to $30.30 for a total cost of $378.75 per respondent.

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 startup 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 
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should not include the hourly costs (i.e., the monetization of the hours) captured 

above in Item 12.

Total Annualized Capital/Startup Cost : $ .00

Total Annual Costs (O&M) : .00

____________________

Total Annualized Costs Requested : $ .00

This is an annual progress reporting form. There are no capital costs and no equipment 

purchases are necessary. The operating cost is $378.75 per grantee multiplied by 85 grantees for 

a total cost of $32,193.75.

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 will host and maintain the report web site and reporting system on ED’s server. RSA 

employs information technology specialists who dedicate time for the update and maintenance of 

the AIVRS data collection in the MIS system. The estimated annualized cost of operating the 

system is $5,500 in FY 2014. In addition, RSA program personnel time estimated for two 

supervisory managers at .5% of their time and two program managers, GS-13 at 20%, and onehalf time of a program manager, GS-13 at 10% equals approximately $55,028. The total 

estimated annualized cost to the Federal government is $60,528. 

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).

This information collection includes an adjustment decrease of 3 burden hours from 1,066 hours 

to 1,063 hours. The burden hour reduction is due to in many cases revising data fields for 

clarification with direct language and the automatic calculation of several data element fields. 

We estimate with these adjustments the number of hours per response will decrease from 13 to 

12.5. However, the number of grantees has increased from the previous collection submittal by

3.6%. In the previous collection, there were 82 grantees responding, but currently there are 85

grantees reporting. 
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The estimated number of proposed responses multiplied by the response burden hours follows:

Responses: 85

Burden Hours: 12.5

Difference in Current OMB inventory: 3 burden hours

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

tabulation and publication. Address any complex analytical techniques that will be used. 

Provide the time schedule for the entire project, including beginning and ending dates of 

the collection of information, completion of report, publication dates, and other actions.

RSA staff will use the information collected from the annual progress reporting form to report 

annually to Congress and for program monitoring purposes. RSA will generate standard reports 

to meet requirements of the Rehabilitation Act, EDGAR, and GPRA. The reporting system will 

yield frequencies, cross tabulations, and other tabular displays of information to meet the needs 

of RSA staff, ED staff, and Congress under provisions of the Rehabilitation Act, EDGAR, and 

GPRA. RSA will prepare these reports according to statutory and regulatory requirements. RSA 

will prepare other data tabulations on an as-needed basis to meet specific information needs.

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 three-year expiration date for OMB approval will be displayed on the Internet version of the 

form and hard-copy versions.

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

Paperwork Reduction Act.

There are no exceptions to the certification statement.

B. Collections of Information Employing Statistical Methods

No statistical methods will be used for this data collection, as all RSA grantees will be asked to 

complete the progress form. In fiscal year 2014, RSA is estimating 85 respondents.