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OMB 83-1 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.

The Annual Vocational Rehabilitation Program/Cost Report (RSA-2) collects data on the vocational 

rehabilitation (VR) and supported employment (SE) program activities for agencies funded under the 

Rehabilitation Act of 1973, as amended (Rehabilitation Act). The RSA-2 captures: 

 administrative expenditures for the VR and SE programs;

 VR program service expenditures by category;

 SE administrative expenditures and service expenditures;

 expenditures for the VR program by number of individuals served;

 the costs of types of services provided; and

 a breakdown of staff employed by the VR agencies.

These data are used to evaluate and monitor the financial performance and programmatic achievements 

of VR agencies.

The basic data comprising the Annual Vocational Rehabilitation Program/Cost Report (RSA-2) are 

mandated by the Rehabilitation Act. The Appendix to this document shows the applicable portions of 

the Rehabilitation Act that explicitly or implicitly require the recording and reporting of specific data 

elements by VR agencies to the Rehabilitation Services Administration (RSA). 

Section 13 of the Rehabilitation Act requires the Commissioner to collect and report information 

specified in Section 101(a)(10) to the Congress and the President in an Annual Report. Section 626 

requires the same information be reported for individuals who received SE services. Data on persons 

served also are needed to satisfy Section 131 calling for an exchange of data between RSA, the Social 

Security Administration (SSA), and the Department of Labor (DOL). 

This is a request for a revision of an existing data collection. The revisions currently proposed will 

improve RSA’s ability to monitor and analyze the performance of VR agencies and will eliminate 

redundancy between the RSA-2 and the federal financial report (FFR). In addition, the form’s 

instructions will be revised to make them more clear and concise. Following approval by OMB, VR

agencies will need time to re-program their data collection systems and conduct systems testing. RSA 

will implement the revised form in the 2014 federal reporting year. 
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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 RSA-2 is completed by state VR agencies electronically (see #3 below for more information). 

RSA has collected these data from states via the RSA-2 for over 20 years. The RSA-2 is designed to 

show how grant funds provided to state VR agencies have been spent by breaking their spending down 

by specific categories. This is the only source of detailed information on annual expenditures made by

state VR agencies. Total expenditures from all funding sources -- federal funds, state matching funds, 

and funds derived from other sources expended for VR and SE purposes and under the control of the 

state VR agencies are reported. RSA uses this data to:

 assist with setting agencies’ VR goals and determine whether those goals are being achieved; 

 determine the average cost of the services the VR program provides;

 provide information necessary for the completion of ED’s annual budget request;

 respond to inquiries from Congress, other federal agencies, states, organizations, and private 

individuals;

 respond to audits conducted by the Department of Education’s Office of Inspector General and 

the General Accounting Office; and

 plan for the distribution of federal funds for training and manpower development. 

In addition, when these data are analyzed in conjunction with data collected through other instruments 

(RSA-113, Quarterly Cumulative Caseload Report and the RSA-911 (1820-0508), Case Service 

Report), RSA can assess the accomplishments and fiscal practices of VR agencies, and compare these 

to data from prior years. This assessment allows RSA to identify problem areas and target technical 

assistance.

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.

RSA has a Management Information System (MIS) that agencies use to access the data collection 

directly through the internet by using the following URL: http://rsa.ed.gov. All VR agencies have 

submitted their RSA-2 data electronically into the MIS since FY 2010.

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

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

The RSA-2 is the only source of data that provides RSA with detailed annual financial expenditure 

information. Standard federal financial reporting forms provide some financial information, but it is of 

such a general nature that it is not sufficient to meet the purposes described in #2 above. However, two 

schedules with eight total data elements on the RSA-2 were found to be redundant with information 

collected on standard financial reporting forms, and have thus been eliminated. Additionally, RSA 

removed line item subtotals and totals that could be calculated electronically in the MIS. This reduces 

the effort required by the agency to complete the form and reduces calculation errors.
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5. If the collection of information impacts small businesses or other small entities (Item 5 of 

OMB Form 83-I), describe any methods used to minimize burden.

The collection of information does not involve small business or other small entities.

6. Describe the consequences to federal program or policy activities if the collection is not 

conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing 

burden.

The data cannot be collected less frequently than annually due to the fiscal year limitation on the use of 

federal funds by state VR agencies, because the data is used for the provision of the Department’s 

annual budget request, and because the previously mentioned report to Congress is due annually. The 

most important use of the data is for monitoring state VR agencies. The need for that data collection 

could not be less frequently than annually in order to be as recent as possible.

7. Explain any special circumstance that would cause an information collection to be conducted 

in a manner:

 requiring respondents to report information to the agency more often than annually;

 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 cause the RSA-2 to be conducted according to the bullets 

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.
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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.

RSA regularly consults with the Council of State Administrators of Vocational Rehabilitation 

(CSAVR) on developments affecting the RSA-2 system. CSAVR is an umbrella organization, 

headquartered in suburban Washington, DC, representing the 80 respondents (state VR agencies)

The current revision of the RSA-2 has been undertaken with the assistance of a Technical Work Group 

(TWG) comprised of state VR staff. The membership of this group was recommended by the CSAVR. 

The TWG has reviewed drafts of issue papers, revision plans, and revised the RSA-2.

Consultations also included representatives of the two major providers of third-party software for 

completing the RSA-2 form.

Finally, see attached document “RSA-2 Comments and Analysis” for RSA’s responses to comments 

received and subsequent changes as a result of the 60-day publication of the proposed revised RSA-2

data collection and instructions in the Federal Register on Monday July 2, 2012, page 39,224. A 30-day

FRN will also publish seeking additional comments. 

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

of contractors or grantees.

No payment or gift will be provided to respondents, other than remuneration of grantees.

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

assurance in statute, regulations, or agency policy.

The data to be collected on the RSA-2 report are not of a confidential nature, as the data only describe 

agency expenditures and do not include any personal information other than the signature block for the 

submitting official. There are no assurances of confidentiality provided. 

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. This 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 sensitive data are required to be reported on the RSA-2.
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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 13 of OMB Form 83-I.

 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 burden of collection of information for the revised form is estimated to be 320 hours for the 80 

respondents submitting one report each per fiscal year (an average of 4.0 hours per submission). The 

total cost burden to the state VR agencies is estimated to be $16,000 (320 hours multiplied by $50.00 

an hour).

The previous burden was estimated to be 385 hours for 80 respondents submitting one report each per 

fiscal year (average 4.8125 hours per submission). The proposed revisions remove approximately onethird of the items from the current RSA-2. Two complete schedules (Schedule IV for other VR funds 

and Schedule V for carryover) have been deleted to eliminate redundancy between the RSA-2 and other 

standard federal accounting forms. Additionally, the RSA-2 will now ask agencies to calculate 

expenditures on a cash basis using only their liquidated obligations, instead of including unliquidated 

obligations, which will simplify completion of the revised schedules that remain in the form. Twelve

additional items have been added to the costs of purchased services section, but since the data collected 

in the RSA-2 are maintained by state VR agencies as part of their normal operations in order to prepare 

the RSA-911, these additions should require minimal new effort to report. As with the previous 

submission, the only burden factor considered is the amount of time required to copy and enter the 

information into the report form. This burden is included in the Information Collection Budget. 

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 
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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.

In regard to the programming necessary for the redesigned RSA-2, roughly half of the state VR 

agencies have service contracts with vendors or are scheduled to revise their internal data systems;

therefore, the burden incurred from the revision of their systems to collect information on the 

redesigned RSA-2 will be borne by their vendors, not the VR agencies themselves. Approximately 20

percent of VR agencies will program the changes of the form in-house; consequently, costs will be 

minimal. The remaining agencies will have to contract for the changes to be made. The cost of the 

contracts should not be high considering that most of the changes consist of eliminating data elements 

and adding only nine services provided to individuals. 

The estimated cost to those agencies effecting the changes in-house would be $80,000 – based on 20 

agencies multiplied by $100 per hour multiplied by 40 hours effort. The estimated cost for contracting 

the changes to be effected could vary from $10,000 to $20,000.

This collection does not require capital costs, maintenance costs, or the purchase of services for the 

respondents. There are no start-up costs associated with this collection because the summary data are 

already collected by the VR agencies for the purpose of maintaining their federal grants.

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.

There are no additional annual costs to the federal government for the newly-redesigned RSA-2 form. 

The changes, for the most part, involve the elimination of data collection schedules and the addition of 

twelve service category fields. Most importantly, the in-house programmer will make the necessary

initial changes to the form.

Regarding the annual cost to the federal government, these revisions will effectively streamline the 

form for both grantee submission and for RSA staff to maintain. RSA staff will review submitted 

forms on an annual basis, follow up with agencies when corrections are needed, and approve the form 

on the RSA MIS system. The collection of data on the revised RSA-2 form will not require additional 
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costs associated with equipment, overhead, printing or support staff, other than the in-house 

programmer’s initial revisions to the form. 

To calculate the annual cost, RSA staff will spend approximately 1.0 hour annually related to the RSA2 form (reviewing each submission, following up with grantees when corrections are required, and 

approving the form). At an average rate of $60/hour for salary and fringe benefits, 1.0 hours X 

$60/hour equals $60 per submission. Since the RSA-2 is a required form for all 80 grantees that 

receive VR and SE awards, the total estimated cost to the federal government to maintain this form is 

$60 X 80 grantees, or $4,800 total. 

15. Explain the reasons for any program changes or adjustments reported in Item 16 of the 

OMB Form 83-I.

There is a program change burden reduction of -65 annual burden hours. Four of the revisions to the 

RSA-2 will decrease the overall burden on state VR agencies. The first two of these revisions are the 

removal of two schedules or sections of the form. These sections were found to be redundant with 

other fiscal data collection forms. The third revision is the change in the method of calculating 

expenses by eliminating the need to include unliquidated obligations. The fourth revision is to remove 

data elements that RSA could calculate based upon other information provided by the agency in the 

form (subtotals and totals).

The revisions to the section of the form that collects information on funds spent on purchased services 

will include twelve more items than are currently present. These revisions will align the service 

categories on the RSA-2 with those on the RSA-911 (1820-0508) data collection instrument and should 

reduce confusion and effort on the part of state agencies.

The one-time costs of revising programming will be minimal and is expected to decrease the time spent 

on collecting the purchase services information since many of the revisions bring the information 

collected on services to VR customers in line with those included on the RSA-911. 

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.

Data from the RSA-2 is used in monitoring agency performance and for the Annual Report to the 

Congress required by Section 13 of the Rehabilitation Act. 

The RSA-2 report is submitted by the state agency via RSA’s MIS. These submissions in the MIS are 

reviewed by RSA staff and are then either approved or sent back to the agency for correction and/or 

revision. The RSA-2 data is approved based on the reviewer’s familiarity with the agency as well as by

RSA’s analysis of differences with prior year data. When the 80 agency submittals have been

approved, the database of all submittals are published for display in the MIS. 

The due date for the RSA-2 is December 31. The approval process is time-intensive and state agency

submittals are frequently late, adding to the timeline needed for an approved and useable database. The 
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anticipated date of approval is March 31 or three months following the required submittal date. The 

use of the data contained in the RSA-2 for monitoring reports will generally be available immediately

from RSA’s MIS, but may take a month or more for specialized queries.

RSA anticipates that this revised RSA-2 form will be available for distribution to agencies by January

31, 2013, thus allowing agencies one year to accomplish programming necessary to collect the 

information requested on the form, prior to implementation of the 2014 federal reporting year. The first 

submittal of the RSA-2 using the revised form will be due December 31, 2014.

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 expiration date for OMB approval will be displayed.

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

Paperwork Reduction Act Submissions," of OMB Form 83-I.

We made no exceptions to the certification statement identified in Item 20, “Certification for 

Paperwork Reduction Act Submissions.”

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This information collection does not employ statistical methods.

Appendix

How the Data Collected, via the RSA-2, Address Statutory Requirements of the Rehabilitation 

Act of 1973, as amended

1. Section 3(b) of the Rehabilitation Act requires RSA to "take whatever action is necessary to 

ensure that funds appropriated pursuant to this Act are expended only for the programs, 

personnel, and administration of programs carried out under this Act."

Schedule I of the RSA-2

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captures the total VR and SE program funds under the control of and 

expended by state VR agencies.

Schedule II of the RSA-2 provides a total number of labor hours for VR agency staff working on the 

VR program. This schedule provides a breakdown of staff effort related to the VR program.

Schedule III of the RSA-2 report provides a cost breakdown of the various services provided which 

serve multiple VR client needs in the administration of the public VR program. These data are 

collected for several purposes, including both programmatic and financial operations/expenditures 

 

1 For the remainder of the appendix, a reference to a “schedule” means a schedule on the RSA-2.
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tracking. For program management, the data provide a meaningful and critical insight into the extent to 

which mandatory services are provided by a state program and by the VR program nationally. For 

fiscal management purposes, the data permit state agencies and RSA to assess the impact of 

expenditure levels for specific services on outcomes for agency clientele.

2. Section 13 requires that the RSA Commissioner submit an annual report that is full and 

complete to the President and Congress. 

Information in the RSA-2 is necessary for this annual report. Two of the most critical activities carried 

out under the Act are the expenditure of appropriated monies in furtherance of the goals of the Act and 

the provision of a variety of services to individuals with disabilities. Schedules I, II, and III provide the 

bases upon which to inform the Congress fully and completely about these activities. These schedules 

call for dollars expended and the number of persons in receipt of service types for the fiscal year in 

question. RSA believes that the categories listed on Schedules I, II, and III satisfy the letter and spirit 

of the "full and complete" provision in Section 13(a). 

3. Section 14(a) articulates a requirement for the conduct of cost/benefit studies when it says “. . . 

their general effectiveness in relation to their cost . . .” Additionally, OMB has mandated that 

total dollars must be used in such cost/benefit analyses.

The proper evaluation of program effectiveness (and impact) requires determination of the relationship 

between program outcomes and program inputs. 

Determining effectiveness includes more than the obvious goal of the program, i.e. to rehabilitate 

persons with disabilities. Included would be, for example, such important goals as: 

(a) holding within reasonable bounds, the amount and proportion of expenditures devoted to 

agency overhead or to construction activities (and away from client services); 

(b) lowering, if necessary, amounts of money spent on and the number of clients in receipt of 

medical services since these services often indicate cases of persons who are not significantly

disabled or who needed only a remedial medical service that could have been provided 

elsewhere; and 

(c) increasing, if necessary, the number of persons receiving on-the-job training, a service which 

has proven to be a valuable by-product of governmental and private sector cooperation.

Additionally, OMB requires that RSA project future capacity given proposed budget levels. This 

requires knowledge of the total amount of money available to and spent by state agencies. This 

projection activity would not produce sound estimates if millions of state VR agency dollars which are 

used to take clients into the caseloads, and to serve and rehabilitate them, are not completely accounted 

for. The availability of these data permits more effective and accurate budget projections to be made.

4. Section 101 provides that the Commissioner be assured that services providable under the Act 

are being provided in accordance with the individualized plan for employment. (Section 

101(a)(9)(B)). Sections 103(a)(1) through (18) and 103(b)(1) through (6) identify and define those 

services which are available to eligible individuals by VR agencies under the Act. 
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The data collected on Schedule III measure the extent to which the listed services are provided by the 

state VR agencies in helping individuals with disabilities achieve employment outcomes.

5. Section 103(b)(2)(A) further includes as a service: "The establishment, development, or 

improvement of community rehabilitation programs, including, under special circumstances, the 

construction of a facility.”

The data collected on Schedule I, Item 3.A and B of the RSA-2 are needed by RSA to determine the 

financial extent to which VR community rehabilitation programs (CRP) are established or constructed.

6. Sections 101(a)(24)(A) and (B) require the use of for-profit and non-profit organizations for 

the provision of services for the rehabilitation of individuals with disabilities. 

The extent of such use is measured by the collection of the data on lines 2.B.1 and 2.B.2 of Schedule I 

of the RSA-2.

7. Section 103(a)(5) requires that no training services in institutions of higher education be paid 

for with funds from this title unless maximum efforts have been made to secure grant assistance 

from other funding sources.

The RSA-2 report contains data on the number of clients trained and funds expended for this purpose. 

These data are analyzed by RSA staff and used to monitor the extent to which VR funds are used for 

training purposes. 

On a related topic, the labor hours reported on the RSA-2 are used as the basis for distributing 

discretionary training funds for in-service training of state agency personnel and for Rehabilitation 

Continuing Education Programs. This method of distributing these training funds has proven equitable.