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U.S. DEPARTMENT OF EDUCATION

REHABILITATION SERVICES ADMINISTRATION (RSA)

STUDY OF THE DELIVERY OF SERVICES UNDER THE STATE 

VOCATIONAL REHABILITATION GRANTS PROGRAM

Office of Management and Budget

Clearance Package 

Supporting Statement for Paperwork Reduction Act Submissions

Part B

Justification

February 14, 2013
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SUPPORTING STATEMENT PART B

FOR PAPERWORK REDUCTION ACT SUBMISSION

B. Collection of Information Employing Statistical Methods

The agency should be prepared to justify its decision not to use statistical methods in any 

case where such methods might reduce burden or improve accuracy of results. The 

following documentation should be provided with the Supporting Statement Part A to the 

extent that it applies to the methods proposed. For further information, please consult 

OMB’s Standards and Guidelines for Statistical Surveys.

1. Describe the potential respondent universe (including a numerical estimate) and any 

sampling or other respondent selection method to be used. Data on the number of 

entities (e.g., establishments, state and local government units, households, or persons) 

in the universe covered by the collection and in the corresponding sample are to be 

provided in tabular form for the universe as a whole and for each of the strata in the 

proposed sample. Indicate expected response rates for the proposed sample. Indicate 

expected response rates for the collection as a whole. If the collection had been 

conducted previously, include the actual response rate achieved during the last 

collection.

The response universe consists of 80 State VR agencies (Combined, General and Blind) that receive 

Federal grant funds to serve individuals with disabilities to prepare for and engage in gainful employment. 

This includes agencies in the District of Columbia and Territories (Puerto Rico, the U.S. Virgin Islands, 

Guam, Northern Marianas, and American Samoa). The survey of all 80 State VR agencies will be 

conducted as a web-based survey. Because this is a census, no statistical sampling methods will be 

applied. The survey period will last six weeks.

RSA will send out the first electronic notice to all State VR agencies to inform them of the forthcoming 

data collection immediately after receiving OMB clearance. To facilitate the smooth operation of the 

survey and cooperation of the agencies, the contractor sought the endorsement of the Council of State 

Administrators of Vocational Rehabilitation (CSAVR) and the National Council of State Agencies for the 

Blind (NCSAB). CSAVR responding saying it endorses the survey.

The contractor anticipates that at a minimum 90 percent of VR agencies will respond to this survey. If the 

response rate is below 80 percent by the end of four weeks, the contractor will contact the non-responding

VR agencies to encourage them to participate. This will include follow-up phone calls and e-mails. 

During the survey process, the contractor will examine the responses for completeness and consistency 
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and will communicate with respondents as needed to obtain complete data and address inconsistencies in 

the responses. 

2. Describe the procedures for the collection of information, including:

 Statistical methodology for stratification and sample selection.

 Estimation procedure.

 Degree of accuracy needed for the purpose described in the justification.

 Unusual problems requiring specialized sampling procedures, and

 Any use of periodic (less frequent than annual) data collection cycles to reduce 

burden.

This survey data collection will not use any statistical methodology for stratification and sample selection 

because the whole universe of VR agencies will be surveyed. The post-survey case studies to three VR 

agencies will be limited to the 20 agencies being profiled, and exclude the four agencies visited earlier

(Arizona, Mississippi, and the two agencies in North Carolina). The selection of agencies for visits will be 

determined by the survey responses and hypotheses developed from the contractor’s analysis of survey 

and administrative data. The focus will be on those agencies with exceptional service delivery practices, 

interagency collaboration, and/or cost perspectives.

There are no unusual problems requiring specialized sampling procedures.

Questionnaire Design

The contractor conducted pre-survey site visits to four agencies in three states to inform the survey 

development process. The contractor drafted the questionnaire in collaboration with RSA staff. The 

contractor conducted a pretest of the instrument with three VR agencies (Arizona, Mississippi, and North 

Carolina General) and revised the instrument based on their feedback. The contractor also shared the 

instrument with CSAVR and NCSAB and sought their endorsement of the data collection. CSAVR 

provided feedback and endorsement. The contractor and RSA revised the instrument based on the 

CSAVR feedback.
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Data Collection Methods and Procedures

Below are the steps that will be followed for the data collection:

 The contractor will develop the web application of the survey instrument.

 RSA will send an electronic notice to all VR agencies to inform them of the forthcoming data 

collection. 

 The contractor will follow up with an introductory e-mail to the VR contact person. This email will include a description of the purpose of the evaluation and how information will be 

used and request the agency to identify a staff member who will be responsible for 

coordinating between the agency and the contractor. 

 The contractor will send a follow-up e-mail to the VR agency directors with information on 

how to enter the survey webpage and establish a username. A second e-mail will provide the 

password to access the survey. Each agency will receive a unique user name and password.

 VR agencies will access the secure web survey and complete the survey.

 The contractor will monitor the website and survey responses.

 The contractor will download the survey responses into a database to analyze the data.

 The contractor will contact non-responding VR agencies (after four weeks of survey 

administration) to encourage them to respond to the survey or clarify any questions they may 

have. 

Followup of non respondents

Contractor staff members will follow up by telephone and/or e-mail with those VR agencies that do not 

respond to the web survey within four weeks after they were sent the web link and instructions on how to 

access the survey. These staff members are experienced in nonresponse avoidance and conversion of non 

respondents. 

There is no use of periodic data collection cycles to reduce burden.

3. Describe methods to maximize response and to deal with issues of non-response. The 

accuracy and reliability of information collected must be shown to be adequate for 

intended uses. For collections based on sampling, a special justification must be 

provided for any collection that will not yield “reliable” data that can be generalized to 

the universe studied.

The following describes procedures to be followed to maximize the number of respondents who complete 

the survey: 
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 The contractor received endorsement of the data collection from a major organization of state VR 

agency administrators, CSAVR. 

 The contractor will contact VR agency directors using the advance notification e-mails and ask

the directors to select individuals who are knowledgeable and experienced with VR agency 

service delivery, partnerships, and costs. The instrument allows for multiple respondents from the 

same agency to complete a particular section of the survey. 

 An advance e-mail will be sent to the identified VR staff member to explain the purpose of the 

study and how to access the survey. 

 The contractor will follow up with identified staff to clarify questions and ensure timely 

submission by the established deadline. 

 The contractor will create a dedicated e-mail account for this study and provide a phone number 

that VR agencies can call if they have any questions. 

4. Describe any tests of procedures or methods to be undertaken. Testing is encouraged 

as an effective means of refining collections of information to minimize burden and 

improve utility. Tests must be approved if they call for answers to identical questions 

from 10 or more respondents. A proposed test or set of tests may be submitted for 

approval separately or in combination with the main collection of information.

The contractor conducted a pretest of the instrument with three state VR agencies in the summer of 2012. 

Based on the pretesting results, revisions were made to the instrument. In addition, as part of the process 

to obtain endorsement of the data collection from CSAVR and NCSAB, the contractor obtained feedback 

on the instrument from CSAVR, then met with RSA and revised the instrument to addresses the feedback.

5. Provide the name and telephone number of individuals consulted on statistical aspects 

of the design and the name of the agency unit, contractor(s), grantee(s), or other 

persons who will actually collect and/or analyze the information for the agency.

Name Affiliation Telephone Number Responsibility

Frank Bennici Westat 301-738-3608 Consult and analyze data

Joseph Gasper Westat 240- 314-2485

Consult, collect, and analyze data

Robert Harmon Westat 240-314-2348

Consult, collect, and analyze data