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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification 

1. Explain the circumstances that make the collection of information necessary. Identify

any legal or administrative requirements that necessitate the collection. Attach a hard 

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 

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 Act of 1973 as amended by the Workforce Innovation and 

Opportunity Act (Act), requires the Commissioner of the Rehabilitation Services 

Administration (RSA) to conduct annual reviews and periodic on-site monitoring of the 

vocational rehabilitation (VR) program to determine whether a state agency is complying 

substantially with the provisions of its State Plan under section 101 of the Act and with 

the evaluation standards and performance indicators established under section 106. To 

fulfill its monitoring responsibility, RSA is reviewing a maximum of 14 VR agencies in 

each fiscal year (FY) from FY 2012 through FY 2016. When, based on its monitoring, 

RSA determines that a state agency has failed to administer and operate the VR program 

in compliance with its State Plan, the Act and implementing regulations at 34 CFR Part 

361, the agency must develop a corrective action plan (CAP) for RSA approval within 45 

days from the issuance of the final monitoring report. 

As explained in response to Question 3, To promote the consistency of the information 

contained in the CAPs and the ability of RSA to assess a VR agency’s completion of the 

action steps therein, as well as to ease the burden on the VR agencies in the development 

of and reporting on the CAPs, In FY 2011 RSA developed a form and on-line submission 

and reporting process through its management information system (MIS). Beginning in 

FY 2012, each of the VR agencies monitored during the year that RSA has found to be 

out of compliance with federal requirements used this form located on the RSA MIS to 

submit a CAP for RSA approval and thereafter to report progress on the action steps 

contained in the CAP on a quarterly basis, until such time as each compliance finding 

represented by the CAP is resolved.
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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 CAP must contain the specific steps that the VR agency will take to resolve each 

finding, timelines for the completion of each step and methods for evaluating that the 

findings have been resolved. RSA requires the agency to report progress toward 

completion of the CAP on a quarterly basis. Using this information for each VR agency

required to submit a CAP, RSA has been able to track the agency’s progress toward the 

resolution of the compliance findings and identify the need for technical assistance to 

enable it to carry out the corrective actions. In addition, RSA has been able to use this 

on-line system to identify trends in the nature of the compliance findings common among 

the VR agencies and the technical assistance needs of the VR agency network as a whole, 

thereby assisting the agencies to avoid future findings of non-compliance.

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.

Since FY 2011, RSA has required VR agencies to use a standard online form for the 

development of CAPs. This on-line system enables RSA to carry out this activity. The use 

of a consistent form and Web-based submission process allows the VR agencies to 

develop and report progress on the CAPs in a more efficient and timely manner, thus 

reducing the reporting burden.

Prior to the development of the online CAP in FY 2011 RSA had accepted the CAP in 

any format submitted by a VR agency, so long as it included all required information. 

Likewise, RSA did not require agencies to use a uniform method for the reporting of 

progress on CAPs. Lacking a uniform Web-based reporting system, RSA experienced 

difficulty in tracking the progress of the VR agencies toward the resolution of the CAPs. 

..

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 CAP must contain the specific steps that the agency will take to resolve each finding, 

timelines for the completion of each step and methods for evaluating that the findings 

have been resolved. No similar information is available to RSA through other 

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

The collection of information does not impact small businesses 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.

When, based on its monitoring, RSA determines that a state agency has failed to 

administer and operate the VR program in compliance with its State Plan, the Act and 

implementing regulations at 34 CFR Part 361, the agency must develop a CAP for RSA 

approval within 45 days from the issuance of the final monitoring report. RSA uses the 

information required in a CAP, to determine that a VR agency has resolved findings of 

non-compliance and that no further corrective action must be taken.

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
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 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate that it has instituted procedures to 

protect the information’s confidentiality to the extent permitted by law.

 There are no special circumstances that require this information collection to be 

conducted in any manner listed above.

There are no special circumstances that require this information collection to be 

conducted in any manner listed above.

8. As 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.

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 Department published a 60-and 30-day Federal Register Notice (FRN) and received 

no public comments during the 60-day FRN period. RSA has also engaged VR state 

agency representatives in field testing. An electronic version of the CAP was made 

available to participants to enter existing CAPs. RSA also solicits information via 

teleconferences to gain input on ease of access, user interface, and ideas on improving the 

user experience. 

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

remuneration of contractors or grantees with meaningful justification.

RSA has made no decision to provide any payment or gift 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 is no assurance of confidentiality, because the collection instrument does not 

collect individual, personal or sensitive data.

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.

This report contains no 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.



CAP Development and MIS 

Submission

CAP Quarterly Response and 

MIS Submission

Total Annual 

Burden

Number of 

Respondents

15* 15* 15

Frequency of 

Response

Initial Quarterly

Total Annual 

Responses

15* 45* 60

Hours per 

Response

50 25

Total Hours 750 1125 1875

Cost per Hour $35 $35

Total Cost per 

Response

$1750 $875 $2625

Total Cost $26,250 $39,375 $65,625

RSA has estimated the time required for each respondent to develop the CAP and complete the 

form. RSA conducted a field test of three respondents during Phase 1 and found that the CAP 

can be developed and submitted into the MIS in an average time of 50 hours. In addition, RSA 

estimates the hourly cost to respondents to be $35.00, and cost per development and submission 

for the CAP to average $1,750 per respondent. RSA estimates a total annual cost burden for 

CAP development to be $26,250 and 750 hours. The additional burden for quarterly update 

estimates totals 45 responses. 

*RSA intends to monitor 70 of its 80 agencies between 2012 and 2016, reviewing 14 agencies 

per year. Because the number of agencies developing and reporting on a CAP will vary, RSA is 

using 15 respondents as the number developing CAPs per year and 45 quarterly progress 

responses or 3 quarters (beginning the quarter after initial CAP development) X 15 respondents.
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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. Also, these estimates should 

not include the hourly costs (i.e., the monetization of the hours) captured above in 

Item 12

Total Annualized Capital/Startup Cost:

Total Annual Costs (O&M): 

Total Annualized Costs Requested:

States and territories incur no additional cost burden when submitting the CAP.

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.
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CAP review and 

approval

Quarterly progress 

reports review and 

approval

Total Annual Cost 

Annual cost to the federal 

government

22.5 hours x $45/ 

hour = $1012.50

33.75 hours x $45/ 

hour = $1518.75

56.25 hours/ 

$2,531.25

Annual Federal computer 

cost

$500

Total cost to Federal 

Government

$3,031.25

 

RSA estimates that staff will require one and one-half hours to review and approve each 

CAP submission prior to approval of the CAP, totaling 22.5 hours of review time (15 x 

1.5). RSA estimates that staff requires 45 minutes to review and approve each Quarterly 

CAP submission; totaling 33.75 hours (45 x .75) RSA is now using an hourly cost of 

$45.00 for each hour of review, based on an hourly rate of staff responsible for this 

activity. The annual cost burden for review and approval of the CAP and Quarterly

Progress reports is estimated at $3,031.25 and takes 56.25 hours.

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).

There are no program changes or adjustments to this extension request. 

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.

The CAP is not published information.

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.
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RSA is not seeking approval to not display the expiration date.

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

Paperwork Reduction Act.

There are no exceptions to the certification statement.