1 **SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  ICRAS Tracking and OMB Number: **[ICR No. 1173.07] 1820**  **- 0660**  

### A. **Justification 1.**  **E xpl**  **a in 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 authoriz ing 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 (Act), Title VII, Chapter 2
-- In dependent Livin g Services for Older Individuals Who Are Blind authorizes grants to each State and certain territories to provide rehabilitation services to eligible blind individuals. The application required b y the Commissioner of Rehabilitation Services Administrati on (RSA) is the State's written request for grant funds and assurances that the Designated State Agency

(DSA) can carry

out its statutorily

prescribed purposes and functions. This preprint is based on the following: (1) Title VII, Chapter 2 of the Act, as amended; (2) The regulations (34 CFR Part 367); (3) Education Department General Administrative Regulations (EDGAR 34 CFR Part 76) and other applicable EDGAR regulations (refer to 34 FR 367.4). **2. Indicate how, by whom, and for what purpose the in**  **formation 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**
. To receive a grant under § 752(a) of Title VII, Chapter 2 of the Act or a re
- allotment grant under § 752(j)(4), a DSA must submit to, and obtain approval from, the Secretary an application for assistance under this program at the time, in the form and manner, and containing the agreements, assurances, and information, that the Secretary determines to be necessary to carry out the program (§§ 752(c)(2) and 752(i))2

The application package consists of the following documents:

(1) A cover letter from the Commissioner of RSA to the director of the DSA; (2) The assurances required by the Act and in 34 CFR 367.11; (3) Certifications regarding Lobb yi ng. The preprint being submitted for approval is for an extension, without change, of a currently

approved, OMB NO: 1820
- 0660 Written Application for the Independent Living Services for Older Indiv id uals Who Are Blind Formula Grant **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. permitt** **ing 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**
. This collection allows states to email, fax, or mail in a hard cop y o f their information. The decision to allow email or fax submissions was made to provide an option to respondents to submit required information more quickly and easily , reducing burden. **4. Describe ef** 

**forts 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**
. There is no duplication of this information collection. Also, there is no already available information collection that can be used o r modified for use for the purpose described in item 2 above. **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 this information does not involve 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**
. Sections 752(c)(2) and 752(i) of the Act require the S tate to submit an application for the grant to the Commissioner in such form and manner and containing such agreements, assurances, and information as the Commissioner determines to be3

necessary . If the State fails to complete the application as required, the State will not be eligible for Federal funds for the Independent Living Services for Older Individuals Who Are Blind program. This method has been established as the required procedure for requesting grant funds for this program on a three
- ye ar basis. **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 quarterl y;  requiring respondents to prepare a written response to a collection of information in fewer than 30 day s 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 b y 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 p ledge, 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 institut ed procedures to protect the information ’ s confidentiality to the extent permitted by law. There are no special circumstances that would require this information to be collected in a different manner than set forth in the Act. **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.**4

**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 circumstan**  **ces should be explained** 
. The Department published a 60
- day and 30
- day

Federal Register Notices to allow public comment , there were no comments received during the 60
- day comment period
. **9. Explain any decision to provide any payment or gift to**  **respondents, other than remuneration of contractors or grantees**  **with meaningful justification .**  No pay ment or gift has been 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 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 Age**  **ncy 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 19**  **74 (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, si mply state that the**  **Department make s**  **no pledge about the confidentially of the data.** No assurance of confidentiality is provided to respondents. **11. Provide additional justification for any questions of a sensitive nature, such as sexual**  **behavior and a ttitudes, 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**  **g iven to persons from whom the information is requested, and any steps to be taken**  **to obtain their consent.** The written request does not contain any questions of a sensitive nature
. **12. Provide estimates of the hour burden of the collection of**  **information. The statement should:** 5

 Indicate the number of respondents by affected public ty

pe (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 ty pe: recordkeeping, reporting or third party

disclosure. All narrative should be included in item 12. Unless directed to do so, agenci es 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 ROCI S IC Burden Analy sis Table. (The table should at minimum include Respondent types, IC activity , Respondent and Responses, Hours/Respo nse, and Total Hours)
.  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 co llection activities should not be included here. Instead, this cost should be included in Item 14. a. Number of respondents
-- 56 b. Frequency

of response
-- 1 (every three years) c. Total annual responses (axb)
-- 56 d. Hours per response
-- .1 6* e. Total burden hours (cxd)
-- 9 f. State hourly

rate of salary
-- -- $22 g. Total cost (exf)
-- $198.00/per responded
* The hour burden associated with this application is estimated at 10 minutes, or .16 hours, per State or Territory . The estimated hour burden per State or Territory is not expected to vary

significantly . Estimated burden hours are founded on judgments from previous State written request submittals for similar RSA grants
. **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 into6 account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including s ys tem and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which c osts 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 widel y, 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 anal ys is 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 associ ated 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: $.00 Total Annual Costs (O&M): .00 Total Annualized Costs Requested: $.00 There is no additional cost burden to States and Territories. **14. P**  **rovide 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.**  a. Review of each written request
-- .16 hour s b. Number of written requests to review
-- 56 c. Total time to review written requests
-- 9 hours* d. Federal hourl y rate of salary
-- $49 e. Total cost (cxd)
-- $491.00/per responded
* The estimated burden hours to the Federal government does not include time needed for negotiations when a written request is not approvable. Given the perfunctory nature of this written request, it would be unusual for a request to not be approvable
.7

**15. Explain the reasons for any program changes or adjustment**  **s. 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, rei nstatement without**  **change) and include totals for**  **changes in burden hours , responses**  **and cost s**  **(if applicable) .**  There are no program changes or adjustments reported. **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 information collected will not be published for statistical use. **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.** This document is not seeking OMB approval not to display the expiration date. **18. Explain each exception to the certification statement identified in the Certification of**  **Paperwork Reduction Act.** This document meets each of the criteria outlined in th e "Certification for Paperwork Reduction Act Submissions."