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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

ICRAS Tracking and OMB Number: [ICR No. 1173.07] 1820-0660

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 (Act), Title VII, Chapter 2-- Independent 

Living 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 by the Commissioner of Rehabilitation Services Administration 

(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 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.

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))
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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 Lobbying.

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 Individuals 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. 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.

This collection allows states to email, fax, or mail in a hard copy of 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 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.

There is no duplication of this information collection. Also, there is no already available 

information collection that can be used or 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 State 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 be 
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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-year 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 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.

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.
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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-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 payment 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 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.

No assurance of confidentiality is provided to respondents.

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 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:
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 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).

 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.

a. Number of respondents -- 56

b. Frequency of response -- 1 (every three years)

c. Total annual responses (axb) -- 56

d. Hours per response -- .16*

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 into 
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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: $.00

Total Annual Costs (O&M): .00

Total Annualized Costs Requested: $.00

There is no additional cost burden to States and Territories.

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.

a. Review of each written request -- .16 hours

b. Number of written requests to review -- 56

c. Total time to review written requests -- 9 hours*

d. Federal hourly 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.
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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 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 the "Certification for Paperwork 

Reduction Act Submissions."