ED ICS Tracking and OMB Number: (XXXX) 1820

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1 **OMB 83 -**  **1 PA PERWORK REDUCTION A** **CT SUPPORTING STA** 

**TEMENT A.**  **Justification 1.**  **Explain the circumstances that make the collection of information necessary**  **. Identify**

**any legal or administrative requirements that**  **necessitate the collection. A ttach a copy** 

**of the appropriate section of each**  **statute and regulation mandating or authorizing the collection of information.**  The Rehabilitation Act of 1973, as amended ( Rehabilitation Act), requires each state to have in effect a Client Assistance Program (CAP) in o rder to receive payments from its Section 11 2 allotments under the Rehabilitation Act . The approved application prescribed by the commissioner of the Rehabilitation Services Administration (RSA) is the state's written request for grant funds and assurance s that the CAP can carry out its statutorily prescribed purposes and functions. This preprint is based on the following: (1) Title I, section 112 of the Rehabilitation Act, as amended; (2) T he regulations (34 CFR Part 370) published November 2, 1995, in t he Federal Register implementing section 112 of the Rehabilitation Act, as amended; and (3) G eneral requirements for all state plans, including written requests for assistance under section 112 of the Rehabilitation Act, pursuant to the Education Departmen t General Administrative Regulations (34 CFR Part 76). **2. Indicate how**  **, by whom, and for w**  **hat 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 coll**  **ection.** An approved written request is a condition for receipt of federal funds for a state to establish and carry out a CAP. The state must complete the Application by providing assurances that the CAP can carry out its statutorily prescribed purpo ses and functions. **3. Describe w**  **hether, and to w hat extent, the collection of information**  **involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information**  **technology , e.g., permitting elec** **tronic submission of responses, and the**ED ICS Tracking and OMB Number: (XXXX) 1820

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2 **basis for the decision for adopting this means of collection. A lso, describe**  **any consideration of using information technology**  **to reduce burden.** The State Assurances form is a legal document, which requires an a uthoritative signature and minimal reporting burden. States do not submit responses electronically because an authoritative signature is required. RSA considered the possibility of submitting responses electronically, with just a hard
- copy signature page . However, because the reporting requirements are so minimal, RSA determined that electronic submissions would have no benefit for the CAPs in terms of the reporting 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.**  This document collects unique information that is not collected under any other instrument. The written request is required by federal statute and is not obtained through any other data source. **5. If the collection of information impacts small businesses or other small**  **entities (Part II item 8 of new** **OMB Form 83 -**  **I) , describe any**  **methods used to minimize burden.**  The collection of this informa tion does not involve small businesses or other small entities. **6. Describe the consequence 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.** Section 112(f) of the Rehabilitation Act requires the state to submit an application in such manner and containing or accompanied by such information as the secretary deems necessary. If the state fails to complete the application as required, t he state will not be eligible for federal funds for the CAP program and subsequently for the basic state grant funds under section 110 of the Rehabilitation Act . This method has been established as the required procedure. **7. Explain any** 

**special circumsta nce that w**  **ould cause an information collection to be conducted in a manner:** 
**o requiring respondents to report information to the** ED ICS Tracking and OMB Number: (XXXX) 1820

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3 **agency more often than quarterly**  **;**
**o requiring respondents to prepare a w**  **ritten response to a collection of information i**  **n few er than 30 day** **s after receipt of it;** 
**o requiring respondents to submit more than an original**  **and tw o copies of any**  **document;**
**o requiring respondents to retain records, other than**  **health, medical, government contract, grant -**  **in -** **aid, or tax record**  **s for more than three y ears;** 
**o in connection w**  **ith a statistical survey , that is not**  **designed to produce valid and reliable results that can be generalized to the universe of study**  **;**
**o requiring the use of a statistical data classification**  **that has not be en review**  **ed and approved by OMB;** 
**o 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 w ith the**  **pledge, or w h**  **ich unnecessarily impedes sharing of data**  **with other agencies for compatible confidential use; or**
**o requiring respondents to submit proprietary**  **trade secret, or other confidential information unless the**  **agency can demonstrate that it has instituted**  **proced ures 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 Rehabilitation Act

. **8. If applicable, p**  **rovide 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 receive**  **d in response to that notice and describe actions taken by**  **the agency**

**in response to these**ED ICS Tracking and OMB Number: (XXXX) 1820

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4 **comments. Specifically address comments received on cost and hour**  **burden. Describe efforts to consult w**  **ith persons out -** **side the agency to obtain their**  **view s on th**  **e 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 w**  **hom information is to be obtained or**  **those w ho must compile records should occur at least once every**  **3 y ears**  **- even if the collection of information activity**  **is the same as in prior periods. There may** 

**be circumstances that may preclude consultation in a spec**  **ific situation. These circumstances should be explained.**  RSA received recommendations on this collection of information , including the frequency of reporting, from the National Disability Rights Network (NDRN), CAPs, and other advocacy groups. RSA con sidered s uggestions received from all sources during the development of this form and it has not been revised. In addition, a 60
- day and a 30
- day notice will be published in the Federal Register to solicit public comment. **9. Explain any** 

**decision to provi de any**  **pay ment or gift to respondents, other**  **than remuneration of contractors or grantees.** There is no payment or gift to respondents. **10. Describe any** 

**assurance of confidentiality provided to respondents and the**  **basis for the assurance in statute, regul ation, or agency**  **policy**
**.** The written request does not contain specific or personal information. Therefore, confidentiality is assured for all agencies. **11. Provide additional justification for any**  **questions of a sensitive nature, such as sexual beh**  **avior and attitudes, religious beliefs, and other matters that are commonly** 

**considered private. This justification should include the reasons w**  **hy**

**the agency**

**considers the questions necessary ; the specific**  **uses to be made of the information, the explanatio n to be given to persons**  **from w hom 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.ED ICS Tracking and OMB Number: (XXXX) 1820

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5 **12. Provide estimates of the hour burden of the collection of**  **information. The statement should:** 
**o indicate the number of respondents, frequency**  **of response, annual hour burden, and an explanation of how** **the burden w as estimated.**  **Unless directed to do so, agencies should not conduct special survey** **s to obtain inf ormation on w**  **hich to base hour burden estimates. Consultation w**  **ith a sample (few er than ten) 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.** 
**o If this request for approval covers more than one form, provide**  **separate ho ur burden estimates for each form and aggregate the**  **hour burdens in item 16 of new** **OMB Form 83 -**  **I**
**. o**  **Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identify**  **ing and using appropriate w**  **age rate cate gories. The cost of contracting out or**  **pay ing 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 c. Total annual responses (a x b)
-- 56 d. Hours per response
-- .16* e. Total burden hours (c x d)
-- 9 f. State hourly rate of salary
-- -- $25 g. Total cost (e x f)
-- $225

* The burden hours associated with the written Request for a CAP grant are e stimated at 10 minutes, or .16 hours, per state or Territory. The estimated hour burden per state or Territory is not expected to vary significantly. RSA has based the e stimated burden hours on previous submis sions of this information collection

. **13. Pro** **vide 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 show**  **n in items 12 and 14.)**ED ICS Tracking and OMB Number: (XXXX) 1820

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6 **o The cost estimate should be split into tw**  **o componen ts: (a) the 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 w**  **ith generating, maint aining, and disclosing or**  **providing the information. Include descriptions of methods used to estimate major cost factors including sy** **stem and technology acquisition, expected useful life of capital equipment, the discount**  **rate(s), and the time period over wh**  **ich costs w ill be incurred.**  **Capital and start -**  **up costs include, among other items, preparations for collecting information such as purchasing computers and**  **softw are; monitoring, sampling, drilling and testing equipment; and**  **record storage facilities:**
**o 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 purchasing of contracting out information**  **collection services should be a part of this cost burden estim ate. In**  **developing cost burden estimates, agencies may consult w**  **ith a sample of respondents (few**  **er than 10), utilize the 60 -**  **day pre**  **- OMB**  **submission public comment process and use existing economic or regulatory** 

**impact analy sis associated with the rulemakin**  **g containing the information collection, as appropriate.** 
**o 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 w**  **ith requirements not ass ociated**  **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.** There is no additional cost burden to states and Territor ies when submitting a written Request for CAP funds

. **14. Provide estimates of annualized cost to the Federal government. A**  **lso, provide a description of the method used to estimate cost, w**  **hich should include quantification of hours, operational expenses (**  **such as equipment, overhead, printing, and support staff), and any**  **other expense that w ould**  **not have been incurred w ithout this collection of information. A** **gencies also may** 

**aggregate cost estimates from items 12, 13, and 14 in a single table.** ED ICS Tracking and OMB Number: (XXXX) 1820

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7 a. Revie w of each written request
-- .16 hour b. Number of written requests to review
-- 56 c. Total time to review written requests
-- 9 hours* d. Federal hourly rate of salary
-- $4 9 e. Total cost (c x d)
-- $441.00

* The estimate of burden hours to the Federal Government does not include time needed for negotiations when a written request is not approvable. However, g iven the perfunctory nature of this written request, it would be unusual for a request to not be approvable. **15. Explain the reasons**  **for any program changes or adjustments reported in**  **item 16 of the new OMB Form 83**  **- I** 
**.** There are no program changes or adjustments reported, with the exception of updating the hourly wage for State and Federal employees based on current information. **16. For collections of information w**  **hose results w ill be published, outline**  **plans for tabulation and publication. A ddress any**  **complex analy tical**  **techniques that w ill be used. Provide the time schedule for the entire**  **project, including beginning and endin g 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 reason that display would be**  **inappropriate.** RSA is not seeking a pproval to not display the expiration date for OMB approval of the information collection. **18. Explain each exception to the certification statement id**  **entified in, "Certification for Paperw**  **ork Reduction A ct Submissions.”**  This document meets each of the criteria outlined in the "Certification for Paperwork Reduction Act Submissions". **B. Collection of Information Employ**  **ing Statistical Methods** The written request for a CAP grant is a legal document and does not require the use of any statistical methods in obtaining information.