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EDICS Tracking and OMB Number: 1820-0690 Revised: 11/5/2012

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

TECHNICAL ASSISTANCE AND CONTINUING EDUCATION PROGRAM

NEEDS ASSESSMENT, WORKPLAN AND EVALUATION GUIDE

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 

section1. 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.

OSERS funded ten regional Technical Assistance and Continuing Education (TACE) Centers 

between September and December 2008 that currently and will continue to provide technical 

assistance (TA) and continuing education (CE) to state vocational rehabilitation (VR) agencies 

that provide VR and independent living (IL) services to individuals with disabilities under the 

Rehabilitation Act of 1973, as amended and organizations that support state VR agencies (called 

partners). 

The 2008 Notice of Final Priority (NFP) under which the TACE Centers were funded requires 

them to conduct an annual assessment of the TA and CE needs of the agencies and partners in 

their regions. Based on the information gathered from their needs assessments, the TACE 

Centers annually develop workplans that identify the needs they will address and how they will 

address them. The needs assessments and workplans are submitted annually to the 

Rehabilitation Services Administration (RSA) for review and approval. 

The NFP for the TACE Centers also requires TACE Centers to report data on the activities they

conduct under their workplans. This data includes: 

• The number of agency personnel participating in the activities;

• The type of agency personnel participating in the activities;

• The topics of the activities; and

• The participant evaluation of relevance, effectiveness, and quality of the activities.

 

 

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EDICS Tracking and OMB Number: 1820-0690 Revised: 11/5/2012

RIN Number: XXXX-XXXX (if applicable)

The TACE Centers will no longer submit their data collection via the Internet through the RSA 

Management Information System (MIS). The TACE Centers will begin inputting their data 

collection, needs assessment, and workplan information into an Excel spreadsheet and will be 

uploading and submitting it online through G5, the Department of Education's Grants 

Management system, as part of their required annual performance report (ED 524B). In 

addition, the TACE Centers will be required to submit their workplans annually instead of semiannually. 

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 data, needs assessment information, and workplan information to be collected will be 

analyzed and evaluated by RSA for the following purposes:

1. To track the TA and CE needs of state agencies under the Rehabilitation Act of 1973, 

as amended;

2. To track the progress of TACE Centers at meeting those TA and CE needs; 

3. To determine where coordination and collaboration between TACE Centers can be 

achieved to maximize time and resources; and 

4. To evaluate the performance of TACE Centers. 

The TACE Centers will be evaluated not only on the basis of their ability to meet the TA and CE 

needs of agencies and partners, but also in accordance with standard performance measures used 

for TA programs at the Department of Education which are:

• percentage of TA and CE services provided that are deemed to be of high quality;

• percentage of TA and CE services provided that are deemed to be of high relevance; 

and

• percentage of TA and CE services provided by the TACE Centers that are deemed to 

be useful in improving State VR agency policies and practices.

Data collected through this IC will enable RSA to calculate these performance measures.

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.

TACE Centers will utilize an Excel spreadsheet to enter their collection of information and will 

upload the spreadsheet(s) into G5 as an attachment. Once a workplan has been developed and 

implemented, the TACE Center will use the same data collection method to provide data on its 

activities, such as the number and type of personnel who received TA and CE. Previously, the 

TACE Centers uploaded this information into RSA’s Management Information System (MIS), 
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EDICS Tracking and OMB Number: 1820-0690 Revised: 11/5/2012

RIN Number: XXXX-XXXX (if applicable)

but this process proved burdensome to the grantees. We anticipate the use of the Excel 

spreadsheet will be less cumbersome. 

TACE Centers will survey recipients of TA or CE using their own methodology. A copy of the 

survey to be administered by the TACE Centers is included in this clearance package. The 

TACE Center is responsible for aggregating the information from the surveys and entering it into 

an Excel Spreadsheet.

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 TACE Program is a fairly new program and no similar program exists in RSA. Therefore, 

there is no similar information collection.

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 for the ten regional TACE Centers will 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.

TACE Centers need to create new needs assessments and workplans on an annual basis because 

they are used to determine their activities for the following year. TACE Centers can provide 

data on their activities at any time, but RSA will require that they update their plans with data 

annually. Every July, the Centers will submit data that will be used (1) as their annual progress 

report to determine whether they qualify for continuation of funds; and (2) to close out the 

existing workplan and begin a new one. 

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;
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EDICS Tracking and OMB Number: 1820-0690 Revised: 11/5/2012

RIN Number: XXXX-XXXX (if applicable)

 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.

This information will be collected consistent with 5 CFR 1320.5.

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.

RSA published a 60-day and 30-day Federal Register notices on this IC for public comment. 

RSA received two public comments which are attached. 

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

remuneration of contractors or grantees with meaningful justification.
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EDICS Tracking and OMB Number: 1820-0690 Revised: 11/5/2012

RIN Number: XXXX-XXXX (if applicable)

There are no gifts or payments 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.2If 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 are no assurances of confidentiality.

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.

There are 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.

 

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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)
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EDICS Tracking and OMB Number: 1820-0690 Revised: 11/5/2012

RIN Number: XXXX-XXXX (if applicable)

 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.

The estimated hour burden is 817 hours Needs Assessment

The estimate below includes not only the time to enter information into the Excel spreadsheet, 

but also the time to collect the information from the agencies and partners being assessed.

Number of Respondents = 10

Frequency of response = Annually

Annual hour burden per TACE = 42 hours 

Annualized cost per TACE = $1,640

Annual hour burden for program overall = 467

Annualized cost for program overall = $16,400

Workplan

The estimate below includes not only the time to enter information into the Excel spreadsheet, 

but also the time to negotiate the workplan with agencies and partners to receive services. It also 

includes the time to update the workplan once a year. 

Number of Respondents = 10

Frequency of response = Annually

Annual hour burden per TACE = 25 hours 

Annualized cost per TACE = $1,025

Annual hour burden for program overall = 250

Annualized cost for program overall = $10,250

Participant survey

Number of Respondents per TACE = 2,000

Number of Respondents for program overall = 2,000

Frequency of response = N/A (each participant will fill out survey once)

Hour burden per respondent = 3 minutes
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EDICS Tracking and OMB Number: 1820-0690 Revised: 11/5/2012

RIN Number: XXXX-XXXX (if applicable)

Hour burden for participant survey = 100

Annualized cost = 0 (costs included in workplan above)

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 startup 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 : 

There is no cost associated with the needs assessment, workplan, or participant survey that is not 

included in item 12 above. Respondents need only to use existing computers and Internet access 

for this information collection. Further, all ten TACE Centers already administer follow-up 

surveys to all activity participants for their own purposes. 
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EDICS Tracking and OMB Number: 1820-0690 Revised: 11/5/2012

RIN Number: XXXX-XXXX (if applicable)

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.

RSA employs a program specialist at the GS-14 level who dedicates 100% of his/her time to the 

administration of the TACE program. RSA estimates that this program specialist will dedicate 

50% of his/her time to this information collection (50% of 102,000 per year = $51,000). 

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).

Since the TACE Centers will no longer submit their data collection via the Internet through the 

RSA Management Information System (MIS), there is a program change decrease of -250 annual 

burden hours. The centers reported that the RSA MIS was cumbersome as the drop-down menus 

and the selection options via “check boxes” provided limited choices and did not provide an 

accurate picture of the services and technical assistance that the centers were providing to the 

State VR agencies and their partners. The TACE centers also reported that the RSA MIS was 

time-consuming and at times caused a burden on staff.

The TACE Centers will begin inputting their data collection into an Excel spreadsheet and will 

be uploading and submitting it online through G5, the Department of Education's Grants 

Management system. This new data collection method will improve the quality and accuracy of 

the data collected by reducing incorrect data or misinterpretation of reporting requirements for 

several key data fields. The information collected on the Excel spreadsheet adheres to the 

requirements already set forth in regulations and grant agreements.

The TACE Centers will be required to submit their workplans annually instead of semi-annually. 

This will decrease the burden hours for reporting and will eliminate the duplication of 

information, which provided limited supportive data in the management of the program.

In addition, there is an adjustment increase of 100 hours for the participant survey, the 

Department has assessed the potential burden from the participant surveys, and included these 

hours as an adjustment increase.
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EDICS Tracking and OMB Number: 1820-0690 Revised: 11/5/2012

RIN Number: XXXX-XXXX (if applicable)

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.

None of the information in this collection will be published.

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.

The expiration date will be displayed.

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

Paperwork Reduction Act.

There are no exceptions to the certification statement.