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OMB 83-1 PAPERWORK REDUCTION ACT

SUPPORTING STATEMENT

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 copy of the appropriate section of each 

statute and regulation mandating or authorizing the collection of 

information. 

The Rehabilitation Act of 1973, as amended (the act), by Public Laws 93-516, 

95-602, 98-221, 99-506, 100-630, 102-569, 103-73, and 105-220 (The 

Workforce Investment Act of 1998 (WIA)) requires each state agency designated 

to administer the State Vocational Rehabilitation (VR) Services Program and the 

State Supported Employment (SE) Services Program to submit a State Plan for 

VR services and a State Plan supplement for SE services. The approved VR 

State Plan and SE supplement form the basis upon which a state participates in 

programs under Title I and Title VI, Part B of the Act and receives federal funds. 

The VR State Plan and its SE supplement are also affected by the general 

requirements for all State Plans under the Education Department General 

Administrative Regulations in 34 CFR Parts 76, 77, 78, 79, 80, 81, 82, and 85, 

regarding such issues as civil rights, administration of rights, and certification of 

authority to submit the State Plan and official signatures. 

There is no reporting burden in the VR State Plan or its SE supplement that is 

not required by the Act itself. The implementing regulations for these programs 

do not impose any State Plan reporting burden beyond that required by the Act. 

Since the previous OMB approval of the VR State Plan and its SE supplement, 

the Rehabilitation Services Administration (RSA) revised the form so that it is 

consistent with changes made to the VR program implementing regulations 

published January 17, 2001. All State Plan provisions, namely assurances 

and/or attachments that had been previously required solely by regulation have 

been deleted. The deletion of these regulatory State Plan requirements is 

designed to reduce administrative burden on the states to better focus resources 

on the employment needs and choices of individuals with disabilities, particularly 

individuals with significant disabilities. This deletion of the regulatory-based 

State Plan requirements is also intended to more closely align the VR State Plan 

requirements with other WIA partner programs.
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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. 

An approved VR State Plan and SE supplement is a condition for the receipt of 

federal funds under Title I and Title VI, Part B of the act. If a state does not 

submit an approvable State Plan and supplement, federal funds to the state for 

operating its VR and its SE programs would be interrupted. Prior to the passage 

of WIA, the VR State Plan and its SE supplement were submitted for a threeyear period, with certain attachments amended annually. States now only need 

to submit a VR State Plan and SE supplement once, and update it under limited 

circumstances as prescribed in the Act. 

The VR State Plan and its SE supplement are key instruments for RSA's 

assessment of a state VR agency's effectiveness in meeting annual performance 

goals and priorities and compliance with the provisions of the Act.

3. Describe whether, and to what 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 electronic submission of responses, and the 

basis for the decision for adopting this means of collection. Also, describe 

any consideration of using information technology to reduce burden. 

Beginning in FY 2009, states have been able to submit their State Plans through 

the RSA website located at http://rsa.ed.gov. In FY 2011, all 80 VR agencies 

submitted their FY 2012 State Plans through the RSA website. In addition, 

states that are not able to transmit their plans using the website can also make 

their submissions to RSA either electronically using e-mail or on CD-ROM, or in 

hardcopy. See pages 3 and 4 of the Guidance for Development and Submittal of 

the State Plan for Vocational Rehabilitation Services and the State Plan 

Supplement for Supported Employment Services for further guidance regarding 

methods of submission. 

It should be further noted that VR agencies frequently maintain electronic case 

service records and often use automated systems to track the progression of 

service delivery for applicants and individuals eligible for VR services, thereby 

further reducing the burden associated with the collection of data and information 

required to be submitted through the State Plans.

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. 
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The information contained in the VR State Plan and its SE supplement is not 

available in any other format or from any other 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. 

This collection of information has no impact on 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.

Title I, Part B, and Title VI, Part B, of the act require submission of a VR State 

Plan and an SE supplement. The act is very prescriptive with respect to the 

content of the Plan and supplement. As already indicated, the State Plan and 

supplement need to be submitted only once with annual revisions, as necessary, 

in order for states to continue to receive federal VR and SE funds. Reviewing 

State Plan materials is the Department's primary method for determining whether 

state VR agencies are conforming to the requirements of the act and meeting 

stated performance goals and priorities. The State Plan and its supplement are 

in effect the legal assurance from the state VR agency that it will operate and 

administer the VR services and SE programs in accordance with the provisions 

of the act and implementing regulations, as a condition for the receipt of federal 

funds under Title I, Part B, and Title VI, Part B, of the act.

The act also requires annual monitoring of certain State Plan provisions as well 

as periodic on-site monitoring to determine the extent to which states implement 

the assurances that they make in the State Plans and supplements. The 

information provided to the Department by the state VR agencies in their State 

Plans is critical to these monitoring efforts and determining compliance with the 

requirements of the act, and meeting stated performance goals and priorities. 

7. Explain any special circumstance that would cause an information 

collection to be conducted in a manner: 

o requiring respondents to report information to the 

agency more often than quarterly;

o requiring respondents to prepare a written response to
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a collection of information in fewer than 30 days after 

receipt of it;

o requiring respondents to submit more than an original

and two copies of any document;

o requiring respondents to retain records, other than

health, medical, government contract, grant-in-aid, or

tax records for more than three years;

o in connection with 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 been reviewed 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 with the

pledge, or which 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

procedures to protect the information's confidentiality

to the extent permitted by law. 

There are no special circumstances that require the collection of information to 

be conducted along the lines discussed in the bulleted items above. 

8. If applicable, provide 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 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.
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Describe efforts to consult with persons out-side 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 obtained input from the VR agencies concerning the current version of the 

State Plan, including the hours estimated to develop it and submit it through the 

RSA website, when it was approved by OMB in FY 2009. Since that time, RSA 

has regularly received feedback from VR agencies and its staff concerning the 

online submission process begun in FY 2009 and has made adjustments to the 

online system based on this input. In addition, RSA routinely consults with the 

Council of State Administrators of Vocational Rehabilitation (CSAVR) regarding 

the collection of information, such as that represented by the State Plan. 

Specifically, RSA staff participate in meetings of the CSAVR Management 

Services Committee to discuss, among other matters, the various information 

and data collection instruments used to manage the VR and SE programs. 

During the meetings held in Fall 2011 and Spring 2012, the Committee did not 

recommend any changes to the State Plan form or the online system.

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 provide any payment 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, regulation, or agency policy. 

Based upon the provisions of 34 CFR 361.38, the state VR agency or, as 

appropriate, the designated state VR unit, must maintain policies and procedures 

on the protection, use, and release of personal information consistent with the 

provisions of Section 101(a)(6)(A) of the Act. Confidentiality is further assured 

since all information collected within the State Plan is aggregated data.
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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. This 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 in the information collection 

connected with the VR State Plan or its SE supplement.

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 was estimated. 

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 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 hour 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, 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 80 VR agencies administering the VR and SE programs each submit 

the State Plan and Supplement annually. The estimated hours required 

by each to develop and submit the plan to RSA was reduced from 90 to 

25 hours (the amount in the current OMB inventory) due to the 

streamlining of the plan content as a result of amendments to the act and 

implementing regulations, described in more detail in the Supporting 

Statement associated with the extension of prior versions of the State 
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Plan, and the use of the online reporting system begun in FY 2009. 

Consequently, the total hours required by the 80 agencies to develop and 

submit the State Plans is estimated to be 2,000.

In addition, the time required by the VR agencies associated with the record 

keeping through which they obtain the information and data needed for inclusion 

in the State Plan was affected by changes to the implementing regulations 

focusing on the reduction and/or elimination of duplicative and unimportant 

service record content elements. On an annual basis, approximately 1.5 million 

individuals are either applicants for or eligible for VR and SE services. A record 

of service is required for each individual and documents the major decision 

points in the provision of VR and/or SE services to assist the individual to 

achieve an employment outcome. Within the context of federal requirements 

that do not replicate normal accountability documentation that would exist even if 

there were no federal requirements, it is estimated that the average time spent in 

recordkeeping on an annual basis approximates 40 minutes per service record, 

for a total of 1,000,000 hours. 

Combining the annual reporting and recordkeeping estimates, the estimated 

aggregate annual burden approximates 1,002,000 hours.

(1) Number of state agencies submitting State Plans: 80

(2) Total burden hours: 1,002,000

(3) State hourly rate of salary: $22.00 

(4) Total State cost: $22,044,000

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.) 

o The cost estimate should be split into two components: (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 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 
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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 

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 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.

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 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. 

No burden has been imposed by a total capital and start-up cost component or 

by a total operation and maintenance and purchase of services component. 

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. 

(1) Review of 80 State Plans estimated at 4 hours per plan = 320 hours (This 

estimate does not indicate time needed by RSA for negotiations.) 

(2) Federal hourly rate of salary: $49.00

(3) Total federal cost: 320 hours for review x $49.00 = $15,680.00
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15. Explain the reasons for any program changes or adjustments reported in 

item 16 of the new OMB Form 83-I. 

No adjustments were made to the hours or costs associated with the 

development and submission of the State Plans by the VR agencies, or to the 

time and costs connected with their review and approval by RSA staff, reflected 

in the current OMB inventory.

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.

RSA publishes the approved State Plans on its website annually in accordance 

with the following schedule. 

 Submission of State Plans by VR Agencies – July 1st

 Plans reviewed, revised as necessary and materials prepared for approval -

September 10th

 All State Plans approved and published on RSA website - September 30th

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 approval to not display the expiration date for OMB approval 

of the information collection. 

18. Explain each exception to the certification statement identified in,

"Certification for Paperwork Reduction Act Submissions.”

There are no exceptions to the certification statement. 

B. Collection of Information Employing Statistical Methods

The VR State Plan is a legal document and does not require the use of any 

statistical methods in obtaining information.