Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan	

Modifications	under	the	Workforce	Innovation	and	Opportunity	Act

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SUPPORTING	STATEMENT	FOR

PAPERWORK	REDUCTION	ACT	OF	1995	SUBMISSIONS

“Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan	Modifications	

under	the	Workforce	Innovation	and	Opportunity	Act”

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.

This	consolidated	information	collection	would	implement	sections	102	and	103	of	the	

Workforce	Innovation	and	Opportunity	Act	(WIOA)	(P.L.	113-128).	WIOA requires	that, no	later	

than	March	3,	2016, each	State,	at	a	minimum,	submit	a	Unified	State	Plan	as	a	condition	of	

receiving	funds	for	core	programs	subject	to	the	Unified	State	Plan	requirements.	In	the	alternative,	

States	may	submit	a	Combined	State	Plan	as	a	condition	of	receiving	funds	under	certain	named	

programs	subject	to	the	Combined	State	Plan	provisions.	See	29	U.S.C.	§§ 3112	and	3113.	 The	

Unified	or	Combined	State	Plan	requirements	are	designed	to	improve	service	integration	and	

ensure	that	the	publicly-funded	workforce	system	provides a	range	of	employment,	education,	

training,	and	related	services	and	supports	to	help	all	jobseekers	secure	good	jobs	while	providing	

businesses	with	the	skilled	workers	they	need	to	compete	in	the	global	economy. To	that	end,	the	

Unified	or	Combined	State	Plan	would	describe	how	the	State	will	develop	and	implement	a	unified,	

integrated	service	delivery	system	rather	than	discuss	the	State’s	approach	to	operating	each	

program	individually.	

Section	102(a)	of	WIOA	requires	each	State,	at	a	minimum, to	submit	a	Unified	State	Plan	

that	fosters	strategic	alignment	of	the	core	programs,	which	include	the	Adult,	Dislocated	Worker,	

and	Youth	programs (title	I);	Adult	Education	and	Family	Literacy	Act program (title	II);	the	

Wagner-Peyser	program (title	III);	and	the	Vocational	Rehabilitation	program (title	IV).	In	the	

alternative,	section	103	of	WIOA	permits	a	State	to	submit	a	Combined	State	Plan	including the	

aforementioned	core	programs	plus	one	or more	of	the	optional	Federal	programs	listed	in	section	

103(b).	States choosing to	submit	a	Combined	State	Plan,	are	required		to incorporate	all	of	the	

common	planning	elements	required	in	the	Unified	State	Plan,	additional	elements describing	how	

the	State	will	coordinate	the	optional	programs	with	the	core	programs	(WIOA	sec.	103(b)(3)),	and	

elements	 required	by	the	optional	program(s)	that	are	included	in	the	Combined	State	Plan.	

The	consolidated	information	collection	for	the	Unified	or	Combined	State	Plan	and	Plan	

Modifications	will	replace	existing	planning	information	collections	for	the	core	programs under	

various	statutes,	including	the	Workforce	Investment	Act of	1998 (WIA) (P.L. 105-220),	the	Adult	

Education	and	Family	Literacy	Act, and	the	Rehabilitation	Act	of	1973,	as	amended.	For	States	that	

choose	to	submit	a	Combined	State	Plan,	the existing	information	collections	for	the	programspecific	State	plans for	the	optional	programs will	continue	to	exist	under	their	current	control	

numbers. Once	approved,	a	State’s	Combined	State	Plan	meets	the	information	collection	

requirements	for	the	program-specific	State	plans	for	all	optional	programs	that	a	State	includes.	If	
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a	Combined	State	Plan	is	approved,	the	State	is	not	required	to	submit	any	other	State	plan	to	

receive	federal	funding	for	any	optional	program	covered	under	that	Combined	State	Plan	(WIOA	

sec.	103(b)(2)).	If	a	State	plan	for	an	optional	program	changes	from	the	one	approved	under	the	

Combined	State	Plan,	the	State	may	have	to	submit	additional	plans	to	the	appropriate	

Department—such	additional	plans	will	be	counted	under	the	optional	programs’	existing	

information	collection	requirements.	

Note	that	some	of	the	optional	programs	that a	State may	include	in	the	Combined	State	

Plan	currently	fulfill	their	program-specific	State	planning	requirements	through	a	broader	

information	collection	administered	by	the	program’s	appropriate Department.		For	example,	

section	103(b)(2)	of	WIOA	specifically	allows the employment	and	training	activities	carried	out	

under	the	 Community	Services Block	Grant	(CSBG)	Act	administered	by	the	Department	of	Health	

and	Human	Services	(HHS)	and	employment	and	training	activities	under	the	Department	of	

Housing	and	Urban	Development (HUD) to	be	included	in	a WIOA	Combined	State	Plan.		However,	

for	example,	the	existing	CSBG	information	collection	includes	planning	elements	for	the	

employment	and	training	activities	along	with	planning	elements	for	other	activities	under	CSBG.		

Therefore,	if	States	choose	to	include	programs	such	as	these	in	the	Combined	State	Plan, only	the	

portion	of	the	existing	planning	requirements	that	address	the	employment	and	training	activities	

are	included	in	the	Combined	State	Plan	(WIOA	sec.	103),	and, States	are	still	required	to	separately	

submit all other required elements of a complete CSBG State Plan directly to the Federal agency that 

administers the program.	

The	Department	of	Labor is	hosting	this	information	collection	request	(ICR)	under	the	

“common	form”	clearance	option;	the	Departments	of Education,	Health	and	Human	Services,	

Agriculture,	and	Housing	and	Urban	Development	(all	agencies	to	be	jointly	referred	to	as	the	

“Departments”)	actively	participated	in	the	development	of	this	ICR	and	are	expected	to	be	

signatories	to the	“Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	

Plan	Modifications	under	the	Workforce	Innovation	and	Opportunity	Act”	ICR, which	details	the	

requirements	for	State	plans	submitted	under	WIOA.

As	mentioned	above,	this	ICR is	intended	to	cover	the	state	planning	information	collection	

requirements	in	sections	102	and	103	of	WIOA.		The	notice	of	proposed	rulemaking	(NPRM)	

proposing	regulations	that	would	implement	those	sections	was	published	on	April	16,	2015,	at	80	

Fed.	Reg.	20573.		The	comment	period	closed	on	June	15,	2015.		The	proposed	regulations	that	

correspond	to	these	information	collection	requirements	are:	20	CFR	Part	676	(WIOA	Adult,	

Dislocated	Worker,	and	Youth	programs	and	Wagner-Peyser	Act	programs);	34	CFR	Part	361,	

Subpart	D	(State	Vocational	Rehabilitation	Services	Program);	and	34	CFR	Part	463,	Subpart	H	

(Adult Education and Family Literacy Act programs).		

Sec.	102(c)(1)(A)	of	WIOA	states	that	States	must	submit	their	first	Unified	Plan	to	the	

Secretary	of Labor	not	later	than	120	days	prior	to	the	commencement	of	the	second	full	program	

year	after	the	date	of	enactment	of	WIOA,	which	was	July	22,	2014.		Therefore,	the	second	full	

program	year	commences	on	July	1,	2016,	and	the	Unified	or	Combined	State	plans	must	be	

submitted	no	later	than	March	3,	2016.	 Approval	of	this	ICR is	required	as	soon	as	possible	so	that	

the	States	can	begin	working	to	develop	their	plans,	a	process	that	requires	months	of	coordination	

among	State	agencies	and	other	stakeholders.
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If	this	ICR receives	OMB	approval,	it	may	be	finalized	before	the	proposed	regulations	are	

finalized.		If	this	occurs,	the	Departments will	resubmit	this	ICR	to	OMB	for	its	approval	when	the	

Final	Rule	is	published,	as	required	by	5	CFR	1320.11(h).		However,	the	Departments	plan	to	review	

and	analyze	any	comments	received	on	the	NPRM	that	are	relevant	to	this	ICR	together	with	

comments	we	receive	in	response	to	the	Federal	Register	Notice	for this	ICR	as	we	finalize	the ICR.		

This	is	intended	to	enable	the Departments	to	finalize	this	ICR	before	the	proposed	regulations,	and	

to	minimize the	need	to	make	substantive	changes	to	the	ICR	when	the	Final	Rule	is	published.

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.

In	order	for	a	State	to	receive	funding	for	the	core	programs,	the	State	must	submit	a	

Unified	or	Combined	State	Plan	every	four	years	and	a	State	plan	modification	at	least	every	two	

years.	A	State	must	submit	its	Unified	State	Plan	to	the	Secretary	of	Labor,	who,	in	turn,	shares	the	

Unified	State	Plan	with	the	Secretary	of	Education (WIOA	sec.	102(c)(1)).	Unified	State	Plans	are	

subject	to	the approval	of	both	the	Secretary	of	Labor	and	the	Secretary	of	Education,	after	approval	

by	the	Commissioner	of	the	Rehabilitation	Services Administration	of	the	Vocational	Rehabilitation	

services	portion	of	the	plan	(WIOA	sec.	102(c)(2)).	In	approving	the	Unified	State	Plan,	the	

Secretaries	of	Labor	and	Education	must	determine	whether	the	plan	is	consistent	with	Unified	

State	Plan	requirements,	as	well	as	relevant	requirements	for	each	of	the	core	programs	(WIOA	sec.	

102(c)(2)(B)).	

When	a	State’s	Combined State	Plan	is	approved,	it	will	be	considered	as	having	met the	

information	collection	requirements	for	the	program-specific	State	plans	for	all	optional	programs	

that	a	State	includes. The State	is	not	required	to	submit	any	other	State	plan	to	receive	federal	

funding	for	any	optional	program	that	it	included	in	the Combined	State	Plan	(WIOA	sec.	

103(b)(2)).		If	a	State	plan	for	an	optional	program	changes	from	the	one	approved	under	the	

Combined	State	Plan,	the	state	may	have	to	submit	additional	plans	to	the	appropriate	

Department—such	additional	plans	will	be	counted	under	the	optional	programs’	existing	

information	collection	requirements.		As	stated	above,	some	of	the	optional	programs	that	a	State	

may	include	in	the	Combined	State	Plan	fulfill	their	program-specific	planning	requirements	

through	a	broader	information	collection	administered	by	the	program’s	appropriate	Department.		

One	example	is	the	CSBG	program	administered	by	HHS,	where	WIOA	section	103(b)(2)	allows	

States	to	include	the	planning	elements	for	employment	and	training	activities carried	out	under	

the	CSBG	program	Act in	the	Combined	State	Plan	but	does	not	include	the	planning	requirements	

for	the	other	activities of	the	CSBG	program.		If	States	choose	to	include	programs	such	as	these	in	

the	Combined	State	Plan,	only	the	portion	of	the	existing	planning	requirements	that	address	the	

employment	and	training	activities	are	included	in	the	Combined	State	Plan	(WIOA	sec.	103),	and,	

States	are	still	required	to	separately	follow	any	other	program	specific	State	plan	requirements.

Portions	of	the	Combined	State	Plan	covering	a	program	or	activity,	excluding	those	related	

to	the	core	programs, are	subject	to	approval	by	the	head	of	the	Federal	agency	that	administers	
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such	program (WIOA	sec. 103(d)(2)).	The	portions	of	the	Combined	State	Plan	related	to	the	core	

programs	are	subject	to	the	same	approval	requirements	applicable	to	the	Unified	State	Plan.	

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.

States	will	be	required	to	submit	a	Unified	or	Combined	State	Plan	through	an	online	

submission	system developed	by	the	Department	of	Education’s	Rehabilitation	Services	

Administration	(RSA).	This	system	has	been	in	use	for	several	years	by	RSA	programs	and	is	being	

adapted	for	the	Unified	or	Combined	State	Plan.	 The	system	features	a	web-based	portal that	

allows	users	to	enter	data	and	text	in	response	to	the	Unified	or	Combined	State	Plan	elements,	is	

508	compliant,	and	allows	for	public	posting	of	approved	plans.		Grantees	will	access	this	portal	

through	a	landing	page	on	DOL’s	website,	although	the	portal	will	be	temporarily	maintained	on	

RSA’s	servers.		The	system	is	password	protected, and	multiple	users	within	a	State	will	be	given	

access	to	the	system.	The	Departments	will	provide	technical	assistance	on	using	the	system	once	it	

is	available.	The	Departments	believe	that	online	submission	will	reduce	burden	on	the	States	and	

facilitate	the	review	and	approval	process	at	the	Federal	level.	While	this	system	is	not	yet	

available,	the	Departments	are	using	this	ICR	to obtain	PRA	approval	for	the	portal	as	it	will	actually	

appear	to	respondents.	As	substantive	requirements	are	being	cleared	at	this	time,	the	Departments	

anticipate	clearing	the	portal	as	a	non-substantive	change,	a	process	that	does	not	require	public	

engagement	for	certain	limited	minor	changes	to	an	ICR.			

If	the	system	is	unavailable	when	States	are	ready	to	submit	a	Unified	or	Combined	State	

Plan,	then	States	can	temporarily	submit	via	email (address	to	be	determined) a	508-compliant	

Word	or	PDF	document..

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.

Currently,	States	submit	program-specific	State	plans. The	proposed	consolidated	

information	collection,	known	as	the	“Required	Elements	for	Submission	of	the	Unified	or	

Combined	State	Plan and	Plan	Modifications	under	the	Workforce	Innovation	and	Opportunity	Act,”	

is	the	only	data	collection	instrument	for	States	to	submit	either	a	Unified	or	Combined	State	Plan	

under	WIOA for	the	core	programs.	This	consolidated	information	collection	will replace	programspecific	State	plan	collections	for	each	of	the	core	programs.	Providing	a	Combined State Plan	

response	will	count	as	a	response	for	any existing	program-specific	State	plan	information	

collection requirements for	any	optional	program or	program	activities that	a	State	includes	in	its	

Combined	State	Plan. Unified	and	Combined	State	Plans	will	help	to improve	program	effectiveness	

by	promoting	an	overall	collaborative	approach	between	the	various	State	and	Federal	agencies	
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that	provide	the services under the core and combined plan partner programs, and potentially will 

lead to increased efficiencies as service duplication will be minimized.

This	ICR	will	replace	and	subsume	the	residual	burden	reported	in	the	ICRs	that	currently	

contain	Unified	State	Plan	requirements.	The	burden	required	for	fulfilling	the	program-specific	

State	Plan	requirements	for	the	optional	programs	that	may	be	included	in	the	Combined	State	Plan	

will	continue	to	be	separately	accounted	for	under	the	optional	programs’ existing,	approved	

Information	Collections,	except	for	the	burden	for	each	Department	under	this	ICR related	to use	of	

the	Combined	State	Plan. See	item	12	for	a	description	of	how	burden	will	be	apportioned.	

Corresponding	non-substantive	change	requests will	be	cleared under	each	separate	ICR	covering	a	

program	or	program	activities	included	in	a	Combined State Plan;	this	will	ensure	that agencies	

accurately	account	for	overall	burden.

5. If	the	collection	of	information	impacts	small	businesses	or	other	small	entities,	,	

describe	any	methods	used	to	minimize	burden.

The	proposed	information	collection	affects	only	States,	not	small	businesses	or	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.

Sections	102	and	103	of	WIOA	require	that	the	State	submit	a	Unified	or	Combined	State	

Plan	every	four	years	and	a	plan	modification	at	least	every	two	years.	A State	will	not	receive	

funding	for	core	programs	if	it	fails	to	submit	an	acceptable Unified	or	Combined	State	Plan (WIOA	

sec.	102(a)).	 If	this	information	collection	is	not	allowed,	the	Departments	will	have	no	authority	to	

provide	funding	to	states	authorized	by	WIOA,	and	therefore,	the	statute	will	fail	to	be	implemented	

as	intended.

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	that	can	be	generalized	to	the	universe	of	study;
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 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	which	unnecessarily	

impedes	sharing	of	data	with	other	agencies	for	compatible	confidential	use;	or

 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	in	a	manner	inconsistent	with	5	CFR	1320.5.

8. If	applicable,	provide	a	copy	and	identify	the	data	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.

Describe	efforts	to	consult	with persons	outside	the	agency	to	obtain	their	views	on	

the	availability	of	data,	frequency	of	collection,	the	clarity	of	instructions	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.

The	Departments	have	engaged	the	public	through	an	NPRM	published	on	April	16,	2015	

(80	FR	20573)	and	will	in	accordance	with the	PRA	publish	a	60-day	Federal	Register Notice.

In	addition,	the	Departments	sought	early	stakeholder	engagement	through	a	series	of	

listening	sessions.	Those	sessions	resulted	in	better	understanding	by	the	Departments	of	the	

States’	needs	related	to	planning	and	potential	areas	of	clarification.		In	particular,	States	requested	

that	instructions	and	the	ICR be	a	joint	effort	of	affected	Federal	programs,	modeling	the	

cooperative	and	collaborative relationship	that	WIOA	expects	in	the	Unified	and	Combined	State	

Plan	development	and	implementation.		The	proposed	ICR has	been	developed	to	meet	that	need,	

and	included	the	involvement	of	all	WIOA	core	programs	and	the	optional	Combined	State	Plan	

programs.	
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9. Explain	any	decision	to	provide	any	payment	or	gift	to	respondents,	other	than	reenumeration	of	contractors	or	grantees.

No	payment	or	gifts	will	be	provided to	respondents.

10. Describe	any	assurance	of	confidentiality	provided	to	respondents	and	the	basis	for	

the	assurance	in	statute,	regulation,	or	agency	policy.

There	are	no	assurances	of	confidentiality;	respondents	are	State	agencies, and	State	plans	

are	public	documents.	

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.

No	information	of	a	sensitive	nature	will	be	requested in	the	proposed	information	

collection.

12. Provide	estimates	of	the	hour	burden	of	the	collection	of	information.	The	statement	

should:

 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	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.

 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.
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Respondents	and	Annual	Responses

There	are	57	States	and	outlying	areas,	including	the	50	states,	the	District	of	Columbia,	the	

Commonwealth	of	Puerto	Rico,	the	Virgin	Islands,	Guam,	the	Northern	Mariana	Islands,	American	

Samoa,	and,	for	certain	programs,	the	Republic	of	Palau.	These jurisdictions	will	submit	a	plan	the	

first	year	that	plans	are	required,	and	all	57	states	and	outlying	areas	are	required	to	submit	an	

update	in	the	third	year	of	the	planning	cycle.	No	other	submissions	are	required	in	unless	it	is	a	

program-specific	requirement	for	an	optional	program	included	in	a	State’s	Combined	State	Plan.	

This	means	that	the Departments	estimate	they	will	receive	38	State	Plans	annually	over	three	

years.	[(57	+	57)/3	=	38.]		State	Plans	annually	over	three	years.	[(57	+	57)/3	=	38.]	This	is	the	same	

as	the	current	planning	documents	for	each	separate	program.	For	purposes	of	Reginfo.gov	

database	entry	purposes,	the	Departments	assume	38	respondents	will	annually	submit	an	average	

of	one	response	each.

As	explained	in	question	1	above,	this	collection	will	replace	the	following	currentlyapproved	State	Plan	collections	for	the	core	programs that	currently	impose	a	combined	burden	of	

6,845	hours:

 Control	Number	1205-0398,	Planning	Guidance	and	Instructions	for	Submission	of	the	

Strategic	State	Plan	and	Plan	Modifications	for	Title	I	of	the	WIA and	Wagner-Peyser	Act,	

with	an	annual	burden	of	2,280 hours;

 Control	Number	1830-0026,	Adult	Education	and	Family	Literacy	Act	State	Plan,	with	an	

annual	burden	of	2,565 hours;	and

 Control	Number	1820-0500,	State	Plan	for	the	Vocational	Rehabilitation	Services	

Program	and	Supplement	for	the	Supported	Employment	Services	Program	(now	

referred under	WIOA	as	the	VR	services	portion	of	the	Unified	or	Combined	State	Plan),	

with	an	annual	burden	of	2,000 hours.

In	an	effort	to	give	full	meaning	to	the	requirement	that	States	submit	a	Unified	or	

Combined	State	Plan,	the	Departments	propose	to	consolidate	all	currently-approved	programspecific	State	Plan	submissions	for	each	of	the	core	programs	into	one	information	collection	

instrument.	To	that	end,	the	total	burden	hours	associated	with	this	proposed	new	consolidated	

information	collection	is	the	sum	of	the	additional	burden	required	to	satisfy	the	integrated	

strategic	and	operational	planning	requirements	plus	the	currently-approved	requirements	(see	

bullets	above).	However,	the	net	additional	burden	to	respondents	is	only	that	associated	with	the

new	planning	requirements.	

Burden	Hours	and	Monetized	Time	Value

The	Departments	estimate	the	annual	time	burden	to	be	3,278 hours.	The	Departments	

estimate	each	response	will	take	86	hours for	the	Unified	State	Plan	portion	of	the	response.	(38	

responses	x	86	hours	=	3,268	hours.)	For	purposes	of	this	analysis,	the	Departments	estimate 10	
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respondents	will	submit	a	Combined	State	Plan and	that	each	response	will	take	one	additional	

hour	to	complete.	 (10	responses	x	1	hours =	10 hours.	10 hours/38	total	responses	=	0.25, rounded	

to	the	quarter	hour).	This	results	in	a	total	burden	of	86.25	hours	per	response.	(86	hours	+	0.25	

hours	=	86.25	hours.	The	total	annual	time	burden	would	be	3,278	hours.	(86.25	x	38	responses	=	

3277.5	hours.).

Activity Number of 

Respondents

Frequency Total 

Annual 

Responses

Time Per 

Response

Total 

Annual 

Burden 

(Hours)

Hourly 

Rate*

Monetized 

Value of 

Respondent 

Time

WIOA State 

Plan 

Preparation/ 

Submission

57 Every 2 

years

38 86.25 

hours 3,278 $43.231 $141,707.94

The	burden	required	for	fulfilling	the	program-specific	State	Plan	requirements	(for	the	

non-core,	optional	programs	that	may	be	included	in	the	Combined	State	Plan)	will	continue	to	be	

separately	accounted	for	under	the	non-core,	optional programs’	existing,	approved	Information	

Collections.	Those	existing	Information	Collections	are	described	in	the	table	below	for	reference:

 

1

The hourly rate is computed by dividing the FY 2014 national average PS/PB annual salary for state staff as 

provided for through the distribution of state UI administrative grants 

(http://wdr.doleta.gov/directives/attach/UIPL/UIPL_23_13_Att1.pdf) by the number of hours worked in a year 

(1,711). $73,972 annual rate/1,711 hours = $43.23. (180+30=210 + 2= 212 x $43.23=$9,164.76)
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Optional	Program	Control	Number Approved	Burden	Hours

Control	Number	1830-0029,	Carl	D.	Perkins	

Career	and	Technical	Education	Act	of	2006	

(P.L. 109-270)	State	Plan	Guide 2,240	hours	

Control	Number	0970-0145,	Temporary	

Assistance	for	Needy	Families	(TANF)	State	

Plan	Guidance 594	hours

Control	Number	0584-0083,	Supplemental	

Nutrition	Assistance	Program	(SNAP)Operating	

Guidelines,	Forms,	and	Waivers,	Program	and	

Budget	Summary	Statement 1431	hours2

Control	Number	1225-0086,	Grant	Application	

Requirements	for	the	Jobs	for	Veterans State	

Grants	Program 1620	hours

Control	Number	1205-0132,	Unemployment	

Insurance	State	Quality	Service	Plan	Planning	

and	Reporting	Guidelines 1,530	hours

Control	Number	1205-0040,	Senior	Community	

Service	Employment	Program	Performance	

Measurement	System 406	hours

Control	Number	0970-0382,	Community	

Services	Block	Grant	(CSBG)	Model	Plan	

Applications

112	hours3

Control	Number	1205-XX,	Trade	Adjustment	

Assistance	program 50	hours

Control	Number	1205-XX,	Reemployment	

Opportunities	Grant	Program	 40	hours

Control	Number	XX,	Employment	and	Training	

Activities	carried	out	by	the	Department	of	

Housing	and	Urban	Development	(HUD) tbd4

 

2

This number represents estimated average burden for the portion of the SNAP plan that covers programs 

authorized under section 6(d)(4) and section 6(o) of the Food and Nutrition Act of 2008 only. 

3

This number represents estimated average burden for the portion of the CSBG plan that covers employment and 

training activities only.

4

This number represents estimated average burden for the portion of HUD program plans that cover employment 

and training activities only.
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In	order	to	allow	partner	agencies	to	sign	on	to	this	common	form	ICR,	all	Departments, except	

Labor	and	Education, will	assume	one	response for	86	hours,	a	combined	burden	share	of	344	

hours.	(4	Departments	x	86	hours	=	344	hours.)	Responses	between	the	Departments	of	Labor	and	

Education	for	the	remaining	2,934	burden	hours	(3,278	hours	– 344	hours	=	2,934	hours)	are	

respectively	apportioned	on	a	33/67 percent,	split	in	accordance	with	the	level	of	burden	hours	

needed	to	address	the	responses	for	the	Unified	State	Plan	requirements as	shown	by	the	prior	

burden	totals	(i.e.,	2,280	Labor hours/6,845	total	hours	=	33	percent;	4,565	Education	hours/6,845	

total	hours	=	67	percent. Thus	the	DOL	share	of	the	burden	will	be	968	hours	(2,934	x	33%	=	968)	

and	the	Department	of	Education	share	will	be	1,966	hours.	(2,934	x	67%	=	1,966	hours.)

While	States	receive funds that	may	be	used	for	administration (in	part	to	cover	salaries)	to	ensure	

this	information	collection	imposes	no	unfunded	mandates, the	Departments	have	monetized	the	

burden	hours	as	follows:	3,278	hours	x	$43.235 =	$141,707.94. This	cost	is	reflected	in	item	14.

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	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	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	

purchasing	or	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	rule-making	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	

 

5

The hourly rate is computed by dividing the FY 2014 national average PS/PB annual salary for state staff as 

provided for through the distribution of state UI administrative grants 

(http://wdr.doleta.gov/directives/attach/UIPL/UIPL_23_13_Att1.pdf) by the number of hours worked in a year 

(1,711). $73,972 annual rate/1,711 hours = $43.23. (180+30=210 + 2= 212 x $43.23=$9,164.76)
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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.

The agencies	associate no	other	costs	with	this	information	collection.	Program	funds	

provided	by	the	Federal	government	that	may	be	used	in	part	for	administration may	be	used	by	

States	for	any	information	technology	systems	needed	to	comply	with	this	collection.

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.

Based	on	program	experience	and	on	an	assessment	of	average	times	spent	reviewing	plans	

under	WIA,	it	is	estimated	that,	on	average,	8	GS-13s	based	in	the	Washington,	DC	area	will	spend	a	

total	of	8	hours	each,	or	64	hours	total,	reviewing	each	plan.	Pay	for such	an	employee	at	the	Step	4	

level	is	$47.87.6 Providing	a	38	percent	allowance	to	cover	fringe	benefits	and	other	costs, total	per	

hour	cost	for	each employee	is	$66.06	($47.87	x	1.38	=	$66.06); thus, the	Federal	cost	of	reviewing	

and	processing	each	Plan	is	estimated	to	be	$4,227.84,	resulting	in	a	total	cost	of	$240,987 for	all	57	

plans (57	plans	x	64	hours	x	$66.06	=	$240,987).	 Since	plans	are	reviewed	electronically,	

operational	costs,	including	printing	and	support	staff	costs,	do	not	apply.	This	information	is	

summarized	in	the	table	below.

#	Federal	Staff Hours	Per	

Person	to	

Review	Each	

Plan

Per	Person	

Hourly	Rate	

(salary	and	

benefits)

Cost	Per	Plan Number	of	

Plans

Total

8 8 $66.06 $4,227.84 57 $240,987

The	cost	for	developing	the	Web	portal	is	estimated	to	require	no	additional	funds.		

 

6

See http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2015/DCB_h.pdf. 
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As	calculated	in	item 12,	the	Federal	cost	related	to	funds	used	for	administration	that fund	

State	salaries	is	estimated	to	be	$141,707.94.

Federal	administrative	funds	used	to	cover	the	development	of	any	State	systems	needed	to	

comply	with	this	information	collection	are	estimated	to	require	no	additional	funds.

Total	Federal	costs	are	estimated	to	be	$240,987.00	based	on	the	calculations	included	

above.		

15. Explain	the	reasons	for	any	program	changes	or	adjustments	reporting	in	Items	

12	or	13.

This	is	a	new	information	collection	request;	there	is	a	program	change	increase	of	3,278	annual	

burden hours.

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.

For	the	first	planning	year,	State	Plans	are	required	to	be	submitted	to	the	Departments	by	

March	3,	2016.		The	Department	of	Education	and	Labor	must	complete	analysis,	review,	and	

response	on	acceptability	of	State	Plans	within	90 days	of	receipt.		For	any	Combined	State Plan	

programs	administered	by	HHS,	USDA,	or	HUD	that	a	State	may	include	in	its	submission,	response	

for	that	portion	must	be	completed	within	120 days	of	receipt.		Once	approved,	the	Departments	

will	publish	the	State	Plans	electronically	on	the	online	submission	platform.	Such	plans	will	be	

made	available	on	the	portal	publicly.		States	may	choose	to	separately	publish	approved	State	

Plans	in	their	preferred	format.			

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	Departments	request	approval	not	to	display	the	expiration	date	on	any	instruments,	as	

guidance	will	only	be	issued	when	updates	are	required.	Including	the	ICR	expiration	date	could	

cause	confusion	were	the	Departments	required	to	republish	guidance	only	because	the	expiration	

date	was extended;	States	might	be	confused	that	additional	changes	to	the	collection	were	being	

made.	Were	the	Departments	required	to	display	the	expiration	date	but	not	to	reissue	guidance,	

States	might	become	confused	as	to	whether	the	collection	remains	valid.	The	Departments	believe	

inclusion	of	the	public	protection	clause	in	the	public	burden	statement	provides	sufficient	notice,	
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especially	now	that	the	Reginfo.gov	database	provides	easy	access	to	see	whether	a	collection	of	

information	is	approved.	

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

for	Paperwork	Reduction	Act	Submission."

No	exceptions	are	requested.