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

**Modifications	under	the	Workforce	Innovation	and	Opportunity	Act 12**  **05 -**  **0NEW Ju** **ly 2015** 

1 **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	circumst ances	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	i nformation.**  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	S tate	Plan	provisions.	See 29	U.S.C.	§§ 3112	and	3113
. The Unified	or	Combined	State	Plan	requirements are	designed	to improve	service	integratio n	and ensure	that	the publicly- funded workforce	system provide s 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	i n	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
. S ection	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, D islocated Worker, and Youth	programs (title	I) ; Adult E ducation	and Family	L iteracy 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	includ ing the aforementioned core	programs	plus	one	or more	of	the	optional	Federal	programs	listed	in	section 103(b).	State s choos ing 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	Re habilitation	Act	of	1973,	as	amended
. For	States	that choose	to	submit	a	Combined	State	Plan, the existing	information	collections	for the	program specific S tate	plans for	the	optional	programs will	continue	to	exist	under	their	current	control numbers
. O nce	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**Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan**

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2 a	Combined	State	Plan	is	approved, the	State	is	not	required	to	submit	any	other S tate	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 S tate	may	have	to	subm it	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 i nclude	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	Service s 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	i nclude	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, S tates	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 S tate	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.	Re g.	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	Pa rt	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 S tates	must	submit	their	first U nified 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	pla ns	must	be submitted	no	later	than	March	3,	2016. Approval	of	this ICR is	required	as	soon	as	possible	so	that the S tates	can	begin working	to	develop	their	plans,	a	process	that	requires	months	of	coordination among	State	agencies	and	other	stakeholders.**Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan**

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3 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	th e ICR. This	is	intended	to	enable	the D epartments	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 P lan	every	four	years	and	a	S tate	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 P lan	with	the	Secretary	of	Education (WIOA	s ec.	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	Service s Administration of the	Vocational	Rehabilitation services portion	of	the	plan	(WIOA	s ec.	102(c)(2) )
. In	approving	the Unified	State P lan,	the Secretaries	of	Labor	and	Education must determine	whether	the	plan	is	consistent	with Unified State P lan	requirements ,	as	well	as	relevant	requirements	for	each	of	the core	programs	(WIOA	s ec. 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	f ederal 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	includ e	the	planning	e lements	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	thes e	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**Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan**

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4 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 P lan
. **3. Describe	whether,	and	to	what	extent,	the	collection	of	information	involves	the	use**  **of	au tomated,	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)
. Th is	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	Pl an	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	protecte d, and	multiple	users	within	a S tate	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	clea red	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	U nified	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 S tates	to	submit	either	a	Unified	or	Combined	State P lan under	WIOA for	the	core	programs
. This	consolidated	information	collection	will replace	program specific	State	plan	collections	for	each	of	the	core	programs .	Providing	a C ombined State P lan response	will	count	as	a	response	for	any existing	program - specific	State	plan information collection requirements for	any	optional	program or	p rogram	activities that	a	State	includes	in	its Combined	State	Plan
. Unified	and	Combined State	P lans	will	help to improve	program	effectiveness by	promoting	an	overall	collaborative	approach	between	the	various	State	and	Federal	agencies**Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan**

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5 that	provide	the 

### s ervices 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	Unif

ied 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	n on - 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	th at agencies accurately	account	for	overall	burden
. **5. If	the	collection	of	information	impacts	small	businesses	or	other	s**  **mall	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	o r	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 P lan	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	a n	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	of ten	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	uni** **verse	of	study; Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan** 

**Modifications	under	the	Workforce	Innovation	and	Opportunity	Act 12**  **05 -**  **0NEW Ju** **ly 2015** 

6  **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	confiden tial**  **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	pr ior	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	reporte**  **d. 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	inf** 

**ormation	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	potenti al	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	devel opment	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.**Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan**

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7 **9. Explain	any	decision	to	provide	any	payment	or	gift	to	respondents,	o**  **ther	than	re**   ** enumeration	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; r espondents	are S tate	agencies , and S tate	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	t hat	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	reques ted,	and**  **any	steps	to	be	taken	to	obtain	their	consent.** N o	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 .**  **Consu ltation	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	reas ons	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	burde**  **ns.**  **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** 
.**Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan**

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8 **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 S tate P l ans	annually	over	three years.	[(57	+	57)/3	=	38.] S tate P lans	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	burd en	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	consol idate	all	currently- approved	program specific	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	3,27 8 hours
. The	Departments estimate	each	response	will	take	86	hours for	the	Unified State Plan	portion	of	the	response.	(38 respons es	x	86	hours	=	3,268	hours.) For	purposes	of	this	analysis,	the	Departments estimate 10**Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan**

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9 respondents	will	submit	a	Combined	State	Plan and	that	each	response	will	take	one	additional hour	to	complete. (10	responses	x	1	hours =	1 0 hours.	1 0 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/ Sub mission 57 Every 2 years 38 86.25 hours 3,278 $43.23 1 $141,707.94

The	burden	requi red	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	Inf ormation 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 = $4 3 . 23. (180+30=210 + 2= 212 x $43.23=$9,164.76)**Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan**

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10

**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	hours 2 Control	Number	1225 - 0086,	Grant	Application Requirements	for	the	Jobs	for	Veteran s 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	hours 3 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 H ousing	and U rban D evelopme nt	(HUD) tbd 4

2 This number represents estimated average b urden 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 T his number represents estimated average burden for the portion of the CSBG plan that covers employ ment and training activities only. 4 T his number represents estimated average burden for the portion of HUD program plans that cover employment and training activities only.**Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan**

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11 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.) Respons es	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	respons es	for	the	Unified State Plan	requirements as	shown	by	the	prior burden	totals	(i.e
. ,	2,280	L abor 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	$43.23 5 =	$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	informatio n**  **. (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	main tenance	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	sys tem	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	p**  **urchasing	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	subm**  **ission	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	port** **ions	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 annua l 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 n umber of hours worked in a year (1,711). $73,972 annual rate/1,711 hours = $4 3 . 23. (180+30=210 + 2= 212 x $43.23=$9,164.76)**Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan**

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12

**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	a dministrati on may	be	used	by States	for	any	informati on	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	expense**  **s	(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	a n	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 $4,2 27.84,	resulting	in	a	total cost of $ 2 40,987 for	all	57 plans (57	plans	x	64	hours	x	$66.06	=	$240,987)
. Since	p lans	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	estim ated	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
.**Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan**

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13 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 1**  **2	or	1 3.**  This	i s	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 .**  **Add ress	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	pla nning	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	s ubmission	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**  **informa tion	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	c ould 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,**Required	Elements	for	Submission	of	the	Unified	or	Combined	State	Plan	and	Plan**

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14 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.