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RSA-2 Responses and Comments 

A total of 11 commenters responded to the Notice of Proposed Information Collection for the 

Annual Vocational Rehabilitation Program/Cost Report (RSA-2), published in the Federal Register on 

July 2, 2012, including the Council of State Administrators for Vocational Rehabilitation 

(CSAVR), the membership organization for all 80 vocational rehabilitation (VR) agencies. 

These commenters provided a total of 35 comments, eight of which addressed the proposed time 

frame for implementation of the form, 23 related to the form’s instructions and data fields, and 

several supporting the change and the benefits of streamlining the data collection process. 

# Comment Response to Comment

1 Eight commenters expressed concern that the 

proposed FY 2013 implementation date for the 

RSA-2 form does not provide a reasonable 

timeframe to make necessary adjustments for the

data collection, and proposed pushing the 

implementation date back to FY 2014 or FY 2015. 

Commenters indicated the timeframe did not 

provide sufficient time for the agencies to update 

data tracking software in their case management 

systems, secure necessary funds to make the 

software updates, and train staff. Additionally, 

the expected implementation of the RSA-911 is 

FY 2014, and commenters indicated premature 

implementation of the RSA-2 will misalign the 

data in the annual reporting and other reports 

available on the RSA MIS system.

In an effort to align the data collection efforts of 

the RSA-2 form with the RSA-911 form, the RSA2 form will be implemented for data collection 

starting in federal FY 2014. 

2 Three commenters noted concerns surrounding 

the impact of calculating Labor Hours in Schedule 

II. One inquired how the formula change would 

impact the agency’s ability to complete the 

section, as the agency considers 37.5 hours a fulltime work week. The second questioned when a 

full-time position is vacant for a part of the year, 

whether the position is counted under full-time or 

part-time employment. The third asked how the 

calculation change from person years to labor 

hours will affect the funding of discretionary 

grants that base award allocation on this data. 

Since the calculation itself results in labor hours, 

RSA will include a data field in which VR agencies 

may input the number of hours per week

considered full-time in their states. The examples 

provided are to assist agencies in calculating labor 

hours for staff members who work varying 

schedules. For positions that are vacant part of the 

year, the calculation would simply include the 

hours worked/week X weeks worked, and would 

not include time in which positions are vacant. 

The addition of the full-time hours data element 

will facilitate equal consideration for all states 

receiving discretionary grants that are determined 
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# Comment Response to Comment

based upon RSA-2 data.

3 Four commenters responded that the instructions 

for Schedule III are confusing since they state the 

dollar amounts to be reflected on Schedule III are 

the same as the total of the amounts included in 

Schedule I, Section 2, Service Expenditures; 

however, Schedule I, Section 2 includes services 

purchased by the agency, as well as expenditures 

from services provided by agency field office staff 

and agency-operated community rehabilitation 

program (CRP) staff. 

RSA concurs with these concerns and has revised

the Schedule III instructions to clarify that the 

dollar amounts on Schedule III should reflect the 

total of the amounts included in Schedule I, Section 

2.B, Expenditures from Services Purchased by the 

Agency from Public CRPs, Private CRPs, Other 

Public Vendors and Other Private Vendors. 

Agencies will not be required to report numbers 

and amounts for individuals served through 

Services Provided by Agency (Schedule I, Section 

2.A). 

4 Two commenters referenced the definition of 

“Other Services,” including Orientation, Mobility 

and Rehabilitation Teaching/Training Services. 

One noted an error referencing an incorrect line 

on the RSA-2 form stating that expenditures for 

salaries of staff and support personnel, and other 

agency expenses for the provision of management 

and supervision and other services under the 

Business Enterprise Program, should be reported 

on Schedule I, line 4C. The reference to Schedule 

I line 4C should be line 3C. 

The second commenter inquired as to whether the 

example of job coaching reference supported 

employment job coaching or non-supported 

employment job coaching. 

RSA agrees with this comment and will correct the 

error in the definition of “Other Services,”

including Orientation, Mobility and Rehabilitation 

Teaching/Training Services, to reflect line 3C in 

Schedule I. 

Since Schedule I 2.A.1.b and 2.A.2.b include 

supported employment and Title I VR funds, 

expenditures related to job coaching include both 

supported employment and non-supported 

employment job coaching.

5 One commenter noted in the instructions for 

Schedule III, Service Category 20 (Rehabilitation 

Technology), that the inclusion of examples that 

are not explicitly identified in the Rehabilitation 

Act or VR implementing regulations should be 

removed, as the examples could confuse staff into 

believing that the device, and not the need to 

overcome disability-related barriers, defines 

Rehabilitation Technology. 

The definition included in the instructions to the 

RSA-2 was developed from Section 7(30) of the 

Rehabilitation Act, the definition found at 34 CFR 

361.5(b)(45), and the language found at 34 CFR 

361.48(q). The definition of “rehabilitation 

technology” at 34 CFR 361.5(b)(45) includes the 

terms rehabilitation engineering, assistive 

technology devices and assistive technology 

services. The definitions for these terms have been 

incorporated into the definition for rehabilitation 
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# Comment Response to Comment

technology found within the instructions for the 

RSA-2, which is consistent with that contained in 

the instructions for the RSA-911. 

RSA specifically included the examples of hearing 

aids, low vision aids and wheelchairs within the 

instructions to provide VR agencies clarification 

and consistency on this subject. The manner in 

which VR agencies have reported the provisions of 

these devices varies not only from agency to 

agency, but has been reported differently within the 

same agency depending upon the circumstances. 

RSA believes it necessary to include these 

particular examples to ensure agencies are 

reporting the provision of rehabilitation technology 

consistently.

6 One commenter noted in the instructions for 

Schedule III, Service Category 25 (Information 

and Referral) Services, that VR implementing 

regulations do not require services to be provided 

through a cooperative agreement, as described in 

the RSA-2 instructions. 

RSA agrees with this comment and has included an 

“e.g.” before cooperative agreements to indicate 

that this is an example, but is not limiting the 

sources through which information and referral 

services may be provided. 

7 One commenter indicated that GED training be 

moved from Service Category 13 (Miscellaneous 

Training) in Schedule III to Service Category 10 

(Basic Academic Remedial or Literacy Training).

RSA disagrees with this comment as GED training 

is a more advanced level of training than obtaining 

basic or remedial functioning to meet the minimum 

standards to function on the job in the competitive 

labor market.

8 One commenter was concerned about Schedule 

III, Service Category 27 (Customized 

Employment Services), asking what type of 

services are included in this category; if RSA 

expects VR Counselors to track their time, so cost 

can be associated with this category; and how will

an agency differentiate between job coaching in a 

non- customized setting from job coaching in a 

customized setting? The agency requested that 

this category be eliminated, or, if retained, 

described in much further detail, so that 

RSA reiterates that the instructions describe the 

type of services to be included under Service 

Category 27 (Customized Employment Services). 

RSA clarified that VR Counselor time is not 

reported under Schedule III, because only 

expenditures from purchased services are reported. 

Job Coaching is reported in Service Categories 16 

and 17 related to On-the-job Supports, and should 

not be reported under Customized Employment 

Services. 
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# Comment Response to Comment

expectations are clear.

9 One comment inquired as to whether RSA will 

provide technical assistance and training related to 

the RSA-2 form. 

RSA plans to provide training after the final policy 

directive for the RSA-2 form is released. Grantees 

will be notified of training opportunities prior to 

their availability. 

10 One commenter indicated that the proposed 

changes list degrees at colleges that are not 

possible to attain at those places. The example 

provided was that a vocational degree cannot be 

obtained at a university, and this option should be 

removed. 

RSA reviewed the instructions related to Schedule 

III, Service Category 7 (Occupational or 

Vocational Training), which indicates 

occupational, vocational, or job skills training 

provided by a community college and/or business, 

vocational/trade or technical school to prepare 

students for gainful employment in a recognized 

occupation, not leading to an academic degree or 

certification. This definition does not reference 

universities and RSA substantiates that the 

description is accurate. 

11 One commenter inquired as to whether RSA was 

using a cost-benefit analysis using RSA-2 data

based upon a formula used by the Government 

Accountability Office (GAO), and that the RSA-2 

form should only include data related to costs of 

individuals achieving an outcome, not open cases. 

RSA does not utilize a cost-benefit analysis 

formula from GAO or other offices. RSA 

reiterates that the RSA 2 report must reflect all 

expenditures for the VR and SE programs made 

during the FY from federal, state and other 

rehabilitation funds. Reporting of costs restricted 

to outcomes does not provide data on the entirety 

of monetary effort spent on the vocational 

rehabilitation program. This effort allows RSA to 

determine the average cost of the services the VR 

program provides, compare single agency data 

across a given timespan, as well as make 

comparisons between agencies and to national 

averages. RSA has eliminated the first bullet on 

page 1 that referenced agency goals, and has 

clarified how the data analysis is used.

12 One commenter inquired as to how expenditures 

for consultative and technical assistance services 

to assist educational agencies in planning for the 

transition of students with disabilities from school 

to post-school activities, including employment

Expenditures for services to groups should not 

include expenditures related to the provision of 

services to individuals identified on the 

individualized plan for employment (IPE). Since 

VR staff costs are included in Schedule I, Section 
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# Comment Response to Comment

(Services to Groups) should be accounted for, and 

if it should utilize staff time related to percentage 

of cases in a particular status. 

2.A, the Services to Groups costs should only 

represent the expenditure of VR funds on 

purchased services, including consultative and 

technical assistance services to educational 

agencies in planning for the transition of students 

with disabilities from school to post-school 

activities. This may include paid training sessions 

or contracts with providers to conduct training or 

provide technical assistance. 

RSA added a category for Transition Consultation 

and Technical Assistance (3.D.) under Services to 

Groups in Schedule I to clarify that these expenses 

should be included. 

13 Two commenters made reference to the fact that 

the RSA-2 instructions indicate expenditures for 

the report do not include unliquidated obligations. 

One commenter indicated that this will require the 

agency to implement modifications to its

accounting system because the new form requires 

it to change from the modified accrual basis to a 

cash basis of accounting. The other commenter 

indicated that since no unliquidated obligations 

are included on the RSA-2, it will be required to 

make programming changes and conduct testing

of its case management system. 

RSA confirms that the RSA-2 report requires 

agencies to only report liquidated expenditures, and 

excludes unliquidated obligations; however, this 

change does not require VR agencies to change 

their accounting to a cash basis. Since the RSA-2 

requires accrual information, if the recipient’s 

accounting records are kept on the cash basis, the 

recipient shall not be required to convert its 

accounting system. Instead, the recipient must 

develop such accrual information through best 

estimates using available documentation, in 

accordance with OMB Circular A-102. This 

approach is consistent with the reporting 

requirements for the Federal Financial Report (SF425). 

14 One commenter noted that the description of 

Schedule III, Service Category 3 (Vocational 

Rehabilitation Counseling and Guidance) is a new 

category that appears to overlap with Category 2 

(Diagnosis and Treatment of Impairments).

RSA concurs and will be using the description of 

Vocational Rehabilitation Counseling and 

Guidance as it is written in the VR implementing 

regulations.

15 One commenter indicated that since new Service 

Categories have been introduced including Job 

Search Assistance, Job Placement Assistance, and 

Customized Employment Services, that it will be 

RSA concurs that the RSA-2 form will require 

software system modifications and training for VR 

agency, CRP and vendor staff to learn the 

differences between each of the categories. 
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# Comment Response to Comment

a challenge to train staff and vendors to separate 

generic Job Development activities into the three 

discrete categories.