1

OMB Number: 1820-0608

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification 

1. Explain the circumstances that make the collection of information necessary. 

Identify any legal or administrative requirements that necessitate the collection. 

Attach a hard copy of the appropriate section of each statute and regulation 

mandating or authorizing the collection of information, or you may provide a valid 

URL link or paste the applicable section. Please limit pasted text to no longer than 3 

pages. Specify the review type of the collection (new, revision, extension, 

reinstatement with change, reinstatement without change). If revised, briefly specify 

the changes. If a rulemaking is involved, make note of the sections or changed 

sections, if applicable.

Sec. 752(i)(2)(A) of the Rehabilitation Act of 1973, as amended, (attachment A) and the 

corresponding regulations in 34 CFR 367.11(d) require each grantee under this program 

to submit an annual report to the Commissioner of the Rehabilitation Services 

Administration (RSA) on essential demographic, service and outcome information.

There is no difference between this data collection instrument and the previous one used 

from FY 2010 through FY 2013 which will expire in May 2014. RSA therefore requests 

an extension to use this data collection instrument from FY 2014 through 2016. 

2. Indicate how, by whom, and for what purpose the information is to be used. Except 

for a new collection, indicate the actual use the agency has made of the information 

received from the current collection.

The information collected by RSA will be used to evaluate the program, including any 

new GPRA requirements, and make recommendations to Congress. It provides RSA 

with a uniform and efficient method of monitoring the program for compliance with 

statutory and regulatory requirements. 

The information collected via the Form available cannot be used or modified for use of 

the purposes described in Item 2 above.

ED (RSA)-7-OB is the sole instrument collecting data on services provided under the 

Title VII, Chapter 2 program.

3. Describe whether, and to what extent, the collection of information involves the use 

of automated, electronic, mechanical, or other technological collection techniques or 

forms of information technology, e.g. permitting electronic submission of responses, 

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

consideration given to using technology to reduce burden.

This collection uses the RSA's central reporting system which allows states to submit 

their information electronically. The decision to promote the use of this system was 
2

OMB Number: 1820-0608

made to provide an option to respondents to submit required information more quickly 

and easily. This system also auto-calculates numbers and identifies errors before reports 

can be submitted, which reduces both state and federal government burden by allowing 

States to correct errors quickly and easily before the reports are submitted to the federal 

government for review. 

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.

This is the only data collection instrument used for this purpose. There is no duplication.

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

describe any methods used to minimize burden. A small entity may be (1) a small 

business which is deemed to be one that is independently owned and operated and 

that is not dominant in its field of operation; (2) a small organization that is any notfor-profit enterprise that is independently owned and operated and is not dominant 

in its field; or (3) a small government jurisdiction, which is a government of a city, 

county, town, township, school district, or special district with a population of less 

than 50,000.

This collection does not involve any small business or other small entities.

6. Describe the consequences to Federal program or policy activities if the collection is 

not conducted or is conducted less frequently, as well as any technical or legal 

obstacles to reducing burden.

An annual collection is required under Sec. 752(i)(2)(A) of the 1992 Amendments, and is 

necessary for the RSA Commissioner to respond to legislative requirements of an annual 

report to the President and to Congress as mandated by Sec. 13 of the Rehabilitation Act 

of 1973 (Attachment B). This data must also be collected annually in order for RSA to 

determine substantial progress required for the annual funding of formula grants to all 

non-competing Designated State Agencies.

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;
3

OMB Number: 1820-0608

 in connection with a statistical survey, that is not designed to produce valid and 

reliable results than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed 

and approved by OMB;

 that includes a pledge of confidentiality that is not supported by authority 

established in statute or regulation, that is not supported by disclosure and data 

security policies that are consistent with the pledge, or that unnecessarily 

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

 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate that it has instituted procedures 

to protect the information’s confidentiality to the extent permitted by law.

There are no special circumstances that would require this information to be collected 

in a different manner than set forth in the Act.

8. As applicable, state that the Department has published the 60 and 30 Federal 

Register notices as required by 5 CFR 1320.8(d), soliciting comments on the 

information collection prior to submission to OMB. Summarize public comments 

received in response to that notice and describe actions taken by the agency in 

response to these comments. Specifically address comments received on cost and 

hour burden.

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

the availability of data, frequency of collection, the clarity of instruction and record 

keeping, disclosure, or reporting format (if any), and on the data elements to be 

recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained 

or those who must compile records should occur at least once every 3 years – even if 

the collection of information activity is the same as in prior periods. There may be 

circumstances that may preclude consultation in a specific situation. These 

circumstances should be explained.

During its initial development, the collection instrument and instructions were reviewed

by the National Council of State Agencies for the Blind, and almost 90% of the project 

directors funded under the program. All comments and suggestions were considered and 

several recommendations were adopted. A special workgroup recommended the current 

changes for the ED RSA-7-OB reporting form and the elimination of the participant 

survey. IL-OIB project directors reviewed these changes and provided comments at a 

meeting on June 23, 2013. 

A 60 day and 30 day notice was published in the Federal Register for public comment, 

with no comments received during the 60-day comment period. 
4

OMB Number: 1820-0608

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

remuneration of contractors or grantees with meaningful justification.

No payment or gift has been provided to respondents.

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

the assurance in statute, regulation, or agency policy. If personally identifiable 

information (PII) is being collected, a Privacy Act statement should be included on 

the instrument. Please provide a citation for the Systems of Record Notice and the 

date a Privacy Impact Assessment was completed as indicated on the IC Data Form. 

A confidentiality statement with a legal citation that authorizes the pledge of 

confidentiality should be provided. Requests for this information are in accordance 

with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A-108 

– Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A130 Appendix I – Federal Agency Responsibilities for Maintaining Records About 

Individuals, OMB M-03-22 – OMB Guidance for Implementing the Privacy 

Provisions of the E-Government Act of 2002, OMB M-06-15 – Safeguarding 

Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, 

Use and Protection of Personally Identifiable Information). If the collection is 

subject to the Privacy Act, the Privacy Act statement is deemed sufficient with 

respect to confidentiality. If there is no expectation of confidentiality, simply state 

that the Department makes no pledge about the confidentially of the data.

The written request does not contain specific or personal information; there are no 

assurances of confidentiality. 

11. Provide additional justification for any questions of a sensitive nature, such as 

sexual behavior and attitudes, religious beliefs, and other matters that are 

commonly considered private. The justification should include the reasons why the 

agency considers the questions necessary, the specific uses to be made of the 

information, the explanation to be given to persons from whom the information is 

requested, and any steps to be taken to obtain their consent.

The written request does not contain any question of a sensitive nature.

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

statement should:

 Indicate the number of respondents by affected public type (federal government, 

individuals or households, private sector – businesses or other for-profit, private 

sector – not-for-profit institutions, farms, state, local or tribal governments), 

frequency of response, annual hour burden, and an explanation of how the 

burden was estimated, including identification of burden type: recordkeeping, 

reporting or third party disclosure. All narrative should be included in item 12. 

Unless directed to do so, agencies should not conduct special surveys to obtain 

information on which to base hour burden estimates. Consultation with a 
5

OMB Number: 1820-0608

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 in the ROCIS 

IC Burden Analysis Table. (The table should at minimum include Respondent 

types, IC activity, Respondent and Responses, Hours/Response, and Total 

Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for 

collections of information, identifying and using appropriate wage rate 

categories. The cost of contracting out or paying outside parties for information 

collection activities should not be included here. Instead, this cost should be 

included in Item 14.

We estimate that there will be 56 respondents with an estimated 6 hours needed to for 

a total annual burden of 336 hours.

Annual Burden

Number of respondents 56

Frequency of response Annually

Total annual responses 56

Hours per response 6*

Total burden hours 336

State hourly rate of salary $20

Total cost (exf) $6,720

*The hour burden associated with this information collection is estimated at 6 hours 

per State or Territory. The estimated hour burden per State or Territory is not 

expected to vary significantly. Estimated burden hours are founded on judgments 

from previous State written request submittals for similar RSA grants.

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, 
6

OMB Number: 1820-0608

among other items, preparations for collecting information such as purchasing 

computers and software; monitoring, sampling, drilling and testing equipment; 

and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of 

cost burdens and explain the reasons for the variance. The cost of contracting 

out information collection services should be a part of this cost burden estimate. 

In developing cost burden estimates, agencies may consult with a sample of 

respondents (fewer than 10), utilize the 60-day pre-OMB submission public 

comment process and use existing economic or regulatory impact analysis 

associated with the rulemaking containing the information collection, as 

appropriate.

 Generally, estimates should not include purchases of equipment or services, or 

portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory 

compliance with requirements not associated with the information collection, (3) 

for reasons other than to provide information or keep records for the 

government or (4) as part of customary and usual business or private practices.

Also, these estimates should not include the hourly costs (i.e., the monetization of 

the hours) captured above in Item 12

Total Annualized Capital/Startup Cost: $.00

Total Annual Costs (O&M): .00

Total Annualized Costs Requested: $.00

No additional operational expenses are required.

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.

a. Review of each written request - - .16 hour

b. Number of written requests to review - - 56

c. Total time to review written requests - - 9 hours

d. Federal hourly rate of salary - - $38

e. Total cost (cxd) - - $4,256

The average review and approval of an ED RSA-7-OB form takes 2 hours. The RSA 

staffer who reviews the completed forms is paid at an average rate of $38 per hour. The 

cost of the review and approval process is 2 hours x $38/hour x 56 reports = $4,256, 

annual federal cost.
7

OMB Number: 1820-0608

15. Explain the reasons for any program changes or adjustments. Generally, 

adjustments in burden result from re-estimating burden and/or from economic 

phenomenon outside of an agency’s control (e.g., correcting a burden estimate or an 

organic increase in the size of the reporting universe). Program changes result from 

a deliberate action that materially changes a collection of information and generally 

are result of new statute or an agency action (e.g., changing a form, revising 

regulations, redefining the respondent universe, etc.). Burden changes should be 

disaggregated by type of change (i.e., adjustment, program change due to new 

statute, and/or program change due to agency discretion), type of collection (new, 

revision, extension, reinstatement with change, reinstatement without change) and 

include totals for changes in burden hours, responses and costs (if applicable).

There are no program changes or adjustments to this extension request. 

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.

The information collected will not be published for statistical use.

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.

This document is not seeking OMB approval not to display the expiration date.

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

of Paperwork Reduction Act.

This document meets each of the criteria outlined in the "Certification for Paperwork 

Reduction Act Submissions."