EDICS Tracking and OMB Number: 1820-0018 Revised: 04/29/2013

RIN Number: XXXX-XXXX (if applicable)

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SUPPORTING STATEMENT 

FOR THE PAPERWORK REDUCTION ACT SUBMISSION:

APPLICATIONS FOR NEW GRANTS UNDER THE REHABILITATION 

SERVICES ADMINISTATION

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 section1. 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.

The Rehabilitation Service Administration (RSA) administers and supports a 

comprehensive array of discretionary grant programs and projects that serve and assist 

individuals with disabilities. RSA awards grants based on a competitive process. RSA 

reviews applications based on the applicant’s ability to successfully meet the legislative 

and regulatory requirements for each program. This review process gives RSA the 

discretion necessary to determine which applications best address the program 

requirements and are most worthy of funding.

This grant application package is an extension of a currently approved collection. It is 

necessary in order to standardize applications for the many programs in RSA with the 

least amount of burden to the applicants. Without the information contained in this 

application package, the Department would not be able to effectively comply with the 

legislative mandate and conduct expert peer reviews to make grant funding decisions. 

Applicants, including individuals and small businesses, may elect to apply for grants. 

The information required by the government is minimal. The current information 

collection request burden hours are only for the program anticipated to be competed 

during the fiscal year this collection is being submitted, which is 84.129 Rehabilitation 

Long-Term Training.

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. 

 

1

Please limit pasted text to no longer than 3 paragraphs.
EDICS Tracking and OMB Number: 1820-0018 Revised: 04/29/2013

RIN Number: XXXX-XXXX (if applicable)

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RSA is unable to use the Department of Education’s approved generic application 

package because of the program-specific selection criteria required under 84.129, 

Rehabilitation Long-Term Training program published in CFR 385 and 386. 

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. 

RSA requires grant applicants (i.e. institutes of higher education, State agencies, Indian 

tribes, not for profit, for profit, and individuals) to submit their applications via the 

federal government’s central grants system, Grants.gov. The use of this electronic 

submission process allows applicants to prepare, save and continue to work on the 

application before submitting. All components of the application are uploaded into 

grants.gov. This process greatly reduces the burden and cost on applicants to print and 

mail hard copies of grant applications. 

RSA conducts its peer review competitions using distance technology. RSA uses the 

Field Reader module of G5, to expedite the application review process. 

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.

RSA is unable to use the Department of Education’s approved generic application 

package because of the program-specific selection criteria required under 84.129, 

Rehabilitation Long-Term Training program published in CFR 385 and 386. 

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.

The collection of information does not impact small businesses 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.

This information is not collected from entities on a regular basis. It is collected only as a 

part of a grant competition. Applicants, including individuals and small businesses, may
EDICS Tracking and OMB Number: 1820-0018 Revised: 04/29/2013

RIN Number: XXXX-XXXX (if applicable)

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elect to apply for grants. The information required by the government is minimal. RSA

discourages elaborate or lengthy applications. Applicants provide the grant application 

information voluntarily as a condition of competing for the grant. If RSA cannot collect 

this information from applicants, it cannot comply with its legislative mandate and 

conduct expert peer reviews to make grant funding decisions. 

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 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 require the collection to be conducted in a 

manner inconsistent with the guidelines in 5 CFR 1320.5.

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.
EDICS Tracking and OMB Number: 1820-0018 Revised: 04/29/2013

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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.

Over the past three years RSA staff has had in person, e-mail, and telephone 

conversations with applicants about our application process. Changes in the clarifying 

information and the estimates on the number of burden hours are made based on this 

communication. 

In addition, the Department published a 30 day Federal Register notices to solicit public 

comment. 

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

remuneration of contractors or grantees with meaningful justification.

There are no payments or gifts 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.2If 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.

This is not applicable to this information collection.

 

2 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 A-130 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)
EDICS Tracking and OMB Number: 1820-0018 Revised: 04/29/2013

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

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

commonly considered private. 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.

There are no questions 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 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.

Estimates of Hour Burden for this Information Collection: 

Number of Respondents ....... 100

Hours Needed to Complete. 403 

Total Burden Hours ........... 4,000

 

3 Based on discussions with current applicants and grantees 40 burden hours is an average number of hours.
EDICS Tracking and OMB Number: 1820-0018 Revised: 04/29/2013

RIN Number: XXXX-XXXX (if applicable)

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We estimate that CFDA, 84.129 will receive approximately 100 respondents with an 

estimated 40 hours needed to complete for a total annual burden of 4,000 hours. 

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 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 : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

Estimates of Annual Cost Burden to Respondents for this Information Collection:

Preparation of Application ($28.00 per hour X 40 burden hours) .......... 

... .$1,120
EDICS Tracking and OMB Number: 1820-0018 Revised: 04/29/2013

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Postage and Printing ($50.00 per application X 0 applications4) ............ 

... $ 0

Total Cost Burden (per respondent) ............. $1,120

The estimates of annual cost burden to respondents for this collection is based on the 

above table calculated at $28 per hour X 40 burden hours results in a cost of $1,120 per 

respondent. 

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.

RSA anticipates that there will be 1 competition requiring a competition manager and one 

additional staff person devoted to handling the administrative and logistical functions of 

the review. RSA discontinued use of an outside contractor in FY 2012 to handle the 

logistical and administrative functions of the peer review process. As a result, the staff 

time for peer review is estimated at 416 hours for the individual serving as the 

competition manager and 624 hours for the individual providing administrative and 

logistical support with the average grade level being a GS-13 with an hourly rate of pay

at $42.66. This includes: (1) Review and screening of applications; (2) Review of 

resumes of potential reviewers; (3) Contact of potential reviewers to determine 

availability; (4) Secure potential reviewers and ensure proper reimbursement to the 

reviewer ; (5) Review and preparation of peer reviewer material; (6) Conducting the grant 

competition; (7 Review and approval of technical review forms; and (8) Pre-funding and 

competition slate preparation. The annual cost to the federal government estimated for 1

`staff at 416 hours of their time and the other at 624 hours of their time with an hourly 

rate of $42.66 is $44,366.

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).

 

4 RSA is requiring that all submissions be received electronic format unless a waiver is granted.
EDICS Tracking and OMB Number: 1820-0018 Revised: 04/29/2013

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This information collection includes an adjustment decrease of 36,000 burden hours from 

40,000 to 4,000 hours. The burden hour reduction is a result of a reduction in the

respondent pool due to lack of funding for these programs as well as programs with less 

than 10 applications anticipated to compete. The table below provides a breakdown of 

the programs, number of respondents and burden hours included in the previous package 

which totaled 40,000 hours. The current collection with a total of 4,000 hours includes 

only one program, 84.129, anticipated to compete in FY 2013 with a reduced number of 

respondents anticipated for that program as well. 

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 application packages are available electronically via grants.gov or the Department of 

Education’s website, ed.gov. 

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 OMB approval will be displayed.

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

Certification of Paperwork Reduction Act.

There are no exceptions to the certification statement.

CFDA TITLE RESPONDENTS BURDEN HOURS

84.129 Rehabilitation Training – Long-Term

Training

450 18,000

 TOTAL 450 18,000