EDICS Tracking and OMB Number: 1820

- 0018 Revised: 04/29/2013

RIN Number: XXXX

- XXXX (if applicable)

1 **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 section**  **1 . 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 successfull y meet the legislative and regulatory

requirements for each program. This review process giv es 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 effectivel y comply with the legislative mandate and conduct expert peer reviews to make grant funding decisions. Applicants, including individuals and small businesses, may elect to appl y for grants. The information required by the government is minimal. The current information collection request burden hours are onl y for the program anticipated to be competed during the fiscal ye ar 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. E**  **xcept 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)

2 RSA is unable to use the Department of Education’s approved generic application package because of the program

- specific selec tion criteria required under 84.129, Rehabilitation L ong - 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 technolo**  **gical 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 bu**  **rden.** 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 s ys tem, 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 greatl y reduces the burden and cost o n 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 identi fy 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 L ong - 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 t**  **o 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 not**   ** for** **- profit enterprise that is inde**  **pendently 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 entitie s . **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 r educing burden.**  This information is not collected from entities on a regular basis. It is collected onl y as a part of a grant competition. Applicants, including individuals and small businesses, mayEDICS Tracking and OMB Number: 1820

- 0018 Revised: 04/29/2013

RIN Number: XXXX

- XXXX (if applicable)

3 elect to appl y 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 cann ot 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 i**  **n 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 submi t 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 C FR 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 comment s received on cost and**  **hour burden.**EDICS Tracking and OMB Number: 1820

- 0018 Revised: 04/29/2013

RIN Number: XXXX

- XXXX (if applicable)

4 **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 o f 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 ye ars RSA staff has had in person, e

- mail, and telephone conversations with applicants about our application process. Changes in the clarifying information and the estimate s on the number of burden hours are made based on this communication. In addition, the Department p ublished 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 pay

ments or gift s 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 shou ld 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 pled ge of**  **confidentiality should be provided. 2**  **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 make s 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 (Col lection, Use and Protection of Personally Identifiable Information)EDICS Tracking and OMB Number: 1820

- 0018 Revised: 04/29/2013

RIN Number: XXXX

- XXXX (if applicable)

5 **11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other**  **ma tters 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 a**  **n 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 comp lexity, 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 se parate**  **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 estim ates 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 in cluded 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. 40 3 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)

6 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 col lection 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**  **colle cting 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 co**  **st 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 pu rchases 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 reco rds**  **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, 120EDICS Tracking and OMB Number: 1820

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RIN Number: XXXX

- XXXX (if applicable)

7

Postage and Printin g ($50.00 per application X 0 applications 4 ) ............

... $ 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, whic h 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 est im**  **ates 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 s taff 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 potenti al 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 Revi ew 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 hourl y 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 o**  **rganic 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 regulat** **ions, 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, r**  **einstatement 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

RIN Number: XXXX

- XXXX (if applicable)

8 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 respond ent 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 antic ipated 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 o**  **f 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