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OMB 83-1 PAPERWORK REDUCTION ACT

SUPPORTING STATEMENT

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 copy of the appropriate section of each 

statute and regulation mandating or authorizing the collection of 

information. 

The Rehabilitation Act of 1973, as amended (Rehabilitation Act), requires each 

state to have in effect a Client Assistance Program (CAP) in order to receive 

payments from its Section 112 allotments under the Rehabilitation Act. The 

approved application prescribed by the commissioner of the Rehabilitation 

Services Administration (RSA) is the state's written request for grant funds and 

assurances that the CAP can carry out its statutorily prescribed purposes and 

functions.

This preprint is based on the following:

(1) Title I, section 112 of the Rehabilitation Act, as amended;

(2) The regulations (34 CFR Part 370) published November 2, 1995, in the 

Federal Register implementing section 112 of the Rehabilitation Act, as 

amended; and

(3) General requirements for all state plans, including written requests for 

assistance under section 112 of the Rehabilitation Act, pursuant to the 

Education Department General Administrative Regulations (34 CFR Part 

76).

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. 

An approved written request is a condition for receipt of federal funds for a state 

to establish and carry out a CAP. The state must complete the Application by 

providing assurances that the CAP can carry out its statutorily prescribed 

purposes and functions. 

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

involves the use of automated, electronic, mechanical, or other 

technological collection techniques or other forms of information 

technology, e.g., permitting electronic submission of responses, and the 
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basis for the decision for adopting this means of collection. Also, describe 

any consideration of using information technology to reduce burden. 

The State Assurances form is a legal document, which requires an authoritative 

signature and minimal reporting burden. States do not submit responses 

electronically because an authoritative signature is required. RSA considered 

the possibility of submitting responses electronically, with just a hard-copy 

signature page. However, because the reporting requirements are so minimal, 

RSA determined that electronic submissions would have no benefit for the CAPs 

in terms of the reporting burden.

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 document collects unique information that is not collected under any other 

instrument. The written request is required by federal statute and is not obtained 

through any other data source.

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

entities (Part II item 8 of new OMB Form 83-I), describe any methods used 

to minimize burden. 

The collection of this information does not involve small businesses or other 

small entities.

6. Describe the consequence 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.

Section 112(f) of the Rehabilitation Act requires the state to submit an 

application in such manner and containing or accompanied by such information 

as the secretary deems necessary. If the state fails to complete the application 

as required, the state will not be eligible for federal funds for the CAP program 

and subsequently for the basic state grant funds under section 110 of the

Rehabilitation Act. This method has been established as the required 

procedure.

7. Explain any special circumstance that would cause an information 

collection to be conducted in a manner: 

o requiring respondents to report information to the 
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agency more often than quarterly;

o requiring respondents to prepare a written response to

a collection of information in fewer than 30 days after 

receipt of it;

o requiring respondents to submit more than an original

and two copies of any document;

o requiring respondents to retain records, other than

health, medical, government contract, grant-in-aid, or

tax records for more than three years;

o in connection with a statistical survey, that is not 

designed to produce valid and reliable results that can

be generalized to the universe of study;

o requiring the use of a statistical data classification

that has not been reviewed and approved by OMB;

o 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

o requiring respondents to submit proprietary trade

secret, 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 Rehabilitation Act.

8. If applicable, provide a copy and identify the date 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 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 
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comments. Specifically address comments received on cost and hour 

burden.

Describe efforts to consult with persons out-side 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. 

RSA received recommendations on this collection of information, including the 

frequency of reporting, from the National Disability Rights Network (NDRN), 

CAPs, and other advocacy groups. RSA considered suggestions received from 

all sources during the development of this form and it has not been revised. In 

addition, a 60-day and a 30-day notice was published in the Federal Register to 

solicit public comment, with none. 

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

than remuneration of contractors or grantees.

There is no payment or gift to respondents.

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

basis for the assurance in statute, regulation, or agency policy. 

The written request does not contain specific or personal information. Therefore, 

confidentiality is assured for all agencies. 

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. 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 requested, and any steps to be taken to 

obtain their consent. 

The written request does not contain any questions of a sensitive nature.
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12. Provide estimates of the hour burden of the collection of information. The 

statement should: 

o 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. Consultation with a sample (fewer than ten) 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. 

o If this request for approval covers more than one form, provide 

separate hour burden estimates for each form and aggregate the 

hour burdens in item 16 of new OMB Form 83-I. 

o 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.

a. Number of respondents -- 56

b. Frequency of response -- 1

c. Total annual responses (a x b) -- 56

d. Hours per response -- .16*

e. Total burden hours (c x d) -- 9

f. State hourly rate of salary -- -- $25

g. Total cost (e x f) -- $225

* The burden hours associated with the written Request for a CAP grant are

estimated at 10 minutes, or .16 hours, per state or Territory. The 

estimated hour burden per state or Territory is not expected to vary 

significantly. RSA has based the estimated burden hours on previous 

submissions of this information collection.

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.) 
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o The cost estimate should be split into two components: (a) the 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 

record storage facilities:

o 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 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.

o 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. 

There is no additional cost burden to states and Territories when submitting a 

written Request for CAP funds.

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. 
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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 -- $49

e. Total cost (c x d) -- $441.00

* The estimate of burden hours to the Federal Government does not 

include time needed for negotiations when a written request is not approvable. 

However, given the perfunctory nature of this written request, it would be unusual 

for a request to not be approvable.

15. Explain the reasons for any program changes or adjustments reported in 

item 16 of the new OMB Form 83-I. 

There are no program changes or adjustments reported. 

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 reason that display would be 

inappropriate. 

RSA is not seeking approval to not display the expiration date for OMB approval 

of the information collection. 

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

"Certification for Paperwork Reduction Act Submissions.”

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

Paperwork Reduction Act Submissions".

B. Collection of Information Employing Statistical Methods

The written request for a CAP grant is a legal document and does not require the 

use of any statistical methods in obtaining information.