1 **SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION** 

OMB Number: 1820 - 0013 

### A. Justification 1. Explain the circumstances that make the collection of information necessary. I dentify any legal or administrative requirements that necessitate the collection. Attach a hard copy of the appropriate section of each statute and regulation mandating or auth orizing 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 ty pe of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. Section 13 of the Rehabilitation Act of 1973, as amended (the Act) requires the Commissioner to submit a full and complete Annual Report to the President and Congress within 180 days after a fiscal ye ar (FY) on the activities carried out under the Act. This Annual Report should include statistical data reflecting services and activities provided to individuals during the preceding FY. The RSA - 113 fulfills a major role in helping the Commissioner comply with the Annual Report requirement by providing timely data on the overall dimensions of the state vocational rehabilitation (VR) program. The RS A - 113 data are submitted quarterl y b y State vocational rehabilitation (VR) agencies. VR agencies that administer vocational rehabilitation programs provide key caseload data on this fo rm, including numbers of individuals who are applicants, determined elig ible/ineligible, waiting for services, and their program outcomes. These data are used for program projections, planning, management, budgeting , and general statistical purposes . Due to the impending passag e of WIOA, revision of this form was post poned because of the expect ation of the ab i l ity to consider the data collection changes of WIOA for the revision of this data collection. The July 22 nd 2014 e nactment of WIOA was later than expected; consequentl y with the February 28 th 2015 expiration date of this form, it has become necessary

t o extend it without any

changes in order to continue collection of its data elements. 2. Indicate how, b y whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the ag ency has made of the information received from the current collection. The Commissioner will use and has used the RSA - 113 data for the purposes listed in response to Question 1. The RSA - 113 data are also used to determine trends in the acceptance and reha

bilitation of applicants for rehabilitation services. These data have2

been used for the generation of outcome measures permitting assessment of state agency productivity . The outcome measures, in turn, form the basis for monitoring and the timely deliv ery of technical assistance to state agencies, when warranted. In addition, RSA - 113 data are employed in the budget development process and are frequently requested b y the Office of Management and Budget (OMB), the Secretary and Assistant Secretary , and b y the Congress and its staff. 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 electr onic 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 has a Management Information Sy stem that agencies use to access the data collection directl y through the internet b y using the following URL : http://rsa.ed.gov . Agencies do not submit hardcop y media of the RSA - 113. 4. D escribe ef

forts to identify

duplication. Show specificall y wh y an y similar information already available cannot be used or modified for use for the purposes described in Item 2 above. The information requested on the RSA - 113 represents a portion of greater caseload detail already available in state rehabilitation agencies. The agencies, therefore, have only to extract a limited amount of caseload flow data from their own on - going data collection sy stems when preparing the RSA - 113. The RSA - 113 is the only RSA report dealing with current and total state agency caseload flows. No similar information is available from other sources. 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 not - for - profit enterprise that is independentl y owned an d 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. Respondent are agencies of state gover nments only . There is no impact on 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 frequentl y, as well as an y technical or legal obstacles to reducing burden. RSA - 113 data are to be collected quarterly . These data provide current perspectives and insights into caseload trends in individual state agencies that permit earl y detection of questionable and undesirable trends (e.g., reductions in the number of persons with significant disabilities entering the caseloads, declines in acceptance rates and rehabilitation rates, increasing backlogs of eligible individuals who cannot be served, etc.). Using quarterl y RSA - 113 data, RSA staff can perform their oversight functions3

more knowledgeably

in their continuing contacts with state agencies and provide expeditious technical assistance, when needed. Without quarterl y data, their monitoring and technical assistance functions will be seriously limit ed. Further, the availability of quarterl y data permits informed judgments about trends to be made for use in the budget development and preparation process. 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 quarterl y; There are no circumstances that require respondents to report information more often than quarterl y.  requiring respondents to prepare a written response to a co llection of information in fewer than 30 day s after receipt of it; This collection has been in effect for several years and collects information that the respondents maintain continuously . There are no circumstances that require a written response in fewe r than 30 day s after receipt.  requiring respondents to submit more than an original and two copies of any document; Respondents are required to submit the information for the RSA - 911 in RSA’s MI S as stated in number 3 above.  requiring respondents to retain records, other than health, medical, government contract, grant - in - aid, or tax records for more than three y ears; Respondents are not required to retain records for more than three years.  in connection with a statistical survey , that is not designed to pr oduce valid and reliable results than can be generalized to the universe of study; This collection is not a statistical survey .  requiring the use of a statistical data classification that has not been reviewed and approved b y OMB; The collection is 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 unn ecessarily impedes sharing of data with other agencies for compatible confidential use; or The RSA - 113 is an aggregated report form of caseloads and does not identify individual information.  requiring respondents to submit proprietary trade secrets, or oth er confidential information unless the agency can demonstrate that it has instituted procedures to protect the information ’ s confidentiality to the extent permitted by law.4 The RSA - 113 report does not require proprietary trade secrets of other confidentia l information. 8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as required b y 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received i n response to that notice and describe actions taken by the agency

in response to these comments. Specificall y address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the avai lability

of data, frequency

of collection, the clarity

of instruction and record keeping, disclosure, or reporting format (if an y), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom inform ation 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 si tuation. These circumstances should be explained. RSA regularl y contacts the Council of State Administrators of Vocational Rehabilitation (CSAVR) on developments affecting the RSA - 113. CSAVR is an umbrella organization, headquartered in suburban Washingt on, DC, representing the 80 respondents (state VR agencies). Also a 60 - day

and 30 - day

notice will be published in the Federal Register for public c omment. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification . There are no pay

ments of gifts to respondents. 10. Describe an y 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 Sy stems of Record Notice and the date a Privacy Impact Assessment was completed as indicated on the IC Data F orm . 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

– Priva cy 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 o f 2002, OMB M - 06 - 15

– Safeguarding Personall y Identifiable Information, OM:6 - 104

– Privacy Act of 1974 (Collection, Use and Protection of Personally I dentifiable Information) . If the collection is subject to the Privacy Act, the Privacy

Act statement is de emed sufficient with respect to confidentiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data.5

The RSA - 113 is an aggregated report form of caseloads and does not ident ify individual information. There are no assurances of confidentiality necessary

to be provided to respondents. 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other m atters 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 i s requested, and an y steps to be taken to obtain their consent. Data collected on the RSA - 113 is not 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 ty pe (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 ty pe: 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 sep arate hour burden estimates for each form and aggregate the hour burdens in the ROCI S IC Burden Analy sis Table. (The table should at minimum include Respondent types, IC activity , Respondent and Responses, Hours/Response, and Total Hours)  Provide estimate s 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 inclu ded here. Instead, this cost should be included in Item 14. Estimates of reporting burdens are based on the experience of man y ye ars of caseload data collection as well as discussions with respondent representatives. Estimates for both reporting and reco rd - keeping indicate minimal burden because the data called for b y the RSA - 113 are limited in scope and are maintained by respondents for their own needs and use. Some states have a separate agency for the blind and visually impaired, while other states hav e a single state agency . Currently 80 agencies are required to respond to the RSA - 113.6

Estimated time to edit, collect and submit summary data on the RSA - 113 Report

– 1 hour and number of respondents - 80 Number of quarterl y collections from each respondent annuall y – 4 Total number of responses annuall y – 320 Annual cost to respondents: 320 burden hours X $20/hour = $6,400 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 m aintenance 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 includin g s ys tem 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 suc h 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 widel y, 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 anal ys is 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: This collection does not require capital costs, start - up costs, maintenance costs or the purchase of services for the respondents. The summary data required is already maintained for the purpose of maintaining its federal grant. There are no additional costs for this RSA - 113 report.7

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 exp enses (such as equipment, overhead, printing, and support staff), and an y 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. Annua lized Estimated Federal Cost: Annual Federal Costs 50 hours X $25 per hour $ 3,750 Annual federal computer costs: $ 500 $ 4,250 15. Explain the reasons for any program changes or adjustments. Generall y, 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 reportin g universe). Program changes result from a deliberate action that materiall y changes a collection of information and generall y are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, e tc.). Burden changes should be disaggregated b y ty pe of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), ty pe of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours , responses and cost s (if applicable) . There are no program changes or adjustments associated with this request. 16. For collections of information whose results will be published, outline plans for ta bulation and publication. Address an y complex anal yt ical 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 o ther actions. RSA - 113 data are due 30 day s after the first three quarters of the FY, and 60 day s after the fourth quarter, or end of the FY. By the middle to the end of the succeeding month, reports for all state rehabilitation agencies will be collected, edited, revised if necessary , and tabulated. The tabulation comprises eight tables of data displaying all RSA - 113 data for state agencies. The tables contain a variety of anal yt ical measures and comparisons such as percent distributions, percent changes from previous year, percent of caseload composed of significantly disabled persons, acceptance rates and rehabilitation rates. They are also shown by

ty pe of agency

(general/combined and agency for the blind). Data for the fourth quarter represent annua l totals that are published as "Caseload Statistics" on RSA’s website earl y in the succeeding calendar year. The annual totals are also made available, along with an accompan yi ng anal ys is, for the Annual Report to the Congress required b y Section 13 of th e Rehabilitation Act. 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 expiration date for OMB approval will be display ed.8

18. Explain each exc eption to the certification statement identified in the Certification of Paperwork Reduction Act. There are no exceptions to the certification statement identified in Item 2 1 of OMB Form 83 - 1 .