REHABILITATION SERVICES ADMINISTRATION

STATE GRANT FOR ASSISTIVE TECHNOLOGY PROGRAMS

ASSISTIVE TECHNOLOGY ACT OF 1998, AS AMENDED

Annual Assistive Technology Act Data Collection Report

REQUEST FOR OMB APPROVAL

SUPPORTING STATEMENT REQUIRED UNDER

THE PAPERWORK REDUCTION ACT

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 Services Administration (RSA) of the U.S. Department of Education 

(ED) requests clearance for the revision and renewal of a data collection instrument, 

Office of Management and Budget (OMB) Control Number 1820-0572, to be completed 

by grantees under the Assistive Technology Act of 1998, as amended (Public Law 108-

364).

The information collected through this data collection instrument is necessary for RSA 

and states to comply with Sections 4 and 7 of the Assistive Technology Act of 1998, as 

amended (AT Act), and for states to satisfy the reporting requirements in 34 CFR 

76.720, which requires an annual report of program performance. RSA is requesting a 

revision and renewal of the annual data collection instrument (OMB No. 1820-0572). 

Approval of 1820-0572 expires September 30, 2014.

Section 4 Requirements Necessitating Data Collection

Section 4 of the AT Act authorizes grants to public agencies in the 50 states and the 

District of Columbia, Puerto Rico, the Virgin Islands, Guam, American Samoa, and the 

Commonwealth of the Northern Marianas (states and outlying areas). With these funds, 

the 56 states and outlying areas operate “Statewide AT Programs” that conduct 

activities to increase access to and acquisition of assistive technology (AT) for 

individuals with disabilities. These comprehensive activities are divided into two 

categories: “State-level Activities” and “State Leadership Activities.”

According to Section 4 of the AT Act, as a condition of receiving a grant to support their 

Statewide AT Programs the 56 states and outlying areas must provide to RSA: (1) 

applications and (2) annual progress reports on their activities.
Applications: The application required of states and outlying areas is a three-year State 

Plan for Assistive Technology (State Plan for AT or State Plan) (OMB No. 1820-0664). 

The content of the State Plan for AT is based on the requirements in Section 4(d) of the 

AT Act. As a part of this State Plan, Section 4(d)(3) of the AT Act requires that states 

and outlying areas set measurable goals for addressing the assistive technology needs 

of individuals with disabilities in education, employment, community living and 

information technology/telecommunications.

Every state and outlying area is required to include a minimum of seven prescribed 

measurable goals in its State Plan. These seven goals apply to all states and outlying 

areas in order to aggregate information on performance of the program at the national 

level. National aggregation of data related to these goals is necessary for the 

Government Performance and Results Act (GPRA), as well as an Annual Report to 

Congress (see “Section 7 Requirements Necessitating Collection” below). Therefore, 

this data collection instrument provides a way for all 56 grantees—50 U.S. states, D.C., 

Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa, and the Commonwealth 

of the Northern Mariana Islands to collect and report data on their performance in a 

consistent manner, including a uniform survey to be given to consumers. This uniform 

survey is included as part of the data collection package.

Annual Reports: In addition to submitting a State Plan every three years, states and 

outlying areas are required to submit annual progress reports on their activities. The 

data required in that progress report is specified in Section 4(f) of the AT Act.

Section 7 Requirements Necessitating Collection

Section 7(d) of the AT Act requires that RSA submit to Congress an annual report on 

the activities conducted under the Act and an analysis of the progress of the states and 

outlying areas in meeting their measurable goals. This report must include a 

compilation and summary of the data collected under Section 4(f). In order to make this 

possible, states and outlying areas must provide their data uniformly. This data 

collection instrument was developed to ensure that all 56 states and outlying areas 

report data in a consistent manner in alignment with the requirements of 4(f).

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.

As stated above, RSA will use the information collected via this instrument to:

(1) Complete the annual report to Congress required by the AT Act;

(2) Meet the performance reporting requirements in Section 76.720 of the 

Education Department Administrative Regulations (EDGAR);
(3) Comply with reporting requirements under the Government 

Performance and Results Act (GPRA) of 1993 (Public Law 103-62); 

and

(4) Assess the progress of states and outlying areas regarding 

measurable goals in their State Plans for AT.

Data collected from the grantees will provide a national description of activities funded 

under the AT Act to increase the access to and acquisition of AT devices and services 

through statewide AT programs for individuals with disabilities for use by Congress, the 

Department, and the public. In addition, RSA will use this data to inform its program 

management, monitoring, and technical assistance efforts. States will be able to use 

the data for internal management and program improvement.

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.

The annual AT Act data collection is submitted electronically as an online survey. Using 

RSA’s Management Information System (MIS), states complete their annual reports via 

the Internet by entering data into fields, choosing from drop-down menus, selection via 

“check boxes,” and narrative. Paper versions of the plan are neither required nor 

accepted unless there is a technological barrier to use the online system. The MIS will 

serve not only as the venue for submitting the data electronically, but also functions as a 

database to allow both RSA and the public to access information.

Since a web-based data collection system is currently in place, a proposed update to 

the system will be implemented based upon the instrument submitted for review. The 

paper version of the instrument translates directly into a web-based format; throughout 

the document there are numerous references to how certain sections and items are 

used in the electronic system. Upon OMB approval of the paper version, the webbased application for use by the states will be implemented by ED at RSA through the 

MIS. Once updated, the system will meet or exceed requirements for accessibility of 

Section 508 of the Rehabilitation Act of 1973, as amended (The Act), the Federal 

Information Security Management Act (FISMA), and other applicable statutes and 

regulations, and industry standards. The entities completing the annual data report 

already use the MIS for other purposes, such as completing SF-425s, and State Plans 

for AT (OMB No. 1820-0664).

This web-based system allows all 56 grantees—50 U.S. states, D.C., Puerto Rico, the 

U.S. Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern 

Mariana Islands and territories to enter and submit their data electronically at their 

convenience on an ongoing basis. Where appropriate, the system automatically 
generates totals and does other automatic calculations, saving time and reducing the 

chance of mathematical errors.

RSA will have immediate access to the information submitted, allowing RSA to identify 

which grantees have submitted their data. This access will allow RSA to generate 

reports, even on partial data, as requested by Congress or others. States will have 

similar access to their data for management purposes.

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.

The proposed data collection is intended to reduce duplication for states that have a 

single State Plan for AT. Currently, data collected on State Financing Activities (see 

pages 4 through 15 of the instrument) is duplicative of information collected under title 

III of the Assistive Technology Act of 1998, as in effect prior to the 2004 amendments. 

Under a separate funding authority, title III provided for alternative financing programs 

(AFPs) that operate in perpetuity. Thirty-three states received AFP grants funded under 

title III. This program has its own data collection requirements and its own web-based 

data collection instrument (OMB No. 1820-0662) in RSA’s MIS.

Because Section 4 of the AT Act includes AFPs as a form of state financing activity, 

many states have incorporated their existing title III AFP into their State Plan for AT. 

The revised data form would allow states that have incorporated their Title III funded 

AFP program loans into their State Plan for AT to only report this data once. If all AFP 

loans in the state are reported in the State Grant for AT Annual Progress Report (RSA572) under State Financing, the AFP specific data elements that were in the separate 

AFP would be complete and no other reporting is necessary. (Specifically the RSA-662 

AFP Progress Report does not need to be submitted). This is a significant reduction in 

burden for States that include an AFP in their State Plan for AT, since the data would 

not need to be reported separately.

However, a single data collection instrument cannot capture the entire universe of data, 

or entities needing to report that data, for both title III and Section 4 because:

(a) the data collection requirements of section 4 and Title III are similar but 

not the same; and

(b) not all states have both title III and section 4 grants, and, when a state 

does have both grants, both grants do not always go to the same 

agency.

Other than the duplication of title III data described above, this data collection 

instrument is unique to section 4 of the AT Act and does not duplicate other data 

collection efforts. When possible, terminology, definitions and other features of this 
instrument are aligned with data collection instruments already used by AT Act grantees 

for other purposes.

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

8b of IC Data Part 2), describe any methods used to minimize burden.

This information collection does not involve small businesses and will not have a 

significant impact on substantial numbers of 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.

If this information is not collected, neither RSA nor states can fulfill their reporting 

obligations under the AT Act. Those obligations are annual, so the data collection 

cannot occur less frequently than annually.

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.

The proposed data collection is consistent with guidelines set forth in 5 CFR 1320.5, 

and requires no special circumstances.

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 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.

The revision of the annual AT Act data collection instrument was published in the 

Federal Register for a 60-day solicitation of comments period. A 30-day response to 

comments notice followed the initial 60-day Federal Register notice.

The Center for Assistive Technology Act Data Assistance (CATADA), the project 

responsible for coordinating the development of the current instrument, conducted a 

face-to-face meeting in July 2012 in Washington, DC and presented a review of all data 

elements, soliciting suggestions for revisions from representatives of the State Grant for 

AT programs of various types at the conference. CATADA sent an email to all 

grantees in August 2012 that included an initial draft of proposed data element revisions 

and requested feedback from the AT grantees. CATADA facilitated a conference call 

for grantees in October 2012 that highlighted suggested revisions to the instrument and 

again asked for feedback. The State Grant for AT programs provided suggestions for 

general revisions of the data collection system and a conference call was facilitated in 

November 2012 to remind grantees about providing more feedback to the instrument. 

RSA-CATADA facilitated a teleconference in March 2013 to review proposed revisions 

and additional grantee feedback prior to the May 2013 face-to-face presentation in 

Bethesda, MD on the proposed revisions to the instrument. RSA staff participated in all 

meetings. The current instrument takes the suggestions and feedback of the State 

Grant for AT programs into account.
The instrument submitted for review is an updated revision and renewal of the current 

instrument. CATADA and State Grant for AT representatives agreed that the instrument 

in this package captures the data reporting requirements of the states funded under the 

AT Act.

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

remuneration of contractors or grantees.

No payments or gifts are provided to respondents.

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

the assurance in statute, regulation, or agency policy.

Confidentiality for individual consumers receiving services from a State Grant for AT 

program is assured, because the states will not report information that identifies 

individual consumers. States will provide anecdotes about the effect of their programs 

on individual consumers, but states are instructed to write anecdotes in a manner that 

ensures their anonymity. All other data provided is reported in the aggregate.

The web-based system used for this instrument will not allow public access to the 

reporting instrument for data entry, and states will have access to their data only, so 

they will not be able to see or manipulate data of other states. Individual state reports 

will be kept confidential until they have been finalized by the state and accepted by 

RSA.

Once a report has been finalized by the state and accepted by RSA, access to the 

aggregated state-specific and national data will be available to the public via the 

Internet. However, while the public will be able to view the data, they will not be able to 

alter the data. States will be advised that their data will be available to the public in this 

manner.

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.

No questions included in the data collection instrument are considered sensitive.

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

should:
 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 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 item 16 of 

IC Data Part 1.

 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 402 hours needed to 

complete for a total annual burden of 22,512 hours. This information collection has 3 

pieces:

(A) A Web-based system that collects data from states.

(B) A performance measure survey that states collect from individuals

(C) A customer satisfaction survey that states collect from individuals.

(A) Fifty-six grantees report to the Department using the Web-based data collection 

system. A workgroup of grantees estimated that the average amount of time required to 

complete all responses to the data collection instrument is 190 hours annually. The 

estimated response burden includes time to review the instructions, gather existing 

data, and complete and review the data entries. These estimates are based on the 

experience of staff who implements these programs at the state level. This is based on 

a projected equal burden resulting from the balance of elimination of some data 

elements and addition of others as follows:

 Deletion of Active Loan Number and Active Loan amount in State Financing 

Activities

 Deletion of IT/Telecommunications performance measures from Device Loan 

and Device Demonstration Activities

 Addition of IT/Telecommunications performance measure to Training Activity

 Addition of Access performance measure to Device Loan (non-decision making) 

Activities
In addition, we project that clean-up and clarification of data elements will support no 

change in data burden estimates.

(B) The fifty-six grantees ask consumers to complete surveys that provide information 

on their performance related to the state’s measurable goals. Responses from states 

indicated that the average state will ask for this information from 1700 consumers at 5 

minutes per consumer, for a total of 141 hours annually.

(C) The fifty-six grantees ask consumers to complete customer satisfaction surveys. 

Responses from states indicated that the average state asks for this information from 

1700 consumers at 2.5 minutes per consumer, for a total of 71 hours annually.

Therefore, the combined burden of completing the data collection instruments and 

related surveys is 402 hours (190 + 141 + 71) per grantee. In discussions with program 

directors, it was agreed that at least one staff person would need to dedicate one full 

working day each week to all three data collection instruments, with an additional full 

week of data entry at the end of each reporting cycle. With 56 grantees responding, this 

brings the national burden to 22,512 hours annually.

Program staff also estimated the average recordkeeping burden at 22 hours per year for 

a total of 1,232 hours. Therefore, the total annual reporting and data collection burden 

would be 23,744 hours.

Assuming an average hourly cost of $30 per hour for staff members who complete the 

instrument, the cost burden for individual grantees is estimated to be $12,060 annually, 

and the total cost of data collection for the 56 grantees is estimated to be $675,360 

annually. Using the same rate, the cost for recordkeeping is estimated at $660 per 

state or outlying area, $36,960 total for all states and outlying areas, resulting in a total 

reporting and recordkeeping cost of $712,320 per year.

The average hourly cost of $30 represents the average, fully-loaded wage rate, i.e., 

includes pre-tax cash wages, fringe benefits and overhead support for several different 

classes of labor ranging from clerical to managerial labor and accounts for the amount 

of time different types of grantee personnel (i.e., clerical, technical, professional and 

managerial) are expected to expend.

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.

Total Annualized Capital/Startup Cost : $ .00

Total Annual Costs (O&M) : .00

____________________

Total Annualized Costs Requested : $ .00

No costs are incurred by respondents other than those specified in item 12. There are 

no capital costs or equipment purchases necessary. Respondents only need to have a 

computer and internet access to complete the data collection report.

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.

Section 6(b)(5) of the AT Act requires that RSA award a grant, contract, or cooperative 

agreement to an entity to assist states with data collection and reporting. The Center 

for Assistive Technology Data Assistance, CATADA, the entity that received this award

for the start of FY 2011, is responsible for developing the data collection instrument, 

providing training and technical assistance to states on use of the instrument, and 

assisting with writing the annual report to Congress based on data submitted into the 
MIS. Subject to appropriations, RSA anticipates providing approximately $250,000 

each year for five years to the recipient to perform the above data collection and 

reporting activities for the State Grant for AT programs, as well as data collection and 

reporting system training, technical assistance, and analysis for title III AFPs, OMB 

1820-0662. The estimated annualized cost to the Federal government for the State 

Grant for AT portion of the cooperative agreement is $197,500.

In addition, RSA employs one management and program analyst at the GS-14 level and 

one program specialist at the GS-13 level with the responsibility for the administration of 

grants funded under the AT Act, including this data collection. These employees are

housed in the Service Programs Unit, which is overseen by a Unit Chief and Director. 

RSA staff dedicates a percentage of their time to this data collection, creating an 

additional cost. RSA also employs an information technology specialist in the Program 

Support Staff Unit, who built the current State Grant for AT data collection system in the 

MIS and will update the system upon OMB approval of this instrument. The 

development and limited maintenance of this instrument in the MIS is an additional cost 

associated with the State Grant for AT data collection. The above staff dedicates a 

percentage of their time to this data collection, therefore the estimated annualized cost 

to the Federal government for RSA staff time is $66,890.

15. Explain the reasons for any program changes or adjustments to #16f of the IC Data 

Part 1 Form.

This information collection includes an adjustment decrease of 4 burden hours from 406 

hours to 402 hours per state AT program for a total reduction burden of 224 hours. The 

burden hour reduction is a result of a reduction in the due to the updates to the 

instrument noted below. This is a program change and consistent with the IC Data Part 

I Form. The proposed State Grant for AT IC package will result in a reduction in 

burden, but not a reduction in the number of respondents.

State AT Data Collection Instrument 

List of Revisions

The following identifies revisions to the Data Collection Instrument by page number for 

the State Grants for Assistive Technology Annual Progress Report.

Page 8 - Active Loans and Active Loan Amount

Reason for change: This data element is consistently reported incorrectly and needs to 

be simplified. The way it is currently reported is not applicable to some states given the 

loan structure they use and creates inequitable application to grantees.

Description of change: The two active loan data elements have been deleted. 

Financial loan programs will only report the current number of loans that defaulted 

during the reporting period and the net loss of those loans as have been reported 

previously. In addition, the instructions have been clarified to allow financial loan 
programs to “defer” reporting a default to the next fiscal year if they think they can 

“recoup” some of the loan amount during the next 12 months and thus would have a 

more accurate net loss amount to report. This is simply acknowledging how many 

states already report defaults.

Page 11 and 12– Description of Individuals Excluded from Performance Measure

Reason for change: There has been considerable confusion about when it is legitimate 

for individuals to be excluded from the performance measure. Additional description is 

needed to support review and data consistency across grantees.

Description of change: A text box has been added that must be completed when 

individuals are excluded from the performance measure (a positive number is reported 

in line 2.D on page 11 and on page 12).

Page 13 – Anecdotes (State Financing)

Reason for Change: To streamline the narrative text entered for anecdotes. 

Description of change: All of the text entry places for anecdotes will have a 1000 word 

limit for the text that will be pulled via the MIS ad hoc system. A place has also been 

added for grantees to indicate if they have a picture to accompany the anecdote 

narrative entered. These changes have been made for all anecdote sections 

Page 17 - Description of Individuals Excluded from Performance Measure

Same change as above, text box must be completed when individuals are excluded 

from the performance measure (a positive number is reported in line A.F on page 17.

Page 16 – Reuse Open-ended Loans

Reason for Change: To clarify the difference between reuse open-ended loan and short 

term device loan.

Description of change: Language was added to support better understanding of the 

distinction between reuse open-ended loan (generally a device is placed with a 

consumer on an extended basis via loan rather than ownership transferring to the 

consumer) and short term device loan (generally a short-term loan period and transfer 

of ownership is never a consideration.)

Page 19 – Anecdotes (Reuse) 

Same change as above. 

Page 22, 24 & 25 – Device Loan Performance Measure Expansion 

Reason for Change: The current Access performance measure only applies to device 

loans made for a decision-making purpose which leaves many device loans without any 

performance measure reported.

Description of change: To include more device loans in the performance measures the 

acquisition performance measure was applied to the other device loan purposes: those 

made for the purpose of short-term accommodation, using the device during a repair 

period or while waiting for funding, and training or other personnel development 

activities. The device loan section has been revised to include reporting of both access 

and acquisition performance measures as appropriate given the purpose of the loan. 
The acquisition performance measures for device loans will be included in the overall 

acquisition performance measure percentages (along with state financing and reuse).

Page 23 & 24 – Deletion of IT/Telecommunications from Access Performance 

Measure

Reason for Change: The inclusion of IT/Telecommunications as an area of the access 

performance measure was a consistent problem because it was not comparable to the 

other areas of education, employment and community living that are environments of 

AT use. IT/Telecommunications is actually more of a type of AT but is included in the 

AT Act so a performance measure is required for that area.

Description of change: The IT/Telecommunications area has been deleted from the 

access performance measure and instead a new performance measure has been 

established for the IT/Telecommunications area within the Training activity (see below).

Page 23 & 24 – Anecdotes (Device Loan)

Same change as above.

Page 28 – Anecdotes (Device Demo)

Same change as above.

Page 30 – Overall Performance Measure Tables

Reason for Change: Many grantees have total performance measure numbers within 

areas (Education, Employment, etc.) that are too small to calculate valid percentages or 

are zero which mean no performance measure can be calculated at all.

Description of change: To address the small N issue, the data instrument has been 

revised to include two new overall performance measure tables which use the overall 

total performance measure numbers instead of each area (Education, Employment, 

etc.) to compute the performance measure ratios. These tables will be auto-populated 

from the individual performance measure data reported by activity and will allow 

grantees to see their access and acquisition performance measure percentages as they 

submit their Annual Progress Report (572) rather than waiting for the State Plan to be 

auto-populated. (Some entities who implement the program and do the data reporting 

do not complete the State Plan and as a result do not have direct access to the 

performance measure calculations.)

Page 34 – Training Narratives

Reason for Change: To streamline the narrative text entered for training data.

Description of change: All of the text entry places for description of innovation or high 

impact training and transition training will have a 1000 word limit for the text that will be 

pulled via the MIS ad hoc system. Additional text may be entered but will not be 

displayed in a data download.

Page 34 – Performance Measure for IT/Telecommunications Training

Reason for Change: Because it is highly unlikely that the AT Act will be reauthorized or 

amended in the near future, an alternative for addressing the statute requirement for a 

performance measure for IT/Telecommunications was needed.
Description of change: A performance measure has been developed for Training in the 

topical area of IT/Telecommunications. Data on training provided in this topic area is 

already reported. A performance measure has been added for training provided in the 

topical area of IT/Telecommunications and will be collected from the individuals 

reported as participants in those trainings.

Page 37 – Technical Assistance Narratives

Reason for Change: To streamline the narrative text entered for technical assistance 

data.

Description of change: All of the text entry places for description of innovation or high 

impact technical assistance and transition technical assistance will have a 1000 word 

limit for the text that will be pulled via the MIS ad hoc system. Additional text may be 

entered but will not be displayed in a data download.

Page 41 & 42 – Leveraged Funding (Activities not reported previously)

Reason for Change: To clarify the difference between activities reported in Section A 

and B. 

Description of change: Revisions have been made in the narrative description of 

leveraged funding that should be reported in Section B to clarify the difference between 

the two Sections.

Forms: 

Edited Acquisition Performance Measure data collection form (SFA and Reuse) – p. 45

Added new Device Loan Acquisition Performance Measure data collection form – p. 46

Added new Training IT/Telecommunications Performance Measure data collection 

form–p 46

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 aggregate, national data derived from this collection will be used to create an 

annual report to Congress. The format of this report responds to the requirements of 

Section 7(d) of the AT Act.

Because states receive grants every year, there is no end date for the reporting 

requirements. States will remain on a set reporting cycle, with the period beginning 

October 1 and ending September 30 each year. The due date for the completed annual 

data reports is December 31 and the deadline for RSA approval of the collection is May 

31 of each year. Approved annual data reports will be posted on RSA’s website. No 

complex analytical techniques will be used.
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.

RSA will display the expiration date for OMB approval of the information collection. See 

the Paperwork Burden Statement document.

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

Paperwork Reduction Act.

There are no exceptions to the certification statement.