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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

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.

To maximize the use of funds appropriated for formula grant programs, the 

Rehabilitation Act of 1973, as amended (the Act), authorizes the Commissioner 

to reallot to other grant recipients that portion of a recipient's annual grant that 

cannot be used. The Rehabilitation Services Administration (RSA) reallots funds 

for the Basic Vocational Rehabilitation State Grants (VR), Supported 

Employment State Grants (SE), Independent Living State Grants, Part B (IL-Part 

B), Independent Living Services for Older Individuals Who Are Blind (IL-OB), 

Client Assistance (CAP), and Protection and Advocacy of Individual Rights 

(PAIR) programs. The authority for RSA to reallot formula grant funds is found at 

sections 110(b)(2) (VR), 622(b) (SE), 711(a)(3)(c) (IL-Part B), 752(j)(4) (IL-OB), 

112(e) (CAP), and 509(e) (PAIR) of the Act.

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.

The information will be used by the RSA State Monitoring and Program 

Improvement Division (SMPID) to reallot formula grant funds for the awards 

mentioned above. For each grant award, the grantee will need to enter the 

amount of funds to be relinquished and/or any additional funds the grantee 

would like to request.

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 of using information 

technology to reduce burden.

The collection of information will be completed using the RSA Management 

Information System (RSA-MIS). RSA grantees currently enter required State 

Plan and Federal Financial Reporting data (e.g., SF-425) into the RSA-MIS. 

Each grantee has a secure ID and password which is required to logon to the 
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RSA-MIS. This information collection uses the same login credentials to ensure 

uniformity with currently approved data collections. 

Frequently, grantees will submit an initial request that is later amended prior to 

the submission due date. Amendments further delay reallotment due to the time 

required to process changes and re-enter data. Submission of the reallotment 

information through the RSA-MIS enables the grantees to change the 

information up to the due date of the submission. It also reduces the need for 

RSA SMPID staff to enter data into a separate spreadsheet for tracking and 

calculating the revised grant award amounts; thereby, reducing the chance of 

data entry errors.

3. Describe efforts to identify duplication. Show specifically why any similar 

information already available cannot be used or modified for use of the 

purposes described in Item 2 above.

Requiring the data to be entered using the RSA-MIS effectively utilizes data

already available to reduce the amount of information grantees must provide.

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.

Since all grantees currently submit OMB approved required information 

collection data using the RSA-MIS, there should be no additional impact.

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.

Not reallocating the formula awards on an annual basis would result in a loss of 

program funds for grantees able to meet the match requirements. If not 

realloted, funds which grantees are unable to match would be unavailable to 

meet the employment needs of individuals with disabilities and would revert to 

the US Treasury.

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;

This information is collected on an annual basis.

 requiring respondents to prepare a written response to a collection of 

information in fewer than 30 days after receipt of it;
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The RSA-MIS form is available at least 30 days prior to the required 

annual submission date.

 requiring respondents to submit more than an original and two copies of 

any document;

Copies are not required due to electronic submission.

 requiring respondents to retain records, other than health, medical, 

government contract, grant-in-aid, or tax records for more than three years;

Data is maintained in the RSA-MIS and therefore, results in less 

paperwork requirements for grantees.

 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;

The information collected is not connected to a statistical survey.

 requiring the use of a statistical data classification that has not been 

reviewed and approved by OMB;

The information collected does not require statistical analysis or 

classification.

 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

The information collected is not protected by confidentiality and is 

available through FOIA.

 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 information collected does not include any proprietary trade secrets 

or other confidential information.

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 
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that notice and describe actions taken by the agency in response to these 

comments. Specifically address comments received on cost and hour 

burden. 

N/A

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. 

N/A

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. 

N/A

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

remuneration of contractors or grantees.

No payment or gift was provided to any respondents.

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

basis 

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

No assurances of confidentiality are being made to respondents.

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 data of a sensitive or private nature is being requested.

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

statement should:
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 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.

The original data related to the hour burden of the collection was obtained 

from six respondents who are active grantees and VR Finance Directors. The 

respondents previously submitted the requested information in accordance 

with RSA’s annual Information Memorandum related to reallotment. The 

respondents indicated overwhelmingly that collecting the data through the 

RSA-MIS would decrease the time and effort it takes them to respond. 

The respondents estimated it would take less than 2 minutes per award to 

enter the data online. The primary information necessary for the grantee to 

determine whether to relinquish and/or request funds is tracked using 

quarterly SF-425 submissions. Therefore, the grantees do not need to 

complete additional analyses or calculations prior to completing the RSA 

Grant Reallotment form.

 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.

N/A

 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 not be included in Item 14.

The annualized cost was difficult to obtain because grantees were

submitting the requested data through the annual RSA Information 

Memorandum. All the respondents agreed that completing this process 

through the RSA-MIS would reduce the time and therefore, cost related to 

the data 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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 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 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

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.

The form is being collected through the RSA MIS and therefore there are no 

costs.

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

 Data Part 1 Form.
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N/A

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.

Once the reallotment process is complete, any adjustments to the grantees 

award amount are available online from the Department of Education’s Grant 

Award Database. The information is publically available.

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.

N/A

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

Certification of Paperwork Reduction Act.

N/A