Attached below please find some preliminary OMB comments on 1820-0500. As you will see from our comments below, it was difficult to discern from the supporting statement what changes are being requested from the previous approval. We will need this information to complete our review and await your response on this issue.Best,RachelOMB Comments on
State Plan for VR & SE Services
1820-0500
- Item 1 of the supporting statement indicates that you are eliminating all of the regulatory requirements from this submission. Have the regulations changed since the last submission? (This is confusing since you also state that the regs were finalized in Jan 2001.) If not, does this suggest to reporting entities that they don�t need to comply with the regs?
The present version of the State Plan for Vocational Rehabilitation (VR) and its Supplement for Supported Employment (SE), which will expire on January 31, 2007, was in place prior to the 1998 reauthorization of the Rehabilitation Act of 1973 as amended (the Act). Regulations reflecting statutory changes to the 1998 reauthorization of the Act were promulgated in January 2001. In an effort to reduce the paperwork burden associated with developing the State Plan, the 2001 regulations reduced the number of attachments or assurances that must be submitted as part of the VR State Plan and SE supplement, retaining only those attachments or assurances required by the Act. Although the deleted VR State Plan and SE supplement assurances and/or attachments are no longer required components of the VR State Plan and SE supplement, the underlying requirements of these deleted components are still considered essential to the proper and efficient administration of the VR program and are retained in the implementing regulations as VR program requirements. The deletion of these components is designed to reduce administrative burden on the states and to better focus resources on the employment needs and choices of individuals with disabilities, particularly individuals with significant disabilities. In addition, these changes more closely align the VR State Plan and SE supplement components with the State Plan components of other WIA partner programs.
In anticipation of reauthorization of the Act in 2003, the Rehabilitation Services Administration (RSA) was advised by the Department not to submit a revised VR State Plan and its SE supplement, and instead submit the existing VR State Plan and SE supplement for approval. State VR agencies were made aware of changes to the requirements for submission of the VR State Plan and SE supplement reflected in the 1998 reauthorization and 2001 implementing regulations, and have submitted the VR State Plan and SE supplement in accordance with those changes beginning in FY 2001. For a more detailed description of the changes to the components of the State Plan brought about by the 2001 regulations, please see the attached information memorandum, IM 01-20, dated January 19, 2001.
- On p. 6 of the supporting statement, you state that RSA is seeking to extend the currently approved form (which would suggest no changes) for FY07. This conflicts with the discussion in question 1 above. Please clarify whether this approval request is for a revised form or for a continuation of the existing form (with no changes). If the former, please provide a detailed discussion of the changes you are making.
RSA is seeking approval of a revised State Plan as described in item 1 above. We have corrected the error contained in the answer to question 8 of the Supporting Statement accordingly. Please see the attached document. In addition, we will provide you with a document describing the specific changes to the State Plan through a separate email.
Item 14 of the supporting statement should reflect only Federal costs, not costs to the State and Federal governments.
Per your request, we have included the information regarding the cost and hours associated with the completion and submission of the State Planby VR state agencies at the conclusion of the answer to question # 12 of the Supporting Statement. Please see the attached document.
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