Att_Supporting Statement

Att_Supporting Statement.doc

Written Application for the Independent Living Services for Older Individuals Who are Blind Formula Grant

OMB: 1820-0660

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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION


Independent Living Services for Older Individuals who are Blind     



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 (Act), Title VII, Chapter 2-- Independent

Living Services for Older Individuals Who Are Blind authorizes grants to each State and

certain territories to provide rehabilitation services to eligible blind individuals. The

application required by the Commissioner of Rehabilitation Services Administration

(RSA) is the State's written request for grant funds and assurances that the Designated

State Agency (DSA) can carry out its statutorily prescribed purposes and functions.


This preprint is based on the following:

(1) Title VII, Chapter 2 of the Act, as amended;

(2) the regulations (34 CFR Part 367);

(3) Education Department General Administrative Regulations (EDGAR 34 CFR

Part 76) and other applicable EDGAR regulations (refer to

34 CFR 367.4).


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.


To receive a grant under § 752(a) of Title VII, Chapter 2 of the Act or a re-allotment

grant under § 752(j)(4), a DSA must submit to, and obtain approval from, the Secretary

an application for assistance under this program at the time, in the form and manner,

and containing the agreements, assurances, and information, that the Secretary

determines to be necessary to carry out the program (§§ 752(c)(2) and 752(i))


The application package consists of the following documents:


(1) A cover letter from the Commissioner (or Acting Commissioner) of RSA to the director of the DSA;

(2) the assurances required by the Act and in 34 CFR 367.11;

(3) Certifications regarding Lobbying.

The preprint being submitted for approval is for an extension, without change, of

a currently approved, OMB NO: 1820-0660 “Written Application for the Independent

Living Services for Older Individuals Who Are Blind Formula Grant (SC)”


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.


This collection allows states to email, fax, or mail in a hard copy of their information. The decision to allow email or fax submissions was made to provide an option to respondents to submit required information more quickly and easily, reducing 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.


There is no duplication of this information collection. Also, there is no already available information collection that can be used or modified for use for the purpose described in item 2 above.



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.


The collection of this information does not involve 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 frequently, as well as any technical or legal obstacles to reducing burden.


Sections 752(c)(2) and 752(i) of the Act require the State to submit an application for

the grant to the Commissioner in such form and manner and containing such

agreements, assurances, and information as the Commissioner determines to be

necessary. If the State fails to complete the application as required, the State will not

be eligible for Federal funds for the Independent Living Services for Older Individuals

Who Are Blind program. This method has been established as the required procedure

for requesting grant funds for this program on a three-year basis.


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.


There are no special circumstances that would require this information to be collected

in a different manner than set forth in the Act.


  1. 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 60-day Federal Register notice soliciting public comment on this information collection was published November 2, 2010 (Volume 75, Number 211) Pages 67350-67351. No comments were received. The 30-day public comment period will be published at the time of OMB submittal.


  1. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.


No payment or gift has been provided to respondents.


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

the assurance in statute, regulation, or agency policy.


No assurance of confidentiality is provided to respondents.


  1. 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.


The written request does not contain any questions of a sensitive nature.


  1. 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.


a. Number of respondents -- 56

b. Frequency of response -- 1 (every three years)

c. Total annual responses (axb) -- 56

d. Hours per response -- .16*

e. Total burden hours (cxd) -- 9

f. State hourly rate of salary -- -- $20

g. Total cost (exf) -- $180


* The hour burden associated with this application is 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. Estimated burden hours are founded on judgments from previous State written request submittals for similar RSA grants.


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


There is no additional cost burden to States and Territories.


  1. Provide estimates of annualized cost to the Federal government. Also, provide

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.


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 -- $25

e. Total cost (cxd) -- $225


* The estimated burden hours to the Federal government does not include time needed for negotiations when a written request is not approvable. 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 to #16f of the IC Data Part 1 Form.


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 reasons that display would be inappropriate.


This document is not seeking OMB approval not to display the expiration date.


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


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

Reduction Act Submissions."


B. Collection of information employing statistical methods:

This is a legal document and does not require the use of any statistical methods in obtaining information.





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File Typeapplication/msword
File TitleSUPPORTING STATEMENT
AuthorKenneth Smith
Last Modified ByAuthorised User
File Modified2010-12-29
File Created2010-12-29

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