Att_SGAT 572 Supporting Statement

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, 2011.

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 contents of the State Plan for AT are 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 states and outlying areas 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 web-based 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 (Rehab 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-269s, SF-425s, and State Plans for AT (OMB No. 1820-0664).

This web-based system allows all 56 states 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 5 through 16 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 the 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 (RSA-572) 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 in APS in their State Plan for AT, since the data would not need to be reported separately, as it is reported currently.

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:

1. the data collection requirements of section 4 and Title III are similar but not the same; and

2. 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 National Information System for Assistive Technology (NISAT), the project responsible for coordinating the development of the current instrument, established a workgroup comprised of representatives from State Grant for AT programs of various types. NISAT was also responsible for the development of the instrument for data collection and reporting on title III AFPs in OMB Number 1820-0662, as required under section 6(b)(5) of the AT Act, through a cooperative agreement with RSA. NISAT facilitated teleconference meetings of the workgroup through March 2011. During these meetings, State Grant for AT programs provided suggestions for general revisions of the data collection system. RSA staff participated in all meetings. The current instrument takes the suggestions of the workgroup into account.

The instrument submitted for review is an updated revision and renewal of the current instrument. NISAT and State Grant for AT representatives agreed that the current instrument 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 to be developed 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 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.

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. We estimate that the average amount of time required to complete all responses to the data collection instrument is 194 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 implement these programs at the state level. The general consensus of the data collection work group referred to in the response to Question 8 is that the revisions to the State Grant for AT information collection by itself would save about 50 hours from the current estimate of 244 hours.  This is based on an anticipated reduction in burden resulting from the elimination of the following data elements:

• All of the “Are devices included” column in AT Tables for Reuse and Device Loan

• All of the separate TA activity reports, replaced with a total activity table with fewer categories (only the goal areas of education, employment, community living, and information technology)

• The “Related Disability Topics” from the I&A Table

• The entire Coordination and Collaboration Section

• The descriptor tags in State Improvement Outcomes, replaced with one categorization list (only the goal areas of education, employment, community living, IT)

In addition, the clean-up of the instrument and alignment with the MIS is included in the estimated time-savings. 

(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 ask 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 406 hours (194 + 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 22,736 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 recordkeeping burden would be 23,968 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 $12,180 annually, and the total cost of data collection for the 56 grantees is estimated to be $682,080 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 $719,040 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 additional 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 National Information System for Assistive Technology, NISAT, the entity that last received this award, 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. The award RSA made in fiscal year 2006 ended in fiscal year 2010. A competition for a new award is currently being conducted. Subject to appropriations, 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 dedicate a percentage of their time to this data collection, therefore the additional 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.

The proposed State Grant for AT have the reduction of 2,828 hours, but no reduction in respondents. This is a program change resulting from the elimination of data elements to the State Grant for AT and clean-up of the instruments to align with the MIS reducing burden from approximately 50 hours from the current estimated of 244 hours.

State AT Data Collection Instrument

List of Revisions

The following identifies revisions to the Data Collection Instrument for the State Grants for Assistive Technology Annual Progress Report.

State Financing Changes and Rationale	Page(s)
“General Information” replaced with “Overview of Activities Performed” and narrative in A., B and C (financial loans and both “other”) revised to align with MIS data entry. Added question about Title III AFP loans reported. Deleted “Access to Telework” to be ONLY reported in separate Telework report.	4-5 11 12
“Number and Percentage of Loans Made to Applicants with Income of” Table revised to better reflect the distribution of incomes toward the high end. Increments were skewed too low to be useful as frequency distribution.	6
Deleted loan type of “Loan guarantee (no special interest rate)” as duplicate of “Preferred interest (greater than prime) with loan guarantee only”. Deleted “other” loan type. Split “Revolving Loan” into Low and Preferred Interest.	6
Clarified reporting of refinance loans.	8
Added 7 to Financial Loan to include all AFP data elements (unduplicated data).	9-10
Deleted “Other” from Type of AT Device/Service Table in all three State Financing sections, Financial Loan, Other that Provides AT and Other that Provides AT Savings. Other category has not been used or needed.	8 12 13
Revised Number for whom Performance Measure Data are Collected Table to clarify exclusion and auto calculate included number for Other SFA Activities.	11 12
Deleted Additional Activities in both State Financing Other sections to align with MIS structure with numbers used to cue forms.	None
Added required AFP anecdote in D. to cover AFP required data. Revised narrative in Performance Measure E. to delete term “survey” to agree with Instructions.	13 14

Reuse Changes and Rationale	Page(s)
Revised terminology – Reuse, reassignment/refurbish & repair (deleted recycle)	16-20
General Information replaced with Overview of Activities Performed and narrative aligned with MIS data entry structure. Clarified unduplicated recipients.	16-17
Revised Performance Measure Table pulling out those excluded in separate line to clarify allowable reasons for exclusion and to better align with MIS.	17
In Type of AT Device Table for Exchange, Recycle and Open-Ended Loan, deleted column asking if device is included in listing. Also deleted “other” AT category.	18 19
Revised narrative in Performance Measure Section F to delete term “survey” to agree with Instructions.	19
Revised Satisfaction Section G to delete statement of including “sellers and well as buyers” as MIS already excludes sellers.	20

Short-term Device Loan Changes and Rationale	Page(s)
General Information replaced with Overview of Activities Performed and narrative aligned with MIS data entry structure.	21
Added clarification about accommodation purpose, length of short-term loans, and expertise available to support decision-making.	21-22
Added to Primary Purpose Table, “Conduct training, self-education or other professional development activity” and deleted “Other”.	22
Deleted “other” in Borrower Type Table.	22-23
Deleted “usual” in length of loan; deleted reference to no policy as all should have policy; clarified – use midpoint if range and do not include extensions.	23
Deleted column asking if device is included in listing in Type of AT Device Table. Also deleted “other” AT category as not used.	23
Revised narrative in Performance Measure Section F to delete term “survey” to agree with Instructions..	24

Device Demonstration Changes and Rationale	Page(s)
General Information replaced with Overview of Activities Performed and narrative aligned with MIS data entry structure.	26
Added to instructions clarification about differences between demo and training	26
Deleted column asking if device is included in listing in Type of AT Table. Also deleted “other” AT category as not used.	27
Deleted “other” in Participant Type Table.	27
Added required description of “other” in Type of Referral Entity Table; clarified there is no place to report “unable to categorize” or "data is not available”	28
Revised narrative in Performance Measure Section F to delete term “survey” to agree with Instructions.	28

Training Changes and Rationale	Page(s)
Added Overview of Activities Performed to align with MIS data entry structure.	30
Deleted “other” in Participant Type Table and in Primary Topic of Training Table.	31, 32
Added clarification to Topic of Training Table requiring number in Transition Topic cell unless transition narrative is provided in Technical Assistance section.	32
Added clarification to transition training narrative requiring completion unless transition narrative is provided in Technical Assistance section.	33

Technical Assistance Changes and Rationale	Page(s)
Clarified distinguishing between TA and I&A	34
Added Overview of Activities Performed to align with MIS data entry structure.	35
Replaced all “tag” data in Frequency and Nature of TA with table of percentages of TA by area provided during the reporting period with AT Act dollars.	35
Added clarification to transition narrative requiring completion unless transition training data was reported.	36

Public Awareness and I&A Changes and Rationale	Page(s)
Added Overview of Activities Performed to align with MIS data entry structure and NOTE on OMB prohibition on using federal money for “promotional items”.	37
Added to Public Awareness Activity table – “blogs” and “social media” to category of listservs; new category of “other electronic media”. Deleted “other” category (existing categories cover major items, anything else would not necessary to report).	38
Deleted “Related Disability Topics” as category for content in I&A Table. Expanded AT Funding to include Policy/Practice. Deleted “other” as category of recipient. Unable to categorize remains as option for reporting recipients.	38

Coordination and Collaboration Changes and Rationale	Page(s)
Deleted entire section. Data is not required by AT Act and difficult to aggregate nationally.	None

State Improvement Outcomes Change and Rationale	Page(s)
Added Overview of Activities Performed to align with MIS data entry structure. Limited report to 2 major activities maximum. Clarified outcomes reported must result in policy, practice or procedure improvements.	39
Replaced item tags in subsections 4-6 with one pick list asking for categorization in education, employment, health care, community living, or IT/Telecom.	39

Leveraged Funding Changes and Rationale	Page(s)
Added Overview of Activities Performed to align with MIS data entry structure.	40
Added pick list to Fund Source in both Tables A and B with direction to pick one.	40-41
Deleted “Non-AT Act” from use of fund - data is out of scope for AT Act report.	41

State Grant for AT Data Collection Instruction Manual and Definitions

List of Revisions

The following identifies revisions to the Annual Assistive Technology Act Data Collection Instruction Manual and Definitions.

I. General Instructions

Reporting Data – Added clarification for reporting Title III AFP loans ONLY once, either as State Financing (with additional AFP data elements) or in separate AFP report. Clarified Telework financial loans ONLY reported in separate Telework report, NOT State Financing.

Missing Data – Deleted entire section as data should not be missing any longer.

F. Classification of Devices -- Changes/Rationale	Page(s)
Deleted “other” AT Category to align with instrument changes. Added note indicating devices must be reported in one of the 10 categories.	None
Learning AT Category: Clarified instructional software is limited to computer applications and adapted toys should be reported in Recreation/Leisure.	9
Moved “orthotics and prosthetics” in Mobility, Seating and Positioning to a separate header rather than under “Ambulatory aids” so it is clear all orthotics and prosthetics are reported in this category.	10
Clarified Daily Living AT Category: Added “sleeping” and “breathing” to list of activities in definition. Added “life support” to decision rules and examples of “medical and respiratory equipment”. Added clarification of how to report switches. Added “dentures” to list of examples in “eating/feeding equipment”.	11
Environmental Adaptations: Added clarification on reporting switches and added adapted farm equipment (augers, seeding systems) as example when such equipment is not reported as Vehicle Mod & Transportation.	12
Vehicle Modifications: Added “Adapted farm vehicles, tractors and other self-propelled vehicles modified with hand controls, GPS, lifts, etc.” to example list.	13
Clarified reporting of toys and adaptive toys as Recreation, Sports and Leisure.	15

G. Classification of Individuals and Entities -- Changes/Rationale	Page(s)
Deleted “other” category to align with instrument changes. Added note indicating in most sections participants must be reported in one of the 7 categories (except for those that allow an unknown/unable to categorize.)	17
Added clarification to Family Members, guardians and authorized representatives to include persons who participate in an activity with an individual with a disability such as friends and advocates.	16
Added clarification about categorization of IDEA Part C representatives based on the lead agency designation for the state in the discussion related to situations in which more than one category is applicable.	17

H. State Improvement Outcomes - Edited to indicate reporting of maximum of two MAJOR outcomes and aligned with instrument (page 18).

I. Performance Measures – Added clarification about categorizing performance measures for non-respondents (page 21) and aligned with instrument changes.

Coordination and Collaboration – deleted entire section to align with instrument changes.

II. Section-Specific Instructions and Definitions

B. State Financing – Clarified reporting financial loans ONCE; Title III AFP as State Financing (with extra data elements) OR AFP (not both); Telework in separate report only (page 25-27).

I. Additional and Leveraged Funds – Added definitions of fund source type to support new categories in data collection instrument (page 34).

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.