1820-0508 RSA 911 Supporting statement (2)

OMB 83-1 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.

The data comprising the Case Service Report (RSA-911) are mandated by the Rehabilitation Act of 1973, as amended (Rehabilitation Act). Attachment A shows the applicable portions of the Rehabilitation Act that explicitly or implicitly require the recording and reporting of specific data elements by vocational rehabilitation (VR) agencies to the Rehabilitation Services Administration (RSA).

Section 13 of the Rehabilitation Act requires the Commissioner to collect and report information specified in Section 101(a) (10) to the Congress and the President in the Annual Report. Section 14 of the Rehabilitation Act requires the Commissioner to conduct evaluations of the VR program. The information from this data collection is used in evaluating the outcomes of the program. Section 626 requires the same information to be reported for individuals who received supported employment (SE) services. RSA-911 data are also needed to satisfy the requirements of Section 131 of the Rehabilitation Act calling for an exchange of data between RSA, the Social Security Administration (SSA) and the Department of Labor (DOL).

Section 106 requires RSA to define performance indicators and establish standards that VR agencies must achieve to retain program benefits. A subset of data elements from this reporting instrument are abstracted, aggregated, and applied according to prescribed formulae to generate the performance indicators for each VR agency. The results of such calculations are then compared to the established standards to determine agency performance.

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 Commissioner must collect and include in the Annual Report to the President and Congress (Sections 13 and 101(a) (10)), the computation of evaluation standards and performance indicators as required by Section 106 of the Rehabilitation Act, and the data exchange with SSA (Section 131 of the Rehabilitation Act). RSA also uses data reported through this data collection to support its other responsibilities under the Rehabilitation Act. Section 14 (a) of the Rehabilitation Act calls for the evaluation of programs of the Rehabilitation Act and an assessment of their effectiveness in relation to cost. Through the years, many of these evaluation studies have utilized RSA-911 data. The Commissioner must also assure that each Individualized Plan for Employment (IPE) meets the requirements of law, and, most particularly, that emphasis is placed on the achievement of a vocational goal (Section 102 of the Rehabilitation Act). RSA‑911 data provide the means by which the Commissioner monitors the degree to which vocational goals are being achieved, as well as to evaluate the performance of VR agencies. In addition, RSA uses these data during the conduct of both the annual reviews and periodic onsite monitoring of VR agencies required by Section 107 of the Rehabilitation Act to examine the effectiveness of program performance.

Other important management activities, such as the provision of technical assistance, program planning, and budget preparation and development are greatly enhanced through the use of RSA‑911 data. The RSA-911 is considered to be one of the most robust databases in describing the demographics of the disabled population in the country and as such is used widely by researchers’ disability-related analyses and reports.

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 RSA-911 is an electronic text file that is created by extracting selected data elements from the state agency VR case management data systems. This poses little processing burden on the agencies. The text files are submitted electronically to a Department of Education server via secure file transfer protocol (SFTP). If agencies are unable to submit their data to the SFTP server, data are sent on a compact disc via overnight services and must be signed for by the recipient.

4. 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.

The RSA‑911 is the only data collection through which RSA requires data to be reported for each individual who applied for VR services. These data are not otherwise collected by the Department of Education. There is no duplication of data elements with any other reporting systems.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

The collection of information for the RSA-911 does not impact small businesses or other small entities. Respondents are agencies of state governments that must keep comprehensive records on individuals who apply for services in order to better serve them and to fulfill the service record requirements of the Rehabilitation Act. This is true even for the smallest state VR agencies, as defined by the contents of the individualized plan for employment (IPE) governed by Section 102. VR agencies, large and small, must also account to their state governments for the expenditure of funds. The reporting requirements of the RSA‑911 involve a portion of information that agencies must collect to manage their VR programs. To make reporting easier for small agencies, RSA has given agencies the option of sending in data electronically to a Department of Education SFTP server. If agencies are unable to submit their data to the SFTP server, data may be sent on a compact disc via overnight services and must be signed for by the recipient.

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.

It is not possible to collect RSA-911 data less frequently than annually as Section 13 of the Rehabilitation Act requires annual reporting. The major consequence of the non‑collection of data would be that the Department of Education and RSA would be operating the VR and SE programs in violation of the law. A second consequence would be that RSA would lack indicators of program impact and effectiveness, making it difficult to account for the federal dollars allocated for these programs. Furthermore, RSA could not adequately conduct activities such as program monitoring, planning, policy formulation, and technical assistance. Finally, without this data collection, the Commissioner would be unable to comply with Section 106 of the Rehabilitation Act, which requires that the results of evaluation standards and performance indicators be computed annually and reported to Congress.

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 which 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 require the collection to be conducted as described in the bulleted items above.

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.

See attached document “RSA-911 Comments and Analysis” for RSA’s responses to comments received and subsequent changes as a result of the 60-day publication of the proposed revised RSA-911 data collection and instructions in the Federal Register on Monday July 2, 2012, page 39,224.

RSA regularly contacts the Council of State Administrators of Vocational Rehabilitation (CSAVR) on developments affecting the RSA-911 system. CSAVR is an umbrella organization, headquartered in suburban Washington, DC, representing the 80 respondents (VR agencies).

The proposed revision of the RSA-911 system was undertaken with the assistance of a small work group comprised of VR agency staff. The membership of this group was recommended by CSAVR. The work group reviewed drafts of issue papers, revision plans, and the revised RSA-911 itself. The individual members shared perspectives based upon experiences within their respective states.

Finally, a as a result of the comments received from the 60- day notice, revisions were made and the 30-day notice will be published in the Federal Register for public comment.

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

RSA will not provide any payments or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The Case Services Reporting System is a major application requiring a system security plan per OMB Circular A-130, “Management of Federal Information Resources,” Appendix III, “Security of Federal Automated Information Resources,” and of Public Law 100-235, “Computer Security Act of 1987.” A system security plan has been developed in alignment with OMB and legal requirements http://www2.ed.gov/notices/pia/csr_041408.pdf. This plan details the security requirements and describes the security controls that are in place to meet those requirements. Printed reports containing sensitive data produced from this system are maintained within the locked filing cabinets within the access-restricted State Monitoring and Improvement Division within Office of Special Education and Rehabilitative Services Headquarters. Additional storage and safeguards information is contained in the applicable System of Records Notice referenced below.

A System of Records Notice (18-16-02) was published in the Federal Register April 8, 2004 in volume number 69, page 18724 http://www.ed.gov/notices/pai/pai-18-16-02.pdf. All data collection activities will be conducted in full compliance with The Privacy Act of 1974, P.L. 93-579, 5 USC 552a. This system and privacy data in the system will be accessible only to employees of OSERS. Aggregate and other non-privacy data is available to external researchers. A full description of opportunities for consent and how information is shared with other organizations is provided in the System of Records Notice.

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.

There are no questions of a sensitive nature that appear in the RSA‑911 system. Other items sometimes perceived as sensitive, such as race, type of disability, and earnings, are all required by law.

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 13 of OMB Form 83-I.

• 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.

Respondents in the RSA‑911 system are the 80 state VR agencies in the United States and its territories. For most VR agencies the burden to submit RSA-911 data in the past was essentially the time it took for agencies to transfer data elements that they captured in their case management systems into a text file for transmittal to RSA, although some agencies may have to used additional sources of information, e.g. their accounting system data on service expenditures. The estimate of the burden hours also included the time it took for the agency to make changes to the file after RSA ran its edit programs to identify errors and anomalies. That process may have taken more than one communication with the VR agency but, for the most part, only one and sometimes two communications with the agency staff sufficed. In prior RSA-911 data collection supporting statements, 45 hours had been used. For 80 agencies the total burden hours computed to a national total of 3,600.

For this redesigned version of the RSA-911, there may be data elements that we have added that may not have been captured in agency case management systems in the past, such as county of residence, the use of different disability codes, and the three new service codes. As a result, the table following indicates an estimated number of hours it might take agency staff to collect the additional data elements as well as the effort involved in submitting of the text file.

The total burden estimate for the proposed revised RSA 911

Burden Type	Per Agency	Nationally (80 Agencies)
Incremental hours for collecting new RSA-911 data by agency (15 minutes times 125 average number of counselors per agency divided by 60 minutes)	31.25	2,500
Cost per agency based on $30 wage rate (VR counselor wage rate)	$937.50	$75,000
Hours for submitting RSA-911 data file per agency	50	4,000
Cost per agency based on $40 wage rate (Agency IT wage rate)	$2,000	$160,000
Total burden hours - collection and submission	81.25	6,500
Total burden cost - collection and submission	$2,937.50	$235,000

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 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.

This collection does not require the respondents to incur capital or start-up costs in connection with this data collection, because they already collect the data for the purpose of maintaining their federal grants. The costs to the respondents are strictly those associated with the programming and modifications of data retrieval systems as a result of the revisions to the RSA-911 and its instructions. The costs are one-time, first-year costs.

The burden on the VR agencies related to the programming of their case management systems as a result of the redesigned RSA-911 will vary widely because agencies themselves range in size and IT sophistication. Roughly half of the 80 VR agencies use case management and reporting systems purchased from software providers who will be responsible for maintaining their software with the latest updates. The remaining VR agencies have developed their own case management systems for which changes will be made by their IT staff or outside contractors. Approximately, half the agencies will make the changes in-house and half would contract for the changes to be made.

The following tables provide an estimate of the burden hours and costs for reconfiguring the case management and reporting systems for those agencies that effect the changes in-house and for those that contract with others to make the necessary programming changes. Before the effective date of the revised RSA-911, some of the VR agencies that have not already done so may purchase case management software systems.

The costs to the VR agencies to effect the programming changes necessary will differ considerably based on many factors including availability of state IT programmers and contracting costs which may vary widely based on location.

To fully implement the revised RSA 911 case management and reporting system, certain development activities must occur. The system development costs can be estimated by focusing on the systems environment of the VR agencies.

1. VR agencies that have their own (i.e., not vendor provided) case management and reporting systems, which they maintain and update.

2. VR agencies that have their own (i.e., not vendor provided) case management and reporting systems and use IT contractors for system maintenance and updating.

As shown in the below tables, the estimated costs associated with the reprogramming of VR agency case management systems are estimated to total $900,000.

1. VR agencies that have their own (i.e., not vendor provided) case management systems, which they maintain and update

Category	Number of agencies affected	Hours per agency	Total hour burden	Hourly rate	Total dollar burden
Review specifications and write software, prepare deployment plan, test and install (Wage rate for agency programmer)	20	240	4,800	$50	$240,000
Total	Not Applicable	Not Applicable	4,800	Not Applicable	$240,000

2. VR agencies that have their own (i.e., not vendor provided) case management systems and that use IT contractors for system maintenance and updates

Category	Number of agencies affected	Hours per agency	Total hour burden	Hourly rate	Total dollar burden
Review specifications and write RFP. Test and install new software	20	100	2,000	$50	$100,000
Contractor support (Contractor wage rate)	20	400	8,000	$70	$560,000
Total	Not Applicable	Not Applicable	10,000	Not Applicable	$660,000

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.

Costs to the Federal government for processing RSA-911:

Activity	Hours per state agency submission	Estimated Salary and overhead costs for RSA
Receipt of RSA-911 data file	.5	$50
Review of RSA-911 data file	2	$100
Editing RSA-911 record files	2.5	$250
Approval of RSA-911 submission	.5	$50
Total for one agency submission	5	$500
Total for all 80 VR agency submissions	400	$40,000

15. Explain the reasons for any program changes or adjustments reported in Item 16 of the new OMB Form 83-I.

The estimated burden to the responding VR agencies captured in the prior inventory increased as a result of the proposed revisions to the RSA-911, necessitating additional time for staff to collect and submit the data. In addition, RSA made program changes to the information collection as a result of the public comments received during the 60-day comment period. These changes are listed below.

1. Many data elements within the RSA-911 instructions were revised to designate the data elements that require the updating of open case data to ease the burden on the VR agencies when submitting data through the RSA-911 for fiscal year (FY) 2014.

2. Whenever possible, coding options within the proposed data elements were revised so that they are consistent with those contained in the current RSA-911 instructions to ease the burden on the VR agencies when reprogramming their case management systems to account for the required coding options.

3. Whenever possible, the proposed data elements were revised to be consistent in the use of blanks and zeros to ensure more accurate data reporting. For example, VR agencies are to leave blank any fields for which the data is not known or does not apply to the individual.

4. All data elements specified as decimal data types were changed to integer data types. Although more accurate hourly wage information is indicated by the use of decimal data types for “Weekly Earnings at Closure” and “Hours Worked in a Week at Closure,” it is less burdensome to the agencies to use the integer data type consistently throughout the RSA-911. RSA will continue to use its current method of calculating earnings to determine those individuals who achieved competitive employment.

5. The data element “Veteran Status” was clarified by removing language related to active service. Commenters reported that the added language caused confusion regarding possible documentation requirements.

6. The data elements “Zip Code” and “County” were clarified to indicate that VR agencies should report the county and zip code where the individual resides at the time of case closure.

7. The data element “Source of Referral” now includes “Faith-Based Organizations” to more accurately capture all sources of referral to VR agencies.

8. The three data elements related to an individual’s “Involvement with Other Agencies and Services at Application” were combined into one data element through which VR agencies can report up to three service providers and/or funding sources from which the individual was receiving assistance at that time. By combining the three data elements, RSA has clarified that the service providers and/or funding sources are not to be ranked by the individual’s level of involvement.

9. The coding option “Special education certificate of completion/diploma or in attendance,” contained in the current version of the RSA-911, was reinserted in the data element “Level of Education Attained at Application and Closure” to maintain consistent data reporting. Through their comments, VR agencies expressed concern regarding reporting for individuals who earned this type of certificate.

10. The data element “Living Arrangement at Application and Closure” was revised by reinserting the coding option “Halfway House” in place of the proposed coding option “Halfway House – Corrections, – Mental Health, and – Substance Abuse,” to maintain consistent data reporting. VR agencies expressed concern that it may be difficult to determine the type of halfway house in which the individual resided.

11. The second coding option for the data element “Student with Disability in Secondary Education at Application and Closure” was clarified to specify that the individual developed a plan for accommodation under Section 504 of the Rehabilitation Act.

12. The data element “Sensory/Communicative Impairment Types” was added to capture the deaf, hard of hearing and deaf-blind populations as the current versions of the International Classification of Disease (ICD) and the Diagnostic and Statistical Manual of Mental Disorder (DSM) do not reflect these impairment types.

13. The titles and descriptions for the data elements that capture the individual’s “Primary” and “Secondary Disabilities” were clarified because the ICD and DSM are listings of diseases and disorders, rather than impairments.

14. The coding option “Most Significant Disability” under the data element “Significance of Disability” was clarified to indicate that VR agencies establish their own criteria for defining “individuals with the most significant disabilities.”

15. The coding option “Not employed: All other students” under the data element “Employment Status at Application” was clarified by providing examples.

16. The coding option “Personal Income” under the data element “Primary Source of Support at Application and Closure” was clarified by providing examples.

17. The coding option “Private Insurance through Other Means” under the data element “Medical Insurance Coverage at Application and Closure” was clarified by providing examples.

18. Start and end dates were added to the data element for “Trial Work Experience” to differentiate it from the Start and End dates of “Extended Evaluation.”

19. The data element for the “Date of Eligibility Determination” was clarified to emphasize that the initial date of eligibility should be reported, even if the individual was determined ineligible later in the VR process because of changes in his or her circumstances.

20. The fourth coding option for the data element “Supported Employment Goal” was clarified to indicate that the reference to the individualized plan for employment (IPE) is to the amended or final IPE.

21. The data elements contained within “Services Provided” and “Costs for Purchased Services” were clarified to better explain the data captured by these reporting requirements. In particular, the three data elements regarding Services Provided as Comparable Services and Benefits were combined into one data element where VR agencies can provide up to three providers of comparable services and benefits for a service category. By combining the three data elements, RSA has clarified that the providers of comparable services and benefits are not to be ranked by the individual’s level of involvement. The more accurate reporting of the data achieved through these changes will allow RSA to better understand the costs of serving VR populations, as well as the network of partnerships that exist between VR and other agencies that serve individuals with disabilities.

22. Clarifications were made to the descriptions of the following Service Categories to better explain what is included in the reporting requirements:

• Vocational Rehabilitation Counseling and Guidance - to be consistent with the regulations at 34 CFR 361.48(c);

• Graduate College or University Training;

• Occupational or Vocational Training;

• Miscellaneous Training;

• On-the-job Supports – Time Limited, originally titled On-the-job Supports – Short Term; and

• On-the-job Supports –Supported Employment.

23. The data element “Hours Worked in a Week at Closure” was updated to align with that for “Weekly Earnings at Closure” and to reflect only the hours worked when the employment is consistent with the employment goal specified on an individual’s IPE.

24. RSA modified the instructions pertaining to the reporting of “customized employment services” to indicate that the provision of this service is not limited to individuals with significant disabilities.

25. The RSA-911 instructions were streamlined and the Edit Specifications by Element were eliminated.

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.

RSA‑911 data are collected annually and are due to RSA 60 days after the fiscal year of reference (November 30 of each year).

Tabulations are generated to describe program‑related characteristics by (a) state VR agency and by (b) specific target groups (e.g., the type of disability, race or gender). There are 80 state VR agencies and a large number of target groups by which the data can be displayed by type of closure (e.g., with or without an employment outcome).

The analysis of the data will provide demographics, relationships between variables, and program outcomes to assist in understanding and monitoring the VR programs. Summaries of selected characteristics for all persons served including those with significant disabilities are published in the RSA Annual Report to Congress.

The data are also used for preparing monitoring tables, determining performance against RSA’s standards and indicators and by researchers who conduct analyses. Data from the RSA-911 without personally identifiable information is also transferred to the RSA Management Information System, through which tables are generated for use by RSA and the public.

Due to the workload involved in implementing a new monitoring process with new focus areas for the 2011 – 2017 cycles, RSA was unable to complete a final draft of the revised RSA-911 until the spring of 2012. RSA expects to have the data collection available for grantees by April 2013, when they will re-program their data collection systems and conduct necessary systems testing.

Timeline	Process
May 2012	Revised RSA-911 enters clearance
July 2012	Revised RSA-911 published in the Federal Register
April 2013	RSA-911 form approval expected
Jan 2013 – Sept 2013	State agencies update and test systems to address new/revised data elements
October 2013	Agencies use new data elements for FY 2014 program year
November 2014	Agencies submit FY 2014 data to RSA

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.

Approval is not being sought to omit the display of the expiration date for OMB approval of the information collection.

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

There are no exceptions to the certification statement identified in Item 20 of OMB Form 83-1.

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