Comment on FR Doc # 2026-10134

South Carolina Commission for the Blind (SCCB) appreciates RSA’s efforts to streamline the RSA-911 reporting requirements and reduce administrative burden on state VR agencies. SCCB supports the proposed removal of the 63 data elements related to comparable services and benefits; however, additional guidance is needed. While regulations do not require the collection of comparable services and benefits data at the individual case level, 34 CFR 361.53 requires state VR agencies to determine whether comparable services and benefits are available before providing most VR services, unless one of the exceptions outlined in 34 CFR 361.53(a) or (b) applies. State agencies must continue to comply with these regulatory requirements. Therefore, SCCB encourages RSA to issue sub-regulatory guidance describing how agencies can demonstrate compliance with 34 CFR 361.53 without collecting individual-level RSA-911 data elements. This guidance would promote consistent compliance across states while reducing the burden associated with collecting and reporting this information quarterly at the individual case level. Additionally, federal regulations require RSA to collect only aggregate data on purchased service provider types, rather than data at the individual case level as currently required through the RSA-911. SCCB encourages RSA to consider eliminating the remaining 37 purchased service provider type data elements from the RSA-911 and instead collect this information annually in aggregate. Lastly, federal regulations require RSA to collect data on whether an individual was referred to a VR agency by the one-stop system (the current RSA-911 requires reporting on 21 different referral sources). SCCB encourages RSA to consider revising the reporting requirements for data element 21 to collect only the information required by regulation. State agencies that find more detailed referral source information useful could continue to collect that information for their own use. SCCB appreciates the opportunity to provide comments on the proposed revisions to the RSA-911 and supports RSA's continued efforts to reduce unnecessary reporting burden while maintaining compliance with statutory and regulatory requirements.