Comment on FR Doc # 2026-10134

The Vermont Division of Vocational Rehabilitation (DVR) generally supports the proposed ICR for the RSA-911 report and agrees that it will provide a modest reduction in reporting workload for our staff, though any change also creates workload for data systems vendors, system administrators, and staff while they process that change. Comparable Benefits: The practice of identifying comparable benefits from other public programs, health insurance, and employee benefits remains an important aspect of plan development and service provision – and is required by regulation. Counselors are trained and motivated to consider these and all other sources of support that might aid the participant in reaching their employment goal. Vermont DVR believes this practice can be preserved without the added burden of data collection. Counselors have a strong interest in maximizing their limited case service funds and look for sources well beyond the definition of “comparable benefits”. This muddies the concept of comparable benefits, adding to the difficulties of collecting accurate and complete data. Questionable data quality, along with the varying national landscape of public programs, health insurance, and VR practices, make the RSA-911 data on comparable benefits of limited value. The more important and valuable effort is at the systems level, to ensure the existence of infrastructure and cross-sector dialog that supports strong collaboration among public programs, so that counselors have smooth pathways to draw on all available funding sources. For this reason, Vermont DVR does not object to the removal of comparable benefits reporting from the RSA-911, although we have some concerns about how it will be implemented in data systems with least disruption and cost. Highest Educational Level Completed at Program Entry: Vermont DVR welcomes the restoration of DE 76 if that helps to address a gap in data collection on baseline educational attainment at program entry. We have two questions related to this change and would appreciate RSA providing more guidance on these: 1) It is our understanding that the Statistical Adjustment Model (SAM) factors changes in these participant educational attainment into its model. Given that data collection on educational attainment at program entry has evolved over several years, how will the SAM handle this data variation and adjust for gaps or inconsistencies in reporting? 2) Does RSA have guidance on how to choose the “higher” level of attainment? For example, how should a counselor approach coding DE 76 when a participant has an Associate’s degree from 20+ years ago and a recent occupationally-valuable license or certification that did not require an academic credential such as an AA – such as an electrician license, Project Management Professional certification, or LPN diploma? Thank you for the opportunity to comment. We look forward to reviewing RSA’s responses.