Comment on FR Doc # 2026-10134

The Alabama Department of Rehabilitation Services is responding to the request for comments on the proposed changes to the RSA 911 Case Service Report planned for implementation in PY 27. The specific item is “RSA’s proposed revision deletes 63 data elements related to comparable benefits that are not required by statute and are not necessary to be collected at the Federal level.” While it may be correct that collection of the data is not specifically required by statute and is being construed as not necessary to be collected at the federal level, the deletion of these data elements prevents the reporting of services which were part of the rehabilitation plan and intended to result in an employment outcome. Of the individual service categories, each is reported by how the service was provided, with the choices limited to Service Provided by VR Agency Staff (In-house), Service provided by VR Agency Purchase, or Service provided by Comparable Benefits Services and Benefits Providers. As required by RSA regulations, when a service is planned on the Individualized Plan for Employment, the counselor must identify and utilize comparable benefits for specific services. If a consumer’s plan is to attain a bachelor’s degree by attending college, we must utilize the Pell Grant or other available resources. If these comparable benefits equal or exceed the participant’s need for assistance, then there will be no expenditure by the VR agency. In addition, the state agency does not provide college training as an in-house service. Therefore, to report the participant’s pursuit of four-year college degree as an integral part of the rehabilitation plan, the counselor must currently select comparable benefits as the provider. If every current data element for comparable services and benefits is removed, the agency will be unable to report these services provided on the quarterly RSA 911. There are many services that are either integral to the rehabilitation program or in support of the employment outcome which are coordinated and rendered without cost to the VR agency. Mental health treatment, addiction services, diagnosis and treatment of impairments, occupational training, on the job training, basic academic or literacy training and job placement services are just a sample of services that are planned and coordinated as part of the rehabilitation plan but may be provided in whole by mental health agencies, private insurance, DOL individual training accounts, education agencies, or the state employment service. If the proposed change of removing the ability to report services which are not provided in-house or purchased is implemented, the state agencies will cease to report many services which are a necessary component of the rehabilitation plan and successful outcomes. If training or career services are not reported, what becomes of the RSA regulation that comparable benefits be utilized. Does the rule continue to apply but only for services that are purchased or provided in house? Are VR agencies expected to collect and document compliance with the utilization of comparable benefits on each case and each planned service but not report these services to RSA? In addition, if a training service is obtained solely through a comparable benefit provider, should the state VR agency claim credit for measurable skill gains and credentials earned when the actual service is not being reported in the Case Service report? ADRS appreciates the effort by RSA to reduce the reporting requirements in the RSA 911. However, the removal of these 63 data elements appears to create a void in documentation, compliance, and reporting of services on the RSA 911 Case Service Report at the state and national level.