Comment on FR Doc # 2026-10134

Comments on the Proposed Extension and Revision of the RSA-911 Case Service Report Thank you for the opportunity to comment on the proposed extension and revision of the RSA-911 Case Service Report. We appreciate RSA’s ongoing efforts to improve the quality and usefulness of national vocational rehabilitation data. Accurate and consistently coded service data are essential for understanding implementation, evaluating outcomes, informing technical assistance, and supporting continuous improvement across the vocational rehabilitation system. We respectfully recommend several targeted revisions to the Customized Employment (CE) and Supported Employment (SE) data elements. These recommendations are intended to improve reporting consistency, strengthen analytic clarity, and better differentiate Customized Employment from Supported Employment within the RSA-911 data. More precise service definitions will improve RSA’s ability to understand CE implementation, evaluate outcomes, and assess the impact of federal investments in Customized Employment. Supported Employment Services (Data Elements 254 and 255) We recommend revising the Supported Employment service definition to remove the phrase “including customized employment” or otherwise clarify the relationship between the Supported Employment and Customized Employment service definitions. As currently written, the Supported Employment definition incorporates Customized Employment while separate Customized Employment service data elements are also collected. This creates overlapping coding practices, reducing analytic clarity and limiting RSA’s ability to isolate CE-specific utilization and outcomes. In practice, individuals receiving Customized Employment services may appropriately be coded under both service categories, resulting in less distinct national data. Customized Employment Services (Data Elements 275 and 276) We recommend revising the Customized Employment service definition to read: Designed to meet the specific strengths, support needs, and work interests of the individual with a significant or most significant disability through Discovery, customized job development and negotiation strategies that address the business needs of employers, and ongoing support services. This revision would improve the clarity and consistency of RSA-911 reporting in three important ways. First, adding ongoing support services better reflects how Customized Employment is implemented in practice and reduces the need for overlapping Supported Employment coding to capture those services. Second, clarifying the reference to individuals with significant or most significant disabilities addresses ambiguity between the CE definition and the broader Supported Employment framework, supporting more consistent interpretation across states. Finally, explicitly identifying the core components of CE—including Discovery, customized job development, and ongoing support services—more clearly distinguishes Customized Employment from broader employment services and strengthens the usefulness of national CE data. Type of Exit (Data Element 354) We recommend maintaining a distinct exit category for individuals who exit after a signed IPE in competitive integrated employment through Customized Employment. Maintaining a separate exit category improves RSA’s ability to distinguish Customized Employment from broader Supported Employment, track CE implementation over time, and evaluate CE-specific outcomes. Employment Outcome at Exit (Data Element 356) We recommend maintaining a distinct employment outcome category for Customized Employment in Competitive Integrated Employment. Separate employment outcome categories improve RSA’s ability to isolate and evaluate CE-specific employment outcomes, implementation trends, and technical assistance needs across states. Conclusion Collectively, these revisions would improve reporting consistency, reduce overlapping coding practices, strengthen the reliability of national Customized Employment data, and enhance RSA’s ability to evaluate CE implementation and outcomes over time. Thank you for considering these recommendations. Griffin-Hammis Associates, Marc Gold & Associates, UT State IDRPP