Comment on FR Doc # 2026-10134

The Florida Division of Vocational Rehabilitation (DVR) supports and appreciates the proposed ICR for the RSA-911 report. The reduction of detailed reporting requirements should be a continuing goal of the RSA. The gathering, validating, and collating of data for variables that do not meet a functional or legal need is costly and distracts from the intent of the VR program. Staff survey results gathered by DVR illustrate significant concern about the onus of data collection by counseling staff. Excessive data collection that does not contribute to the needs of counselors harms staff morale, reduces time counselors have to serve customers and contributes to increased turnover. Administrative data staff at VR agencies devote a significant portion of their time to the accurate collection and submission of the 911 at significant cost and a divergence of resources that could be used for analysis. DVR recommends RSA consider further revising reporting to collecting only essential data elements for open cases and specific and utility-based data elements for closed cases, and altogether removing unnecessary logically-interrelated data elements. The collection of data that is not utilized is wasteful and costly. A review conducted of academic literature over the past 15 years indicates that statistical analysis of the drivers of the WIOA metrics utilizing the vast data elements in the 911 is rare. While the 911 data is used for the RSA 911 Dashboard and is used by technical assistance centers to a degree, there is little evidence that existing granular 911 data elements have improved program results. Rather, they have been collected at significant cost to VR agencies and have potentially diverted focus of fundamental VR program goals. The complexities of the collection, retention, collation, and submission of the 911 data has contributed to a case management system micro-economy that is focused primarily on data collection rather than efficient service delivery. This has resulted in states spending program dollars for complex case-management systems that offer little improvement in service delivery and are focused on achieving reporting outcomes. DVR recommends RSA continue to refine the data elements contained in the RSA 911 to only what is explicitly required by WIOA or those data elements that will be actively utilized to drive improvements in the delivery of the VR program. Thank you for the opportunity to comment.