Agency Information Collection Activities; Comment Request; Case Service Report (RSA-911)

Maureen Carasiti of Easterseals Southern California supports the Rehabilitation Services Administration's efforts to strengthen the RSA-911 but proposes specific revisions to improve reporting consistency. The organization argues for clearer distinctions between Customized Employment and Supported Employment and seeks clarification on using Transition Discovery as a methodology for Pre-Employment Transition Services.

The commenters, representing Griffin-Hammis Associates, Marc Gold & Associates, and UT State IDRPP, support the proposed extension and revision of the RSA-911 Case Service Report. They recommend specific revisions to the definitions of Customized Employment and Supported Employment to improve data clarity, reduce overlapping coding, and better track specific outcomes.

The commenter recommends that the RSA clarify that Transition Discovery can be used as a methodology for delivering existing Pre-Employment Transition Services (Pre-ETS). They argue that this framework provides a more coordinated, person-centered approach to help students with disabilities build on vocational experiences over time.

The Florida Division of Vocational Rehabilitation (DVR) supports the proposed reduction of reporting requirements for the RSA-911 report. They argue that excessive data collection is costly, harms staff morale, and diverts resources away from core service delivery, recommending a focus only on essential and utility-based data elements.

The Alabama Department of Rehabilitation Services opposes the removal of 63 data elements related to comparable benefits from the RSA 911 Case Service Report. They argue that deleting these elements prevents the reporting of essential services provided by outside agencies and creates a void in documentation and compliance regarding the utilization of comparable benefits.

The commenter supports the information collection activity but provides specific recommendations to improve data integrity. They suggest removing "customized employment" from certain categories to ensure a clear delineation between supported and customized employment outcomes.

The South Carolina Commission for the Blind (SCCB) supports the proposed removal of certain data elements to reduce administrative burdens on state VR agencies. They request additional guidance on complying with existing regulations without individual-level data collection and suggest further revisions to reporting requirements for purchased service providers and referral sources.

The commenter supports the proposed extension and revision of the RSA-911 Case Service Report but recommends specific revisions to the Customized Employment (CE) and Supported Employment (SE) data elements. They argue that these changes will improve reporting consistency, reduce overlapping coding practices, and provide clearer data for evaluating CE outcomes.

The Vermont Division of Vocational Rehabilitation (DVR) supports the proposed removal of comparable benefits reporting from the RSA-911 report, noting it will reduce workload and improve data quality. They also welcome the restoration of DE 76 for educational attainment but request further guidance on how to handle data variations and specific coding scenarios.