Rehabilitation Services Administration (RSA) Requirements

Rehabilitation Services Administration (RSA) Requirements and Reporting

Young women reading to an older gentlemen

About RSA Requirements and Reporting

Independent living services for older individuals who are blind (OIB) are administered through the Rehabilitation Services Administration (RSA). Find information about reports and regulations that are required for OIB programs.

Technical assistance – the OIB-TAC is available for individual questions related to RSA requirements, allowable spending, procedure and contract wording, and data collection and reporting. Learn about the OIB staff and find contact information on our Staff page.

About the 7-OB

The 7-OB report must be completed annually by January 29 for each OIB program. Information reported is for the Federal Fiscal Year, FFY, which begins October 1 and ends September 30. Download the PDF or word document to see the instructions and form. Note that the 7-OB needs to be completed online through the RSA MIS electronic portal. It is recommended that all information for the 7-OB be collected prior to beginning entry in the RSA MIS portal. Questions about the 7-OB report can be directed to the OIB-TAC, or the RSA OIB program liaison.

Download the required forms below:

Resources

RSA MIS Instructions

This section provides basic information about the MIS RSA system, used to submit the 7-OB annual report. Questions related to MIS should be directed to RSA.

Read online:
RSA MIS Instructions

OIB-TAC Course

OIB-TAC offers a course: Unpacking the 7-OB: Understanding Data Collection and Reporting. This course provides an in-depth look at the 7-OB, discusses examples for collecting and calculating information, and suggests ways to streamline processes.

Data Collection

Some contracting agencies may not have case management systems that easily collect and provide needed information for the 7-OB. This excel file was developed to help with the collection of information needed for the report. 

Download the Excel file: 7-OB Data Collection Tool

Certification Regarding Lobbying ED 80-00

The lobbying certificate, a signed agreement that your program has not use federal funds for lobbying activities, needs to be signed each year.  

Read online: Certification Regarding Lobbying ED 80-0013 Form

FFY 2022 OIB GAN Attachments

When the OIB grant is awarded each year, the official email from RSA announcing the new grant, includes these attachments alerting the state of changes and requirements.  

Read online: FFY 2022 OIB GAN

Sample SF425-CAP-OIB-PAIR 07292020

Annual financial report completed by the fiscal unit that reports on funds available and how funding was spent.  

Read online: Sample SF425-CAP-OIB-PAIR 07292020

Title VII Chapter 2

Section of the Rehabilitation Act of 1973 as amended by the Workforce Innovation and Opportunity Act authorizing the older blind program. 

Read online: Title VII Chapter 2

RSA Regulations FAQs

Can a contracting agency be required to provide a match?

No, according to 34 C.F.R. § 367.64 What is the prohibition against a State's condition of an award of a sub-award or contract based on cash or in-kind contributions? 

(a) A State may not condition the making of a subaward or contract under section 752(g) of the Act on the requirement that the applicant for the subaward or contract make a cash or in-kind contribution of any particular amount or value to the State. 

(b) An individual, entity, or organization that is a subrecipient or contractor of the State, may not condition the award of a subcontract on the requirement that the applicant for the subcontract make a cash or in-kind contribution of any particular amount or value to the State or to the subrecipient or contractor of the State. 

(Authority: Section 752(f) and (g) of the Rehabilitation Act of 1973, as amended; 29 U.S.C. 796k(f) and (g)) 

Can a consumer be served in more than one state?

Yes, but there should be collaboration to ensure that services are not duplicated.  There is no requirement for residency in the state.  Although RSA allows for the practice of jointly serving an individual, the state is free to make rules or establish guidelines. 

Read the RSA guidelines:

How long should closed client files be retained?

Record Retention and Access: § 200.334 Record retention requirements

The recipient and sub-recipient must retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and sub-recipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to, financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except for the following:

(a) The records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period.

(b) When the recipient or subrecipient is notified in writing by the Federal agency or pass-through entity, cognizant agency for audit, oversight agency for audit, or cognizant agency for indirect costs to extend the retention period.

(c) The records for property and equipment acquired with the support of Federal funds must be retained for three years after final disposition.

(d) The three-year retention requirement does not apply to the recipient or subrecipient when records are transferred to or maintained by the Federal agency.

(e) The records for program income earned after the period of performance must be retained for three years from the end of the recipient's or subrecipient's fiscal year in which the program income is earned. This only applies if the Federal agency or pass-through entity requires the recipient or sub-recipient to report on program income earned after the period of performance in the terms and conditions of the Federal award.

(f) The records for indirect cost rate computations or proposals, cost allocation plans, and any similar accounting computations of the rate at which a particular group of costs is chargeable (such as computer usage chargeback rates or composite fringe benefit rates) must be retained according to the applicable option below:

(1) If submitted for negotiation. When a proposal, plan, or other computation must be submitted to the Federal Government to form the basis for negotiation of an indirect cost rate (or other standard rates), then the three-year retention period for its supporting records starts from the date of submission.

(2) If not submitted for negotiation. When a proposal, plan, or other computation is not required to be submitted to the Federal Government to form the basis for negotiation of an indirect cost rate (or other standard rates), then the three-year retention period for its supporting records starts from the end of the fiscal year (or other accounting period) covered by the proposal, plan, or other computation.

What is the required state funding match for IL-OIB programs?

Formula grants for the IL-OIB program are current-funded. However, the Rehabilitation Act contains a provision allowing all Title VII grantees to carry over unobligated funds for an additional fiscal year. States participating in the IL-OIB program must match every $9 of federal funds with $1 in nonfederal cash or in-kind resources in the year for which the federal funds are appropriated. Grantees must obtain approval from the Secretary of an application that meets the requirements of section 752(h) of the Rehabilitation Act and 34 C.F.R. §§ 367.30 and 367.31 of the implementing regulations.