Rehabilitation Services Administration (RSA) Requirements

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

Download:
RSA MIS Instructions (Word Doc)

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. See also our course “Understanding Data Collection and the 7-OB Report”.

Download the excel file:

7-OB Data Collection Tool

Download the word file:

7-OB Data Collection Tool Word File

Here are the blank templates of the 7-OB data collection spreadsheet used in Colorado.  This state has multiple contract recipients to collect 7-OB data from. 

1) The Subrecipient template gets sent individually to each agency, and then is returned to the DSA.  Included is a Q&A document to help them correctly enter information for the 7-OB.

2) The Summary spreadsheet is used internally by Colorado’s OIB Program Manager. The Summary tab is the final information that is entered into to the RSA portal.  

Here is a suggested reporting routine: 

• October-November: host an optional training/Q&A session for subrecipients on how to fill out the 7OB collection tool (the Subrecipient Template) . Organize information into a Q&A document for subrecipients to reference.  

• Early November: 7OB reports are due to to OIB Program Manager via the collection tool. (a "first draft") 

• Mid-November: the OIB Program Manager reviews each subrecipient's report line by line, identify any questions or errors 

• Mid-late November: answers to questions/correction of errors are due back ("second draft") 

• End of November/beginning of December: review the submitted revisions, identify any final questions/errors, and compile all 7 subrecipients' data into one master report (the Summary Template) 

• Early December: draft the 7-OB submission in the RSA portal (and complete any internal approval processes). 

• Mid-December: submit the 7-OB report in the RSA portal 

This course provides an in depth look at the 7-OB, provides examples for collecting and calculating information, and suggests ways to streamline reporting.

Register for the online course: 

Understanding Data Collection and the 7-OB Report

7-OB Report

Read online: 

7-OB Report 

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

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

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

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

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)) 

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:

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.

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.