New RSA Guidance for State Vocational Rehabilitation Agencies
On March 12, 2026, the Rehabilitation Services Administration (RSA) released new guidance through the Real Property Reporting and Notice of Federal Interest Recording Dear Colleague Letter (DCL) 26-01. This letter outlines the requirements and instructions for State Vocational Rehabilitation agencies when reporting on real property that has been acquired, constructed, or improved with State Vocational Rehabilitation (VR) Services program funds. More specifically, the guidance addresses the use of SF-429 forms and the procedures for recording a Notice of Federal Interest (NFI).
Alignment with Federal Regulations Through this DCL, RSA ensures that its real property reporting guidance aligns with the Office of Management and Budget’s (OMB) requirements. These requirements are specified in 2 C.F.R. § 200.330, which covers annual reporting for real property, and 2 C.F.R. § 200.316, which addresses the recording of Federal interests. This consistency helps agencies comply with all relevant Federal regulations when managing real property supported by VR funds.
Real Property Expenditures under the VR Program - Table
In April 2026, RSA released the Real Property Expenditures under the VR Program - Table. This document was developed to provide technical assistance to VR agencies regarding expenditures for real property activities within the VR program.
The table is intended as a resource to help agencies understand the categories of costs associated with real property acquired, constructed, or improved using VR funds. However, it is important to note that the document does not cover every Federal requirement related to the listed cost categories. Agencies are responsible for ensuring that any funds expended for real property purposes fully comply with all applicable State and Federal regulations.
To maintain accuracy and relevancy, the table is updated periodically. The most recent version can be located at [add link to table].
RSA Instructions for Uploading SF-429 Forms to RSAMIS
In March 2026, RSA released detailed step-by-step instructions for uploading SF-429 forms to the RSAMIS website. These instructions are designed to assist State Vocational Rehabilitation agencies in meeting Federal reporting requirements for real property acquired, constructed, or improved using VR funds.
To ensure agencies have access to the most current information, RSA regularly updates these instructions. The latest update is available at the SF-429 webpage found on the RSAMIS website. Agencies are encouraged to review the instructions prior to submitting forms to confirm compliance with any new or revised procedures.
OMB’s Instructions for the SF-429 Forms
For guidance on completing the SF-429 forms, including all required Attachments, refer to the instructions provided by the OMB. These instructions are available on the grants.gov website at the Post-Award Reporting Forms page.
It is important to follow OMB’s instructions carefully when filling out Attachments A and C to ensure compliance with Federal requirements.
RSA Training
Webinar: Part 1 – Preparing for SF-429 Real Property Status Reporting
On April 9, 2026, RSA delivered a presentation focused on understanding and preparing for SF-429 Real Property reporting requirements. This webinar provided valuable guidance to State Vocational Rehabilitation agencies regarding the expectations and procedures for submitting the SF-429 Real Property Status Report.
Agencies were informed about the key aspects of the reporting process, including the types of information that must be collected and documented to comply with federal requirements. The presentation highlighted the importance of accurate and timely reporting to ensure proper accountability for real property acquired, constructed, or improved with VR funds.
Additional details and access to the webinar recording can be found below.
Recording for VRTAC Webinar: Part 1 – Preparing for SF-429 Real Property Status Reporting
PowerPoint for VRTAC Webinar: Part 1 – Preparing for SF-429 Real Property Status Reporting
Webinar: Preparing for SF-429 Real Property Status Report Part II: Determining Allowability and Requirements for Real Property Improvements and Renovations
On May 14, 2026, RSA conducted a training session specifically for VR agencies. This training focused on the process used by agencies to determine both the allowability and the requirements associated with making improvements or renovations to real property under the VR program.
During the session, RSA provided guidance to help agencies understand the factors that must be considered when deciding whether proposed real property improvements or renovations are permissible under VR program regulations. The training emphasized the importance of complying with all relevant Federal and State requirements, including those related to funding and reporting, to ensure that all expenditures for real property improvements are allowable within the scope of the VR program.
FAQs for Real Property Reporting
Throughout April and May of 2026, RSA addressed a variety of frequently asked questions (FAQs) related to real property reporting requirements. These questions were discussed during webinars and training sessions, offering guidance to agencies on the proper procedures and expectations for reporting real property status and improvements under the VR program.
To provide ongoing support, RSA has compiled the FAQs into a centralized list, which is accessible for reference. This list will be regularly updated as new questions are received and answered, ensuring agencies have access to the latest information. The link to the most current version of the document is at here.