Sub-Regulatory Guidance

RSA establishes policy and prescribes the methods found necessary for the proper and efficient administration of the programs for which RSA is responsible. Policy is a formal statement, from among one or more legally supportable options, establishing conditions, relationships or conduct which are held to be necessary for implementing or substantiating the letter and/or intent of relevant law and regulations and ensuring the proper management by such laws and regulations.

  • Policy Directives (PD) are formal statements of required action(s) or condition(s) that must be carried out or met by State VR agencies or other RSA grantees in order to be in compliance with the Acts. A PD is legally enforceable because it is based on a statutory or regulatory provision.
  • Technical Assistance Circulars (TAC) are formal statements of guidelines and/or suggested methods to satisfy statutory, regulatory or policy requirements. A TAC addresses those areas of program requirements for which state VR agencies or other RSA grantees have flexibility in determining precisely how such requirements are to be met.
  • Information Memoranda (IM) transmit information to grantees who operate formula or discretionary grant programs authorized by the Acts, and to individuals who are responsible for monitoring these programs.
  • Other DocumentationOther sub-regulatory guidance documents, such as Grant Award Notification Attachments, Frequently Asked Questions, and Dear Director Letters, that support RSA programs.
Sub-Regulatory Guidance Table
Date Issued Sort ascending RSA Number Subject PDF Size
07/23/2007 IM-07-08 Transition Programs & Services: High School/High Tech & Vocational Rehabilitation. 47.21 KB
09/25/2001 IM-01-44 Applicability of the Health Insurance Portability and Accountability Act of 1996 to the Vocational Rehabilitation Services Program. 20.13 KB
09/25/2001 IM-01-43 Basic Information and Resources Available Regarding Post Traumatic Stress Disorder. 89.84 KB
12/18/2000 IM-01-18 Development of National Registry for the Deaf-Blind. 18.99 KB
06/24/1999 IM-99-28 U.S. Postal Service Randolph-Sheppard Initiative. 12.63 KB

Dear Director Letters

RSA issues broad written technical assistance in the form of Dear Director Letters that provide information, technical assistance and clarification regarding implementation of the Rehabilitation Act of 1973, as amended by Title IV of the Workforce Innovation and Opportunity Act (WIOA).

  • RSA transmits a copy of the Vocational Rehabilitation Financial Report (RSA-17) and instructions for completing the form for the State Vocational Rehabilitation (VR) Services program. The Office of Management and Budget (OMB) has approved this form (OMB Control No. 1820-0017) through August 31, 2023. The RSA-17 will be effective for the VR program for new VR grant awards issued on or after October 1, 2020 (Federal fiscal year (FFY) 2021). The RSA-17 form will replace the RSA-2 and SF-425 submissions for these awards. The RSA-17 will collect quarterly cumulative VR financial data on an award-by-award basis.

  • RSA transmits a copy of the SF-425 and revised instructions for completing the form for the following formula award programs: Client Assistance Program; Independent Living Services for Older Individuals Who Are Blind (OIB); and Protection and Advocacy of Individual Rights (PAIR). RSA revised and updated the instructions because the Department has retired parts 74 and 80 of the Education Department General Administrative Regulations and adopted in their place the governmentwide Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 C.F.R. part 200. Through this letter, RSA is rescinding the prior Client Assistance Program, OIB, and PAIR instructions for completing the SF-425 form (RSA-PD-11-03).

  • Cancellation Fees ( ) (PDF, 469.61 KB)

    RSA responds to inquiries received regarding whether "fees for services that were not rendered" or "cancellation fees" are allowable under the State VR Services, State Supported Employment Services, and Independent Living Services for Older Individuals who are Blind programs. In this response, RSA provides an analysis for program staff to use when determining whether such a cost is allowable and, therefore, may be paid with program funds as an administrative cost.

  • MOE Penalty Change Announcement ( ) (PDF, 442.88 KB)

    RSA informs State Vocational Rehabilitation agencies of an important change to the process used to assess maintenance of effort (MOE) penalties for the State VR Services program that will affect the way we allot VR funds in Federal fiscal year (FFY) 2020 and future years.

  • RSA provides a review instrument for the formal interagency agreement between SEAs and VR agencies, as required by Section 101(a)(11)(D) of the Rehabilitation Act of 1973, as amended by Title IV of the Workforce Innovation and Opportunity Act (WIOA), and 34 C.F.R. §361.22(b) along with technical assistance resources.

  • On February 24, 2017, President Trump signed Executive Order (EO) 13777: Enforcing the Regulatory Reform Agenda, which established a Federal policy “to alleviate unnecessary regulatory burdens” on the American people. In accordance with the EO, the U.S. Department of Education published a notice in the Federal Register on June 22, 2017, seeking input on regulations and guidance that may be appropriate for repeal, replacement, or modification. On October 20, 2017, OSERS issued this letter that rescinded some documents, provided under the Rehabilitation Act of 1973, as amended, due to the issuances being outdated, unnecessary, or ineffective.

  • Auxiliary Aids and Services ( ) (PDF, 102.38 KB)

    RSA clarifies whether states may expend funds reserved for the provision of pre-employment transition services on auxiliary aids and services for students with disabilities with sensory and communicative disorders who require such services to access pre-employment transition services.

Other Sub-Regulatory Documents

  • On August 31, 2020, RSA Commissioner Mark Schultz and OSEP Director Laurie VanderPloeg issued this letter discussing the importance of collaboration between Special Education and Vocational Rehabilitation related to secondary transition.

  • In August 2020, OSERS updated the Guide to advance our efforts in ensuring that all students and youth with disabilities are equipped with the skills and knowledge to achieve their post-school and career goals. In this update, OSERS added information about dual enrollment and the Achieving a Better Life Experience (ABLE) Act. The Guide is intended to help students and youth with disabilities and their families to better understand how the state education agencies, the local education agencies, and VR agencies work together to facilitate improved outcomes for students and youth with disabilities.

  • A Questions and Answers document (Q&A), with an accompanying Appendix, on the dual enrollment of students with disabilities in secondary school and postsecondary education institutions, including comprehensive transition and postsecondary education programs for students with intellectual disabilities.

  • This joint guidance by the U.S. Departments of Labor and Education is a resource to provide information to assist State agencies (including VR agencies), educational agencies and institutions, and service providers in performance reporting and evaluation requirements under WIOA. Under WIOA, States are required to use education information and quarterly wage records to measure performance of the six core programs and other title I programs authorized by WIOA, which raises complex issues related to data sharing and privacy. This guidance provides States with information about applicable requirements for, and procedures and options for, matching confidential Unemployment Compensation information from wage records with personal information from VR records, and personally identifiable information from education records, and for protecting the confidentiality of information contained in such records.

Frequently-Asked Questions