Regulation Policy and Management (02REG)
Office of the General Counsel
Washington, D.C. 20420
In Reply Refer to: 02REG
Date: September 1, 2015
From: Chief Impact Analyst (02REG)
Subj: Economic Impact Analysis for RIN 2900-AP65/WP2014-049, Technical Corrections – VA Vocational Rehabilitation and Employment Nomenclature Change for Position Title.
To: Director, Regulations Management (02REG)
I have reviewed this rulemaking package and determined the following.
1. This rulemaking will not have an annual effect on the economy of $100 million or more, as set forth in Executive Order 12866.
2. This rulemaking will not have a significant economic impact on a substantial number of small entities under the Regulatory Flexibility Act, 5 U.S.C. 601-612.
3. This rulemaking will not result in the expenditure of $100 million or more by State, local, and tribal governments, in the aggregate, or by the private sector, under the Unfunded Mandates Reform Act of 1995, 2 U.S.C. 1532.
4. Attached please find the relevant cost impact documents.
(Attachment 1): Agency’s Impact Analysis, dated September 1, 2015
(Attachment 2): Agency’s CFO memo, dated August 28, 2015
Approved by:
Michael P. Shores (02REG)
Chief, Impact Analyst
Regulation Policy & Management
Office of the General Counsel
(Attachment 1)
Impact Analysis for RIN 2900-AP65/WP 2014-049
Title of Regulation: Technical Corrections – VA Vocational Rehabilitation and Employment (VR&E) Nomenclature Change for Position Title
Purpose: To determine the economic impact of this rulemaking.
The Need for the Regulatory Action: In December 2003, a National Performance Plan was implemented for the Counseling Psychologist (CP)/Vocational Rehabilitation Counselor (VRC) position, demonstrating that the job duties and qualifications for these two titles are the same. As a result, the position description for CP was amended to include the synonymous title of VRC. Since this change, VA has updated several regulations to include this synonymous title. To ensure consistency within the regulations, this rulemaking amends VA regulations to reflect this nomenclature change in the title for this VR&E position. No substantive changes are intended by these amendments.
Estimated Impact: We have determined that there are no costs and/or savings associated with publication of this rulemaking.
Assumptions and Methodology of the Analysis: This rulemaking merely amends VA regulations to reflect the changes in titles of a VA staff position. It will have no impact on the operations of VR&E offices or any budgetary impact.
Submitted by:
C.J. Riley, MS, CRC
Policy Analyst
Department of Veterans Affairs
Vocational Rehabilitation and Employment (28)
Washington, DC
September 1, 2015
(Attachment 2)
2
CKRUGER/lbh 05/20/04 281 28A 28 20F H/vrc-28/28/Kruger/GOE fund use letter