[nfbmi-talk] Update on College Policy

joe harcz Comcast joeharcz at comcast.net
Wed Aug 4 22:02:30 UTC 2010


Hi Elizabeth,

I hear your concerns. I am not so concerned personally about the means test 
aspect of this, for as stated in the regs that issue is moot for MCB as all 
of the consumers to my knoledge are recipients of SSI or SSDI and as all 
know a needs test cannot be used for this purpose on SSA recipients by law.

I, share, however your concerns about adding another layer of bureucracy and 
about potential delays in service using this form.

Your suggestion about MCB staff accessing this information through existing 
online account access is both solid and wise.

Moreover, Title II of the ADA, various other provisions of the Rehab Act, 
including 504 require that all information related to ones own records (and 
that includes this) must be accessable to blind folks and based upon 
"primary consideration". It is thus a violation of these provisions to 
engage a blind student with a purely print form. I think that there might 
thus be some "ADA/504 complaints in the wings here if they require this and 
particularly in this format only....Wink....

Let Mr. ADA coordinator chew on that one for a while eh?

Smiles and keep up the great work.

Peace,

Joe
----- Original Message ----- 
From: "Elizabeth" <lizmohnke at hotmail.com>
To: <nfbmi-talk at nfbnet.org>
Sent: Wednesday, July 14, 2010 9:53 PM
Subject: Re: [nfbmi-talk] Update on College Policy



Hello Mary Ann,

Thank you so much for your kind words. I have already presented these 
arguments to the Commission Board, and they seem to be rather adamant about 
keeping the new DELEG financial needs form as part of the new policy. I know 
Fred presented a no harm clause to the student if the financial aid office 
fails to follow through with the completion of this form during the last 
phone conference, but I do not see this clause included in the most recent 
draft of the policy. At times it feels like I’m just beating my head up 
against a brick wall. But I don’t know, perhaps enduring persistence is the 
key here.

Elizabeth

 > From: brightsmile1953 at comcast.net
> To: nfbmi-talk at nfbnet.org
> Date: Wed, 14 Jul 2010 19:25:00 -0400
> Subject: Re: [nfbmi-talk] Update on College Policy
>
> Excellent points Elizabeth
>
> Not everyone who is interested in the college policy was able to attend 
> the
> meeting when this form was discussed.
> If the commission is truly sincere about improving relationships with
> constituents and providing quality services, your points will be taken
> seriously and feedback will be provided in a timely manner. Let's see if
> this is the case..
>
> Mary Ann
>
> ----- Original Message ----- 
> From: "Elizabeth" <lizmohnke at hotmail.com>
> To: <nfbmi-talk at nfbnet.org>
> Sent: Wednesday, July 14, 2010 4:00 PM
> Subject: Re: [nfbmi-talk] Update on College Policy
>
>
>
> Hello Christine,
>
> Thanks for your question. The DELEG financial needs form is a separate 
> form
> that students will be required to fill out in addition to filling out the
> FASFA. It is a form that is already being used by Michigan Rehabilitation
> Services which uses a means test for providing services to college 
> students.
> In my opinion, it appears as though the Michigan Commission for the Blind 
> is
> looking to move in the same direction without being upfront and honest 
> about
> it. I understand other people may have a different opinion about it, but
> this is my opinion.
>
> You will find a copy of this DELEG financial needs form attached to this
> message. If it is approved as part of the new policy, students will be
> required to sign a release form which would permit the Michigan Commission
> for the Blind to send the DELEG financial needs form to the financial aid
> office of the college or university. Once financial aid office fills out
> their portion of this form, they send it back to the Michigan Commission 
> for
> the Blind who then shares this information with the student.
>
> The problems I see with this new DELEG financial needs form is that it 
> would
> create a means test for providing services to college students. It was
> explained during the work group meeting that this form would not create a
> means test, but I simply do not trust what they said. Other arguments I 
> have
> used against the use of this new financial needs form is the undue burden 
> it
> places on the financial aid office to process the paper form. Many 
> colleges
> and universities are posting most of this information online, and the
> Michigan Commission for the Blind could receive this information in a more
> timely manner if they would work with the student to access this 
> information
> through their online account.
>
> Additionally, with the increase of student enrollment, especially at the
> community college level, there is no guarantee that the financial aid 
> office
> would complete and return this form in time for students to receive 
> services
> from the Michigan Commission for the Blind. In essence, there is a
> possibility that a student could receive a delay in the services they
> receive from the Michigan Commission for the Blind if the financial aid
> office does not complete and return the financial needs form on time. Why
> should the student suffer from a delay in services if they were not the
> person responsible for completing and returning this form? If the 
> counselors
> are advocating the importance of the relationship between the college
> student and their counselor with the Michigan Commission for the Blind, 
> then
> why would they want to involve a third party that would hold the potential
> of getting in the way of this relationship? If the client counselor
> relationship is as important as they claim it to be, then would it not be
> better for the counselor to work with the student to obtain this 
> information
> if it is needed at all? And if the students are already filling out the
> FASFA form, then why is a second form needed for something other than
> implementing a means test?
>
> I am by no means an expert on this issue, so if others see things
> differently, then I would like to hear your opinion. The trust I once had 
> in
> the Commission Board member who was appointed to work on this issue has
> slowly eroded over tim., And as long as this financial needs form is a 
> part
> of the policy, I cannot trust that the Michigan Commission for the Blind 
> has
> the best interests of college students in mind when passing such a policy.
>
> Respectfully,
> Elizabeth
>
> > From: Christine_Boone at comcast.net
> > To: nfbmi-talk at nfbnet.org
> > Date: Wed, 14 Jul 2010 10:11:47 -0400
> > Subject: Re: [nfbmi-talk] Update on College Policy
> >
> > Elizabeth,
> >
> > You mention that the DELEG financial needs form is still a part of the
> > proposed college policy. Is that the same thing as the FASFA, which is 
> > the
> > general federal form that all students are required to complete if they
> > are
> > seeking financial aid? or is it something different?
> >
> >
> > -----Original Message-----
> > From: nfbmi-talk-bounces at nfbnet.org 
> > [mailto:nfbmi-talk-bounces at nfbnet.org]
> > On Behalf Of Elizabeth
> > Sent: Wednesday, July 14, 2010 12:02 AM
> > To: nfbmi-talk at nfbnet.org
> > Subject: [nfbmi-talk] Update on College Policy
> >
> >
> > Hello List,
> >
> > I have been told that the July 1 draft of the college policy could not 
> > be
> > found on the Michigan Commission for the Blind website. Therefore, I 
> > have
> > attached it to this message for anyone who is interested in reading it. 
> > I
> > received this attachment from a message I received today, and have not
> > been
> > able to check to make sure that it reads the same as the attachment that
> > was
> > sent out on July 1, 2010.
> >
> > There have been several emails about the timeline issue which are
> > summarized
> > in the message that appears below. If you would like me to forward the
> > emails where the discussion took place, I would be more than happy to 
> > pass
> > them along for anyone who might be interested in reading them. Also, the
> > deadline for submitting comments on the July 1 draft has been extended 
> > to
> > July 19, 2010 as indicated in the message that appears below.
> >
> > I have briefly looked over the newly revised policy, but have yet to
> > really
> > comment on it. I know the DELEG financial needs form is still a part of
> > the
> > policy, and in my opinion, that is the only major difference between 
> > this
> > policy and the policy they are currently using. I know that it was
> > explained
> > during the work group meeting that this form is not a means test, and 
> > the
> > language of the policy has changed a bit about financial participation,
> > but
> > I still see this form as a way to implement a means test for college
> > students. I am deeply opposed to the use of this new form, and I cannot
> > support any policy that includes this form as part of the policy.
> >
> > I believe that covers everything for the moment, but if you have any
> > further
> > questions or comments, they are always appreciated. I forgot how busy
> > convention can be, so I apologize for the delay in getting back into the
> > swing of things here in Michigan.
> >
> > Elizabeth
> >
> > ----------------------------------------------------------------------------
> > ----
> > From: geri.taeckens at isahealthfund.org
> > Subject: Modification for colege policy for July 19
> > Date: Tue, 13 Jul 2010 18:51:55 -0400
> >
> > Hi to all! Important modifications.
> >
> > First, the deadline for responding on the July 1 policy draft attached
> > here
> > has been extended to Monday, July 19. All comments must be in by noon on
> > that day so I can get the final draft out for editing to get to the 
> > board.
> >
> > Second: I will recommend to the board on 8-27, that the final draft be
> > accepted for 1 year, with a plan to review it after data is collected on
> > key
> > factors in this policy.
> >
> > Third, Virginia from MSU office for disabled students has brought to our
> > attention some very pertinent mandates by the federal government 
> > regarding
> > timelines. I did send you what she wrote and have modified policy A
> > essential elements number 4 and 5 for your review. I personally feel 
> > much
> > better aligning these 2 statements with something tangible.
> >
> > Fourth, There has been concern voiced by a few folks about the statement
> > in
> > policy B, regarding non-accredited colleges. Some feel this option 
> > should
> > not be available to MCB consumers. Unless anyone has a good reason why
> > non-accredited colleges should be sponsored by MCB, I recommend we 
> > delete
> > that segment from the policy.
> >
> > I have placed examples of how these 3 segments might be written.
> >
> > Policy A.
> >
> > 4) The timeline for completing a post-secondary training or college
> > program is established by the training or educational institution and
> > federal mandates related to financial aid. Financial aid recipients must
> > complete their degree program within 150% of the educational 
> > institutions
> > expected time for completion. Example, a student working on a 4-year
> > degree
> > would be eligible for financial aid for 12 semesters or 6 years. A 
> > student
> > working on a 2-year associate's degree would be eligible for a maximum 
> > of
> > 3
> > years (6 semesters. MCB students are encouraged to complete their 
> > training
> > or degree based on these timelines. Students with additional 
> > disabilities,
> > medical issues, family situations, job duties, and or who are
> > non-traditional students are encouraged to engage their counselor in
> > developing a timeline for completion suitable for their needs; keeping 
> > in
> > mind that the educational institution will require a student to complete
> > an
> > application for appeal/extension with the college's financial aid 
> > office.
> > Requests/appeals are carefully reviewed prior to a student receiving an
> > extension and if the extension is granted, the extension is closely
> > monitored to assure the student is making progress. Go to www.ED.gov for
> > complete details on college-university timeline mandates.
> >
> > 5) If a student's attendance at training is interrupted for a period of
> > time and classes cannot be attended for one of the reasons referenced in
> > Policy A - 4, the period of time the student is absent does not count
> > against the identified timeline according to MCB and the educational
> > institution. A written, dated, request, including the reasons for this
> > break in attendance shall be submitted to the MCB counselor. It is
> > important to note however, that the timeline for students receiving
> > financial aid still applies as described in policy A-4, requiring a
> > student
> > to complete a 4 year degree in a total of 12 semesters, with a maximum 
> > of
> > 18
> > semesters, unless an appeal has been granted. MCB Students and 
> > counselors
> > should also be aware that some programs require a continuum of 
> > attendance
> > such as degrees that include rapid advancements like computer sciences,
> > medicine, and education. A break in such programs could require a 
> > student
> > to take additional classes to fulfill new requisites.
> >
> > Policy B. Accreditation
> >
> > MCB cooperates with colleges, universities, and other degree-granting
> > institutions, including correspondence, home-study and vocational 
> > training
> > programs that are accredited by a regional accrediting body recognized 
> > by
> > the U.S. Department of Education.
> >
> > Note... Delete this next section.
> >
> > Exceptions may be made where accreditation is pending or conditional and
> > the
> > course of study is sufficiently unique to justify use of the 
> > institution.
> > Students and their MCB counselor should discuss the risks and benefits 
> > of
> > attending a non-accredited training program or university as it could
> > negatively impact a student's ultimate vocational goal.
> >
> > _________________________________________________________________
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