[nfbmi-talk] College policy edited board draft for 8-27 meeting

J.J. Meddaugh jj at bestmidi.com
Thu Aug 26 22:29:11 UTC 2010


I know this but 99% of people don't and will be told this by their 
counselors.


----- Original Message ----- 
From: "joe harcz Comcast" <joeharcz at comcast.net>
To: "NFB of Michigan Internet Mailing List" <nfbmi-talk at nfbnet.org>
Sent: Thursday, August 26, 2010 5:23 PM
Subject: Re: [nfbmi-talk] College policy edited board draft for 8-27 meeting


> And yes, you still can do so inspite of whatever policy they have. For, 
> again this is a function of the IPE.
> ----- Original Message ----- 
> From: "J.J. Meddaugh" <jj at bestmidi.com>
> To: "NFB of Michigan Internet Mailing List" <nfbmi-talk at nfbnet.org>
> Sent: Thursday, August 26, 2010 3:14 PM
> Subject: Re: [nfbmi-talk] College policy edited board draft for 8-27 
> meeting
>
>
>> It seems like we lost any support for taking classes part-time in 
>> combination with employment. Wasn't this something we were pushing for as 
>> an organization and in the various stages of developing this policy? 
>> There are many situations where taking classes part-time may be 
>> appropriate, including career-related jobs, the need for additional 
>> income during school, family/childcare commitments, etc.
>>
>>
>>
>> ----- Original Message ----- 
>> From: "Fred Wurtzel" <f.wurtzel at comcast.net>
>> To: "'Geri Taeckens'" <geri.taeckens at isahealthfund.org>; "'Elizabeth'" 
>> <lizmohnke at hotmail.com>; <luzenskis at michigan.gov>; <alissa161 at gmail.com>; 
>> <cannonp at michigan.gov>; <dcgorton601 at comcast.net>; <mohnked at hotmail.com>; 
>> <wild-rose at sbcglobal.net>; <furtond at michigan.gov>; 
>> <grace at menzelcoaching.com>; <debate912 at gmail.com>; <mpvi at intergate.com>; 
>> <heibeckc at michigan.gov>; <jbrown at mpas.org>; <pilarskij at charter.net>; 
>> <jonesl2 at michigan.gov>; <kisiell at michigan.gov>; "'Larry Posont'" 
>> <president.nfb.mi at gmail.com>; <laury-johnsons at michigan.gov>; 
>> <lovep at michigan.gov>; "'Lydia Schuck'" <laschuck at juno.com>; 
>> <mcnealg at michigan.gov>; <mcvoys at michigan.gov>; <silveya at michigan.gov>; 
>> <smithd11 at michigan.gov>; <martzvir at msu.edu>; <whitee2 at michigan.gov>; 
>> <wilsond9 at michigan.gov>; "'NFB of Michigan Internet Mailing List'" 
>> <nfbmi-talk at nfbnet.org>; <marywurtzel at comcast.net>
>> Cc: <brlbumps at sbcglobal.net>; "'John Scott'" <jcscot at sbcglobal.net>; 
>> <margwolfe at usa.net>
>> Sent: Thursday, August 26, 2010 1:26 AM
>> Subject: Re: [nfbmi-talk] College policy edited board draft for 8-27 
>> meeting
>>
>>
>>> Dear Commissioners and College Policy Team,
>>>
>>>
>>>
>>> I must say that this is a vastly improved document when compared to the 
>>> one
>>> presented at the Marquette Commission meeting.  Thanks to Geri, 
>>> Elizabeth
>>> and Gwen, strides have been made to make this much more humane and
>>> user/consumer friendly.  There are, still, lingering artifacts from that
>>> earlier document.  There are pressures to reverse the progress that has 
>>> been
>>> made.  I have annotated the document posted on the MCB web site on 
>>> 8/10/2010
>>> and included it below.  Elizabeth Mohnke has composed a very good 
>>> document
>>> that gives an in-depth review of the Rehabilitation Act regulations as 
>>> they
>>> relate to this document.  I have only covered this topic lightly.  I
>>> strongly encourage you to review her document to assure full compliance 
>>> with
>>> the Rehab Act.  She did a highly commendable job of research.
>>>
>>>
>>>
>>> In the interest of time and space, I have limited my comments, with 1
>>> exception to those places where errors or shortcomings occur.  This is 
>>> not
>>> meant to be negative, as I said, this is a great deal better than the
>>> Marquette document that you wisely rejected.  I simply wanted to keep it
>>> short in order to help you get through it as quickly as possible.
>>>
>>>
>>>
>>> Thank you all for your patience and hard work.  I understand there is
>>> pressure to get this done, however, it is most important to get it done
>>> right.
>>>
>>>
>>>
>>> Thank you for your attention in this most important matter.
>>>
>>>
>>>
>>> Best Regards,
>>>
>>>
>>>
>>> Fred Wurtzel
>>>
>>>
>>>
>>>
>>>
>>> MCB College Policy Proposal
>>>
>>>
>>>
>>> Preamble
>>>
>>> The mission of the Michigan Commission for the Blind (MCB) is to provide
>>> individuals who are blind and visually impaired the opportunity to 
>>> achieve
>>> employment and independence.  We believe in the capacity of each blind
>>> person to achieve their individual level of excellence, to be productive 
>>> and
>>> independent, and to be involved in their community.
>>>
>>>
>>>
>>> Statement of Fundamental Principles
>>>
>>> The Michigan Commission for the Blind believes rehabilitation is a
>>> cooperative venture between the agency and the individual, with the
>>> individual having primary responsibility for personal successes and
>>> failures, and that each individual is different with unique strengths,
>>> challenges, interests and aptitudes which require vocational 
>>> rehabilitation
>>> counseling, planning and training specific to their individual needs.
>>>
>>>
>>>
>>> MCB values:
>>>
>>> .     Empowering and enabling individuals to make their own choices
>>>
>>> .     Enabling technology that helps consumers integrate into all 
>>> aspects of
>>> society
>>>
>>> .     A positive, respectful and effective partnership between 
>>> consumers,
>>> MCB, its counselors-staff, and institutions of higher education
>>>
>>> .     Supporting and empowering students to achieve their academic 
>>> goals,
>>> consistent with their talent, skills, abilities, hopes, and dreams
>>>
>>> .     The right of any consumer to advocate for themselves through due
>>> process if they are not satisfied with decisions made by MCB personnel
>>>
>>> A.    Prerequisites for college and other post secondary training
>>>
>>> Establishing the Individualized Plan for Employment The 
>>> consumer-counselor
>>> team shall establish the consumer's vocational goal through the
>>> Individualized Plan for Employment (IPE).  (See section 361.48, Scope of
>>> Services from the Rehabilitation Act PA 260.) When that goal includes 
>>> the
>>> need for post secondary training-education, the consumer-counselor team
>>> shall include in the IPE the following expectations:
>>>
>>> .     a proposed time-line for completing training-education
>>>
>>>
>>>
>>> Commissioners: Strike "proposed".  A timeline can be changed through an 
>>> IPE
>>> amendment.
>>>
>>>
>>>
>>> .     course load
>>>
>>> .     supplies and equipment
>>>
>>> .     location of training-education
>>>
>>> .     types of certificates or degrees to be obtained
>>>
>>>
>>>
>>> Essential Elements/Procedures:
>>>
>>> 1)    College Assessment
>>>
>>> Students shall participate in a college assessment to ensure that they 
>>> have
>>> the skills necessary for college participation. Students shall 
>>> demonstrate
>>> competent skills related to educational performance and independent 
>>> living.
>>> (See MCB College Assessment.) If students cannot successfully 
>>> demonstrate
>>> competent skill levels in these areas, they shall work with their 
>>> counselor
>>> to receive additional training at the Michigan Commission for the Blind
>>> Training Center or another qualified vocational training center, or in
>>> another manner consistent with their Rehabilitation needs based on 
>>> informed
>>> choice.
>>>
>>> 2)    Prospective students may be asked to participate in vocational
>>> exploration      which may include:
>>>
>>> .     job shadowing
>>>
>>> .     mentoring
>>>
>>> .     labor market analysis
>>>
>>> .     volunteer or paid work experience
>>>
>>> .     others as defined by the IPE
>>>
>>> .
>>>
>>> 3)    Prospective students shall provide a letter of acceptance to the
>>> institution of higher learning of their choice, a curriculum outline, 
>>> and
>>> the financial documents identified below in the financial aid policy 
>>> (Policy
>>> B) to their MCB counselor before financial sponsorship by MCB can be
>>> provided.  Other documents may be identified by the consumer-counselor 
>>> team
>>> which may be needed before entering a college or post-secondary training
>>> program.
>>>
>>> 4)    Timelines for completing a post-secondary training or college 
>>> program
>>> is established by these training-educational institutions.  Students 
>>> should
>>> complete their training or degree within one additional year of these
>>> established timelines.
>>>
>>>
>>>
>>> Commissioners:  Drop the "1 year" requirement.  There is already a 
>>> caveat
>>> and any other agreements regarding time can be agreed to between the 
>>> client
>>> and counselor.
>>>
>>>
>>>
>>> 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.
>>>
>>> 5)    If a student's attendance at training is interrupted for a period 
>>> of
>>> time and they are unable to attend classes for one of the reasons 
>>> referenced
>>> in Policy A - 4, the time period that they are not attending
>>> training-educational programs does not count against the identified 
>>> timeline
>>> according to MCB.  A written, dated, request, including the reasons for 
>>> this
>>> break in attendance shall be submitted to the MCB counselor.  Students
>>> should also be aware that the
>>>
>>>
>>>
>>> Commissioners:  Strike "Students should also be aware that the".  Add 
>>> "Each"
>>> before "Training."  The counselor can explain this if the college has 
>>> not
>>> already done so.  The rest of the sentence clearly states this point.
>>>
>>>
>>>
>>> training-educational establishment may have their own requirements about
>>> timelines and that even if MCB approves a break in attendance; it could
>>> jeopardize the attainment of a certificate or degree if the 
>>> post-secondary
>>> institution requires a student to complete their program with in a 
>>> specific
>>> time frame. Examples of programs that might require a continuum of
>>> attendance are those in which rapid advancements are common such as in
>>> computer sciences, medicine, and education.
>>>
>>>
>>>
>>> Commissioners:  Examples are superfluous.  They do not hurt, but are 
>>> wordy.
>>>
>>>
>>>
>>> 6)    The definition of a full course load is defined by each
>>> training-educational institution.  MCB students are required to carry a 
>>> full
>>> course load unless their individualized plan specifies otherwise.
>>>
>>>
>>>
>>> Commissioners:  Above, "are required should be replaced with "shall".
>>>
>>>
>>>
>>> 7)    The decision to participate in a community college, four year
>>> university, out-of-state training-educational program, correspondence, 
>>> or
>>> home-study program shall be based on the individual student's needs and
>>> interests.  The MCB consumer-counselor team should refer to policies B 
>>> and C
>>> of the college policy so that the requirements for utilizing accredited 
>>> and
>>> non-accredited institutions, in- and out-of-state institutions, and
>>> financial supports, are compatible with the student's institution of 
>>> choice.
>>>
>>>
>>>
>>>
>>> Commissioners:  Above, "team should refer" should be "team shall refer".
>>>
>>>
>>>
>>> 8)    The type of degree or certification a student is sponsored for 
>>> will be
>>> based on the students' vocational goal and whether gainful employment in
>>> that vocation requires associates, bachelors, master's degree, or other 
>>> type
>>> of certificate.
>>>
>>>
>>>
>>> Commissioners:  Above, "will be determined" should be "shall be 
>>> determined".
>>> This section is a little weak for consumers.  It may be used to justify 
>>> not
>>> helping a student attain the best degree, since the term "gainful
>>> employment" is included.  The argument will be that if a person can get 
>>> a
>>> minimum wage job with an associates degree, the Commission will not help
>>> with a bachelors.  I have heard counselors say exactly this.
>>>
>>>
>>>
>>> MCB, in most cases, provides sponsorship for post-secondary training to 
>>> the
>>> level of degree or certificate which will facilitate gainful employment. 
>>> If
>>> it is clear that an advanced degree will be required for competitive
>>> employment, the student's IPE should reflect this and they may continue
>>> their education uninterrupted until they obtain the degree identified in
>>> their IPE.
>>>
>>>
>>>
>>> Commissioners: "in most cases," should be replaced with "may"
>>>
>>>
>>>
>>> 9)    MCB's standard financial sponsorship is based on semesters held
>>> September through April. A POSSIBLE exception COULD BE two 16 week
>>> semesters, OR three 10 week quarters.  MCB's ability to financially 
>>> sponsor
>>> summer classes is considered an exception and a written, dated, request 
>>> must
>>> be submitted to the MCB Counselor.  Approval will be determined with in 
>>> 2
>>> weeks of the request based on the fiscal budget and availability of 
>>> funds.
>>>
>>> 10)   If a student decides that their vocational goal or plan to obtain
>>> their vocational goal needs to change, the student and their MCB 
>>> counselor
>>> will discuss a new plan with possible guidance by the director of 
>>> consumer
>>> services and an IPE amendment shall be developed.
>>>
>>>
>>>
>>> Commissioners:  Above, "counselor will discuss" needs to be "counselor 
>>> shall
>>> discuss".
>>>
>>>
>>>
>>> 11)   MCB may provide financial support for up to 24 credit-hours of
>>> remedial study if it is not available free of charge.  Additional hours 
>>> may
>>> be considered if the consumer-counselor team agrees it is needed.
>>>
>>> 12)   Prior to a student attending their training-educational program, 
>>> the
>>> MCB counselor shall provide an explanation of DISABLED STUDENT resources 
>>> at
>>> their particular institution and encourage the student to contact the
>>> student assistance department to discuss any services or needs they may 
>>> have
>>> before or while attending that institution.
>>>
>>>
>>>
>>> The Memorandum of Understanding (MOU) is a written agreement between MCB 
>>> and
>>> some of the state universities and colleges which defines what MCB and 
>>> each
>>> college or university will be responsible for in terms of supplying a
>>> student with materials, equipment, and services.  The MCB counselor 
>>> shall
>>> explain to a student, prior to their enrollment in a college or 
>>> university,
>>> which institutions hold a MOU with MCB and what the student can expect 
>>> from
>>> MCB and that educational institution. Students are encouraged to 
>>> advocate
>>> for their needs by consulting with MCB counselors and the appropriate
>>> representative of their college or university, if there are questions
>>> related to the provision of these accommodations.
>>>
>>>
>>>
>>> Commissioners:  What happened to the "hold harmless" clause.  You need 
>>> to
>>> know that the Rehab act provides for problem resolution on this point.
>>> Leaving it out here is a way to intimidate students and does not lead to 
>>> a
>>> friendly and positive working relationship, especially in view of the 
>>> Rehab
>>> Act language to deal with this situation.  This is fundamental and 
>>> serious,
>>> if you wish to be consumer oriented and open.
>>>
>>>
>>>
>>> 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.  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.
>>>
>>>
>>>
>>> Commissioners: Above, "counselor should discuss" needs to be "counselor
>>> shall discuss".
>>>
>>>
>>>
>>> Policy C.  Financial Aid
>>>
>>> According to state and federal mandates, MCB is to provide financial
>>> sponsorship to a student who is eligible for post- secondary
>>> training-education to the amount that is not covered through other 
>>> financial
>>> resources.
>>>
>>> Commissioners: Above, the mandated sections need citations.  Also, " MCB 
>>> is
>>> to provide" needs to be "MCB shall provide"
>>>
>>>
>>>
>>> Other financial resources include, but are not limited to; grants and
>>> comparable benefits.  According to Rehabilitation Act 361.48 F. MCB
>>> counselors are required to ask the parents-guardians of potential MCB
>>> students if they are willing to participate in the financial support of
>>> their son-daughter's post-secondary training-educational costs.
>>>
>>>
>>>
>>> COMMISSIONERS, COMMISSIONERS!: This is not true.  The Commission is 
>>> required
>>> to find all possible grant funding and the student is required to seek
>>> financial aid.  There is no, no I say, requirement to ask parents for
>>> participation.  This statement undermines the credibility of the policy
>>> since it is not true and undermines the relationship between the parent 
>>> and
>>> the agency, since the counselor can judge when it is appropriate to ask.
>>> This is very important to create a trusting and consumer oriented policy 
>>> and
>>> program administration.  This is not "warm and fuzzy" talk, it is sound
>>> public policy..
>>>
>>>
>>>
>>> There is no requirement for parents-guardians to provide financial 
>>> support.
>>> Students are required to apply for specified grants identified in Policy 
>>> C-
>>>
>>>
>>>
>>> Commissioners: " Students are required" needs to be "Students shall 
>>> apply".
>>>
>>>
>>>
>>> 3.  Students are not required to apply for or utilize training or
>>> educational loans.
>>>
>>>
>>>
>>> Essential Elements:
>>>
>>> 1)    Rehab Act 361.5.10, defines comparable services and benefits as 
>>> any
>>> related service, financial benefit, or assistance available to a 
>>> consumer to
>>> partially or fully pay for the required cost of vocational 
>>> rehabilitation
>>> services.
>>>
>>> 2)    Students who receive a merit scholarship which has a specified 
>>> purpose
>>> shall use that scholarship as designated to defray educational expenses.
>>>
>>> 3)    Other comparable benefits that shall be used towards the cost of 
>>> post-
>>> secondary training or education include financial aid, grants, stipends
>>> administered through the student's college or university, employer 
>>> benefits,
>>> workers compensation, health insurance if applicable, and similar public
>>> benefits.
>>>
>>> 4)    Comparable benefits do not include Social Security benefits such 
>>> as
>>> Social Security Disability Insurance (SSDI,) Supplemental Security 
>>> Income
>>> (SSI), or unrestricted awards or scholarships based on merit.
>>>
>>> 5)    According to Rehabilitation Act, 361.42 a4 students requesting 
>>> college
>>> sponsorship are required to apply for federal financial aid by 
>>> completing
>>> the Free Application for Federal Student Aid (FAFSA.)
>>>
>>>
>>>
>>> Commissioners: " sponsorship are required to apply" needs to be
>>> "sponsorship, shall apply".
>>>
>>>
>>>
>>> 6)    MCB counselors shall utilize the DELEG/MCB Statement of Financial 
>>> Need
>>> Resources and Authorization form as a budgeting tool to help determine 
>>> the
>>> amount of MCB financial support that is needed for the student's
>>> post-secondary training-educational program.
>>>
>>> 7)    The student shall annually submit to their counselor all necessary
>>> documents, including the Student Aid Report (SAR) to their counselor by 
>>> July
>>> 1 in order to attend college in the fall, or by November 1 for 
>>> winter/spring
>>> attendance.  Consumers who are unable to meet either deadline may be
>>> considered for college training starting the following semester.
>>>
>>>
>>>
>>> Commissioners:  Item 7 needs to be stricken.  Our opinion is that 6, 7 
>>> and 8
>>> should all be stricken, however, if the MCB is determined to have this
>>> policy, they need to take full responsibility and not hold the student
>>> hostage to the whims of college financial aid offices who have no legal
>>> obligation to cooperate with this superfluous form.
>>>
>>>
>>>
>>> 8)    The student's MCB counselor shall submit the signed copy of the
>>> DELEG/MCB Statement of Financial Need, Resources and Authorization form 
>>> to
>>> the financial officer at the college or university.  The completed form
>>> shall be returned to the student's MCB counselor.  The student's MCB
>>> counselor shall share the information on the DELEG/MCB Statement of
>>> Financial Need, Resources and Authorization form with the student and 
>>> shall
>>> give the student a copy of this document.
>>>
>>> 9)    MCB contributions toward college-related costs may include the
>>> following:
>>>
>>> .     tuition and fees for required curriculum courses including 
>>> electives,
>>> as long as the electives fall within the requirements for certificate or
>>> degree.  Electives that might fall outside the scope of these 
>>> requirements
>>> may be considered by MCB if a student and their MCB counselor agree, in
>>> writing, to this exception.
>>>
>>> .     required textbooks and course materials defined in the course
>>> syllabus.
>>>
>>> .     reader services related to course work and/or activities related 
>>> to
>>> expectations for obtaining the identified certificate or degree
>>>
>>> .     text books services such as Braille, enlarged print, audio 
>>> recordings,
>>> computer scanned, or other modified materials leading to course work and 
>>> or
>>> activities related to expectations for obtaining the identified 
>>> certificate
>>> or degree
>>>
>>> .     any costs for room and board that exceed the normal living costs 
>>> as
>>> defined by, (34CFR361.53).
>>>
>>> .     rehabilitation technology services and equipment as identified in 
>>> the
>>> IPE; refer to "Scope of Services"-letter R. Rehabilitation Technology, 
>>> in
>>> the MCB Policy Manual, for further details.
>>>
>>> 10)   MCB does not pay for the cost of college applications, required
>>> entrance exams or testing fees. MCB counselors may assist consumers with
>>> pursuing financial resources to pay for the costs of applications, 
>>> entrance
>>> exams and or testing fees if the consumer requests such assistance.
>>>
>>>
>>>
>>>
>>>
>>> Commissioners:  This section is illegal under the Rehab Act.  MCB may 
>>> not
>>> pick and choose services like this.  All planning is required to take 
>>> place
>>> in the IPE.
>>>
>>>
>>>
>>> 11)   MCB may pay for the cost of preparation classes or materials for
>>> entrance exams if determined appropriate by the consumer-MCB counselor 
>>> team.
>>>
>>> 12)   MCB may assist with the cost of professional certification exams
>>> and/or fees.
>>>
>>> 13)   If a consumer is in default of a student loan, no financial aid,
>>> including Pell Grants, will be available to the consumer.
>>>
>>> 14)   MCB is prohibited from paying for any training or related services 
>>> at
>>> an institution of higher education for an individual who owes a refund 
>>> on a
>>> grant or is in default of a student loan unless the individual makes 
>>> maximum
>>> effort to resolve the default. Maximum effort means that the consumer 
>>> must
>>> work out a satisfactory payment plan with the Higher Education Services
>>> Corporation (HESC), lending institution, or grantor, and re-establish
>>> eligibility for financial aid.
>>>
>>>
>>>
>>> Commissioners:  according to an attorney we consulted on this policy, 
>>> this
>>> is not true.  This rule applies to colleges, but according to the Rehab 
>>> Act,
>>> not to Rehab agencies.  Such decisions fall under the concept of
>>> individualized services as suggested by the "I" in IPE., so the MCB may 
>>> pay
>>> for college costs even if there is a student loan default.  Again, such
>>> errors undermine the agency credibility and weaken the client oriented 
>>> goal
>>> of the Commission.
>>>
>>>
>>>
>>> 15)   Private college attendance, whether in-state or out-of-state, can 
>>> be
>>> sponsored by MCB if the consumer-counselor team agree that attending the
>>> intended program will enhance their goal for employment.  The 
>>> contributions
>>> for tuition at a private college shall not exceed the highest amount
>>> required for tuition for Michigan residents attending a state supported
>>> college or university in Michigan.
>>>
>>>
>>>
>>> Commissioners:  in 15 and 16 " out-of-state, can be"  Needs to be
>>> out-of-state, may be".
>>>
>>>
>>>
>>> Commissioners:  Again, as above, the idea is that the MCB may pay higher
>>> tuition if the course of study is not offered at a State supported
>>> institution.
>>>
>>>
>>>
>>> 16)   Out-of-state college attendance can be sponsored by MCB if the
>>> student's identified program is not available in Michigan or the
>>> consumer-counselor team agree that attending an out-of-state college 
>>> will
>>> enhance their goal for employment.  The contributions for tuition at a
>>> comparable program shall not exceed an amount greater than the highest
>>> tuition rate for Michigan residents attending a state-supported college 
>>> or
>>> university in Michigan.
>>>
>>>
>>>
>>>
>>>
>>> Commissioners:  Same as above.  Can needs to be "may" and tuition may be
>>> paid if no comparable course of study is available in-state.
>>>
>>>
>>>
>>>
>>>
>>> 17)   Out-of- country study (study abroad) shall be funded if it is part 
>>> of
>>> an approved course of study for a student's approved vocational goal. 
>>> MCB
>>> shall support the cost in an amount no greater than the highest tuition 
>>> rate
>>> for Michigan residents attending a state-supported college or university 
>>> in
>>> Michigan.
>>>
>>>
>>>
>>> Commissioners:  Same as above.  Out of Country should be covered if not
>>> available in Michigan.
>>>
>>>
>>>
>>> 18)   A student may request assistance from their MCB counselors to help
>>> them in locating financial resources if participating in an out-of-state 
>>> or
>>> abroad program or private college will enhance the attainment of their
>>> vocational goal.
>>>
>>>
>>>
>>> Commissioners: There needs to be some kind of requirement that the 
>>> counselor
>>> does, in fact, provide assistance.  The mere fact that a student 
>>> requests
>>> assistance does not assure the counselor will do anything.
>>>
>>>
>>>
>>> Policy D.  Academic Progress
>>>
>>> All students shall perform at least at the minimal performance standards 
>>> set
>>> forth by the training or educational institution.  For under-graduate
>>> college students, this typically means minimum cumulative grade point
>>> average of 2.0 on a 4.0 scale, equaling a C average.  For graduate 
>>> students,
>>> this typically means a 3.0 grade point average equaling a B average.
>>> Students should be knowledgeable of their training or educational
>>> institutions requirements for performance so they can avoid probationary
>>>
>>>
>>>
>>> Commissioners: " Students should be knowledgeable " needs  be" Students
>>> shall be knowledgeable
>>>
>>> to status. Students shall provide their grades or performance 
>>> evaluations to
>>> their MCB counselor within two weeks of the end of each semester or 
>>> training
>>> period.
>>>
>>>
>>>
>>> Essential Elements:
>>>
>>> 1)    The student's chosen curriculum has requirements, as determined by 
>>> the
>>> academic program and/or by the college or university that should be 
>>> followed
>>> by the student unless exceptions are approved by both the student's MCB
>>> counselor and the academic program director to attain their goal to
>>> re-establish good academic standing with MCB.
>>>
>>>
>>>
>>> Commissioners:  #1 above is intrusive and paternalistic.  The
>>> student/college relationship should be between those parties.  The MCB 
>>> does
>>> not need to approve changes agreed to by the college.
>>>
>>>
>>>
>>> 2)    An MCB counselor shall hold an evaluation consultation with a 
>>> student
>>> to assess their educational-training performance for any of the reasons
>>> listed below.  A written plan for correction for an identified area of
>>> struggle shall be established between the student and their MCB 
>>> counselor.
>>>
>>> .     Classes are dropped for a reason other than "good cause," when MCB 
>>> has
>>> already paid for the cost of tuition and fees.  Good cause may include
>>> problems related to obtaining agreed upon materials, equipment, and or
>>> services, or other influences that disrupt students performance that are
>>> clearly not the fault of the student and are communicated and agreed 
>>> upon
>>> between the student and the MCB counselor.
>>>
>>> .     Dropping a class puts the student at less than their identified 
>>> course
>>> load status defined in the IPE.
>>>
>>> .     A grade of "Incomplete" is taken in a class.  The student shall
>>> resolve the "Incomplete" grade during the next semester enrolled.
>>>
>>> 3)    In the case when a student has failed or dropped a class and when 
>>> MCB
>>> has paid for the cost of this class, the student shall be required to 
>>> pay
>>> that amount.   The student should make arrangements with their MCB 
>>> counselor
>>> to pay this fee by the end of the following semester.
>>>
>>>
>>>
>>> Commissioners:  First the above section should be changed to give the
>>> opportunity for a repayment plan if the student cannot repay the cost in 
>>> the
>>> required time.  People on SSI may not be able to cover that kind of
>>> repayment plan.  Again, a reasonable policy must take into consideration 
>>> the
>>> student's ability to pay.  If the goal is to move the student through
>>> college as expeditiously as possible, a delay due to a repayment plan is 
>>> not
>>> consistent with the goal.
>>>
>>>
>>>
>>> 4)    If there is failure by the educational institution or MCB to 
>>> provide
>>> agreed upon quality materials or services in a timely manner, the 
>>> consumer
>>> shall not be held responsible by MCB for failed or incomplete grades.
>>>
>>> .     The term, "quality materials" means usable, workable materials 
>>> that
>>> allow a student to access and produce information in a reasonable manner
>>> that promotes successful performance and does not unduly hinder their
>>> efforts to meet course expectations. Example readable Braille or large 
>>> print
>>> text, correct text editions, accessible up-to-date maps, tables, 
>>> formulas,
>>> etc.
>>>
>>> .     The term, "timely manner," means MCB students receive 
>>> instructional
>>> materials in specialized formats at the same time that their student 
>>> peers
>>> receive their instructional materials.  Specialized formats shall be
>>> provided in a medium that is usable by a student and may not always be
>>> available in the student's preferred format. Example: an audio version 
>>> of a
>>> text may be provided in full or in installments, if Braille or large 
>>> print
>>> is not available in a timely manner.  In situations such as Math or 
>>> Science
>>> where Braille or large print is essential to learning, such specialized
>>> formats shall be provided.
>>>
>>> .     Students are encouraged to initiate early preparation for 
>>> obtaining
>>> course syllabi and/or communicating with class instructors to obtain 
>>> text,
>>> equipment, and other required materials. Students should then 
>>> communicate
>>> their needs to the appropriate resources in charge of providing
>>> accommodations-materials.
>>>
>>> .     Time frames for MCB to provide services, equipment and materials 
>>> may
>>> be discussed by the consumer-counselor team and put in writing with the
>>> agreed upon date that those services, equipment, or materials are to be
>>> delivered.
>>>
>>> .     Quality materials and timely services can be disrupted if there is 
>>> a
>>> last minute instructor or material change.  Such occurrences that result 
>>> in
>>> a student falling behind or taking an incomplete would also exempt a 
>>> student
>>> from any financial burden and allow more time for the student to reach
>>> required expectations in performance.
>>>
>>>
>>>
>>> Commissioners:  The above section is excellent!  This is a balanced and
>>> positive statement that supports students and expects a respectful and
>>> cooperative working relationship.  Bravo! For this.
>>>
>>>
>>>
>>> Commissioners:  " incomplete would also"  needs to be " incomplete shall
>>> also
>>>
>>>
>>>
>>>
>>>
>>> Policy E. Exceptions and Complaints
>>>
>>> The policies contained in this section on post-secondary education are
>>> designed to assist students in achieving ultimate success in their
>>> endeavors.  Though they are designed to address the needs of all 
>>> potential
>>> student consumers, MCB recognizes that there may be particular 
>>> circumstances
>>> which will require a non-traditional approach to education.  The process 
>>> for
>>> addressing these variations is as follows:
>>>
>>>
>>>
>>> Essential Elements:
>>>
>>> 1)    Students needing clarification or adjustments in these policies 
>>> are
>>> encouraged to engage their counselors in constructive communication to 
>>> most
>>> effectively meet individual needs.
>>>
>>>
>>>
>>> Commissioners:  "are encouraged to engage their counselors in 
>>> constructive
>>> communication to most effectively meet individual needs.  " is wordy,
>>> unclear and could be replaced with encouraged to negotiate changes with
>>> their counselor.
>>>
>>>
>>>
>>> 2)    The MCB counselor may consult with the MCB director of consumer
>>> services regarding clarification policies/practices.
>>>
>>> 3)    Students are encouraged to document, in writing, those services 
>>> and
>>> items that they feel have not been provided in a satisfactory manner and
>>> actively communicate their needs with their MCB counselor.
>>>
>>> 4)    If resolution is not reached through verbal and/or written
>>> communication in regards to a complaint or disagreement with a 
>>> consumer's
>>> MCB counselor, MCB encourages consumers to advocate for themselves and
>>> utilize due process as outlined in the agencies grievance protocol. MCB
>>> Policy Manual - II. GENERAL POLICIES - Conflict Resolution
>>>
>>>
>>>
>>> CONCLUSION:
>>>
>>>
>>>
>>> The ultimate goal of this policy is to guide the relationship between 
>>> the
>>> Michigan Commission for the Blind and the prospective student who is 
>>> blind
>>> or visually impaired.  Through this process all qualified MCB consumers 
>>> can
>>> obtain a post-secondary certificate or degree and become employed at the
>>> level of their greatest capacity.  In order to realize this goal:
>>>
>>>
>>>
>>> Commissioners:  " consumers can obtain" needs to be " consumers may 
>>> obtain"
>>>
>>>
>>>
>>> 1.    The MCB Counselor will assist MCB students in their efforts to 
>>> become
>>> self-empowered so that by the end of the post-secondary 
>>> training-educational
>>> process, the student is functioning at their maximum capacity and is
>>> prepared to be independent and enter the work force at the level of 
>>> their
>>> capability.
>>>
>>>
>>>
>>> Commissioners:  " Counselor will assist" needs to be " Counselor shall
>>> assist"
>>>
>>>
>>>
>>> 2.    The MCB counselor and student will communicate with each other at
>>> least once mid-semester unless the consumer and counselor both agree 
>>> such a
>>> meeting is not required.
>>>
>>>
>>>
>>> Commissioners: " student will communicate" needs to be " student shall
>>> communicate
>>>
>>>
>>>
>>> 3.    The MCB student will exercise self-determination in obtaining 
>>> their
>>> post secondary degree or certificate through:
>>>
>>> .     Learning to communicate needs and information in a positive,
>>> assertive, self-advocating style
>>>
>>> .     Actively communicate needs to their MCB counselor, appropriate
>>> representatives of their chosen educational institution, and other
>>> significant professionals involved in post-secondary activities
>>>
>>> .     Learning and utilizing networking skills
>>>
>>> .     Identifying and utilizing accommodations and resources
>>>
>>> .     Exercising their greatest capacity for learning and achievement.
>>>
>>>
>>>
>>> Commissioners:  " student will exercise"  needs to be " student shall
>>> exercise"
>>>
>>> To me this is a little patronizing and paternalistic.  There is no role 
>>> for
>>> the MCB counselor in this process.  There ought to be, at least 1 
>>> sentence
>>> or phrase added to commit the Counselor to assisting in this growth and
>>> transformation.
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
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