[nfbmi-talk] College policy edited board draft for 8-27 meeting
joe harcz Comcast
joeharcz at comcast.net
Thu Aug 26 23:17:02 UTC 2010
Yup, that's the real problem ... The real issue with a college policy in my
opinion is to inform not the student, but rather those counselors and to
keep them from continually acting in aarbitrary and capricious manners as
they are so often want to do.
Man, I tell you a whole lot of them are simply off the reversation and need
some schooling in the Rehab Act and in even basic IPE development. What is
wrong with this picture when these folks have to get a grad degree and get
Certified (CRC) and when they either don't know or violate the very act that
gives them their rather high salaries to begin with? And beleive me I'm not
whining for them one wit as they do get good bucks and must be held
accountable for this.
(I am ommitting from these comments the many good counselors in MCB, but,
frankly their ranks have dwindled substantially over the years).
Joe
----- 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 6:29 PM
Subject: Re: [nfbmi-talk] College policy edited board draft for 8-27 meeting
>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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