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

Elizabeth lizmohnke at hotmail.com
Fri Aug 27 00:55:30 UTC 2010


Hello J.J.,
 
You bring up a good point. While the policy states that individual time lines can be established to account for personal circumstances including employment situations, the proposed policy still requires students to take a full course load as defined by the educational institution. The draft that we submitted to the review committee did not mention how many credits a student needed to take in order to receive services from the Michigan Commission for the Blind. I believe your concerns here would serve as an excellent public comment for tomorrow’s meeting.
 
Elizabeth
 
 > From: jj at bestmidi.com
> To: nfbmi-talk at nfbnet.org
> Date: Thu, 26 Aug 2010 18:29:11 -0400
> 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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> >>>
> >>
> >>
> >> _______________________________________________
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