[nfbmi-talk] College Policy Comments

[Fred Wurtzel]

Hello Geri and List,

I wish to begin by stating that the draft document is vastly improved in
content and quality from the draft presented at the Marquette Commission
meeting.  It was, and is, clear that there is a vast chasm between
Commission staff and consumers on what constitutes quality and humane
rehabilitation services.  There are lingering artifacts from the original
document which still reflect the more regressive and patronizing points of
view.  Though there not very many critical items, I will list each one
below.  As part of this preamble, I will mention that the burdensome and
potentially punitive attempt to create the groundwork for a means test
remains in the form of redundant, superfluous and unnecessary supplemental
financial needs form.  There are still areas where the Commission is
unnecessarily inserting itself between the training entity and the MCB
client.  The recent removal of non-accredited training from permissible
services is paternalistic and, again, reduces the ability of the counselor
and client to work together to develop the most effective plan for
employment possible.  Commission policy must root out paternalism, distrust
of clientele and gotcha games which only thwart progress toward employment
for MCB consumers.

Following are specific examples of items that still need work:

Under "A" Prerequisites, the sentence citing the rehab act and P.A. 260
needs to be clarified by putting a comma after "Rehabilitation Act" and
citing the proper section of P.A. 260.

Remove the word "proposed" in "proposed timeline."  The word "proposed" begs
the question of when it will be the final timeline.  If circumstances
change, there are procedures for making changes, so the timeline ought to be
what is agreed to.

Number 4 regarding timelines is good beginning with the words "MCB students
are encouraged. . ."  The language preceding this clause is a covert way to
slip the timelines back into the college policy.  These federal "mandates"
are not part of the Rehab act and have escape clauses in them. It is
sufficient to say that students will comply with rules and expectations of
the institution that they will attend and leave the individual timelines to
the relationship between the college and the student.  

In number 5 the policy is sliding back into that old habit of paternalism
and coerciveness.  The language following ". . .their needs." Should be
eliminated and replaced with a simple sentence that the student be familiar
with the college's policies ant those of the U.S.  Department of education.
This language is heavy handed and manipulative.  There are escape clauses
which account for individual need.  An appropriate  sense of    urgency can
be conveyed without treating clients like children.

In item 7 the word "should" needs to be stricken.

In item 8, the word "will" needs to be replaced by "may" or "shall." In the
sentence, "mcb, in most cases. . ." needs to strike the word "will".

Item 10 replace "will" with shall in the sentence that says "student and MCB
counselor will discuss. . ."


Item 13 is an excellent example of where this policy is vastly improved from
the original.  BRAVO!

Under "B" regarding accreditation, it is generally desirable to use
accredited institutions.  However, there may be situations where such
institutions do not exist or have for some viable reason not received
accreditation.  Under the "informed choice" provision of the rehab act, the
client and counselor may make the decision to utilize "alternative training
means, such as a master in a trade or occupation that does not formally
provide training.  Informed choice needs to be considered in this policy
section.

C-6 is not true.  It has not been mandated by the Commission Board that the
staff require an extra form for collecting financial information.  This is
another attempt to make something seem like it is credible when, in fact,
the Director is usurping power from the board.  This form is ill-advised and
should not be implement, but it may be implemented by the Board via adoption
of this policy.  Please drop this requirement from the policy.  Sooner or
later, some college burdened by excessive unfunded mandates will refuse to
provide this information and the MCB client will be delayed and penalized by
circumstances beyond their control.  MCB staff should utilize on-line
information presently available to gather this information and not add
unnecessary layers to the bureaucracy.

Item 8 should be deleted.

Item 10 is illegal for students receiving SSI or SSDI.  MCB may not require
such students to pay for the costs of their program.  Since it is impossible
to enter college without applying, such applications are part of the cost of
attendance.  Again it is illegal to deny application fees to SSI or SSDI
clients.  It may be ok to limit the number of applications filed at a time,
until the student is accepted, though this may unnecessarily delay
enrollment.

Item 13 "will" in "will be available" needs to be "shall."

Item 15 "can be" needs to be changed to "may be."  As we discussed in the
June meeting at Michigan works, the provision for paying for the highest
Michigan college is ok, unless the program is not available at a public
college.  In that case, MCB should sponsor the entire cost, since there is
no lower cost alternative in state.

Item 16 needs the same changes as 15.  

Item 18 needs to include provision that the counselor will make a maximum
effort to assist the student if the student asks for such support.  Such
assistance needs to be documented by the counselor.

Item D is much improved from original.  Again, BRAVO!

Item 1 should be stricken.  MCB does not need to approve arrangements
between the institution and the student.
  The word "reestablish" is inappropriate in this item, since it is not
discussing any violations.

It is appropriate for the client and counselor to develop a plan for items
2-3.  It may be unreasonable for a student to repay the tuition for dropped
classes within 1 semester.  There needs to be an escape clause to develop a
reasonable repayment plan for those unable to repay within a semester.
Someone on SSI receiving only $600/month may not be able to meet the
requirement.
Item 2 "will hold" needs to be changed to "shall hold."
"written plan will" needs to be "written plan shall."

"must resolve" needs to be "shall resolve".

Item 3 ""will be required" needs to be "shall be required."
 In item 3 the word "should" may be ok if there is an escape clause in there
for alternative repayment plans.  Otherwise probably ought to be "may" or
"shall."  As stated earlier,, especially for those on SSI there needs to be
the possibility of an alternative repayment plan.

Item 4 has been gigantically improved. 2 BRAVOS are in order, here.  BRAVO!
BRAVO! 
Under the bullet, "students should then" needs to be "students shall then."

"consumer will" needs to be "consumer shall."
In the next bullet "should be discussed" needs to be "shall be discussed."

In the next bullet "can be disrupted" needs to be "may be disrupted."

"would also exempt" needs to be shall also 

E. deserves another BRAVO!

Item 5 "will be" needs to be "shall be."

exempt."

Under conclusion "consumers can obtain" should be consumers may obtain."
Item 1 "counselor will assist" needs to be "counselor shall assist."

Item 2 "student will communicate" needs to be "student shall communicate."
Item 3 "student will exercise" needs to be student shall exercise."


Again, though there is continual pressure to regress, this policy continues
to improve.  It is so much better now.  With the above corrections, I
believe we will have an exemplary college policy.  Geri and Elizabeth, you
2, have stuck with it and are to be commended.  As always, the hardest part
of the effort is getting a quality document finished and delivered  you are
nearly there.  GO, GO, GO!

Warm Regards,

Fred Wurtzel