[nfbmi-talk] College Policy Comments

Elizabeth lizmohnke at hotmail.com
Thu Jul 15 19:52:34 UTC 2010


Hello List,
 
First, thanks to Fred Wurtzel for submitting such a detailed review on the current draft of the college policy. Your comments are deeply appreciated. However, for those of you who would still like to make comments to the current draft of the college policy, the deadline for submitting comments has been extended until noon on Monday, July 19, 2010. 
 
Please do not ask me why the deadline was extended. I fail to understand the leadership style of Commissioner Geri Taeckens who is now claiming that she “just doesn’t have the time” to make the changes to the policy that Fred suggested in his email. Of course the last time we submitted a revised draft of the policy to the committee we were accused of “rewriting the policy” By one of the Commission staff members. Talk about a tough crowd to please! 
 
Once again, I am attaching the July 1, 2010 draft of the policy along with the new DELEG Financial Needs form to this email for those of you who are interested in reading them. As indicated in a previous email, this Financial Needs form is NOT the same as the FASFA form. These are two entirely separate forms. If you have any further questions or comments, please do not hesitate to speak up as I will do my best to answer any further questions and would appreciate any further comments.
 
Warm Regards,
Elizabeth

> From: f.wurtzel at comcast.net
> To: nfbmi-talk at nfbnet.org; geri.taeckens at isahealthfund.org; pilarskij at charter.net
> Date: Thu, 15 Jul 2010 04:43:50 -0400
> Subject: [nfbmi-talk] College Policy Comments
> 
> 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
> 
> 
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