[nfbmi-talk] College Policy Comments

Fri Jul 16 10:43:34 UTC 2010

Way to go, Fred!  You are to be commended on the work that you have done 
also.  I wholeheartedly recommend that the changes you've suggested below be 
incorporated into the policy.

Mary Ann
Mary Ann.
----- Original Message ----- 
From: "Fred Wurtzel" <f.wurtzel at comcast.net>
To: "'NFB of Michigan Internet Mailing List'" <nfbmi-talk at nfbnet.org>; 
"'Geri Taeckens'" <geri.taeckens at isahealthfund.org>; <pilarskij at charter.net>
Sent: Thursday, July 15, 2010 4:43 AM
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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