[nfbmi-talk] comments on state plan are on mcb web site

[joe harcz Comcast]

For those who cannot access them here are the comments of Commissioner Schuck:

Lydia Schuck’s comments on state plan to be submitted to RSA July 1 by Michigan Commission for the Blind.  Mrs. Schuck is both a parent of a teen in transition and a member of the Commission for the Blind Board of Commissioners.

 

1.  P. 15 of the state plan assures that we are in compliance with the ADA.  The Michigan Commission for the Blind cannot truthfully make this assurance:

 

(c) Facilities.

Any facility used in connection with the delivery of services assisted under this State Plan meets program accessibility requirements consistent with the provisions, as applicable, of the Architectural Barriers Rehabilitation Act of 1968, Section 504 of the Rehabilitation Act, the Americans with Disabilities Act of 1990 and the regulations implementing these laws.

 

Buildings in which the commission serves clients and conducts meetings are not all in compliance with ADA standards.  This is an ongoing concern that is not being addressed satisfactorily by agency leadership and personnel.

 

2.                   P. 38 of the state plan mentions coordination with the Community Mental Health Organization.  Youth of transition age who are still in school cannot receive supports through Community Mental Health.  It is all up to the school.  A student, such as my own daughter, who needs a job coach to provide services and then have those services fade away as she  becomes capable in the workplace, cannot receive services from any agency except the schools, who don’t have programs for academic kids with autism who want to start working.  If she were not in academic programs, she could get much more support from the schools’ community-based programs.  For transition age students, there is no collaboration outside of summer programs for youth.  

 

3.  Last paragraph on page 58.  It is inappropriate to refer to a client who receives supported employment services as a “supported employment individual”.  This is like saying the “lung cancer woman”.

 

4.  p. 58 and elsewhere.  Summer transition programs serve very few teens as a percentage in urban areas.  Any discussion of goals and strategies should name percentages that will be targeted to receive information about programs and how follow-up will be done to be sure to reach teens.   A plan should be developed to disseminate information more effectively.

 

5.  Indicator 1.6  Staff training should address how to encourage consumers to move beyond depending on SSI.  Agency personnel seem too willing to accept the situation when people get discouraged and just give up.  



 

6.  P. 54  New staff immersion training time sections reads as follows:

 

MCB also require that all new staff attend a two-week program at the MCB Training Center under the blindfold to get a better understanding of blindness and the Skills of Blindness training offered at the Center.

This should read “up to 80 hours” of immersion training, since “two-week” suggests more training under blindfold than a mere 80 hours.  Some personnel do not even get the 80 hours. 

 

6.  p. 57-59  Comprehensive Needs Assessment  While the agency has complied with the requirement to assess state needs, outcomes for youth in transition are not mentioned as a group in this assessment.  Youth in transition fit into the words of the plan below, but are not measured as a separate sub-group, and should be.  

·                     individuals with most significant disabilities, including their need for supported employment services;

·                     individuals with disabilities who are minorities; 

·                     individuals with disabilities who have been unserved or underserved by the vocational rehabilitation program; and

·                     individuals with disabilities served through other components of the statewide workforce investment system.

We are a consumer-controlled commission, but the results of the comprehensive needs assessment completed in 2008 is not available through the state website search function on the MCB website.  In a consumer-controlled commission model, consumers should be able to see if their concerns were reflected in the needs assessment.  Our study is conducted as part of the MRS assessment, so without seeing the plan, consumers cannot determine to what extent needs of blind consumers were measured.  It is very difficult for consumers to have input into the development of the annual state plan if they cannot get to the data and report of state needs collected in 2008 and published in 2009.  

 

7.  Section 4.10, p. 15 and following  

The Commission Board has seen but not approved a new staff orientation checklist in draft form.  The checklist does not include any assurances of compliance with the checklist nor specified any mechanism to confirm compliance.  Supervisors of new employee should assure and document the process of new staff orientation.  Development of new staff orientation procedures is a point of discussion in a Commission Board Ad Hoc training committee, chaired by Commissioner Lydia Schuck, laschuck at juno.com .  In house development of the survey to determine the effectiveness of new staff orientation is admirable, and a very good step, but this is just a beginning, and the commission board has not reviewed or approved the survey yet.

 

Respectfully submitted, June 25, 2011 

Lydia Schuck

Parent of blind teen

Member of Michigan Commission for the Blind Commission Board