[nfbmi-talk] comments on state plan

[Lydia Schuck]

Please find attached and in the body of this email, my input on the FY
2012 State Plan to be submitted July 1, to the Rehabilitation Services
Administration.

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
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