[nfbmi-talk] look at these

[joe harcz Comcast]

Now look at the federal requirements for non-delagable autorities here. They go to the appropriate roles of the Designated State Agency (aka LARA) in the case of MCB's goofy and illegal state plan.

Riddled throughout the plan are violations of these sections and more:
'
In addition, regulations found at 34 CFR 361.13(c) require that certain functions be reserved solely to the staff of the DSU and that these functions may not be delegated to any other agency or individual (34 CFR 361.13(c)(2)).  At a minimum, these “non-delegable” responsibilities relate to decisions affecting:

 

·         eligibility, the nature and scope of services, and the provision of those services (34 CFR 361.13(c)(1)(i));

·         the determination that individuals have achieved employment outcomes (34 CFR 361.13(c)(1)(ii)); 

·         policy formulation and implementation (34 CFR 361.13(c)(1)(iii)); 

·         the allocation and expenditure of VR funds (34 CFR 361.13(c)(1)(iv)); and 

·         the participation of the DSU in the one-stop service delivery system in accordance with Title I of the Workforce Investment Act (WIA) and the regulatory requirements specified in 20 CFR Part 662 (34 CFR 361.13(c)(1)(v)).

 "







That especially goes to any issues of budgeting and finance of VR funds!



Even if this were legal (wiping out MCB/PA 260)....



The authority oover budgeting and financing goes to the Designated State Unit (the stuppid new bureau) and not to LARA, Zimmer, or Al Pohl, etc.



The point is in the Rehab Act the feds wish to assure that federal VR dollars go to VR programs and are administrated by VR agencies, not those who no nothing about VR even on a nominal basis.



Joe