[nfbmi-talk] letter, written by Fred Schroeder

[joe harcz Comcast]

To those in the blindness community; to those in the disability community 
over all; to those who wish to safeguard this or that federally funded and 
narrow interest I say this:

The state plan, and fundamental state plan of MCB is not the only thing at 
risk here.

the entire VR, Title I and Part B federal funding streams are at risk 
because this governor and his minions have acted in extra legal fashion.

While thisanalysis by Fred Schroeder  was correct as far as it went there is 
much more at stake and allies and others with other disabilities should know 
it to.

Shoot the 88 BEP jobs aren't the only jobs at issue here. The $17 million 
for VR, and federally funded blindness services under the Rehab Act funding 
schemas aren't all that is issue here.

If the employees for example at MCB alone don't think this impacts their 
jobs including their personal jobs whether being cooks at the training 
center, or VRTs, or O and M instructors or CRCs then they got a different 
thing a coming.

If the sellout and I'll use that term, administrators don't think their jobs 
are at issue then they've got another thing coming if this course continues 
though they might be the last standing while the titanic sinks into the 
ocean.

If CILs think this doesn't impact them and their funding and their programs 
well they will have another thing coming if they think of this as a narrow 
issue.

Ditto for those with other disabilities under MRS or for the integrity of 
the MRC which is already in a shambles and virtually destroyed already by 
the corruption of the process with CRPs.

If the CRPs think they'll get by then they will have another thing coming as 
more and more federal funds are effectively ciphered off into general fund 
accounts with this sort of extra legal end run around the design of these 
programs.

Oh and if the CEOs at those same NISH and other programs don't like the 
regulations and the federal rules for equity and fair play and for a basic 
living wage let alone a minimum wage then maybe those programs that have 
waggged the VR dog so often and so venally over and over again should be 
repealed and those self-same hacks at those bodies should get jobs in the 
private sector that so much of their NISH propaganda so emulates whilst at 
the same time in traditional hypocritical fashion denigrates.

In other words ladies and gentlemen the likes of NISH and most rehab hacks 
at the top of the proverbial food chain depend upon the Javitts-Wagner Oday 
Act, the Rehab Act, the IL and other amendments to all of them. So do the 
state hacks.

But they all whant the federal funds to keep on a flowing without federal 
accountability. In other words they want them diverted to their own self 
interests and most often to sinking general funds by other means.







Argh...It goes on and on...

Don't we know what happens to ostriches? They get their heads cut off.

And for those on this list who think that making waves and demanding 
accountability and that demanding performance is the cause of this and that 
we shouldn't raise our voices both individually or collectively for fear of 
being "cut off" from this or that program whether it be a little stipend as 
an intern or a job with the agency or a little token of fealty as an 
assistive tech consulting contract or whatever let me tell you you will all 
be cutoff. YOu won't be cut off at the knees either but, rather you'll be 
cut off right at your necks and right where you live and your means to live 
too.

Students who bithch, rightfully so about grad funding and against the 
wrongful means testing won't get one thin dime of anything for anything. For 
again all those federal dimes are at risk or at least the lions share of 
them.

And they are all at risk all this is at risk not just because of bad 
financial times, or of this or that debate between the likes of NFB or ACB 
or any of that other stupid stuff.

No they are at risk because too many wish to let the powers that be and have 
always wished the powers that be no matter who they were dictate programs 
and not to have the voice of the blind speaking for themselves along with 
others with other disabilities speaking for themselves...Or rather all of us 
speaking for OURSELVES come together.

Colleagues the time for self interest, not to be redundant is over. It is 
ended it is caput!

None of us survives in a true and meaningful form without the rights of our 
and sisters in his and her heart in our individual and collective actions.

This is not a radical concept for Americans for Ben Franklin himself told 
all involved in our Great American Revolution this:

"We must hang together, or surely we'll hang separately."

Now we who are blind or otherwise disabled wish to draw lines in the sand 
and wish to retake the high ground here in Michigan? Do we wish to go as 
always intended in the crude terms from a handout to a hand up and to 
"freedom and equality of at very least opportunity", let alone results?

Well then now is the time to fight.

And for those who are old in tooth such as I am without much skin now in his 
personal game I say think of the younger generation.

and for that younger generation who frankly I've seen in so many cases not 
understanding the true civil rights struggles of your elders upon the 
benefits and so-forth that you enjoyed just a few years back you've got to 
get some revolutionary back bone or you will be the victims of this infamy 
and not our generation

For the cynical and the totally self interested I'll end this diatribe by 
saying this: "Each and everyone of us are bang picked off one by one and 
group by group; client/customer, union reemployed by union employee; service 
contractor by service contractor; etc., etc., etc.

Five fingers are easily broken by a power that wishes to break them with 
just the simplest of physical methods. But when united into a fist the power 
of a united people is invincible. Or at very least the predators against our 
interest will not be allowed to break us, knuckle by knuckle; finger by 
finger solely on the basis of our common digital division and, thus, common 
vulnerability in those regards.

Regardless as to this angstan and I do express angst to most of my own blind 
cand disabled community for not acting before this crisis; and I say most 
and not all.


----- Original Message ----- 
From: "Larry Posont" <president.nfb.mi at gmail.com>
To: "nfbmi-talk" <nfbmi-talk at nfbnet.org>
Sent: Sunday, March 18, 2012 7:50 PM
Subject: [nfbmi-talk] letter, written by Fred Schroeder


National Federation of the Blind of Michigan
20812 Ann Arbor Trail
Dearborn Heights, MI 48127

March 18, 2012

Dear Fellow Federationists:
Here is a letter, written by Fred Schroeder, the Vice President of
the National Federation of the Blind. It concerns the Michigan
Commission for the Blind. You may want to read it.

Sincerely,
Larry Posont, President
National Federation of the Blind of Michigan
(313) 271-3058
Email: president.nfb.mi at gmail.com
Web page
www.nfbmi.org

Fredric K. Schroeder, Ph.D.
9522 Lagersfield Circle
Vienna, VA 22181


March 13, 2012

The Honorable Rick Snyder
Governor of Michigan

P. O. Box 30013
Lansing, MI 48909
Dear Governor Snyder:

I am writing in my capacity as the former Commissioner (1994–2001) of
the U.S. Rehabilitation
Services Administration, the federal agency that provides the majority
of the funding to support
the work of the Michigan Commission for the Blind.

I would like to express my concerns about your recent Executive Order
No. 2012-2, dated
February 24, 2012. This Executive Order makes significant changes to
the manner in which
individuals with disabilities in Michigan receive services. I am
particularly concerned about the
impact that these changes will have on blind individuals and
individuals who have visual
impairments in the State of Michigan. Let me address my concerns
regarding certain provisions
in the Executive Order as follows:

Transfer of the Michigan Commission for the Blind

Executive Order No. 2012-2 transfers the Michigan Commission for the
Blind to the
Department of Human Services (DHS). The Michigan Commission for the
Blind currently
receives over $17,000,000 in federal funds per year to provide
vocational rehabilitation and
other services to blind individuals. This funding will be in jeopardy
if the organizational
changes do not comply with federal requirements for state vocational
rehabilitation
programs. For example, the Executive Order is unclear about the
organizational placement
of the transferred agency within DHS. Is it to be a freestanding
organizational unit or is it to
be merged into Michigan Rehabilitation Services under DHS? If the
entity providing
services to blind individuals is to remain a separate unit within DHS,
all federal
organizational and State Plan requirements must be met for such a
unit. Organizationally, it
must be a unit that meets the specific requirements in 34 CFR
361.13(b). The unit must have
a full-time director, have 90 percent of its staff working full time
on rehabilitation work, and
must be at an organizational level within DHS that is comparable to
that of other major
organizational units of the agency.

Business Enterprise Program

The Executive Order moves the Business Enterprise Program from the
Commission for the
Blind and the Department of Licensing and Regulatory Affairs to the
Michigan Department
of Technology, Management and Budget. This will invalidate the
currently approved State
Licensing Agreement between the federal Rehabilitation Services
Administration and the



The Honorable Rick Snyder
March 13, 2012
Page 2

Michigan Commission for the Blind. Under the current State Licensing
Agreement, 88
facilities (48 state and 40 federal) are operated by blind vendors in
Michigan. The Michigan
Department of Technology, Management and Budget is not eligible to
serve as the State
Licensing Agency for the Business Enterprise Program. Applicable
federal regulations at 34
CFR 395.2 require that an application for a State Licensing Agency can
only be submitted by
a state vocational rehabilitation agency providing vocational
rehabilitation services under an
approved State Plan. Given this situation, all of Michigan’s blind
vendors operating on
federal property will lose their source of income.

Creation of the Michigan Council for Rehabilitation Services

The Executive Order creates the Michigan Council for Rehabilitation
Services as a
replacement for the Michigan Rehabilitation Council. The membership of
the new Council
and its duties appear to be consistent with the federal requirements
for a State Rehabilitation
Council under both the Rehabilitation Act of 1973, as amended, and
program regulations at
34 CFR 361.16-361.17. However, the language is clear that the new
Council applies only to
Michigan Rehabilitation Services. It does not mention its
applicability to the transferred
duties and functions of the Michigan Commission for the Blind. If the
intent is to place the
transferred Commission under Michigan Rehabilitation Services, then
the new Council
would apply to services for blind and visually impaired individuals.
However, the Executive
Order is not clear on this point. If the transferred Commission is to
be a freestanding
organizational unit within DHS, then a separate Council may be needed
or the functions of
the new Council must be expanded to cover services to blind and
visually impaired
individuals.

If the intent is to merge the Michigan Commission for the Blind’s
programs into the
Michigan Rehabilitation Services Agency, I urge you to consider the
impact on services to
blind and visually impaired individuals in the state. Studies
conducted over the past four
decades have repeatedly demonstrated the effectiveness of specialized
services for the blind:
Cavenaugh, B. S. (2010). An update on services and outcomes of blind
consumers served in
separate and general/combined vocational rehabilitation agencies
(prepared for the National
Council of State Agencies for the Blind by the Rehabilitation Research
and Training Center
on Blindness and Low Vision, Mississippi State University, Mississippi
State, MS: RRTCMSU)
found that—

o
Separate blindness agencies continue to serve a higher percentage of
consumers with
demographic/disability characteristics associated with lower labor
force participation
rates.
o
Separate blindness agencies continue to close a higher percentage of
legally blind
consumers into competitive employment.
o
Separate blindness agencies close a higher percentage of legally blind
consumers into
employment without supports in integrated work settings.


The Honorable Rick Snyder
March 13, 2012
Page 3

o
Separate blindness agencies close a higher percentage of legally blind
consumers into
self-employment.
Establishment of a Blind and Visually Impaired Services Advisory Board

If the intent of the Executive Order is to maintain the specialized
service structure of the
Commission for the Blind and move it intact into DHS, the Commission
will need to retain
its independent consumer-controlled commission or it will need to
establish a State
Rehabilitation Council.

The Executive Order creates a Blind and Visually Impaired Services
Advisory Board.
However, the Board does not meet the federal requirements for either
an independent
consumer-controlled commission or a State Rehabilitation Council under
Section 101(a)(21)
of the Rehabilitation Act of 1973, as amended. It also does not meet
the specific
requirements of 34 CFR 361.16 of the program regulations, given that
it will have no
standing under an amended Michigan State Plan for vocational
rehabilitation. An amended
State Plan will be required based upon the organizational changes in
this Executive Order.

The 1992 Amendments to the Rehabilitation Act of 1973 first introduced
the requirements
for a State Rehabilitation Advisory Council (now the State
Rehabilitation Council). The
1992 Amendments made clear that the intent of Congress was that each
state vocational
rehabilitation agency should be run by an independent,
consumer-controlled commission.
However, as federal law cannot dictate organizational structure to
state governments, an
option was made available for an advisory council in lieu of the
consumer-controlled
commission. Under the Executive Order, Michigan will be taking a step
backward to a less
preferable organizational construct for serving its citizens who are
blind or visually impaired.

Elimination of the Position of Director of the Michigan Commission for
the Blind

The Executive Order also eliminates the position of Director of the
Commission for the
Blind. However, in order to remain a freestanding vocational
rehabilitation unit, the entity
providing services to blind and visually impaired individuals must
have a director who is
full-time and has the authority to make the final decisions regarding
eligibility, service
delivery, rehabilitation policy, and the allocation and expenditure of
vocational rehabilitation
funds (see 34 CFR 361.13(c), which spells out the specific responsibilities 
for
administration).

No Improved Coordination and Little Administrative Savings

Research shows that only minimal administrative savings can be
achieved by consolidation
of separate agencies serving blind individuals into larger agencies
serving individuals with all
types of disabilities. In fact, these savings are offset by less
effective, less well-organized,
and less efficient services under a generalist’s model. In the late
1990s, Cavenaugh, Giesen,



The Honorable Rick Snyder
March 13, 2012
Page 4

and Pierce at Mississippi State University conducted an analysis of
national data and found
that blind people who are served through separate agencies for the
blind are nearly twice as
likely to be self-supporting at closure as blind people served by a
consolidated vocational
rehabilitation agency. Consolidation weakens specialized services,
reduces program
efficiency, and saves little, if any, money.

In summary, Executive Order No. 2012-2 will have a significant,
negative impact on the lives of
blind and visually impaired individuals in the state of Michigan. As
noted above, the changes
outlined in the Executive Order will place at risk the $17 million in
federal funds that currently
support programs for the blind and visually impaired in the state, and
will weaken the specialized
services essential for the rehabilitation of blind and visually
impaired residents of Michigan. It
will put in jeopardy the jobs of 88 blind Randolph-Sheppard vendors,
and it will damage the
partnership between the vocational rehabilitation program and blind
and visually impaired
residents of the state.

I respectfully ask that you rescind Executive Order No. 2012-2 and
maintain the existing
organizational structure.

Respectfully yours,


Fredric K. Schroeder, Ph.D.
Commissioner (1994–2001), Rehabilitation Services Administration


U.S. Department of Education
cc: Members of the Board, Michigan Commission for the Blind

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