[nfbmi-talk] letter, written by Fred Schroeder

[joe harcz Comcast]

Dear Fread,

You know our leagle recourse. and in fact you and others have several 
thousand of documents that have not been used in these regards including 
those relateded to the OMA case files which have been paid for by members 
and not employed as the weapons of democracy and our collective interest 
that they are.

Look without looking at them I know for a flying fact they prove coagency 
conflicts of interst, mass violations of civil rights, violations of the OMA 
and FFOIA and so on and so forth in spades...

Yet we the NFB paid for this action and didn't even know the law firm and 
closed its action with board action while leaving everything in a 
netherworld which only left us vulnerable to the insider types of wheeling 
and dealings that we get accused of by the mass media.

Now I'm not going to get in to the right or wrong of this bovine scatology 
or other partisan political maneauvering including Larry Posont's $500 
contributition to the Snyder campaigan.

The problem with all of this crap is that it pits political and self ser--  
Original Message ----- 
From: "Fred Wurtzel" <f.wurtzel at att.net>
To: "'NFB of Michigan Internet Mailing List'" <nfbmi-talk at nfbnet.org>
Sent: Sunday, March 18, 2012 9:39 PM
Subject: Re: [nfbmi-talk] letter, written by Fred Schroeder


> Joe,
>
> You are preaching to the choir.  What is our legal recourse?
>
> Best Regards,
>
> Fred
>
>
> -----Original Message-----
> From: nfbmi-talk-bounces at nfbnet.org [mailto:nfbmi-talk-bounces at nfbnet.org]
> On Behalf Of joe harcz Comcast
> Sent: Sunday, March 18, 2012 8:39 PM
> To: NFB of Michigan Internet Mailing List
> Subject: Re: [nfbmi-talk] letter, written by Fred Schroeder
>
> What others are not looking at as well, but I'm pointing in that direction
> is that all the State Plans and all the federal money for all PWD under
> title I and even Part B funds for IL dispensed by the DSU are at risk
> because of this rash act without including true stakeholders in this 
> process
> and that includes whether the Administration here likes it or not the MRC,
> the MCB Board, the Members of the SILC, common citizens of all 
> disabilities
> and in fact the members of the State of Michigan Legislator who were dully
> elected for good or ill to do their jobs.
>
> In other words this is not a dictatorship.
>
> And the executive branch of government of one state cannot act 
> unilaterally
> on the one hand and expect the feds to fund all of these programs on the
> other without accounting for funds.
>
> Joe
> ----- 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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