[nfbmi-talk] letter, written by Fred Schroeder

[joe harcz Comcast]

Deaar Fread,
\
No you are preaching to the choir. I agree. Not only call but block and 
goagainst in all legal fashion Executive Order 2012-2.

It is as simple as that for now but not for always
----- 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 10:26 PM
Subject: Re: [nfbmi-talk] letter, written by Fred Schroeder


> Joe,
>
>
> For my part, I believe the NFB of Michigan can and will do what needs 
> doing.
> NFBMI needs every person to call their State Senators and Reps, tomorrow,
> Tuesday, Wednesday and on until it gets fixed.  They operate on numbers of
> their constituents calling, so call, call, call, call, and then get 
> everyone
> you know to call, too.The state switchboard number is 517-373-1837.  If 
> you
> know your Senator or Rep, they can connect you.
>
>
> You are preaching to the choir.  If you think RSA is going to ride over 
> the
> hill like so many soldiers at the 11th hour, you are dreaming in
> Technicolor.  The only ones who will stop this is us here in Michigan and
> RSA will do little if anything to help.
>
> So, again, I ask, what is the remedy?  Which lever needs pulling?Where is
> the weak spot?Where is our strength?
>
> Our strength is us.  So encourage everyone to do something, not just 
> seathe
> with riteous indignation, even though to do so is very excusable.
>
> 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 10:04 PM
> To: NFB of Michigan Internet Mailing List
> Subject: Re: [nfbmi-talk] letter, written by Fred Schroeder
>
> 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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