[nfbmi-talk] letter, written by Fred Schroeder

[joe harcz Comcast]

While I find this a bit of a mixed message Fred in the flurry of all the 
activity around it I certainly agree that we collectively and individually 
as Federationists need to be beating down the doors of our legislators both 
state and federal on this issue. And certainly it is true as has always been 
the case that NFB will and is leading the charge.

There is, however one card in this deck that does go to RSA as they 
ultimately hold the federal purse strings.

And that is a point that must be hammerred home to again our state reps and 
senators and is in fact a message loud and clear here.

Whether or not the entire $17 million for blindness services alone is at 
stake or more or some portion thereof one thing is very clear and that is 
this ill conceived scheme will cost Michigan something in the millions and 
will cost us jobs and not just jobs for blind folks too.

If the Governor or anyone else wishes to ignore these facts they do so at 
their peril of losing at least a portion of federal funds if not them all.

Frankly, I don't think any but the most "libertarian" type is willing to 
risk such a thing in an election year if that is indeed brought to each and 
everyone's attention, which it should be of course.

I hope that none of my comments are taken to taint the heroic work that you, 
Larry, Joe S and untold others are doing in the trenches. For that is not 
the case and this isn't aimed at you all.

In addition though to working within our community I have been alerting 
others in the broad community of PWD about the dangers of this ill conceived 
move including those in CILs, the MRC, etc.

In addition all are openly wonderring once again what our brothers and 
sisters in MCBVI are doing and that includes the leadership and members of 
the ACB.

It is time, long since time for individual agendas and even partisan agendas 
to end on this issue.

This isn't an ACB v. NFB issue. This isn't a "Democrat" v. "Republican" 
issue. This isn't even solely (though we are the most concerned at the 
moment) a pure blindness issue.

You, Larry and all are correct in that all should be contacting their own 
and other legislators for sure and getting others to do the same.

I also urge those who can do so to pack the next Commission Board meeting on 
Friday and beyond that  to attend in person any public hearings as rummied 
up as they might be in person if possible.

As neither I nor anyone can be in multiple places at once I urge all to 
call, write or do whatever possible tonip this in the bud right here and 
now.

Again I applaud you, Fred and others for the work you've  been doing in all 
of these regards.

Again hope you didn't take my comments as a critique of you or others who 
are working diligently in the trenches.

Peace with Justice,

Joe
----- 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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