[nfbmi-talk] no due process in bsbp

[joe harcz Comcast]

All,
Note the following segment from EO 2012-10 and also from the BSBP State Plan:
"
E.        Any authority, powers, duties and functions relative to final agency decisions for cases arising under the Randolph-Sheppard Act, 20 U.S.C. 107 to 107f, the Rehabilitation Act of 1973, Public Law 93-112, as amended, 29 U.S.C. 732, and the Blind and Visually Disabled Persons Act, 1978 PA 260, MCL 393.351 to MCL 393.369, are transferred from the Commission for the Blind to the Director of the Department of Licensing and Regulatory Affairs."



These are non-delegable authorities to the Designated State Agency!



And the agents also run the Michigan Administrative Hearing System.



There is no due process if the self-same DSA ccan make final agency determinations on everything including Title I complaints!



This doesn't just go to the Randolph Shepard and the BEP program. It is a fundamental denial of impartial due process proceedings with an assured outcome by the very agencies in question.



I recommend that the SRC members acquaint themselves with these absurdities so that they might conduct their due diligence in holding this agency accountable for following Title I of the Rehab act which is its charge.



Sincerely,



Joe Harcz