[nfbmi-talk] BSBP Commission Report and Recommendations to Governor
Terry D. Eagle
terrydeagle at yahoo.com
Wed Apr 8 18:15:49 UTC 2015
Dear Fellow Federationist,
Attached and below is the 58 page report and recommendations of the BSBP
Commission to the governor and LARA director.
To Rick Snyder
Governor of Michigan
and
Michael Zimmer
Acting Director, Michigan Department of Licensing and Regulatory Affairs
Report of the Michigan Commission for Blind Persons
Lylas G. Mogk, MD, Chair
Josie Barnes-Parker
LeeAnn Buckingham
Marianne Dunn, PhD
Gary Gaynor
Michael Hudson
Joseph Sibley
December 12, 2014
With BSBP Responses, March, 2015
Table of Contents
Section
Pages
Executive Summary
3-7
The Governor’s Charges to the Commission:
Observations and Recommendations
I. Study and review the needs of the blind community
8-13
in Michigan
II. Advise LARA concerning the coordination and
14-25
administration of state programs serving the blind
community.
III. Recommend to LARA changes in state programs,
26-43
statutes and policies that affect the blind community
IV. Secure recognition of accomplishments and
44-45
contributions of blind residents
V. Monitor, evaluate, investigate and advocate programs
46-48
for the betterment of blind residents
VI. Advise the Governor and the Director of LARA of the
49
nature, magnitude and priorities of the challenges of
blind persons.
VII. Advise the Governor and the Director of LARA on the
50-55
state’s policies concerning blind individuals
Future of the Commission
56
Appendix: Organizational Structure of BSBP
57-58
Note: As there is some overlap in the charges to the Commission, there
are some repetition of observations and recommendations in different
sections.
Executive Summary
Since the initial public meeting in January 2013, the Commissioners have
studied and addressed the Governor’s charges to the Commission. All
Commissioners have appreciated the opportunity to contribute to this
important assessment of the state’s services to blind and visually
impaired persons. This report contains the Commission’s unanimous
observations and recommendations with the hope that it will help strengthen
services and broaden the population served.
The Commission believes that maintenance of an agency specifically
dedicated to the needs of those with blindness is critical. That agency,
however, must lead the state transforming what it means to be blind in
Michigan by dismantling stereotypes and articulating blindness to clients,
employers and the community as a challenge that can be successfully
addressed with education, compensatory skills, focused training, and high
expectations for reaching full potential and by collaborating with
community organizations, institutions and employers.
The Commission’s principal recommendation is the development and
implementation of a Strategic Plan based on reassessment of the bureau’s
mission, goals, leadership, staff, structure, content, and consumer role
and exploration of best practices in other leading agencies. The Commission
believes, however, that implementation can only be accomplished by an
invigorated agency, in contrast to today’s Bureau of Services for Blind
Persons, that operates with a vibrant, innovative outcomes-driven approach
and a culture of shared goals, teamwork and accountability.
With the realization that not all of the Commission’s recommendations,
which number over 100, could be implemented immediately, the Commission
recommends the following as priorities.
Priority Recommendations
Bureau of Services for Blind Persons
Culture. The Commission recommends:
1. Creative, collaborative leadership by example at every level, as
set forth in Section II.
BSBP Response: Since the Bureau of Services for Blind Persons was
established in October 2012 under Executive Order 2012-10, its first
Director has worked diligently to establish and foster a creative,
collaborative environment by leading through example. Much progress has
been made, however, BSBP must continue its efforts in this area. While
culture change within an organization is sometimes not as swift as desired,
BSBP is on the right track.
2. Supportive supervision of staff that encourages initiative and
facilitates optimal performance and best client outcomes, as set forth in
Section II.
BSBP Response: BSBP has created employee engagement teams which are
studying and reviewing various functions and areas within the Bureau. For
example, BSBP has an employee engagement team studying the services
provided for Independent Living and Older Blind. This effort will continue
with recommendations and final reports from the various employee study
teams by the fall.
3. Development of a culture that prioritizes clients first, staff
second and administration third, demonstrates mutual respect and adheres to
comprehensive performance standards, as set forth in Section II.
BSBP Response: BSBP has created an internal standard by which employees
must return emails and telephone contacts from clients within 2 working
days. In addition, BSBP has started the process of coordinating the
Training Center services with Vocational Rehabilitation and Business
Enterprise Program functions. The entire coordination process is being
reviewed with recommendations for structural changes necessary to carry out
the Bureau’s statutory responsibilities. As indicated above, BSBP has
engaged staff participation in subject matter review and organizational
decisions to improve our services. BSBP has standardized its comprehensive
performance standards for its employees.
Structure. The Commission recommends:
1. Providing local services including assessments, skills of
blindness, technology and job readiness training, as set forth in Section
III.
BSBP Response: BSBP utilizes its mini adjustment program by which staff
introduce to Michigan’s blind community the skills, programs and services
that are available through BSBP and the Training Center in different
geographical regions throughout the state. The Training Center is
reviewing and determining what skill areas of blindness need to be expanded
in its curriculum. Job readiness training and coordination of those
services are in the final stages of review for implementation. The east
side of Michigan is served for skills of blindness, technology and job
readiness through a partnership agreement with Detroit Receiving Hospital.
2. Reconsidering the organizational structure of Consumer Services,
for example creating separate divisions for vocational rehabilitation,
independent living and youth/transition, as set forth in Section III.
BSBP Response: BSBP is finalizing its review of necessary structural
changes to its consumer services division. The Advisory Commission
recommendations and the management review should result in structural
changes which will enhance BSBP’s services to Michigan’s blind community.
3. Dedicating the Training Center to the dual purpose of intensive
blind skills development and specific training in selected job skills for
which a market has been identified, set forth in Section III.
BSBP Response: BSBP and the Training Center are reviewing and studying
areas of job training and development which can be added to the Center’s
expanding curriculum.
4. Reconsidering the structures of the Business Enterprise Program
(BEP) and Business Assistance and Development Program (BADP) to maximize
cost/benefit and client success, as set forth in Sections III and VII.
BSBP Response: Structurally, the BADP has been established as its own
Division. The idea behind BADP Division was to assist private
entrepreneurs in private sector business arena. The BEP is a Section within
the Administrative Services Division. BEP licenses entrepreneurs to
administer food service operations within businesses established under the
Federal Randolph-Shepard Act and MI Public Act 260 of 1978. The BEP
Program has extensive specialized training and close monitoring of these
pre-established facilities.
5. Centralizing market research for employment trends and job
development and creating employer incentives for hiring qualified
individuals who are blind specific, as set forth in Section I.
BSBP Response: This recommendation will take time to study and staff need
to discuss and determine how best to incorporate this into BSBP
programming. BSBP has nothing to report by way of progress in advancing in
this direction.
Content. The Commission recommends:
1. Significantly increasing the technologies available to staff and
clients, as technology has become the equalizer for individuals who are
blind and visually impaired, as set forth in Section III.
BSBP Response: BSBP has made significant progress in this regard and
agrees that advancing available technology provides staff and clients who
are blind with equalizing access to information and tools for performing
their jobs. BSBP staff have been provided with screen reading technology,
iPhones, and iPads as appropriate to their duties and responsibilities.
The Bureau has developed and presented technology training opportunities
for both clients and staff to enhance technological skills. Within the
Business Enterprise Program, licensed operators have been trained in
establishing a web based presence in order to better market their
businesses, have initiated a pilot testing of a new state of the art
technology, accessible point of service system, and has a Request for
Proposal (RFP) nearly finished to use technology to track sales and
inventory. BSBP supports this goal and will continue to advance in this
direction.
2. Establishing protocols for assessment and guidelines for
intervention and informed choice, as set forth in Sections I, II and III.
BSBP Response: BSBP is in agreement with this goal and will work toward
full implementation of its intent. The Commission’s recommendations
encourage accountability and merit considerations within the vocational
rehabilitation process. Establishing specific guidelines that can be
understood and implemented on a consistent and fair basis while respecting
client choice will take time. BSBP will report further on this in the
future.
3. Establishing training in specific job skills leading to employment,
as set forth in Section II.
BSBP Response: BSBP clients have unique needs to learn “skills of
blindness” such as orientation and mobility, and functioning independently
without sight. BSBP will take this recommendation under advisement and
consider options for specific job skills training. Also, BSBP provides
additional comments with regard to training later in this document.
4. Establishing reliable outcomes measures that include consideration
of cost/benefit, as set forth in Section III.
BSBP Response: BSBP responds in detail to Section III later in this
document. However, BSBP hereby acknowledges that cost/benefit
relationships must be considered along with measurable outcomes for
vocational rehabilitation clients.
State Policies. The Commission recommends:
1. Increasing the age to be categorized as “Homemaker” to at least
66, the current age for Social Security benefits, and preferably to 75,
thus allowing the limited “Older Blind” benefits to accrue to those who
are truly older, as set forth in Section VII.
BSBP Response: The recommendation suggesting that the age limit for
Homemakers be changed to 66 and preferably 75 would have an adverse effect
on vocational rehabilitation outcomes and the hourly wage paid to
competitive closures. The large number of Homemakers decreases the return
on the investment relating to competitive closures.
2. Promoting early blind skills training and training to maximize
independence in school age children, as set forth in Section VII.
BSBP Response: BSBP begins working with youth at age 14. The coordination
of services between the school system and the Bureau is to assist in
helping students obtain the appropriate training and resources needed to
acquire the skills of blindness in order to compete with sighted peers.
Blind children who are not age appropriate for VR services can and should
be participating in programs that are supported by IDEA (Individuals with
Disabilities Education Act) as well as LIO (Low incidence Outreach) program.
3. Identifying a funding source for services to seniors who are blind
and visually impaired. As set forth in Section VII.
BSBP Response: Currently, the older blind grant is provided to States based
on the population. There are suggestions by seniors to increase funding for
senior services which would include the Older Blind program. The Bureau
collaborates with a variety of agencies to expand services to this
population; such as, the Area Agency on Aging and the Office of Services to
the Aging, along with American Association of Retired Persons (AARP).
4. Meeting ADA requirements in all state buildings and websites, as
set forth in Sections I and VII.
BSBP Response: BSBP has been involved on a voluntary basis for the past
year in assisting the State’s ADA (American’s with Disabilities Act)
Coordinator to review signage, accessibility and website compliance.
Several BSBP staff have dedicated time and energy to this process. Since
the ADA Coordinator is responsible for managing this process, it would be
best to address these issues with that office. However, BSBP has been
fully cooperative and supportive of these efforts.
The Governor’s Charges to the Commission:
Observations and Recommendations
I. Study and review the needs of the blind community in Michigan.
A. Numbers of Legally Blind:
Commendation:
The BSBP reported serving 4,136 clients in 2013.
Observation 1
The following numbers were reported to the Commission, totaling 4,136: 1851
VR, 561 Closed VR, plus 702 Youth LV and 1022 IL; however, the 2013 Review
Report lists 1687 VR and 561 “applicants”.
Recommendation 1
BSBP record clients and coordinate records such that the numbers are
consistent in all reports.
BSBP Response: BSBP agrees that data should be as consistent as possible,
although, in order to explain discrepancies in data, the data reporting
resources must be considered.
Observation 2
There remains a large and varied population of blind and visually impaired
residents in MI who are unserved.
a. In 2012, 203,826 MI residents answered “yes” to the Census Bureau
American Community Survey’s question “Are you blind or do you have
serious difficulty seeing even when wearing your glasses?”
b. If a very conservative estimate of only 20% of the “yes”
responders age 14 and over were legally blind, that would be 38,671
persons. BSBP served 10.7% of that number.
Recommendation 2
BSBP take steps to increase the number served by:
a. Expanding outreach and reporting back to referrers.
b. Increasing efficiencies.
c. Restructuring programs for increased accessibility.
d. Initiating cost-saving policies.
The Commission’s recommendations for strategies to accomplish these are
set forth in Section III.
BSBP Response: The Census data does not take into consideration the
numbers of people already served and successfully employed and individuals
who wish not to receive services. According to the U.S. Census Bureau, 2012
American Community Survey, ages from 18-64, Michigan had 106,017 with a
visual disability this includes legal blindness and is 1.7% of the total
population of Michigan. (a). One of the priorities and performance measures
for staff is to conduct monthly outreach activities with employers, CRP’s
(Community Rehabilitation Programs), job fairs, community fairs, and senior
centers. One of the State Plan objectives outlines the need to monitor and
increase services to minority males and other underserved populations. WIOA
(Workforce Innovation and Opportunity Act) will require more in-depth
partnerships. (b. and c.) BSBP’s programs are accessible and collaboration
with a variety of community agencies and organizations demonstrates the
accessibility of BSBP’s programs. BSBP also provides extensive services
in the home environment both vocational and instructional. (d). BSBP
employs an effective process to monitor spending practices in order to
serve its consumers.
B. Needs of Legally Blind Community
Commendation:
The BSBP is committed to addressing the specific needs of blind clients.
Needs of the Blind Community: Observation 1
Individuals who are legally or totally blind need hope that their lives can
continue to be full, joyful and productive.
Needs of the Blind Community: Recommendation 1
BSBP can and should be the voice of hope. This requires:
a. Creating a culture in which an enthusiastic, creative staff feels
encouraged and supported in their work by equally creative and enthusiastic
supervisors.
b. Establishing protocols for prompt, enthusiastic and attentive
response to inquiries.
c. Bringing State websites and buildings into compliance with ADA
regulations.
d. Making the BSBP website not only accessible but a vibrant source of
practical information and examples of success that can inspire and empower.
e. Providing communications in a format that established clients can
access, Example: sending electronic letters to established clients known to
be totally blind rather than large print hard copies which are inaccessible
to them, requiring others to read it to them and thus promoting a culture
of dependence.
f. Involving consumers more directly, including, e.g. redesigning the
Vocational Rehabilitation Individual Plan for Employment (VRIPE) to
prioritize active consumer input and accountability.
g. Enhancing outreach.
The Commission’s recommendations to accomplish this are set forth in
Sections II and III.
BSBP Response: The services BSBP provide enable individuals to learn
skills of independence, obtain training, education and employment. The
acquisition of skills and abilities coupled with the ability to feel
included in one’s community because clients are able to live and work with
their sighted peers creates an environment of hope. This commitment to a
person-centered approach keeps consumers in the forefront and their needs
always a priority.
Needs of the Blind Community: Observation 2
Individuals who are legally or totally blind need encouragement to master
the skills that empower them to be active, productive members of society.
Needs of the Blind Community: Recommendation 2
BSBP can and should be the source of encouragement toward achievable goals.
This requires:
a. Creating a culture in which an enthusiastic, creative staff feels
encouraged and supported in their own work by equally creative and
enthusiastic supervisors.
b. Developing a systematic assessment protocol to identify the
individual’s skills, psychosocial status, personal needs and career
interests and goals, all of which vary depending on:
(1) Age.
(2) Time in life of vision loss.
(3) Stable or progressive nature of loss.
(4) Degree and pattern of loss: legally blind by virtue of visual acuity
vs by virtue of visual field loss are very different and require different
rehabilitation strategies.
(5) Residual usable vision with a focus on “blind” rehab, the
assessment, documentation and use of usable residual vision may be
underemphasized.
(6) Awareness of and fluency with compensatory techniques.
(7) Educational and vocational goals.
(8) Educational status.
(9) Previous experience and current skills.
(10) Psychosocial, physical, intellectual and cognitive factors.
(11) Location and access to an environment that supports independence,
through transportation and/or walkability.
c. Employing the results of the assessment to create a profile of strengths
and linking this to specific training objectives and outcomes.
The Commission’s recommendations of strategies to accomplish this are set
forth in Sections II and III.
BSBP Response: Bureau staff is committed to a person first philosophy,
which promotes success and encourages achievement of goals. It is the
responsibility of the Bureau and of the consumers to engage in productive
learning that will establish a foundation that can be built upon and BSBP
staff provides training and learning opportunities to instill this concept.
BSBP staff often assists consumers that come to the Bureau who have no idea
when or how he/she will re-enter the labor market. When those services and
experiences participating in the process results in achieving employment
and continuing their life it is a huge testament to the work the Bureau
does every day.
Needs of the Blind Community: Observation 3
Individuals who are legally or totally blind need individualized, goal-
oriented, accessible, state-of-the art training in both living skills and
vocational skills to empower them to be productive, full participants in
society. The 70% unemployment rate for individuals who are blind is
unacceptable.
a. Technology has become a functional equalizer for individuals who are
blind or visually impaired, who must master it to interact fully in the
greater society.
b. Mastering living skills is necessary but does not equate to vocational
preparedness, which is equally necessary.
c. Clients need more than case management locally; they need training and
many cannot be away from home for extended periods and/or cannot train
fulltime and therefore cannot access Visually Handicapped Services or the
Training Center.
d. BSBP staff includes many counselors, who act, by their own description,
as case managers, but there are few staff to actually train clients in
essential skills, and those staff tend to be concentrated at the Training
Center.
e. The local job market and employment trends need to figure significantly
into vocational decisions and training needs.
f. Clients need training in job skills that are marketable.
Needs of the Blind Community: Recommendation 3
BSBP can and should be the provider of state-of-the-art training that
empowers individuals in the blind community to become productive, full
participants in society. This requires:
a. Developing a culture of acceptance and expansion of its use of
technology, including providing the range of current technology and
training, beyond computers.
b. Differentiating living skills from vocational preparedness and
training for both.
c. Providing consistent, comprehensive assessments and skill training
locally.
d. Reconsider staff positions to include training capability locally.
e. Creating a protocol for staying up-to-date with respect to the local
job market and trends. This may be best accomplished centrally, with
experts dedicated to amassing this information and providing it to staff.
f. Becoming actively engaged in developing training programs for specific
job categories to maximize job placement, e.g. certification programs and
associate degree programs.
(1) This could be undertaken at the Training Center (TC) and also in
collaboration with Michigan Career and Technical Institute (MCTI), which
appears to have mastered this strategy.
(2) This would apply in large part to Transition clients, who currently
make up approximately 30% of BSBP clients.
The Commission’s recommendations to accomplish this are set forth in
Sections II and III.
BSBP Response: BSBP can and should provide state of the art training.
BSBP demonstrates this by promoting and encouraging higher education and
vocational training for consumers. The Bureau is dedicated to assisting
consumers in obtaining that training. It is also necessary that BSBP staff
diligently participate in professional development that provides them the
opportunity to cultivate and/or determine the training needed to achieve
excellence.
Needs of the Blind Community: Observation 4
Market analysis and job development are essential pieces in gaining
employment for individuals who are legally blind and these functions are
beyond the scope of each individual counselor.
Needs of the Blind Community: Recommendation 4
The state create positions for experts to:
a. Monitor market trends for each local area, region, statewide and
nationally and provide this continuously updated information to counselors,
to the Business Assistance and Development Program and the Training Center.
b. Undertake serious job development by seeking employment
opportunities throughout the state, starting with:
(1) With Michigan companies receiving federal contracts that require them
to include 7% disabled among their workforce.
(2) National and statewide companies demonstrating the desire to hire
workers with disabilities, e.g. Meijers, Inc.
c. Develop “brokerage-facilitator” relationships regionally with
employers using recruitment and retention strategies to establish job
opportunities, facilitate placement and promote success. This entails:
(1) Breaking down barriers to employment, including misconceptions around
blindness.
(2) Identifying and providing accommodations.
(3) Identifying incentives for employers to hire the blind and visually
impaired.
BSBP Response: BSBP is finalizing its review of addressing the necessity
of expert positions for counselors and teachers within its organizational
structure. BSBP will explore the possibility of creating “lead worker”
positions for counselors and teachers to enhance and improve the status of
these important positions while developing expertize in each area.
Needs of the Blind Community: Observation 5
Individuals who are blind and visually impaired need transportation to
their place of employment and to community institutions and businesses, as
few are able to drive.
a. Michigan has limited public transportation and community
transportation systems for the elderly and disabled.
b. The hours and range of services are limited and coordination
between systems is inconsistent.
Needs of the Blind Community: Recommendation 5
The state fund a mandate that communities provide transportation to legally
blind residents to their necessary destinations or coordinate their
services with those in neighboring communities to achieve this.
BSBP Response: BSBP sees value in and supports community transportation
services for the legally blind, but is unable to mandate it. BSBP does not
initiate or advocate legislative action, as this recommendation appears to
require. It is LARA’s prerogative to recommend legislation to the Governor.
II. Advise LARA concerning the coordination and administration of state
programs serving the blind community
A. Coordination of Programs
Commendations: The BSBP is working to increase coordination and
communication among its programs. The Training Center makes comprehensive
client progress reports available to referring staff.
Coordination of Programs: Observation 1
Coordination among the BSBP divisions is undermined structurally by:
a. Inaccessibility of computerized client data among all employees dealing
with that client.
b. Overlapping responsibilities, for example transportation arrangements to
the Training Center, resulting in conflicting directives from the referring
counselor and the Training Center.
c. Performance standards and evaluations based largely on number of
closures without regard to a cooperative system that also recognizes and
values assists with closures. This discourages sharing of resource
information that would benefit clients.
Coordination of Programs: Recommendation 1
Revise structures to facilitate coordination:
a. Assure that all computerized client data and reports are
accessible to all employees across divisions working with that client.
b. Delineate responsibilities to avoid overlap.
c. Revise performance standards to reflect a priority on communication and
collaboration in the interest of all clients.
d. Redesign the Vocational Rehabilitation Individual Plan for Employment
(VRIPE) to become a more dynamic, “real-time” electronic tool that
follows clients across divisions and contains.
(1) Relevant assessment data.
(2) Consumer profile summary including job aspirations linked to market
realities.
(3) Specific actions taken by both the consumer and the BSBP toward
employment outcomes.
BSBP Response: BSBP is finalizing its review of coordinating facilities
and functions to better serve clients. BSBP’s future structure may need
change in order to achieve better coordination of services. The issue is
being finalized for recommendation to BSBP’s Director.
Coordination of Programs: Observation 2
Coordination is undermined by information feedback gaps between divisions,
within regions and between regions and contracted agencies, for example.
Visually Handicapped Services (VHS).
a. Client assessments do not accompany referrals from the regions to the
Training Center or to VHS.
b. Final outcomes information is not provided by the regions to the
Training Center or VHS and thus they cannot assess the full impact of its
services.
c. There is inconsistent communication between staff members working with
the same client, for example Vocational Rehabilitation Counselors and
Employment Specialists.
Coordination of Programs: Recommendation 2
a. Require full client information, including assessments, to accompany
referrals to the Training Center and Visually Handicapped Services.
b. Require final client outcome to be reported to the Training Center and
Visually Handicapped Services.
c. Require that BSBP staff working with the same client share and discuss
client information, assessments and progress and put in place a system to
facilitate this.
BSBP Response: Visually Handicapped Services (VHS) has been changed to
Visually Impaired Services (VIS). The Training Center and VIS are two
separate entities. Consumer information is confidential. (a) Assessment
materials are available as needed to the TC (Training Center) from BSBP’s
database. VIS receives referral information including relevant
assessments. (b) The TC has the ability to access the final outcome of all
consumers, as well as compile data annually and share with the staff. In
general, the Bureau’s nonspecific consumer data can be shared with VIS.
Coordination of Programs: Observation 3
Staff relations undermine coordination in some instances.
a. Resentment of Michigan Rehabilitation Services personnel
transferred to BSBP undermines coordination of services in the best
interest of clients.
b. Management-staff relations in some regions discourage the free and open
communication that is required to coordinate service.
Coordination of Programs: Recommendation 3
Leadership must address these staff-staff and management-staff issues and
model the desired behavior. The Commission has been informed that this
process has been launched with the 2014 staff retreat.
BSBP Response: BSBP held its first agency-wide in-service training/meeting
for all professional staff in Mt. Pleasant last July 8-10, 2014. This was
an opportunity for all BSBP staff to receive information and ask questions
directly from the Bureau’s leadership. Topics covered included Freedom of
Information Act requests for information, case management system, overview
of all bureau divisions by section, discussion on ways BSBP can better work
together, the Bureau Director’s vision for the future of BSBP, and
training on generational diversity. The next BSBP all staff in-service
training will be held in Mt. Pleasant in July 14-16, 2015. The agenda has
not yet been finalized. The BSBP Director regularly meets with all BSBP
management to keep managers and staff informed and engaged in BSBP’s
direction. The Director plans on holding an all staff meeting on April 6,
2015 to discuss the future direction of BSBP and how to improve the
services provided to Michigan’s blind community. BSBP management has also
been actively supporting the annual employee engagement survey to obtain
direct, anonymous feedback from staff on ways the Bureau can improve
communication and teamwork throughout the agency.
Coordination of Programs: Observation 4
The target population of the Business Assistance and Development Program
(BADP) and the Business Enterprise Program (BEP) appear to overlap, as both
place self-motivated clients in individual businesses.
Coordination of Programs: Recommendation 4
The unique activities of the BADP and its relationship and coordination
with the BEP and Vocational Rehabilitation require further delineation.
BSBP Response: The Business Enterprise Program (BEP) dates back to the
1930’s, established by federal and state legislation that reserves the
preference for licensed blind operators to run concession establishments in
property owned or occupied by State and Federal workers.
The Business Assistance and Development Program (BADP) was established in
2013 to assist BSBP vocational rehabilitation clients interested in
establishing their own businesses and providing training on how to run a
private business. The BADP is also responsible for establishing and
maintaining a training program for business entrepreneurs. The BADP is a
separate program from the BEP and is intended to meet the additional needs
of BSBP Vocational Rehabilitation clients.
B. Administration of Programs: Consumer Services (CS)
Commendation: BSBP is working to assure that programs are administered
effectively and that staff is empowered to work to their fullest capacity.
Administration, Consumer Services: Observation 1
It distresses the Commission to observe and report that a culture of mutual
respect, collaboration and teamwork, which would produce high staff morale
and ultimately high performance and best outcomes, is undermined by the
following:
a. Leadership at the department and regional levels is inconsistent,
ranging from engaged/supportive to unengaged/lax to engaged/punitive.
Expectations, supervision and support of staff vary widely.
b. Assessing performance by number of individually secured closures with
no corresponding system for recognizing assists with closures discourages
sharing of information and collaboration in the best interests of clients.
c. The contributions of professional staff are not always valued equally
nor are they paid equally.
(1) Some managers clearly value the work of Vocational Rehabilitation
Counselors
(VRC) higher than that of Rehabilitation Teachers (RT).
(2) No RT holds a leadership role; dept and regional mgrs are all VRCs.
(3) VRCs earn less than RTs.
(4) Employment specialists transferred from Michigan
Rehabilitation Services
(MRS) are resented on the assumption of insufficient
knowledge about blind
rehabilitation.
Administration, Consumer Services: Recommendation 1
To achieve a culture of mutual respect, collaboration and teamwork and
thereby improve staff morale, which ultimately results in best client
outcomes:
a. Place in leadership positions those who demonstrate organizational
vision and leadership capacity: energetic, competent, collaborative,
decisive, creative, fair-minded with a global perspective and steadfast
commitment to client service and outcomes.
b. Create a systematic protocol for assessing all staff performance,
including leadership, with clear guidelines that go beyond number of
closures to include rationales for decisions, collaboration and quality of
interactions and services.
(1) Including a 360-degree peer-peer and peer-leadership evaluation is
desirable but this requires a level of trust, respect and shared goals that
may render it unfeasible within BSBP at this time.
c. Include staff at every level in discussions of policy and procedures
that affect them.
d. Create a protocol for consistent communication among regional staff and
between regions to facilitate their contributing to the success of shared
clients.
e. Work toward eliminating the hierarchies between VRCs and RTs.
(1) Propose pay equity between RTs and VRCs.
(2) Create the position of RT Supervisor, who understands and values the
work of RTs and participates in their evaluation.
(3) Educate managers to value the contributions of all staff.
f. Work toward acceptance of MRS staff as equal partners by:
(1) Acknowledging their expertise and experience.
(2) Assisting them in understanding the unique needs of blind and visually
impaired clients.
BSBp Response: (a) BSBP, since its creation, has promoted or hired
qualified individuals for leadership positions based on job specifications
and civil services rules. (b) Civil Service and LARA have established
performance measures and plans on an annual basis to measure performance.
(c)(d) BSBP shares information with staff that affects their performance.
(e)(1)(2)(3) The teacher reclassification which resulted in higher pay
helped to improve the morale of teachers, however, a lower morale developed
amongst counselors who have similar responsibilities and are at a lower pay
scale. BSBP will explore the possibility of a more equal effort on IL
management. Rehabilitation Teachers are eligible to apply for management
positions within BSBP. BSBP managers participate in management training
that emphasizes the importance of staff input.
Administration, Consumer Services: Observation 2
A consistent culture of operating at peak performance by example,
empowerment, supervision and support is not apparent within BSBP and is
undermined by the following:
a. The lack of respect for and recognition of value of professional
certification.
b. Administration of continuing education appears to be uninformed and lax.
(1) The individual responsible for planning continuing education
volunteered
lack of awareness of the content of conferences offered to BSBP
staff.
(2) There is no apparent strategy to identify educational needs and
research ideal
conference offerings.
(3) Minimal participation is required; most is left to the individual staff
member.
(4) Benefit of and learning from educational offerings are not
systematically assessed.
(5) Educational needs of staff that are outside the usual offerings are not
systematically addressed, for example geriatrics in face of a large
population of senior blind and visually impaired.
c. Staff performance is not systemically assessed with clear guidelines,
thus allowing for wide variations, a sense of favoritism and a deficiency
of feedback that would promote self-improvement.
(1) Managers vary widely with respect to standards, timing and process.
(2) Human resources reported no review of client files for two years
although the stated goal was 7-8 files per staff per year.
d. Support beyond continuing education and supervision is insufficient to
empower staff to operate at peak performance.
(1) Assessment tools to appropriately evaluate the vocational skills and
interests of clients and their motivation and self-initiation are not
always provided, although this is essential information on which to begin
vocational planning.
(2) Essential technology, e.g. adaptive computers, is not always provided
to sighted staff, thus precluding them from demonstrating this essential
technology to clients.
(3) Client processing procedures are inefficient and inconsistent across
regions, placing an excessive burden on staff and decreasing their
efficiency.
(a) Professional staff in some regions is called upon to handle initial
client phone inquiries while in other regions the office staff assumes this
responsibility.
(b) Professional staff on occasion learns that the client is not eligible
for services only after they have completed an assessment in the client’s
home.
e. Each counselor is expected to have updated information on emerging
market trends
and existing job opportunities and individually perform job
development, which
the Commission finds unrealistic.
Administration, Consumer Services: Recommendation 2
To achieve a culture of operating at peak performance by example,
empowerment, supervision and support:
a. Place in leadership positions those who demonstrate vision and
leadership capacity: competent, collaborative, decisive, creative, fair-
minded with a global perspective.
b. Provide the support to upgrade and sustain staff knowledge and skills.
(1) Encourage professional staff to hold certification in their respective
specialties and offer increased pay for those who do.
(a) The benefit of this goes well beyond the initial testing as it requires
and sustains a culture of ongoing learning and updating of knowledge and
skills with continuing education that is essential to optimal performance.
(b) Private agencies for the blind require this, blind Rehabilitation
training programs encourage this and taxpayers deserve no less.
(2) Poll staff on an ongoing basis with respect to their continuing
education needs, as the unique needs of their various clients and the
resources available to them evolve and change.
(3) Explore the potential for collaboration with the following to provide
opportunities for pertinent continuing education for BSBP professional
staff, with learning criteria and exit assessments of knowledge gained.
(a) WMU Departments of Vocational Counseling, Rehabilitation Teaching, and
Occupational therapy.
(b) MSU Departments of rehabilitation counseling, psychology and geriatrics
(c) WSU Departments of psychology, geriatrics and occupational therapy.
(4) Take advantage of available training resources including the
Mississippi State National Resource Training Center whose website.
provides, for example, recent conference proceedings on employment outcomes
(5) Create and adhere to continuing education requirements for all staff.
c. Provide sufficient support beyond continuing education to empower staff
to perform optimally.
(1) Provide assessments of vocational skills, interests, motivation and
ability for all new clients with vocational aspirations.
(a) Designate and train one staff member in each region to be responsible
for all assessments.
(b) Contract out for assessments.
(2) Provide magnification and text to speech computer software including
Jaws and ZoomText, e-readers, smartphones, handheld CCTV and computer/TV
plug-in CCTV (e.g. Max) to all professional staff regardless of their
visual status and train them in their use, as these are essential tools in
the demonstration “toolkit”.
(3) Assign support staff the responsibility of processing new clients to
the point of establishing eligibility before referral to professional
staff. Support staff responsibilities should include:
(a) Handling phone inquiries, explaining services, stating eligibility
requirements and sending requisite forms by mail or email.
(b) Receiving completed forms and assessing eligibility.
(c) Informing clients of eligibility (or not) and referring eligible
clients to professional staff.
(4) Provide counselors with ongoing updated information about market
trends and
job opportunities locally, regionally and statewide. See also
Sections III and
VII.
BSBP Response: (a) BSBP continues to provide leaders with the appropriate
training for them to gain the qualities that are necessary for leading an
organization. (b)(1) BSBP makes available to all staff the opportunity to
grow in their profession with both in-state and out of state training
opportunities, as well as trainings provided directly by BSBP. (2) BSBP
continues to evaluate the needs of staff in order to make available
appropriate training. (3) BSBP staff continues to collaborate and support
the professional development. (c) The Vocational Rehabilitation process
requires that consumers are evaluated to determine capabilities in order to
develop appropriate plans for achievement. This practice may utilize
various methods to reach the outcome, such as internal and external
assessments obtained by staff. (2) Qualified BSBP staff have the necessary
tools to demonstrate technology and all staff have the opportunity to use
such equipment. (3) BSBP is reviewing its intake process. RSA requires
that eligibility is determined by a vocational rehabilitation counselor.
(4) BSBP provides updated information to staff statewide. Staff is
encouraged to work closely with their local Michigan Works! and One Stops
to obtain pertinent employment information for the clients we serve.
Administration, Consumer Services: Observation 3
The following undermines a culture of fiduciary responsibility to taxpayers
while maintaining the best interests of clients:
a. The apparent absence of guidelines for:
(1) Correlating expenditures with expected outcome, which allows for
inconsistency across regions and expenditure of funds with inadequate
consideration of beneficial outcome.
(2) A timeframe in which progress toward a goal might be expected, which
allows for repetitive identical services over many years in which the
client experiences repetitive failure before re-evaluating the goal.
Example: Client graduated from high school at age 26 and after four and a
half years and $66,199.34 spent on the goal of competitive employment
including contracted repetitive job coaching and coached internships, it
was concluded that she requires supportive employment.
b. A re-interpretation of “informed choice” appears to exist such
that in practice it means “free choice”. This allows for expenditures
with minimal consideration of client potential, market forces or outcomes
that can be reasonably expected and produces an experience of failure for
the client.
Example: Client with technical associate’s degree and prognosis of total
vision loss sent for a second associate’s degree initially in interior
design, then universal design. After completion of the second degree and
$21,844.91 of BSBP funds invested, client was unable to find employment, as
no jobs in that field were available. Client was then sent out of state for
Lions IRS training, whose intake report notes that client was apprehensive
because of past failure in obtaining a job after completing a vocational
program elsewhere.
c. The absence of any financial contribution of the client to their
own rehabilitation, however minimal, which may serve to undermine their
investment in the process.
Administration, Consumer Services: Recommendation 3
To achieve a culture of fiduciary responsibility to taxpayers while
maintaining the best interests of clients:
a. Create clear guidelines for expenditures for educational and vocational
preparation programs with respect to potential for beneficial outcome.
(1) Require clients and staff to jointly assess college programs with
respect to the job market and to the client’s potential to gain permanent
employment in that field.
(a) Client choice should prevail in most cases but such choices need to be
made with the realization that with choice comes responsibility for
resource utilization and outcomes.
(b) A suitable plan and contingencies should be documented before approving
expenditures.
(2) Require staff to direct prospective vocational program students as is
currently done for college bound students to:
(a) Apply for financial aid. The institution, not BSBP, therefore does the
financial assessment and report residual need.
(The Commission was informed that creating a system for clients to
contribute financially to the cost of their own training would require
additional BSBP staff).
(b) Consider and declare what can contribute toward their expenses, however
minimal. The Commission recognizes that this may not be possible within the
vocational rehabilitation rules.
(3) Require staff to track the client’s progress toward a goal and to
encourage the client to reconsider the goal when no progress is achieved in
a reasonable time period.
(4) Require or at least request that clients consider and declare what
they can afford to contribute, however minimal, to the devices and services
provided. The Commission recognizes that this may not be possible within
the vocational rehabilitation rules but believes it would be a productive
step for both the client and the BSBP.
(5) Base device dispensing on the results of a low vision evaluation
wherever
available, to assure that the devices are useful in accomplishing the
client’s desired tasks and therefore cost-effective.
(6) Submit to rigorous outcomes study by a reputable external party to
establish whether expenditures result in desired outcomes.
b. Require that ODs and MDs who do low vision evaluations bill Medicare
and/or Medicaid for their services rather than charging BSBP for the
examination. Medicare and Medicaid reimburse for low vision evaluations, so
no cost for a low vision exam should accrue to BSBP for IL clients over 65
and for those of any age with Medicare or Medicaid.
c. Refrain from referring clients to a preferred provider for a BSBP-
funded low vision evaluation when another provider has already submitted a
current low vision evaluation.
Example: clients in East Region have on occasion been referred to a
specific optometrist for a low vision evaluation in spite of the client
already having a current low vision evaluation on record.
BSBP Response: (a) (1) (a) (b) BSBP policies and procedures outline the
guidelines for secondary education, vocational training etc. Clients and
staff work together in developing appropriate plans for employment as it
relates to an informed choice by the client. (2 - 5) BSBP will continue to
evaluate family and consumer ability to contribute. (3). BSBP performs
annual reviews and managers evaluate cases, at a minimum, quarterly.
(5)(b)(c). BSBP must utilize comparable benefits first. BSBP does negotiate
lesser cost with vendors when possible. (6) BSBP is audited by the state
and federal government regarding utilization of funds and appropriateness
of services. (b) BSBP must utilize comparable benefits first and the staff
of BSBP informs consumers of various providers, allowing them to make
informed choices. (c) BSBP agrees that one low vision assessment is
appropriate to provide low vision devices unless there is a significant
change in vision, however, a review should be conducted bi-annually.
C. Administration of Programs: Training Center
Commendation:
The Training Center leadership is enthusiastic and committed to promoting
the best interests of its clients.
Administration, Training Center (TC): Observation
The TC has been essentially unchanged for decades and appears to focus on
independent living skills as goals in themselves rather than as preparation
for employment. No new vision has been articulated.
Administration, Training Center (TC): Recommendation
The Director of the TC is called upon to develop a grand vision to make
this unique resource a cost effective national model for:
a. Prevocational training.
b. Training in selected specific vocations, with independent living as an
essential part
c. Modeling and requiring professional behavior that is expected of
employed individuals.
This requires rethinking goals, strategies, personnel, equipment and
logistics geared to the 21st century as well as the current vocational
scene.
See also Section III-C for programmatic recommendations.
BSBP Response: The Training Center (TC) historically has focused on the
development of independent living skills but recognizes that the mission of
BSBP is to assist individuals in becoming employed. BSBP believes that
training individuals to be as efficient as possible in all areas of
personal adjustment in combination with incorporating cutting edge
technology and vocational exploration awareness and training will result in
consumers being more employable. The opportunity for Training Center staff
to provide and teach employability skills and adaptive computer skills will
lessen the need for outsourcing of these services. Providing onsite work
experiences will also lessen the need to purchase those services from
outside vendors. The staff at the Training Center is professional, educated
and have numerous skills that will allow the Training Center to, in some
sense, be compared to a one-stop concept. It is the vision of the Training
Center Director, consistent with the BSBP’s Executive Director’s goal,
that the TC should be a resource for staff. Currently the Training Center
has launched a 10 week module driven adaptive computer and technology
training program that is likened to a freshman college computer class with
the adaptive technology caveat. This prepares consumers to participate in
additional training and employment opportunities and allows them to compete
with sighted peers. The implementation of an iOS Apple product operating
program will allow students to utilize smart phone technology to again
compete with sighted peers in their personal lives as well as vocationally.
A holistic approach to rehabilitation will ultimately result in well
trained competitive blind individuals. A handbook is being designed in
cooperation with TC staff, Bureau staff and will also incorporate consumer
insight that clearly defines responsibilities and expectations of consumers
and staff. This is a document that will be available and used as a guide
to the training center experience when completed. This is a work in
progress and further emphasizes the commitment to being a transparent
program.
D. Administration: Business Enterprise Program (BEP)
Commendations:
The working relationship between the BEP administration and the Elected
Operators Committee (EOC) has reportedly improved.
Administration, Business Enterprise Program: Observation 1
The Promotional Agents spend a disproportionate time on paperwork and
soliciting price quotes, thus undermining their ability to actually assess
and assist operators.
Business Enterprise Program: Recommendation 1
Improve efficiency and effectiveness of Promotional Agents by:
a. Assign to the central office staff the responsibility of soliciting
three price quotes, selecting the vendor, and purchasing the equipment that
the PA’s request for their operators.
b. Streamlining PA documentation.
c. Considering the optimal ratio of PAs to Operators, as the current ratio
of 1:15-22 “just evolved”. In franchises the ratio is approximately 1:6.
BSBP Response: Each BEP facility is unique in its requirements, space
restrictions and specific equipment needs. Promotional Agents are required
under promulgated rules to evaluate facilities, determine needs, and assign
appropriate equipment. Promotional Agents are in the position of
understanding and coordinating all relevant information required for
purchasing. Time spent relaying this information would equal time spent
soliciting quotes under current procedures. Additionally by allowing quotes
to be directly reviewed by Promotional Agents insures that equipment meets
all specifications and requirements of the facility prior to purchase.
Business Enterprise Program: Observation 2
The administrative structure that casts the Promotional Agents in multiple
roles as advisor, facilitator and enforcer, though with negligible
authority, promotes an adversarial relationship between the operators and
the Promotional Agents.
Business Enterprise Program: Recommendation 2
The role of the Promotional Agents is re-examined to promote mutually
agreeable and successful relationships between them and the operators.
BSBP Response: Promotional Agents are required to complete 4 forms on the
BEP database; Facility evaluations are conducted annually; site visits
every six weeks; phone calls and case note forms only as needed. All other
documentation required by Promotional Agents is consistent with state
requirements for all positions. The evaluative process is designed to
ensure that licensed operators are providing quality products and services
in a clean and inviting environment as required by promulgated Rules.
Business Enterprise Program: Observation 3
Some operators are unsuccessful in spite of completing the training course,
passing the test and having the support of a promotional agent.
Business Enterprise Program (BEP): Recommendation 3
The selection of BEP candidates, the training and the testing should be re-
evaluated to more accurately identify those who are motivated and capable
of success.
BSBP Response: BSBP fully supports this recommendation and has already
implemented this strategy. Client referrals to the BEP program come
directly from the Vocational Rehabilitation Counselors and Managers. The
BEP Section has been working directly with the VR Counselors and Managers
to promote the job opportunities available within the BEP for VR Clients.
In addition to promoting the BEP as a job opportunity, the BEP staff
emphasize the nature of the responsibilities and skills required for the
client to become a successful BEP licensed operator. Assessments and
training for clients referred to the BEP are now conducted at the Kalamazoo
Training Center. The training is lengthy, challenging and is conducted
both in a classroom as well as on-the-job field experience. Candidates for
BEP must meet all requirements and pass required tests in order to become
licensed operators. All of this pre-license training is intended to
produce successful quality licensed operators for the program. Once
licensed, the BEP licensed operator continues to be monitored and evaluated
to achieve a successful business.
Business Enterprise Program (BEP): Observation 4
The administration of the BEP remained in spite of a negative audit report,
which would appear to undermine quality control and inspiration for other
leaders to perform optimally.
Business Enterprise Program: Recommendation 4
Administrators are held accountable for the performance of their
departments, as they would be in any private business.
See also Section III-D for programmatic recommendations.
BSBP Response: BSBP supports and has already implemented this
recommendation. The Administrator’s performance is evaluated every year.
In addition, administrators with their managers continuously work together
to resolve issues and implement changes necessary to improve performance.
Several changes in performance management of BEP staff have been
implemented in the past year that include: updates with data system that
allows on demand monitoring of the quality and quantity of site reviews; bi-
monthly follow-up on any missing site visits. BEP Administration has put
in place monitoring and follow-up of operator reporting requirements
(validation of income, sales tax and inventory). In addition, new
equipment will include electronics that will provide detailed sales
information from cash registers and vending.
E. Administration: Business Assistance and Development Program (BADP)
Business Assistance and Development Program (BADP): Observation 1
Ironically, while one of the roles of the BADP is to review business plans,
the BADP itself was created and is being staffed without a clear business
plan beyond several paragraphs generally describing its goals.
Business Assistance and Development Program (BADP): Recommendation 1
The BADP clearly outline at least three and five year plans.
See also Section III-E for programmatic recommendations.
BSBP Response: BSBP observes that BADP programmatic recommendations were
made by the Advisory Commission at Section III. F. of the report (page 30).
BSBP will evaluate the Advisory Commission’s comments and provide an
updated action plan.
III. Recommend to LARA changes in state programs, statutes and policies
that affect the blind community.
A. Changes in State Programs: Vocational Rehabilitation
Changes in Program, Vocational Rehabilitation: Observation 1
Some procedures are inconsistent and inefficient.
a. There is no standard protocol followed for assessing new clients.
b. The procedure for re-opening recently closed cases is redundant.
Clients who report stable vision and health or who have end-stage vision
loss are required to undergo medical and ophthalmic examinations and file
new reports, even within a relatively short time since closure.
Example: Adult client totally blind in one eye and with near total
blindness in the other was required to submit a new eye report when
requesting further computer training one year after closure, although her
vision loss was permanent and not improvable.
c. The ophthalmic report form is unnecessarily long, with information
unusable to BSBP, for example eye pressure and retinal findings.
d. There is no standard protocol followed for processing new callers and
establishing eligibility. In some regions the secretary handles initial
contact, in others the VRC is assigned immediately and may even go to the
clients’ home only to discover the client is ineligible.
Changes in Program, Vocational Rehabilitation: Recommendation 1
Increase efficiencies.
a. Institute standard assessment protocol procedures as set forth in
IIB-2c.
b. Re-open cases within a three year period without requiring medical and
ophthalmic re-examination for clients who have experienced no changes in
health or vision and whose ophthalmic condition is not improvable. Do not
require any repeat ophthalmic examinations for clients known to be totally
blind.
c. Streamline medical and ophthalmic examination forms.
(1) Create a single-page form with only relevant information.
(a) Visual acuity and/or visual field.
(b) Diagnosis and prognosis.
(2) Offer an electronic option.
d. Designate the office staff to receive all inquiries, process required
paperwork and
confirm eligibility by visual criteria before referring to a Vocational
Rehabilitation
Counselor or Rehabilitation Teacher.
BSBP Response: BSBP has an established assessment process. BSBP accepts
the recommendation with the understanding that for specific programs
current medical documentation may be required. BSBP will investigate the
feasibility of developing a new eye and medical examination form. BSBP will
review and unify an intake process. Currently, each office has established
an intake process to collect the necessary documents. RSA requires that
eligibility is determined by a vocational rehabilitation counselor.
Changes in Program, Vocational Rehabilitation: Observation 2
Local and regional services are insufficient to meet the need and those
that exist are not maximally efficient.
Changes in Program, Vocational Rehabilitation: Recommendation 2
Increase and reorganize local and regional services.
a. Optimize the resources of Visually Handicapped Services (VHS), the
agency contracted and fully funded by BSBP in Detroit.
(1) Require VHS to reorganize and streamline its services to address
individual needs rather than present a standard curriculum.
a. Provide Orientation and Mobility (O & M) separate from other skill
development.
b. Provide adaptive computer training separate from other skill training.
c. Provide Braille separate from other skill training.
(2) Require VHS to reorganize its services to allow variable days and time
frames to fill each hour rather than providing only 9-week whole-day blocks
of time and assist them in this process.
(3) Establish guidelines for referrals to VHS.
(4) Provide VHS with full client information, including assessments and
goals.
b. Provide onsite job assessments and interventions for job jeopardy
clients and for all employed clients as first line rather than sending all
to the Training Center. This can be accomplished by contracting with
Occupational therapists, to do onsite job assessments, as Michigan
Rehabilitation Services does.
c. Provide local assessments of aptitudes and skills relevant to
employment.
d. Provide Orientation and Mobility (O & M) training in each region by an
O& M who will travel to clients specifically for that training. This can
certainly be done in metropolitan areas by:
(1) Employing an O & M in each region.
(2) Contracting O & M services.
Either of these would be much less expensive than a Training Center stay
for O & M training and more relevant to the client’s area.
e. Provide training in adaptive computers and other common technology
(iPad, iPhone) locally and independent of other training as appropriate,
without having to refer to the TC or VHS. This can be accomplished by:
(1) Equipping and training current staff.
(2) Using the existing technology services of the Libraries for the Blind.
(3) Employing a technology expert in each region.
f. Collaborate with community colleges, regional business centers,
conference centers and community centers to develop no-cost or low-cost
sites for local services as well as partnerships for employment.
BSBP Response: (a) Visually Impaired Services (VIS) is not fully funded by
BSBP. The programming is individualized to maximize the efficiency of
services. BSBP staff will continue to work with VIS to ensure quality
training is provided to consumers. VIS services are predicated on the
individual’s need which may vary depending on one’s ability to
participate. BSBP utilizes its referral process that all parties are in
agreement with including appropriate client information, assessments and
goals.
(b) (c) BSBP utilizes professionals trained in the field of blindness to
perform onsite job assessments and interventions. If necessary, BSBP will
authorize outside vendors to perform assistive technology assessments and
training at the worksite. BSBP is currently assessing a variety of
assessment tools to be utilized in the field. (d) BSBP is reviewing the
Advisory Commission recommendations of d (1) as well as d (2). (e) BSBP
will continue to utilize all resources available to them including the
Training Center, Library, VIS and field staff. BSBP will study employing a
technology expert. BSBP does partner with all of the above and will
continue to expand to include more partners in the future.
Changes in Program, Vocational Rehabilitation: Observation 3
Potential employers are discouraged from hiring blind and visually impaired
candidates when they are responsible for installing necessary equipment and
facilitating accommodations without facilitation.
Example: Client who completed skills training and resume building gained a
second interview, but when the employer realized that accommodations would
be necessary and would be the company’s responsibility, the job was not
offered.
Changes in Program, Vocational Rehabilitation: Recommendation 3
Extend vocational rehabilitation services to include communicating with the
potential employer to facilitate the accommodations, thus removing that
responsibility from the employer and promoting the hiring of the visually
impaired candidate: This would include, for example:
a. Installing the job-site accommodations.
b. Introducing the new employee to the building.
c. Supporting the employer and client with consultation and
partnership until the working arrangement is stabilized.
BSBP Response: Following the new federal requirements of Workforce
Innovation and Opportunity Act (WIOA), changes are being made that will
provide wraparound services to the employer in partnership with BSBP staff.
Changes in Program, Vocational Rehabilitation: Observation 4
Outcomes must inform service design and implementation, yet no systematic
outcomes measures are in place beyond number of closures and an unreliable
consumer survey.
Changes in Program, Vocational Rehabilitation: Recommendation 4
BSBP develop reliable outcomes measures that are tracked, recorded and used
as guides for assuring optimal program design and delivery of services.
BSBP Response: Since vocational rehabilitation services are predominantly
federally funded, BSBP adheres to the federal RSA (Rehabilitation Services
Administration’s) extensive data reporting requirements.
Changes in Program, Vocational Rehabilitation: Observation 5
(Also under Consumer Services, Administration 3)
The following undermines a culture of fiduciary responsibility to taxpayers
while maintaining the best interests of clients:
a. The apparent absence of guidelines for:
(1) Correlating expenditures with expected outcome, which allows for
inconsistency across regions and expenditure of funds with inadequate
consideration of beneficial outcome.
(2) Tracking and monitoring counselor spending per client.
(3) A timeframe in which progress toward a goal might be expected, which
allows for repetitive identical services over many years in which the
client experiences repetitive failure before re-evaluating the goal.
Example: Client graduated from high school at age 26 and after four and a
half years and $66,199.34 spent on the goal of competitive employment
including contracted repetitive job coaching and coached internships, it
was concluded that she requires supportive employment.
b. A re-interpretation of “informed choice” appears to exist such that
in practice it means “free choice”. This allows for expenditures with
minimal consideration of client potential, market forces or outcomes that
can be reasonably expected and produces an experience of failure for the
client.
Example: Client with technical associate’s degree and prognosis of total
vision sent for a second associate’s degree initially in interior design,
then universal design. After completion of the second degree and $21,844.91
of BSBP funds invested, client was unable to find employment, as no jobs in
that field were available. Client was then sent out of state for Lions IRS
training, whose intake notes that client was apprehensive because of past
failure in obtaining a job after completing a vocational program elsewhere.
c. The absence of any financial contribution of the client to their own
rehabilitation,
however minimal, which may serve to undermine their investment in the
process.
Changes in Program, Vocational Rehabilitation: Recommendation 5
To achieve a culture of fiduciary responsibility to taxpayers while
maintaining the best interests of clients:
a. Create clear guidelines for expenditures for educational and vocational
preparation programs with respect to potential for beneficial outcome.
(1) Require clients and staff to jointly assess college programs with
respect to the job market and to the client’s potential to gain permanent
employment in that field.
(a) Client choice should prevail in most cases but such choices need to be
made with the realization that with choice comes responsibility for
resource utilization and outcomes.
(b) A suitable plan and contingencies should be documented before approving
expenditures.
(2) Require that staff direct prospective college/vocational program
students to:
(a) Apply for financial aid. The college, not BSBP, will therefore do the
financial assessment and report residual need.
(b) Consider and declare what they can contribute toward their expenses,
however minimal. The Commission recognizes that this may not be possible
within the vocational rehabilitation rules but believes it would be
beneficial to both clients and BSBP.
(3) Require that staff track the client’s progress toward a goal and to
encourage the client to reconsider the goal when no progress is achieved in
a reasonable time period.
(4) Require or at least request that clients consider and declare what
they can afford to contribute, however minimal, to the devices and services
provided. The Commission recognizes that this may not be possible within
the vocational rehabilitation rules but believes it would be a productive
step for both the client and the BSBP.
(5) Base device dispensing on the results of a low vision evaluation
wherever available, to assure the usefulness and cost-effectiveness of
devices provided.
b. Negotiate volume pricing with manufacturers/distributors for low
vision devices.
c. Require that ODs and MDs who do low vision evaluations bill
Medicare and/or Medicaid for their services rather than charging BSBP for
the examination. Medicare and Medicaid reimburse for low vision
evaluations, so no cost for a low vision exam should accrue to BSBP for IL
clients over 65 and for those of any age with Medicare or Medicaid.
BSBP Response: (a). BSBP will continue to cooperate with RSA in receiving
further instructions for the implementation of WIOA, with the expectation
of preparing transition youth continuing to be a priority. (1)(a)(b). BSBP
continues to do outreach with community colleges, vocational tech programs
and Michigan Works! training etc. Just as nationally, some BSBP clients
receive great vocational preparation and are highly educated, yet
unsuccessful in obtaining employment. The client’s Individual Plan of
Employment (IPE) needs to reflect the individual’s study and goals in
choosing their future vocation. BSBP procedure is evolving to require a
thorough investigation and research by the client with the counselor’s
assistance as to what types of jobs and income, necessary training etc. for
their vocational goal choice. The BSBP policy states that comparable
benefits must be utilized first. (2)(a)(b) and (4). BSBP will take into
account family and consumer ability to contribute. (3). BSBP performs
annual reviews and managers review cases, at minimum, quarterly. (5)(b)(c).
BSBP must utilize comparable benefits first. BSBP does negotiate lesser
cost with vendors when possible.
Changes in Program, Vocational Rehabilitation: Observation 6
The division structure does not reflect the important distinction between
vocational rehabilitation and blind and independent living skills.
Changes in Program, Vocational Rehabilitation: Recommendation 6
BSBP consider Vocational Rehabilitation as a separate division with its own
manager.
BSBP Response: BSBP is reviewing this recommendation and the Executive
Director will determine if it should be implemented to enhance services to
Michigan’s blind community.
B. Changes in State Programs: Youth Low Vision/Transition
Commendations:
Relationships with school personnel have improved in previously troubled
areas and many counselors are very committed to their students’ best
interests.
Changes in Program, Youth Low Vision/Transition: Observation 1
The Counselor’s job is made more difficult by the facts that:
a. Some students, blind from birth, have extremely poor blind skills by
the time they are in high school and the counselor begins working with them
Example: A client totally blind from birth was noted at her college
assessment at the Training Center to eat with hands and to require many
additional hours of training and practice in orientation and mobility.
b. Some schools provide assistance to blind and visually impaired students
that
undermines rather than fostering their independent function.
Example: An 18 year old, who could read at 7th grade level very slowly in
48-point font and had no note-taking skills. His school aide takes notes
for him.
c. Clients’ and parents’ expectations vary widely and are not necessarily
related to the client’s abilities and prospects
Example: The client above stated vocational goals of high school English
teacher, radio/TV announcer, lawyer or mental health counselor with no
indication that he was apprised of the requirements and the gap he must
close.
d. Some counselors are responsible for older clients in addition to
youth/low vision clients, thus spreading the expertise and relationships
too thin for full effectiveness.
Changes in Program, Youth Low Vision/Transition: Recommendation 1
BSBP facilitate counselors’ jobs by:
a. Providing training in blind skills for ages much younger than 14.
See also under Statutes, section 7.
b. Establishing relationships with intermediate school districts to
encourage and educate them to support a goal of self-sufficiency among
students at younger ages and to include parents in such discussions and
goal setting.
(2) Allowing counselors to specialize in Youth Low Vision/Transition and
assign them those clients exclusively. The Commission recognizes that in
more rural areas, specialization may be impossible but believes it is
desirable where possible.
BSBP Response: The Youth Low Vision program is separate from VR Transition
services. (a) BSBP has extended youth transition services to age 14.
Research shows that Vocational Rehabilitation involvement at an earlier age
is effective from transition, through school and leads to employment. (b)
BSBP is fully engaged in this activity. (d) BSBP will study this
recommendation to increase the number of allowable FTE’s.
Changes in Program, Youth Low Vision/Transition: Observation 2
Relationships between counselors and students and between counselors and
schools are inconsistent across regions.
a. Counselors in some regions find schools unwelcoming; in others,
schools are very enthusiastic about their participation
b. School personnel feel that some tasks handed to them are the
rightful purview of the counselor, for example assisting a student in
completing the BSBP application forms.
c. Some Counselors’ involvement with students is restricted to annual
IEP. Meetings.
Changes in Program, Youth Low Vision/Transition: Recommendation 2
BSBP establish a protocol and support for counselors to develop close
working relationships with students, their families and with school
personnel.
a. Counselors meet with school personnel in their areas once a month to
create and maintain open lines of communication.
b. Counselors assist students in completing BSBP applications in the
students’ homes, thus allowing them to meet not only the students but also
their families early on and to gain family support for BSBP services.
c. Counselors meet with students, families and school personnel on a
regular basis, not only at annual Individualized Education Program (IEP)
meetings, to observe students’ independent function and suggest and
promote ways to increase it.
d. Counselors concentrate on what the teachers cannot do, for example
identify summer job opportunities including internships and place them in
these positions.
BSBP Response: (a-d) BSBP has an established practice in working with
school districts, students and families to outline the variety of services
that BSBP can offer including summer transition programming and transition
activities. WIOA will require that 15% of the overall VR budget be applied
to Pre-Employment Transition Services. Under the current Individuals with
Disabilities Education Act (IDEA) regulations, BSBP is mandated to
participate in the IEP’s (Individual Education Plan) after the school
receives written parental consent. Counselors are encouraged to attend
transition council meetings in the local areas, Michigan Transition
Services Association (MTSA) conference and Michigan Transition Outcomes
Project (MITOPS) in order to network with school personnel.
Changes in Program, Youth Low Vision/Transition: Observation 3
Extensive funds over long periods of time are devoted to competitive
employment for transition clients who are not capable of it.
Example: Client graduated from High School at age 26. Over the next 4 and
½ years $66,199.34 was spent for competitive employment (contracted
repetitive job coaching, coached internships) with the conclusion that she
requires supportive employment. Counselor was going to see if the funds
spent could be transferred from supportive funds to VR.
a. This may be in part a result of unchecked “client choice or “parent
choice”.
b. This may be a result of the absence of a policy or guidelines on what
constitutes a reasonable expenditure per likely outcome as demonstrated
within a reasonable timeframe.
Changes in Program, Youth Low Vision/Transition: Recommendation 3
BSBP develop guidelines to assure a reasonable cost-benefit ratio of funds
spent.
a. Redefine “informed choice” such that it does not mean “free
choice” but rather that it reflects a decision-making process that is
informed not only by client interests but also by well-assessed client
potential and well-assessed market forces.
b. Require an assessment of the cost vs anticipated outcome with
respect to expenditures.
c. Establish a time frame and/or number of repetitions of identical
service and/or training at which a disposition must be identified.
BSBP Response: BSBP, in accordance to RSA requirements, must not restrict
funding to assist the consumer as long as the vocational goal is viable in
accordance to one’s skills and abilities.
Changes in Program, Youth Low Vision/Transition: Observation 4
Funds and services are in some instances withheld from clients who hold
excellent promise for success but need guidance.
Example: 23 year old contacted her Counselor upon completing a BSBP-funded
BA in communications with very high grades with the goal of pursuing either
a master’s degree or a job and was told that she should (1) pick another
field rather than continuing in communications and (2) apply for ten jobs
per week and report back in a few weeks. As she is unsure of how to
construct a resume, who to contact, when to tell the employer she is
visually impaired and how to be effective in an interview, she is
floundering and the BSBP’s investment in her undergraduate education is
being wasted.
Changes in Program, Youth Low Vision/Transition: Recommendation 4
Guidelines be established and followed by all counselors to assure
consistent services responsive to the needs of all clients and the best
interest of the state in facilitating their success.
BSBP Response: BSBP has established policies and procedures for all
programs.
Changes in Program, Youth Low Vision/Transition: Observation 5
The unique needs of this age group, as differentiated from adult and senior
ages, deserve more specific attention.
Changes in Program, Youth Low Vision/Transition: Recommendation 5
BSBP establish a separate division for Youth Low Vision/Transition
consumers that would concentrate on, for example:
a. Early intervention.
b. Job experience during high school.
c. Coordinated use of Michigan Career and Technical Institute (MCTI)
programs.
d. Collaboration with community colleges.
(3) Evaluating existing contractual services for this clientele via ISDs,
which offer soft skill training only, vs vocational habilitation.
BSBP Response: (a-e) The new WIOA legislation requires a unified state
plan that will increase collaboration with Workforce Development partners
including Michigan Works!, Career Tech Education, Michigan Career Technical
Institute etc.
C. Changes in Programs: Independent Living/Older Blind
Changes in Program, Independent Living/Older Blind: Observation 1
Independent living skills are necessary for everyone who is blind or
visually impaired, whether employed or not, but they are distinct from
vocational skills, a distinction that is not reflected in the current
divisional structure.
Changes in Program, Independent Living/Older Blind: Recommendation 1
BSBP consider creating a separate division for independent living skills
for all clients including older blind, with its own Rehabilitation Teacher
manager.
BSBP Response: BSBP will explore the possibility of a more focused effort
on IL management. Rehabilitation Teachers are eligible to apply for
management positions within BSBP.
Changes in Program, Independent Living/Older Blind: Observation 2
Providing adequate services to the current and the escalating number of
seniors who are legally blind requires:
a. Services designed specifically for those consumers.
b. Adequate funding.
Changes in Program, Independent Living/Older Blind: Recommendation 2
BSBP define optimal services for seniors while seeking adequate funding for
those services.
BSBP Response: BSBP is constantly exploring additional funding for
independent services and is aware of the “baby boomer” generation growing
into an aging population. BSBP’s Independent Living staff is reviewing
policies and procedures for the IL program.
D. Changes in Programs: Training Center
Changes in Program, Training Center: Observation 1
The TC’s efficiency and cost-effectiveness is undermined by suboptimal use
of space and staff.
a. Dormitory capacity was reduced from 50 clients to 28 by changing all
previously double rooms to single rooms with private bathrooms. The
rationales stated were:
(1) Clients prefer single rooms.
(2) Clients do not want to room with someone who has a communicable
disease, e.g. hepatitis
(3) Clients need to learn to manage their own space independently.
b. Instruction observed at the TC was one-on-one (Braille, OT) or at most
two students (woodworking), when a small class format would appear to have
been viable.
c. A paid kitchen staff prepares meals, while clients are taught personal
kitchen skills in a separate kitchen. The only kitchen skill mentioned that
might be associated with employment and is sometimes undertaken in the main
kitchen is dishwashing.
d. The TC now has 24 hour nursing care for half as many clients as
formerly, although emergency medical services are readily available.
e. The TC has a very large area dedicated to computer training, full use
of which would require a large number of students at one time and is
unused to date.
f. The TC is located on a very large property, most of which appear to be
unused.
g. The reduction in TC client census was accompanied by additions to
staff, thus increasing the per-client cost.
Changes in Program, Training Center: Recommendation 1
The TC increase its efficient use of space and staff by:
a. Converting at least half of the single rooms to double rooms. The
rationales:
(1) Individuals with communicable diseases should not be in residence at
the TC.
(2) This would promote close friendships, a stated benefit of the TC.
(3) This would continue to offer individual rooms to those who would
specifically benefit or particularly desire, for example the elderly.
(4) MCTI has double rooms, with bathrooms shared by four students.
b. Offering small class format over one-on-one instruction, as one
instructor could manage several students at different skill levels.
c. Training kitchen skills in the main kitchen such that clients help
prepare and serve resident meals. This could be employment training for
some clients.
Example: Blind, Inc, the NFBTrainingCenter in Minneapolis has students
preparing and serving all lunches, including table setting and clean up,
supervised by paid staff.
d. Utilizing local emergency rooms or out-patient clinics as
necessary, reducing the need for 24/7 nursing care.
Blind, Inc. the noted NFBTrainingCenter in Minneapolis has no nursing staff
and states that the presence of a nurse invites sickness. Their staff is
trained in first aid and they transport students to medical care facilities
if and as necessary.
e. Strategic planning for optimal allocation and use of training
spaces.
f. Strategic planning for optimal allocation and use of acreage.
g. Strategic planning for optimal staff/client ratio.
BSBP Response: The Training Center underwent a $4 million renovation to,
among other things, convert double rooms to single rooms with single baths
in 2010. Single occupancy rooms support the health and privacy of
consumers. Nurses are available to provide education, training and
monitoring of individuals who manage a variety of chronic conditions (such
as diabetes). Most class size ratios are 1-2 to 1-3 client to teacher.
Individualized instruction is available if the client and their counselor
determine that it is most appropriate. The TC utilizes many areas to
promote work experiences such as the kitchen, maintenance and clerical.
Currently the TC is engaged in interior and exterior studies that will
assist in utilizing space most effectively.
Changes in Program, Training Center: Observation 2
The TC’s efficiency and effectiveness with respect to employment is
undermined by:
● Its focus on independent living as its own goal rather than as
prevocational training for employment.
● Its unclear definition of “job readiness”.
● Its lack of follow-up regarding outcomes.
a. The TC does not model employment by requiring a full day of
instruction with prompt attendance at all scheduled classes, as a job would
require.
Example: Client documented as refusing fitness and OT class, missing 16 O &
M classes and appearing in pajamas for others, being verbally rude to OT,
belligerent, ill mannered and disrespectful in industrial arts but remained
at the TC for 7 weeks.
b. The TC appears to define “Job readiness” as having basic skills of
blindness and a resume, whereas actual job readiness is likely to require
more.
c. The TC does not necessarily address the specific deficit that
jeopardized the job.
Example: 32 year old presented with difficulty driving to and from his
job. He stated he could perform his job and wanted to keep it. He was sent
to the TC for a week as an emergency in “job jeopardy”. The TC final
report stated that he didn’t need Braille and he did fine in all other
skills tested. There was no mention either by the counselor nor the TC of
his presenting problem, which was transportation to and from his work and
no mention as to whether he returned to his job or not.
d. No training is provided for specific jobs for which there is a market.
e. The TC does not systematically track vocational outcomes data for its
graduates and thus no way to judge its own effectiveness.
Changes in Program, Training Center: Recommendation 2
The TC’s efficiency and effectiveness with respect to employment would be
improved by:
a. Treating the TC training as a job: modeling and requiring behavior
that would be expected of an employee including promptness, full attendance
and appropriate attire.
b. Creating a definition of job readiness that is meaningful and
universally understood within BSBP.
c. For “Job Jeopardy” clients, addressing the deficit that is
jeopardizing the job.
d. Establishing a separate vocational training program beyond the
existing adjustment to blindness and job readiness programs.
e. Identifying several jobs/professions that have market viability
and developing specific training programs for these.
Example: The Lions World Services IRS training program in Arkansas
f. Tracking vocational outcomes of its graduates.
BSBP Response: The Training Center provides a core set of classes and
assessments. Computer Training allows the client to achieve equal skills
in technology. BSBP has recently implemented an advanced computer class
that has been very successful. However, BSBP has a responsibility to
provide not only prevocational training for employment but also independent
living skills. Newly blind elderly individuals can continue to function in
their own homes with training.
The Training Center works with a variety of individuals from all stages and
walks of life. Some students need more personal management training than
others. Teachers have to work with each student at their level. Often the
biggest barrier to employment is a student’s soft skills which are
addressed during training. The Training Center has policies and procedures
that students are made aware of when they arrive and are expected to adhere
to. In addition, the Training Center has a comprehensive Vocational
Exploration class. All students are provided the basics of the class and
prevocational students are provided in-depth training, testing, vocational
exploration, current job trends, resumes, and even hands on training as it
relates to their individualized employment choices and strengths.
The Training Center is currently working with the BSBP database to
incorporate it with the current system. Once that is completed tracking
student outcome data will become readily available.
Changes in Program, Training Center: Observation 3
The TC’s efficiency and effectiveness is undermined by the absence of a
policy for client admission:
a. Clients attend the TC who are too ill to fully participate.
Example, a client on dialysis may miss two or three of the five days per
week and others are precluded by fatigue from participating more than a few
hours per day. At $2,000/client per week, or even at the revised figure of
$1,300 per client per week, this represents many lost training hours that
could be devoted to another client.
b. Clients are referred on occasion to the TC who desire and require
training in only one skill, which could be trained locally.
Example: 68-year-old client in residence at the TC who wanted and needed
only to learn to use a computer.
c. Clients are encouraged on occasion to state an artificial vocational
goal in order to get computer training or personal use.
Example: 68 year old desired computer training to write a novel but was
told she had to have a vocational goal so she picked one, which she had no
intention of pursuing.
d. Clients’ blind skills are not assessed prior to referral. The TC
reports that many clients have had no training whatsoever in any blind
skills before admission.
e. Clients’ literacy and learning potential are not assessed prior to
referral nor early on at the TC, resulting in clients with inappropriate
goals remaining in classes for many weeks from which they cannot benefit.
Example 1: 59 year old referred to TC with vocational goal of retail sales
person. whose 11-week stay included 36 O & M sessions, 81 computer classes
and 15 sessions of Braille before being excused because of inability to
read and spell. Psych eval at TC states: “He does not know what city he
lives in but can give a street address; states he has a 9th grade education
but spells at 1st grade level, hasn’t worked for 11 yrs, recently in
hospital for alcohol-related dehydration, IQ 3rd percentile, verbal IQ 2nd
percentile. Could do hands-on occupation that involves simple, repetitive
work”.
Comments: His literacy level should have been identified before declaring
an unrealistic vocational goal and referring him to the TC and it should
not have required 11 weeks at the TC to identify his capability
Example 2: 36 year old in residence at the TC for five months with
vocational goal of Lions IRS training. Braille intake states “needs an
evaluation by the OT to try to determine his reading level.” Career
assessment indicates his 50% reading comprehension of at 7th grade level
and 5th percentile vocabulary did not meet Lions’ requirements. After 84
computer sessions still ranked “beginner”. After five months the
conclusion was that he should practice reading and if he can’t qualify for
IRS he should look for customer service job, which is what he had going in.
g. Clients are referred although their employment deficits are not
those addressed by
the TC.
Example: client referred as job in jeopardy whose problem was
transportation to his job, which is not something the TC addresses and
which was not mentioned in any of the TC documentation.
h. Clients are referred who are not ready to participate.
Example: client who refused some classes, did not appear for others, did
not dress appropriately and was disrespectful to staff.
Changes in Program, Training Center: Recommendation 3
The TC’s efficiency and effectiveness would be increased by creating clear
admission criteria, onsite participation guidelines, and behavioral
requirements, including:
a. Sufficient health to participate 8 hours a day, 5 days a week.
b. A goal requiring intensive and/or multi-faceted training. If a single
skill, e.g. basic computer training, is desired or needed, this should be
provided locally.
c. Accurate statement of vocational goal or of independent living goal.
d. Sufficient blind skills, assessed locally, to benefit from advanced
blind skill training and/or specific job skill training.
e. Appropriate vocational goals based on local assessment of basic skills,
including literacy.
f. The cause of “job in jeopardy” being a skill addressed at the TC.
g. Stated understanding of the requirements for full participation and
respectful behavior (and early dismissal if these are not observed).
BSBP Response: Section 504 of the Americans with Disabilities Act (ADA)
makes it illegal for programs that receive federal funds to discriminate
against individuals with disabilities. Those individuals have a right to
receive training. The Training Center requires eye and medical exams on
all referrals. The referrals are reviewed by nursing staff to determine if
a potential student can fully participate in training.
The Training Center staff is devoted to providing as much individual
attention to student needs within a small class. Training Center
classes/services (which include vocational assessments) often assist with a
“job in jeopardy” situation especially if they need additional computer
training or have personal management issues.
Changes in Program, Training Center: Observation 4
The staff/client ratio and per client cost of running the Training Center
are high.
a. The staff/client ratio, including all support and maintenance
staff, is almost 1 to1 (.93 staff per client).
Blind, Inc., the NFB Training Center in Minneapolis, has .63 staff per
client. Their director observed: “The more staff there is the more
tendency to baby the students”.
b. The lowest estimated per client cost for the TC has been stated as
$1,300/week or $5,200/month.
Blind, Inc. charges $4,000 per month which includes a bus pass and $300
month allowance per student for expenses including breakfasts and dinners,
which they can prepare in their apartments or purchase out.
Changes in Program, Training Center: Recommendation 4
BSBP should consider instituting the recommendations above that would serve
to increase efficiency, and decrease staff/client ratio and costs while
promoting client independence.
BSBP Response: Please see response to recommendation II C. 1.
E. Changes in Programs: Business Enterprise Program (BEP)
Commendations:
Positive steps have been taken with respect to auditing, operator
reporting, emergency procedures and emphasis on independence vs
entitlement.
Changes, Business Enterprise Program: Observation 1
The small vending shop is no longer an optimal or perhaps even a viable
business model and the cost of operating the BEP program benefits a
relatively small number of consumers and many of them minimally.
a. The BEP program was designed at a time when small vending shops were
the primary source of cigarettes, the use of which has significantly
declined, as well as snack food and newspapers.
b. The above are now available ubiquitously and conveniently at gas
stations, 7-11s, fast food outlets and/or online.
Changes, Business Enterprise Program: Recommendation 1
The State should reassess the BEP business model and operator employment
package:
a. Examine successful BEP programs in other states.
b. Explore other models that may offer greater benefit to clients per
cost.
c. Evaluate responsibilities and benefits of operators for efficacy
and compliance with the Randolph Sheppard Act.
If the BEP is to continue its current model:
BSBP Response: The Randolph Sheppard Act and PA 260 of 1978 clearly
defined the business model for BEP facilities. Licensed operators are
required to act as sole proprietors and are expected to manage their own
businesses independently, including recordkeeping, ordering, marketing, and
daily maintenance in accordance with promulgated rules.
Changes, Business Enterprise Program: Observation 2
There is a range of ability, motivation and receptivity to modernization
among operators, which impacts their success.
Changes, Business Enterprise Program: Recommendation 2
Improve the selection process of operators:
a. Assess motivation (“internal locus of control”) as well as potential
for sufficient skill development in selecting BEP candidates.
b. Include feedback from host operators in selection of BEP candidates.
BSBP Response: Promulgated rules and federal regulations require the
Elected Operator Committee (EOC) to actively participate in a process
whereby the committee makes recommendations to BSBP on the development and
implementation of major administrative decisions and policy as well as
program development. Also, see response to II. D. Recommendation 3 above.
Changes, Business Enterprise Program: Observation 3
There is a range of efficiency among operators which impacts their success.
a. Some are not computer literate nor do they have computers.
b. Some do not have credit card machines.
Changes, Business Enterprise Program: Recommendation 3
Increase the efficiency of operators by:
a. Requiring electronic records and reporting and provide computers
and training in their use as part of BEP training.
b. Requiring credit card machines and train operators in their use.
BSBP Response: Each licensed operator is an individual entrepreneur within
the structure of the program which requires them to demonstrate computer
literacy prior to program training. Candidates entering into training are
provided computers prior to the start of class. Current licensees are
provided a computer and training upon submission of a written plan for
their use. It is up to the licensees as to how they utilize these tools.
Use of credit card machines and other business technology are decisions
made individually by the licensed operators and are not mandated within the
rules.
Changes, Business Enterprise Program: Observation 4
The Bidline is archaic and unwieldy.
Changes in Program, Business Enterprise Program: Recommendation 4
The bid system should be revamped and offered electronically, as candidates
have already completed training and should be computer literate and in
possession of a computer.
BSBP Response: The current bid system also provides electronic submission
of monthly operator reporting via a telephone and is state of the art
technology sought after from other BEP programs in the country.
Changes, Business Enterprise Program: Observation 5
Operators, once trained and operating their businesses, are on the one hand
considered independent business operators, but on the other hand are
encouraged to be dependent by the provision of extensive support services.
Changes, Business Enterprise Program: Recommendation 5
Operators, once well trained and equipped, should then be expected to
manage their own businesses independently, including for example record
keeping, ordering, marketing, and daily maintenance.
BSBP Response: Licensed operators are required to maintain records and are
expected to manage their own businesses independently within the confines
of the program. This includes recordkeeping, ordering, marketing, and
daily maintenance in accordance with promulgated rules.
Changes, Business Enterprise Program: Observation 6
Operators having the option to reject the expert business advice of the PAs
undermine the cost-effectiveness of BSBP financial support of BEP.
Changes, Business Enterprise Program: Recommendation 6
BSBP’s agreement with operators should include a requirement that
accepting the financial support of BSBP comes with accepting the business
advice and fully cooperating with Promotional Agents.
BSBP Response: BSBP is reviewing this recommendation to determine if the
suggestion should be implemented.
F. Changes in Programs: Business Assistance and Development Program
Changes, Business Assistance and Development Program: Observation 1
The BADP represents a prioritization that the Commission questions in the
face of other unmet needs.
a. The BADP appears to focus on the same client population as the
BEP, i.e. those able to and interested in running their own businesses.
b. Small business is the riskiest type of employment, as 90% of all
small businesses in the U.S. fail.
c. Employment specialists are few within BSBP and job development
minimal.
d. There is consistent comment that summer employment is critical for
the future employment prospects of blind youth.
Changes, Business Assistance and Development Program: Recommendation 1
The BADP expand its purview to include job development with existing
companies, including those who hold federal contracts, to provide:
a. Opportunities for permanent employment.
b. Opportunities for summer jobs for students.
c. Focused training, in collaboration with the TC and MCTI.
The Commission believes that this is likely to put more blind and visually
impaired individuals in competitive employment than will developing
independent small businesses.
BSBP Response: As stated in Section II.E., BSBP is reviewing the Advisory
Commission’s programmatic recommendations for the BADP and will evaluate
the comments.
G. Changes in Programs: Braille and Talking Book Library
Changes in Program, Braille and Talking Book Library: Observation 1
The public libraries funded through the Braille and Talking Book Library do
not all require their entire staff to be proficient in serving clients who
are blind or visually impaired.
Changes in Program, Braille and Talking Book Library: Recommendation 1
BSBP require that all public libraries funded through the Braille and
Talking Book Library do require that their entire staff receive training to
become proficient in serving clients who are blind or visually impaired.
BSBP Response: This recommendation asks that all sub-regional libraries in
Michigan be required to manage and administer library service to the blind
in the way that 2 sites have chosen to go. From a service perspective,
there is no evidence that one model is superior to another. There are pros
and cons to each. This is a local, administrative choice based on the host
library’s resources in relation to the population they serve. All staff
providing service to blind and physically handicapped patrons are given
training as needed. Orientation (not in depth training) is provided to all
staff in a public library so that all have some knowledge of what the
service provides, who qualifies, and how to offer assistance (disability
etiquette) to a blind patron who comes into the library. This is different
from the recommendation that all sub-regional libraries be required to
train all staff to be proficient in providing this specialized service.
H. Changes in State Statutes and Policies:
Please see Section VII
BSBP Response: BSBP will ask the Independent Living and Older Blind
engagement team to review the Advisory Commission’s recommendation to
raise the status of Homemaker from age 55 to age 66. In addition, the team
will review the possibility of raising it to the recommended level of 75.
BSBP is studying model and structural changes to the operation of the
Business Enterprise Program.
The Advisory Commission has recommended changes for the Department of
Education and other state agencies in coordination with BSBP. A joint task
force under the Workforce Innovation and Opportunities Act (WIOA) has been
created and is working on several of the recommendations of the Advisory
Commission. Key staff from BSBP are participating in that project. By
2016, WIOA requires many of the same changes recommended by the Advisory
Commission in this area.
The Advisory Commission has recommended that BSBP develop more vehicles for
consumer and public input. BSBP, in coordination with the Michigan Council
of Rehabilitation Services, is in the process of developing such new
vehicles. In the last year BSBP has conducted outreach at the state fairs,
various community and consumer groups and continues to develop and improve
its mini-adjustment programs which go into communities to provide
information and initial introductory training to blind citizens in those
geographic areas.
IV. Secure recognition of accomplishments and contributions of blind
residents.
Commendation: BSBP presents an annual awards lunch and ceremony to honor
successful clients and the businesses in which they are employed.
Observations: Most sighted individuals and many visually impaired
individuals are unaware of the spectrum of abilities and accomplishments of
those who are blind and visually impaired, while those attending the awards
luncheon are already aware.
Recommendations:
1. BSBP post a video of the highlights of its awards luncheon on its
website.
BSBP Response: See Below
2. BSBP create a video for its website sighting the challenges and
accomplishments of blind and visually impaired individuals. A starting
point could be featuring the Commissioners who are legally blind, as they
provide a range of experience as to time of onset of visual impairment and
professional and avocational activities and are readily at hand, along with
a student and a senior citizen with adventitious vision loss.
BSBP Response: See Below
3. BSBP feature video/audio testimonials on its website of clients
attesting to the benefits and outcomes to inspire others seeking services
of BSBP.
BSBP Response to 1, 2 & 3: The State is still developing guidelines for
video use on state websites. While media technology is allowed to be used
there are strict guidelines on the use, formats and video size which is
currently limited to 5 MB. In 2011 a video was made of a Commission
meeting but was very costly to audio describe the video and make it fully
accessible. Because of the large file size, this was only distributed on a
DVD that the Department had to charge for when requested. The file was
unable to be posted on the website. Possibly audio recordings could be
created and made available for streaming from various special event
meetings and pictures with descriptive tags will continue to be put on the
State websites.
4. When the BSBP has completed a Strategic Plan and is able to
promptly provide more clients with local services specific to their needs,
an advertising campaign should be undertaken to increase awareness among
the public of what individuals who are blind and visually impaired can
accomplish with rehabilitation.
BSBP Response: BSBP currently participates in many events where the Bureau
services are marketed. The Director has given more than 100 speeches
during his tenure to many different groups inside and outside State
government.
Staff continually participate in giving presentations and hosting booths at
various venues including independent living and older blind events within
Michigan communities, the U.P. State Fair, the Library Without Walls
conference and the Optometry and Ophthalmology conference to name a few.
The Bureau has invested in new pop up marketing signs for staff to use in
booths. These signs are portable, easy to use and offer an opportunity to
get the Bureau of Services for Blind Persons name and logo out to the
public. The Bureau continually provides brochures and signature guides
marketing all the various programs which are distributed at these events.
These marketing materials are also available at Michigan Works! Offices,
Area Agencies on Aging, Secretary of State Offices and doctors’ offices
throughout the state.
V. Monitor, evaluate, investigate and advocate programs for the betterment
of blind residents.
In carrying out its responsibility, the Commission conducted a five-prong
study including (1) holding public meetings with pertinent presentations
requested, (2) posing questions to the Administration both verbally and in
writing (3) reviewing BSBP materials, client files and state statutes, (4)
forming subcommittees for each of the three areas designated by the BSBP
director as priorities - Consumer Services, Training Center and Business
Enterprise Program and a fourth Finance subcommittee that reported back to
the Commission at public meetings and (5) conducting interviews with
collaborating community agencies. A list of Commission activities is set
forth below.
Ten public meetings were conducted with 25 individuals presenting who
represented the departments, agencies and consumer groups listed in Section
5. Questions were posed to the Administration which the Commission thought
appropriate staff would be able to answer easily but was informed that 623
staff hours were required to answer them, which totals fifteen forty-hour
weeks for one staff member. Review of materials included among other the
State Plan, state statutes, the 2013 BSBP Annual Report, the old Policy
Manual (the new policy manual initially scheduled to be completed by June,
2013, postponed to November, 2014 and has not been made available to the
Commission at the time of this writing), and eight client files which were
provided in hundreds of pages of hard copies for each of the seven
Commissioners, including the four who are blind.
The Consumer Services Subcommittee traveled to each regional office, and
twice to the Central and East regional offices, met with the directors and
selected staff in a group and additional staff individually. Prior to the
first meeting, the Commission submitted written questions. The reception of
the Commission varied widely from region to region from welcoming,
enthusiastic and forthcoming with an understanding that the Commission
shared their goals of achieving the best possible services, to hostile,
furtive and reluctant to respond to questions the Commission and other
regions considered benign and unthreatening.
The Training Center subcommittee visited the Center, where they were
welcomed by both the outgoing Director and at a later visit by the incoming
Director as well as the Training Center staff who were enthusiastic and
pleased to discuss their work. The subcommittee also participated in
subsequent phone conferences with the Director and staff as well.
The Business Enterprise Program subcommittee met with the Director and the
Promotional Agents, shadowed three operators at their sites and met with
others, attended an Elected Operators Committee meeting and participated in
subcommittee phone conferences. Upon creation of the Business Assistance
Development Program (BADP) the subcommittee also met with its director.
The Finance subcommittee met with the Director and Assistant Director who
were very helpful in explaining the financial structure of the BSBP.
Commissioners visited and met with collaborating agencies that included
Visually Handicapped Services in Detroit, the director and teachers in the
Intermediate School District in Livonia, the Manager of the Michigan
Rehabilitation Services office in Livonia, the director of eye care in the
Special Needs Clinic in Saginaw and Blind Incorporated, the training
program of the National Federation of the Blind in Minneapolis. All of the
above were exceedingly welcoming and forthcoming.
Commission Activities:
All Commissioners:
Six public meetings in 2013, 4 public meetings in 2014, in Lansing
Presentations from:
BSBP Division and Dept Directors
Regional Directors
Parents of Blind Children
Directors and Staff, Centers for Independent Living,
Director and staff, Advocacy Organization
Chair and Vice Chair, Elected Operators Committee (BEP)
Chair and Vice Chair, MI Federation of the Blind
Chair, MI Council of the Blind and Visually Impaired
Director, MI Rehabilitation Services
Chair, MI Rehabilitation Council
Visit to the MRS Training Center in Plainwell
Consumer Services Subcommittee and Chair
Meetings with:
East Region manager and selected staff
Central region manager and selected staff
West region manager and selected staff
Individual staff in Flint, Saginaw, Lansing and Detroit
Manager and staff, Visually Handicapped Services, Detroit Receiving
Director and teachers, Intermediate School District, Livonia
Subcommittee meetings
Attendance at Annual awards ceremony, Lansing
Training Center Subcommittee and Chair
Meeting with:
Previous TC Director and staff
Current TC Director
Vocational director
Subcommittee meetings
BEP Subcommittee (*and Chair)
Meeting with:
Director*
Four Promotional Agents*
Three operators, at their sites
Subcommittee phone meetings*
Director of BADP
Attendance at Elected Operators Meeting
Shadowing elected operators at their sites
Finance Subcommittee
Meeting with BSBP Director, Asst Director and Accountant
Chair alone:
Meetings:
BSBP Director and Asst Director
RSA Administration, D.C. (phone)
Site Manager, MI Rehab Services, Livonia
Optometrist, Special Needs Vision Clinic, Saginaw
Presentation to MI Rehabilitation Council
Participation in phone conference, MI Rehabilitation Council
Review of client files
Visit to Blind, Incorporated, and NFB prevocational training center,
Minneapolis, MN
VI. Advise the Governor and the Director of LARA of the nature, magnitude
and priorities of the challenges of blind persons.
The priorities and challenges of blind persons are extremely individual.
Children and youth need to learn the basic communication, computation and
reasoning skills that all children need to learn, in addition to mastering
skills of blindness that allow them to participate in the community. Adults
with adventitious vision loss need to learn adaptive skills for home,
community and employment and need job placement and seniors need to learn
adaptive skills for safe and optimal function as their vision loss
exacerbates other deficits of age.
The key is (1) to identify the specific needs of each individual quickly
and address them efficiently and economically as possible with creative
leadership, highly skilled and motivated staff and flexible programs
including early intervention, intensive local services, up-to-date
technology and job training consistent with market demand and (2) to
address community barriers to employment and participation, notably lack of
community and employer awareness of the potential of blind candidates and
of transportation challenges in most Michigan communities.
VII. Advise the Governor and the Director of LARA on the state’s policies
concerning blind individuals.
State Policies: Observation 1
The State has set the age at which management of ones’ home is considered
a vocation and vocational goal of “Homemaker” at 55 or younger.
a. Management of ones’ own home beyond the age of 55 is not considered a
vocation or vocational goal, although the same responsibilities accrue:
(1) Regardless of whether the homemaking allows another to work.
(2) Regardless of whether the individual is also caretaker for another in
the home.
b. This age cut-off was established decades ago and given the aging of the
current population and the level of activity of the aging population, it is
an anachronism.
State Policies: Recommendation 1
The State should revise the age for the vocational designation of
“Homemaker” to at least age 66, the current age recognized by the federal
for Social Security Administration benefits, and preferably to age 75.
a. This would more accurately reflect the demographics and level of
function of the 21st century population.
b. This would allow the limited resources for older blind to accrue to
those who are truly older.
BSBP Response: The recommendation suggested that the age limit for
Homemakers be changed to 66 and preferably 75 would have an adverse effect
on vocational rehabilitation outcomes and the hourly wage paid to
competitive closures. The large number of Homemakers decreases the return
on the investment relating to competitive closures.
State Policies: Observation 2
Very little money is available for Older Blind, although they are the
majority of visually impaired and are at high risk for injury. The
Commission understands that the Rehabilitation Services Administration
(RSA) is attempting to elicit more funds from Congress for this purpose.
State Policies: Recommendation 2
The State should explore ways to dedicate more funding to its senior
citizens who are blind and visually impaired.
a. Solicit more from the legislature.
b. Support RSA’s efforts to solicit more from Congress.
BSBP Response: (a) BSBP is not permitted to lobby the legislature for any
reason; (b) BSBP supports RSA’s efforts to increase funding.
State Policies: Observation 3
The Business Enterprise Program was designed at a time when small vending
shops were the primary source of cigarettes, snack food and newspapers,
which are now available at gas stations, 7-11s and fast food outlets and
the latter online as well, and is no longer an optimal model for business
success.
State Policies: Recommendation 3
The State should reassess the BEP business model and operator employment
package:
a. Examine successful BEP programs in other states.
b. Explore other models that may offer greater benefit to clients per
cost.
c. Evaluate responsibilities and b.
BSBP Response: BEP and Administrative staff attend yearly national
educational conferences. These educational conferences include practices
presentations by other states. It also allows for networking with other
State Administrators to discuss successes and lessons learned. Currently,
BEP is reviewing micro markets which allow more product choices (including
many microwavable options as well as sundries) and allows self-checkout in
a secured space thus lowering employee costs. The BEP staff has numerous
checks, balances and reporting practices that evaluate responsibilities and
compliance.
State Policies: Observation 4
State services for infants, toddlers and school age children who are blind
or visually impaired are grossly inadequate for the 21st century and
undermine and sometime preclude their opportunity to become productive
members of society.
b. Early and consistent training in blind skills does not appear to be
the norm.
Example: transition student visually impaired from birth whose not
orientation and mobility skills and table/eating skills are inadequate.
b. Parents of blind children need guidance to help their children
reach their full potential.
c. Services in many schools foster dependence of blind and visually
impaired students rather than promoting independence.
Example: students are given an aide to take notes in class and guide the
student from class to class, rendering the student incapable of taking his
own notes or of navigating the building on his own.
d. Technology has become the equalizer for individuals who are blind
but many students do not have access to adequate technology and those who
do may underutilize it because of substandard training.
e. Students are given two pair of glasses per year, whether the
glasses improve their vision or not, using funds that otherwise could be
used for technology that would allow them to function competitively.
State Policies: Recommendation 4
The State Department of Education should re-examine and revise its services
through schools to provide early, consistent and effective intervention.
a. Parents of blind infants should receive training in ways to
stimulate these infants and maximize their activity and learning.
b. Parents of older children should receive guidance on encouraging
involvement in age-appropriate activities that build a sense of community
and offer important prevocational experiences.
c. Pre-school and early elementary students who are blind should
receive training in orientation and mobility skills.
d. Elementary through high school students should receive the
electronic devices that would promote independent academic function make
them competitive in the classroom and at home and they should be able to
keep at least one device, as they keep glasses. This would cost less than
two pair of glasses per year currently provided.
Examples: Computers that connect with whiteboards for class
interaction; portable CCTVs that focus at both distance and at near rather
than head-mounted telescopes that are less useful and less used by students
who don’t want to look different from their peers. Electronic equipment is
common and well accepted.
e. Glasses should be provided only when a new Rx actually improves the
student’s visual acuity significantly and only one pair per year should be
dispensed unless absolutely necessary.
BSBP Response: Currently, students who are visually impaired or blind are
eligible to receive special education services from birth to age 26 as
applicable through the Department of Education. BSBP advocates for quality
services to be provided. (e) The Youth Low Vision program states that an
individual may receive assessments and/or recommended devices bi-annually.
If someone’s vision has decreased significantly within this two year
period, BSBP can assist with exams and recommended devices.
In order to provide comprehensive services to visually impaired students, a
recommendation should be made to transfer Low Incidence and Outreach’s
blind and visually impaired services, media center with emphasis on Braille
production and teacher consultants within the Department of Education to
BSBP through an Executive Order. This effort is in line with WIOA as it
requires agencies to develop agreements to carry out the required services.
State Policies: Observation 5
The Governor’s Executive Directive No. 2014-1 recommends to “all State
Departments and Agencies a goal of hiring self-identified individuals with
disabilities within state government.”
State Policies: Recommendation 5
Government agencies, certainly including BSBP, seek to hire individuals who
are legally blind. Government agencies, certainly including BSBP, seek to
hire individuals who are legally blind. This should apply to full time,
part time, internships and student assistants.
BSBP Response: BSBP, since its creation in October of 2012 has constantly
recruited and attempted to hire individuals who are legally blind.
Presently, approximately 20% of BSBP’s full time equivalency (FTE’s)
positions are occupied by legally blind individuals. US Census data
indicate 1.9% of Michigan’s population is blind. BSBP has made every
effort to recruit blind individuals who qualify for internships or as
student assistants.
State Policies: Observation 6
The State does not employ occupational therapists trained in vision
rehabilitation for BSBP although they are also able to address the range of
physical and cognitive challenges of seniors who are now the majority of
visually impaired and to do job site assessments, which the current BSBP
staff cannot do.
State Policies: Recommendation 6
The State revises its employment categories to include occupational
therapist specializing in vision rehabilitation.
BSBP Response: It appears that this recommendation should be studied and
the information presented to LARA and the Department of Civil Service for
their consideration.
State Policies: Observation 7
The State, via the BSBP, pays full retail price for many of the devices it
provides to clients.
State Policies: Recommendation 7
The State considers negotiating volume pricing with
distributors/manufacturers of low vision devices, including electronic
equipment, to allow its funds to benefit more clients.
BSBP Response: This idea has been discussed with management and LARA
purchasing but has not yet been fully reviewed. There are outstanding
questions regarding identifying client needs, cost of stocking equipment,
quality control and distribution of the equipment.
State Policies: Observation 8
Michigan has limited public transportation on which legally blind residents
rely for independent living and employment.
State Policies: Recommendation 8
The State mandate that communities provide transportation to legally blind
residents and coordinate their services with all metropolitan communities.
BSBP Response: BSBP sees value in and supports community transportation
services for the legally blind, but is unable to mandate it. BSBP does not
initiate or advocate legislative action, as this recommendation appears to
require. It is LARA’s prerogative to recommend legislation to the Governor.
State Policies: Observation 9
Consumer and public feedback is essential to promoting optimal Bureau
performance; however, consumers and the public currently have no vehicle
for providing input and feedback other than attending public meetings of
the Commission, which are not structured for this purpose.
State Policies: Recommendation 9
Develop a vehicle for consumer and public input and feedback. This could
for example be a committee of representatives from recognized organizations
for the blind and visually impaired, from constituent groups such as
parents of blind children and from consumers from each age group -
transition, vocational rehabilitation and older blind - who could serve as
both advisors to the BSBP and ombudsmen to consumers.
BSBP Response: BSBP has continued its outreach to consumers and the public
in general to educate about the factors of being blind. BSBP has also
streamlined a complaint and grievance process by developing procedures so
that Michigan’s blind community may receive the services they are entitled
to, through an informal grievance process.
State Policies: Observation 10
The name “Bureau of Services for Blind Persons” is inaccurate, confusing
to clients and the public by (1) equating “blind” with “legally blind”,
which are terms with very different meanings and (2) suggesting a social
service agency rather than an agency promoting the independence and
employment of individuals who are legally blind.
a. Everyone who is totally blind is also legally blind but very few
who are legally blind are totally blind; they have low vision or are
visually impaired.
b. The original term “economic blindness” was coined in the 1930’s
to identify those unlikely to be able to support themselves because of
their vision, and was later changed to “legal blindness”. The definitions
were arbitrarily placed at 20/200 and/or 20 degrees of field, which
themselves describe very different conditions and functional impact which
require very different rehabilitation and different from those who are
totally blind.
State Policies: Recommendation 10
The State changes the name of the Bureau to accurately describe its mission
to empower not just to serve, and the persons it is created to serve. One
example could be “Bureau to Advance Independence and Employment of Persons
who are Legally Blind”.
BSBP Response: BSBP was created by Governor Snyder’s Executive Order 2012-
10. The EO clearly indicates that the Bureau of Services for Blind Persons
will serve Michigan’s blind community. The suggestion by the Advisory
Commission to change the name to a more lengthy title would create more
problems with references in documents, telephone services, pre-printed
marketing materials and other items that would be affected. It would be
very cumbersome, for example, to answer our phone “Bureau to Advance
Independence and Employment of Persons who are Legally Blind.
The Future of the Commission
The Commission serves in an advisory role to the Governor and the Director
of LARA. In order to fulfill the Governor’s charges I, V and VII, the
Commission requires access to information about every aspect of the major
state program serving the blind, the Bureau of Services for Blind Persons
(BSBP). This information has been provided but with delay, repeated
requests, complaints about the staff time required and an overall sense
that the Commissioners are adversaries to the BSBP. An effective ongoing
role for the Commission would seem to require a relationship with BSBP of
collaboration and partnership in the shared goal of best serving Michigan
residents who are blind and visually impaired. Upon submission of this
report, therefore, the Commission respectfully requests clarification of
its further role, if such is anticipated.
Appendix A
Structure of the Bureau of Services for Blind Persons
(As of April, 2014)
Divisions bolded. Leadership bolded and underlined
Executive Division
Senior Management Executive
Senior Executive Management Assistant
Office assistant, student assistants
● Administrative Services Division
State Division Administrator
Braille and Talking Book Library:
Librarian Manager
State Administrative Manager
Department analysts (2)
Secretary
Student assistant
Rehabilitation Consultant Manager
Business Enterprise Program (BEP)
Department manager(s)
Promotional agents (4)
Student assistants (4)
● Business Assistance and Development Program
Division Administrator
Department Manager(s)
Student assistants
● Consumer Services Division
State Division Administrator
Secretary
Deaf-Blind
Rehab Instructor
Secretary
East Region
Vocational Rehabilitation (VR) Manager
Rehabilitation Counselors (3)
Blind Rehabilitation
Instructor (2)
Secretary
Student Assistant
VR Manager
VR Counselors (3)
Blind Rehab Instructor
Employment Services Interviewer
Secretaries (2)
Central Region
Vocational Rehabilitation Manager
Flint: Vocational Rehab Manager
Rehab Counselor (2)
Secretary
Saginaw: Blind Rehab Instructors (3)
Secretary
Lansing: VR Counselors (2)
Blind Rehab Instructor
Employment Services Interviewer
Secretary
Gaylord: VR Counselor
Blind Rehab Instructor
Secretary
West Region
Vocational Rehab Manager
Grand Rapids: Blind Rehab Instructors (5)
Secretary
Kalamazoo: VR Counselor
Employment Services Interviewer
Secretary
Escanaba: Blind Rehab Instructors
Secretary
● Training Center
State Division Administrator
Executive Secretary
Activities Therapy aide
Blind Rehab Instructors (13)
Trades instructor
State Administrative Manager
Maintenance Mechanic
Supervisor
Maintenance Mechanic
Registered Nurses (3)
Rehab Services
Coordinator (2)
Department analyst
Accounts Technician
Secretary
Cooks (3)
Domestic service aides
(2)
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