[nfbmi-talk] Report of the Michigan Commission for Blind Persons
Larry Posont
president.nfb.mi at gmail.com
Wed Apr 22 01:53:31 UTC 2015
National Federation of the Blind of Michigan
7189 Connors Rd.
Munising, MI 49862
April 21, 2015
Dear Michigan Federationists:
Here is the report written by the Advisory Committee with
responses by the Agency. I am asking for volunteers to assist in
writing the National Federation of the Blind of Michigan’s position
statement on this report. Please contact me if you would like to
assist.
Sincerely,
Larry Posont
President
National Federation of the Blind of Michigan
(906) 387-3546
Email: president.nfb.mi at gmail.com
Web page: www.nfbmi.org
Munising home of the beautiful Pictured Rocks.
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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