[nfbmi-talk] Important Section of BSBP Commission Report

[Elizabeth Mohnke]

Hello All,

My policy analysis skills may not be what they used to be, but I am doing my
best to read through the BSBP Commission Report making brief comments on the
recommendations as I read them. However, I came upon a section with too many
concerns to list in brief summary form. I thought I would post this specific
section for those of you who may have given up reading too far into the
report. The following can be found in Section III starting on page 20 in the
Word attachment. It reads as follows:

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.