[Nfbsf] My experience and end result when posting to the DOL website about Section 14c Certificates

[Jessie Lorenz]

This is really well stated.
Thank you for submitting such well thought through comments.

Jessie


Composed  on iPhone using Siri.


On Jun 22, 2019, at 11:35 AM, Lisa M. Irving via NFBSF <nfbsf at nfbnet.org> wrote:

Hello All, 





A few weeks ago we were encouraged to post comments to the Department of
Labor's website on the topic of Section 14c Certificates. Here's what my
experience was like. I followed the  link Jim Barber posted to the website
and I was able to register. (You have to register in order to comment). I
noticed a sentence that made reference to calling or emailing if
accommodations were needed. I shared that information with a friend who is
less tech savvy in hopes that he will also share his lived experience as a
former sheltered workshop employee. I must have spent 25 minutes trying to
locate the link or button or collapsed menu for the comment section. I
planned to cut and past my comments I previously wrote in Word into the
DOL's comment section. I later learned the comment section was not
accessible. Go figure. Ultimately, I emailed feedback concerning the mostly
accessible DOL website and asked Carolyn Crawford, a DOL employee, to
include my remarks in the comment section. (Emails are separate from the
comments). Separate but equal doesn't work for me. Below you will find my
comments regarding phasing out Section 14c Certificates posted in the
comment section on my behalf by Carolyn Crawford. I'll try to post the link
I used and Ms. Crawford's contact information upon request. 



Here is my letter. 



Subject: The Future of 14C Certificates and Disabled Workers in 2019 



 In 2015, I had the opportunity to persuade Congresswoman Susan Davis to
not support the use of 14c Certificates. Most of us can agree that in 1938
when this landmark legislation was passed it was a first step in ensuring a
meaningful life and financial security for America's disabled working age
adults. I would like to think that most of us would also agree that times
have changed over the past eighty-one years since that legislation passed. 







 Between 1938 and 2019, as a whole, society's expectations and inclusion of
working-age adults has substantially improved to the point that sheltered
workshops and sheltered employment is limited, but exists. Why are some
disabled adults placed in sheltered employment where they are paid
sub-minimum wages? Some individuals and some agencies would have you believe
that it's financially in the best interest of the disabled employee. I
disagree and here's why. Vermont and New Hampshire have demonstrated that
eliminating 14c Certificates and paying at least a minimum wage has not
bankrupted organizations, and their disabled employees are not homeless, and
have not lost government assistance. 







Speaking of "government assistance", the goal of work is to decrease
government dependency for most people with disabilities. Working-age adults
who receive SSI may have their benefits reduced, however, if they receive at
least one dollar a month -in addition to their salary, they will maintain
Medicaid. Generally speaking, subsidized housing  including Section Eight,
and HUD have higher income thresholds so losing housing is highly unlikely.
Finally, there are highly trained experts to assist disabled working adults
and their guardians to work within regulations surrounding spend downs and
different program eligibility rules. These professionals are called, Work
Incentive Program Planning Assistance Coordinators. They do not charge for
their services. 







To summarize, 14c Certificates at one time served a useful purpose, but no
longer fit into today's rehabilitation model. Using scare  tactics to
enslave a vulnerable protected class of individuals needs to be halted by
means of phasing out 14c Certificates and replacing antiquated employment
practices with customized employment which includes job carving where
appropriate. Finally, everyone has purpose and value. A person's value
cannot be diminished to sub-minimum wages in the United States of America in
2019.







Respectfully submitted,







Lisa M. Irving, National Federation of the Blind of California, San
Francisco Chapter Board Member

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