[Rehab] Policies vs. Regulations

[Richard Davis]

Hi Justin,
I agree with Dave Andrews. The other thing I would do is call the
Legislative Reference office in the state capitol and raise the issue with
them. I think state agency policies are by definition public documents. And
I find state agency people are more afraid of state officials than federal
ones.
Dick Davis

On Mon, Jan 23, 2023 at 6:47 PM David Andrews via Rehab <rehab at nfbnet.org>
wrote:

> I would check with RSA!  I would be surprised if agencies weren't
> required to make their policies public!
>
> I will ask our policy person tomorrow also.
>
> Dave
>
>
> At 09:45 PM 1/9/2023, you wrote:
> >Hello everyone,
> >
> >In one state, not Vermont, we've been having conversations with a
> >state VR agency about how the agency refuses to make its VR policies
> >public. The agency has a habit of using its policies to justify not
> >doing something but then never publishing its policy manual. The
> >state does make public its regulations in the state regulatory code,
> >but I'm pretty sure this is technically different, especially when
> >the agency staff insist that the state VR policy manual is not for
> >public distribution. This would be a pointless statement if it were
> >the same thing as the published regulations.
> >
> >I'm trying to figure out how to articulate what the difference is
> >between agency policies and state regulations. My best attempt is as
> >follows, but please help me out if you think you can:
> >
> >##
> >Regulations create a set of rules that must be followed in a program
> >of government and any agency which runs such program. Agencies make
> >their own policies to carry out the functions of the agency (deliver
> >the program), and the policies set by the agency must not contradict
> >the regulations of the program placed on the agency.
> >##
> >
> >To me, it feels like they should be obligated to make the policies
> >of their VR program public. Even the Client Assistance Program in
> >this state doesn't have a copy of the VR agency policies, which
> >seems ridiculous.
> >
> >Thank you,
> >
> >Justin
> >
> >
> >Justin Mark Hideaki Salisbury
> >he/him/his
> >
> >Phone: 808.797.8606
> >Email: President at Alumni.ECU.edu<mailto:President at Alumni.ECU.edu>
> >LinkedIn: https://www.linkedin.com/in/justin-salisbury
> >ResearchGate: https://www.researchgate.net/profile/Justin_Salisbury
> >
> >
> >"Once social change begins, it cannot be reversed. You cannot
> >un-educate the person who has learned to read. You cannot humiliate
> >the person who feels pride. You cannot oppress the people who are
> >not afraid anymore."
> >
> >Cesar Chavez
>
>
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