[Rehab] Policies vs. Regulations

[Deborah Allen]

Hi Justin,
You bring up a good point here. I don’t think the problem is limited to one state. Agencies also tend to have separate policies, some public, and some just for staff. The other issue is all of the unwritten expectations.
Kind regards,
DEBORAH


Sent from my iPhone

> On Jan 23, 2023, at 7:16 PM, Richard Davis via Rehab <rehab at nfbnet.org> wrote:
> 
> 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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