From: Jamal Mazrui 
Subject: An NCD statement on some rehab issues (Forward)
Unfortunately, some misleading information about the National
Council on Disability and rehabilitation policy issues has been
broadly circulated over the Internet.  Be assured that there
is another side to these issues that deserves your attention if
this is a subject of interest.  We welcome any questions and
appreciate your support in helping to correct misconceptions that
others may have inadvertently acquired.
Jamal Mazrui
National Council on Disability
Email: 74444.1076@compuserve.com
Phone: (202) 272-2004
TTY: (202) 272-2074
Fax: (202) 272-2022
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        A STATEMENT BY THE NATIONAL COUNCIL ON DISABILITY
             EXPLAINING ITS PROCESS AND ACTIONS ON
THE REHABILITATION ACT ISSUE OF "SEPARATE AGENCIES FOR THE BLIND"
             AND THE REHABILITATION ACT PROGRAM OF
    "INDEPENDENT LIVING SERVICES TO OLDER BLIND INDIVIDUALS"
                         March 28, 1997
                          INTRODUCTION
The statutory mandate of the National Council on Disability is to
advise Congress and the President on disability-related policy.  In
its analysis of federal policies and programs, the NCD brings
several principles to its deliberations:  consumer control and
empowerment; equity for people with different disabilities; a
cross-disability perspective; a preference for integration;
effectiveness and efficiency of service delivery systems.  In some
cases, the values we hold dear are in conflict, and the course of
action we should take is not clear.  Such is the case with
government administrative structures that serve individuals who are
blind or visually impaired, where separate may not mean equal or
constructive.  Since we have learned that some misleading
information has been circulated that raises questions about our
deliberations in this area, we have prepared this document to
explain the rationale for the Council's recommendations and the
steps we took to obtain consumer input in their development.
    SEPARATE VOCATIONAL REHABILITATION AGENCIES FOR THE BLIND
                           Background
In the public vocational rehabilitation (VR) program, the federal
government makes a significant administrative distinction between
visual disabilities and all other disabilities.  Each year, about
half the states submit two VR grant applications for the 80%
federal matching funds:  one to serve individuals with disabilities
in general and one to serve blind persons in particular.  For
several years, it has been a matter of public debate in the
disability community whether these separate service delivery
structures actually perform better or worse for blind people and
whether they are equitable to people with other disabilities.
As part of its legal mandate to improve enlightened, coordinated
approaches to disability policy, NCD sought to develop
recommendations on this as well as other issues during the current
process of reauthorizing the Rehabilitation Act.  We did this as
part of a series of recommendations on the Rehabilitation Act,
following public hearings held jointly with the Rehabilitation
Services Administration (RSA) of the U.S. Department of Education.
The Council knew that controversial issues would arise, which might
be politically easier to avoid altogether.  Yet with present
Congressional emphasis on federal accountability for results and
elimination of duplication, and considering our desire to provide
meaningful guidance to Congress on thorny issues, we felt a
responsibility to proceed as objectively as possible in conveying
our answers to difficult, persistent policy questions.
                Community Input and Deliberations
In various ways, we solicited and received substantial input from
consumers and professionals with an interest in this subject,
including discussion of the particular recommendations we were
considering.  It should be noted that the Council has, within its
board and staff, individuals having both professional and personal
familiarity with relevant rehabilitation issues.  Our communication
channels included a November meeting with the Director of Public
Policy at National Industries for the Blind, who also serves as
treasurer of the American Council of the Blind; email
correspondence with the Director of Governmental Affairs at the
National Federation of the Blind; a review of position statements
by various organizations of and for blind persons; published and
unpublished research on the subject; and communications with
research directors at the American Foundation for the Blind and the
Mississippi Research and Training Center on Blindness and Low
Vision.  We also had numerous dialogues with the President of the
National Council on State Agencies for the Blind, and reviewed
statistics he provided.  Additionally, we reviewed the
rehabilitation position paper of the National Council on
Independent Living, and spoke with officials of the organization to
clarify their position.
The extensive process of gathering and analyzing input from various
sources led the NCD Public Policy Committee to conclude that, on
the whole, research to date neither justifies nor invalidates the
claim that separate VR agencies result in superior employment
outcomes for individuals with visual disabilities, especially when
the emphasis is on placements in the competitive labor market.
Published research on the issue supports this conclusion, as well
as some frank statements by blindness leaders.  Without guidance
from empirical research, the decision about separate agencies is
based primarily on management and philosophical reasons.  Without
enumerating here the multiple reasons on both sides of the issue,
the Public Policy Committee concluded that, on balance, the
argument for a single VR administration was more persuasive, at
least at the federal level.  In deliberating this topic, NCD was
aware that some professionals who work for separate agencies (or
who have contracts with them) might understandably feel concerned
about the possibility of administrative consolidation.  Such
dilemmas naturally arise when significant policy change is being
considered.  Still, we believed that our policy recommendations
should be motivated mainly by what is best for the intended
beneficiaries of the public VR program:  people with disabilities
who need help preparing for the world of work.
Although the value of separate administration based on disability
type was being questioned, the need for separate direct services
according to disability was never in doubt.  Such services, e.g.,
instruction in braille or cane travel, are often provided by
specialized nonprofit organizations that contract with state VR
agencies.  Under the "client choice" provisions of the
Rehabilitation Act, consumers can choose among competing qualified
providers with funding supporting that choice, irrespective of
whether the state has a separate or combined VR administrative
structure.
Mindful of the need for specialized services to blind and other
disability constituencies, our proposal on the Rehabilitation Act
explicitly required the federal government to assure that funding
for direct services to blind consumers was not reduced if a state
combined its blind and other disability administrations.  We
further made it clear that states were not mandated to combine
agencies:  a single VR application would be accepted from each
state, but each state could configure its administration however it
wished to best meet the needs of its citizens, just as it does with
other programs.  During the RSA public hearing process, we heard
extensive testimony that the specialized needs of various
underserved disability groups were not being met.  To strengthen
the commitment to specialized disability based services, our
proposal added a requirement that states include specialized
service plans within their VR grant applications to the federal
government, including but not limited to, plans to meet the
particular needs of blind and visually impaired persons, deaf
persons, people with multiple chemical sensitivities, and
individuals with mental illness.
Since the field generally agrees that a majority of blind persons
have secondary disabilities, it seemed sensible to address the
specialized needs of consumers by encouraging an integrated
approach that responds to each particular need, rather than
separating a person's rehabilitation processes based on a single
trait.  Since the unemployment rate of blind people remains at 70%
after decades of  separate administrative structures, NCD was
convinced that alternatives should be considered.  It should be
noted that as citizens of America, not just persons with
disabilities, we were also concerned about the need to balance the
budget for the sake of future generations, including future
generations of individuals with disabilities.
                         Recommendations
Although we discussed these recommendations by phone and email with
blindness advocates over a period of months, their organizations
remained united and vocal in their opposition to the risk of policy
change.  Although we ultimately agreed that the research data was
inconclusive, an effort to reach a compromise position with the
blindness organizations proved unproductive.  After public
testimony at our board meeting, the Council voted to withdraw its
original proposal in favor of the following recommendation:
The National Council on Disability recommends to Congress that it
ask the General Accounting Office to conduct a study evaluating the
performance, benefits, and costs of separate versus combined
vocational rehabilitation agency structures for individuals who are
blind or visually impaired.  The study should include meaningful
input from people with disabilities, especially persons with visual
disabilities.  The final report should be published in sufficient
time to permit consideration of its recommendations during the next
process of reauthorizing the Rehabilitation Act, scheduled for the
year 2002.  This report should describe its methodology and
recommendations as a matter of public record.
We believe that a study would be especially timely during this
current period of reexamining government service delivery
structures and weighing alternatives.  Whatever conclusions GAO may
reach, they would inform policy planning that affects individuals
with disabilities, and would allow public officials who have
questions about service delivery structures to guide their thinking
by outcome-oriented research.  The results would also permit much
advocacy resources of consumer and professional organizations to be
spent on debates other than this one, year after year.  Of course,
traditional government approaches in other disability areas should
be similarly analyzed during their reauthorization processes.
INDEPENDENT LIVING SERVICES FOR OLDER INDIVIDUALS WHO ARE BLIND
                           Background
Title VII of the Rehabilitation Act provides guidelines and funding
for programs to provide independent living services to individuals
with disabilities.  Most of this title reflects the perspectives of
consumer control, systems change, and cross-disability delivery of
services.  The title also contains Chapter 2, which provides
services to older blind persons with visual impairments.  In
contrast to most of this Title, these services are generally
provided and administered by the state rehabilitation agency, with
advisory, but not controlling input by consumers.
                Community Input and Deliberations
In addition to the input described previously, NCD has heard
through numerous sources about the lack of independent living
services for older people with disabilities.  As the population of
people with disabilities ages, e.g., polio survivors or persons
with spinal cord injuries, its needs change for services and
support.  Additionally, as the entire population ages and the
majority of people over 65 experience some type of long term
disability, the need for home-based services grows.  Clearly, there
is a need for expanded services to older individuals with
disabilities, not limited to those with visual impairments.
Independent living centers have the capacity to meet needs for long
term services by leveraging existing resources oriented toward
acute care.  Their approach, which combines systems advocacy with
service delivery, has been shown to broaden and augment services to
people with disabilities by making mainstream public services
accessible, such as senior citizen centers.  In contrast to the
traditional rehabilitation model, consumers of independent living
centers are empowered to make changes in their lives as they
interact with peers at every level of center structure.
                         Recommendations
Considering the philosophy of consumer control and empowerment in
service delivery systems, equity and fairness to other disability
groups, and the need for expanded services to older individuals
with disabilities, the Council adopted the following
recommendation:
The National Council on Disability recommends to Congress and the
President that the federally-funded program for older blind
individuals under the Rehabilitation Act be expanded to become a
cross-disability grant offered to qualified centers for independent
living, as defined elsewhere in the Act, and that its funding be
increased in order to effectively meet the needs of older Americans
for independent living services.
                         CLOSING REMARKS
The National Council on Disability takes seriously its mandate to
hear consumer views and to promote the values of inclusion,
independence, and empowerment in public policy.  We remain
committed to improving outcomes and processes experienced by
persons who are blind or visually impaired.  Some examples of this
commitment include our support for access to the graphical user
interface, detectable warnings on subway platforms, tactually
identifiable currency, better work incentives for Social Security
beneficiaries, and useable information on federal programs and
processes.
The Council has a broad mandate to weigh the interests of a wide
variety of constituencies in the context of policy planning guided
by principles of inclusion, independence, and empowerment.  We
believe we have wrestled responsibly with current rehabilitation
questions and contributed sound proposals to the policy making
process.  Often, such challenges are not easy.  Let us all protect,
however, the independent role of the National Council on Disability
in developing recommendations on public policy, holistically
considering people of all disabilities, ages, and backgrounds.
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