Very good analysis by Mike Byington
for a Commission or Separate Agency for the Blind
Date: Tue, 27 Apr 1999 13:10:34 -0500
Taken the ACB-L Mailing List:
Anyway, I want to respond to Ron concerning his question about commissions
for the blind or separate agencies as opposed to combined agencies. He
raises some very good and fair questions, but I believe the answer is that
there are some very good reasons why separate agencies or commissions are
the better form of structure for delivering services to people who are
blind.
First of all, it is important to acknowledge up front that there are both
good and bad commissions and separate agencies for the blind. Being
separate does not insure being better. There are also some pretty good
agencies which are considered to be combined agencies in addition to a lot
of pretty bad ones.
The issue becomes one of how much control blind consumers have to correct a
bad agency if indeed the agency needs improvement. There are usually fewer
layers of administration between a commission for the blind or separate
department for the blind and the Governor or Legislative process than there
is in the combined agency. It is thus easier to get the attention of people
who have some power when there are problems. Separate agencies and
commissions for the blind usually have budgetary control over their money
to a greater extent than is the case in the combined agency. This means
some generalist administrator who knows nothing about blindness has less of
a chance of coming in and making arbratrary budget decisions without
adequate knowledge or background about what actually matters in the
rehabilitation of blind citizens. Separate agencies and commissions for the
blind usually are able to submit separate plans to the Rehabilitation
Services Administrations. These plans are specific to blindness and to what
is needed by blind citizens.
Even given the differences noted above, however, there are not actually two
types of agencies, separate and combined. In making comparisons divided
into just these two categories, we are not comparing like quantities on
each side. A number of research projects have been done where the structure
of blind services delivery systems has been evaluated. These have resulted
in findings that there are at least six different structures for the
delivery of blind services operating in the United States. Not all
Commissions for the blind or separate agencies have the same number of
administrators between themselves and the governor and legislature. There
are combined agencies which may have no more bureaucracy above them, and
maybe even a few who have less than is the case with some of the programs
which are called commissions. There are combined agencies with separate
blindness units where those units have quite a bit of budgetary control and
autonomy, and then there are combned program with no separate units at all
or with weak separate units having no budgetary control. There are combined
units which nonetheless submit separate blindness plans to the
Rehabilitation Services Administration, although most combined agencies
submit combined plans.
ACB has been attempting to help its affiliates maintain the greatest amount
of consumer control possible in state service delivery systems for the
blind. In instances where this has ben translated as defending a commission
or separate agency over a combined services concept, what has really been
happening is that, whatever system of services has been in place in a State
is being threatened with replacement by a system which would give blind
consumers less control and less to say about the services they receive.
There are combined agencies with separate units where ACB has helped with
the defence of the separate unit because even that separate unit was about
to be taken away. This is the current situation we have in my own State.
The bottom line is that the issue is not the name of the agency structure.
Whether the agency is called a bureau, a commission, a department, or a
division is less important than a number of specific factors which seem to
make services for the blind work best. I will try to outline what some of
these factors are. In looking at an agency, it is good to ask the following
questions. If the answer is yes, it is important to defend those yes
answers and see to it that these factors stay in place. If the questions
are answered no, then it is probably a good idea to work for systems change
to turn the no answers into yes ones.
1. Does the blind services agency get to propose its own budget to the
Governor and/or Legislature of the State? (Many combined units must propose
their budget to other generalist administrators who then propose their
version of the blind services budget to yet other generalist administrators
and on up a complicated line until the budget gets to the power brokers in
an unrecognizable form.)
2. Are the people who supervise the blind services administrator in a State
appointed by the governor and perhaps inclusive of the governor? (In
combined agencies, again, the supervision of the blind services unit
usually happens by way of a generalist administrator.)
3. Are at least a majority of the people who are in charge of the agency
which serves blind people in the State blind or legally blind themselves?
(Some of the best commissions for the blind in the country have a
requirement that a majority of the members are blind or legally blind.
Also, many of the separate agencies are required to have the governor
and/or governing body appoint a person to run the agency who is qualified
in the field of blindness, and often there is language strongly encouraging
that the head of the agency be blind or legally blind. In many combined
agencies, the blind services unit head is a generalist who has worked their
way up through the system. They may consider running the blind services
agency to be just another rung in the ladder and to be interchangeable with
running a food stamp program, foster care program, program for the
retarded, the mentally ill, etc.)
4. Is the group of consumers which provides input to the agency made up of
blind consumers? (In many combined agencies, the Rehabilitation Services
Council provides consumer oversight, and this committee is made up of all
disability groups. There is thus no true input from blind ciizens.)
5. If there is specific consumer input from a group specific to blindness,
is action relating to this input legislatively mandated? (Rehabilitation
Services Councils have certain duties, such as signing off on the State
Plan. These duties are mandated in the Federal Rehabilitation Act. In some
states, there is state-specific legislation which sets forth duties for a
blind services council. Separate plan States are mandated to have a council
specific to blindness via the federal legislation.
6. Is a separate rehabilitation plan specific to blindness submitted? (This
relates to the last question. The development of a separate state plan on
blinness allows for more spefici input as to the needs of blind citizens.
In theory, combined unit states can submit separate plans, but most do not.
My State, Kansas, used to submit a separate plan even though it was a
structurally combined delivery system, but it made the administrative
decision a few years ago not to do so any more.)
7. Are rehabilitation services for the blind, rehabilitation teaching for
the blind, residential rehabilitation for newly blinded individuals, the
business enterprises program, any State operated national industries for
the blind affiliated programs, older blind services, library services for
the blind, the State school for the blind if there is one, orientation and
mobility services for the blind, prevention of blindness programming, older
blind services, etc. all under the supervision of the State blind services
agency? (In some states there is commission or freestanding agency forthe
blind, but many essential services needed by blind individuals do not exist
or are not under the control and supervision of the separate agency or
comission. They are instead supervised by other bureauracies in the state.)
8. Does the state agency serving blind have control, in cooperation with
blind consumers, or the equipment purchased to assist blind citizens? (Even
in some states where strong commissions or freestanding agencies exist, the
state purchasing division or department and not the blind services agency
has control over equipment decisions, bid specification writing, equipment
bidding and ordering, etc. The system generally works best then blind
people and the people who know about blindness are in charge of such
things.)
If the answers to all eight of these questions can be turned to yeses, then
it does not make any difference whether the blind services agency is called
a commission, a department, a bureau, a cumquat, or a purple
doodeckaheedra. ACB is working to make certain that agencies for the blind
havethe autonomy to operate in the best interests of blind citizens.
Florida may still call itself a commission or a department, but I know that
changes have been made in Florida State government which have taken away a
great deal of autonomy over the past couple of years. Carl McCoy had a lot
more autonomy in Florida than the current director does. California may be
officially a combined agency, but ts blind services personnel have more
autonomy than is the case in many other combined States. All of these
things must be considered when evaluating ACB's overall position.
One last humorous note. Florida and Texas are two States where
freestanding, autonomous services for blind people are taking some of the
worst hits. Maybe the problem in those states is that we need to get blind
services out from under the Bushes.
----------