Separate Agency for the Blind: Best Practice for Success
	by James H. Omvig
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	From the Editor: Ever since Dr. Jernigan went to Iowa in 
1958 to transform the worst agency serving blind people in the 
country into the best program anywhere, we have known how 
important it is for effective rehabilitation of the blind to be 
conducted by a separate agency. "Because separate agencies do a 
better job" is not a sufficient reason to give legislators being 
lured by the siren song of consolidation. Jim Omvig is one of the 
people whom Dr. Jernigan first rehabilitated and then trained to 
assist him to do his work in Iowa. Jim is a blind attorney who 
has now been involved in rehabilitation for more than thirty 
years. He wrote the following paper for several Arizona 
legislators some years ago. It is as relevant and helpful today 
as it was then.
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	Background
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	Every state has some form of vocational rehabilitation and 
training program for its blind adults, for which the federal 
government pays approximately eighty percent of the cost. The 
blind receive these services in one of two ways: either from a 
large general rehabilitation agency, which tries to serve people 
with all types of disabilities, or from a separate agency for the 
blind, which presumably has the requisite expertise and serves 
only blind consumers. Then in turn, if a separate program for the 
blind is established, it may be either a section or division 
within a much larger umbrella agency, or it may be a completely 
separate and independent agency, directly accountable to the 
governor, the legislature, the blind, and the general citizenry. 
It is up to each state to determine which governmental structure 
is best suited to meet the particular needs of its blind 
citizens.

	Congress has recognized that the problems of the blind are 
unique and therefore that meaningful services for the blind are 
distinctly different from rehabilitation and related services for 
people with other disabilities. Accordingly, federal law permits 
the states to establish a completely separate, independent agency 
for the blind if they wish in order to address these unique needs 
in a comprehensive, specialized program. The relevant federal law 
is Title 29 USC, Section 701 (a) (1) (A) of the Rehabilitation 
Act of 1973, as amended.

	Experience has shown that the blind always have the best 
possible chance of receiving quality services when such services 
are delivered through an independent, separate agency for the 
blind. There are numerous reasons for the tremendous success of 
these programs. They are outlined in the section below.
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	Why a Separate, Independent Agency for the Blind?
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	Rehabilitation of the blind has more in common with 
independent living services for the blind, services for the older 
blind, orientation and adjustment training for the blind, sight 
conservation, and sheltered employment for the blind than it does 
with rehabilitation of other disability groups or the socially or 
economically disadvantaged. Likewise small business enterprise 
programs for the blind have more in common with rehabilitation 
services for the blind than they do with other types of small 
business programs.

	Even so, some argue that the blind should be lumped together 
with other disability groups or served through some giant 
umbrella agency to achieve integration and coordination of 
services. Until you think about it carefully and have certain 
facts presented to you, this might sound like pretty good, 
logical thinking.

	There is, indeed, a need for coordination and integration of 
state services for the blind, but terminology should not be 
confused with reality. If, for instance, a state has a supervisor 
of highway construction, a supervisor of elementary education, a 
supervisor of pest control, and a supervisor of health and 
welfare, it does not follow that integration and coordination are 
achieved by creating a Department of Supervisors and lumping all 
of these people and functions together. Nor is any real 
integration or coordination achieved by establishing a Department 
of Health and Highways. Health is one function, highways another, 
and they cannot meaningfully be integrated.

	If such a department is established, all that can be 
accomplished is to superimpose a costly administrative hierarchy 
upon the two departments. They will still remain separate 
functions whether they be called departments, divisions, 
sections, bureaus, or whatever. In fact the administrative 
hierarchy will be detrimental and will only cause inefficiency 
and waste in such a situation.

	Relating all of this to the blind, fragmentation is 
increased rather than helped by putting all of the services for 
the blind into a division of a super-department. What is needed 
is common sense rather than textbook theory and neatness of 
somebody's organizational chart. Sound reasoning tells us that 
the various services for the blind complement and supplement one 
another and form one unique entity. They are only very slightly 
and incidentally related to services for people with other 
disabilities or other disadvantaged groups despite the similarity 
of terminology.

	The people who administer rehabilitation and other services 
for the blind should be able to administer the entire package, 
and they should not be distracted by other duties. Furthermore, 
they should not be responsible to people who have other program 
interests and who may, therefore, subordinate the needs of 
programs for the blind to other interests or pet projects. At the 
same time the professional agency for the blind administrator 
must be responsible to some authority as a check and balance and 
a testing ground for his or her judgment. This authority should 
be a lay board, preferably one containing a number of blind 
people themselves--people who know firsthand what the services 
are and what they should be to achieve best results.

	In those states where separate, independent agencies exist, 
the governor (often with the advice and consent of the Senate) 
appoints the members of the lay board. The board hires the 
director, and the director then hires other staff and provides 
the leadership and day-to-day management of the program.

	On the other hand, if the administrator of programs for the 
blind is responsible to the head of some super-agency or even 
directly to the governor, he or she is really not responsible to 
anyone, for these people are not knowledgeable about what is 
needed and are likely to be extremely busy with other matters. 
Thus an independent department or commission for the blind 
administering all state services for the blind is clearly best 
suited to meet the requirements for a good program.

	It is, of course, possible to have an inefficient 
independent agency just as it is possible to have an inefficient 
program under any other type of structure, but the odds are much 
better for good programs if you have the independent agency 
system. This all depends, of course, upon the caliber and 
expertise of the people who do the administering. However, if all 
other things are equal, an independent commission affords the 
best organizational structure. Let me be more specific about what 
I have been saying. Even though the same words are sometimes used 
when we talk of various service programs, the mere use of such 
words is where the similarity ends. For example, rehabilitation 
of people using wheelchairs or of the deaf is in no sense the 
same process as rehabilitation of the blind. And this is equally 
true when discussing a hundred other types of rehabilitation. In 
other words, the problems facing blind people are unique. From 
this it naturally follows that those who are hired to provide 
rehabilitation services for blind people must possess a unique 
reservoir of knowledge specifically related to the problems of 
blindness, if effective programs are to be carried on. If we are 
to be truly effective, we need experts whose training and 
experience relate specifically to the problems of blindness. It 
is sheer nonsense to expect any human being to be knowledgeable 
about and to possess the necessary expertise to deal effectively 
with all of the problems of everyone needing various types of 
rehabilitation services.

	"But," it is sometimes argued, "it is desirable to have the 
uniformity of administration found in a large super-agency." This 
argument might be made with considerable validity for producing 
license plates or for regulatory agencies--licensing, permits, 
etc. Its validity is much more doubtful, however, with respect to 
human-service programs, which for maximum efficiency must operate 
on a person-to-person basis. As I have said, neatness of 
somebody's organizational chart and uniformity of administrative 
pattern must not be permitted to obscure the human element. In 
fact, there is considerable evidence that bigness itself is a 
negative, not a positive factor.

	"But," it is further argued, "programs for the blind and 
others which sound similar should be merged into large 
departments so that they will not function in a vacuum and be too 
independent." An interesting point can be made here. The best way 
to hide a tree is in a forest. A separate, independent agency for 
the blind with a lay board would always operate in the spotlight 
of inescapable scrutiny, accountability, and responsibility. If 
its programs are not functioning well, the blind can and will 
rise in protest, and there can be no possibility of evasion, no 
shifting of responsibility, no passing the buck. There is no 
hierarchy of administrators, divisions, or bureaucrats to stand 
between unhappy blind consumers and the people employed to give 
them service.

	On the other hand, if you want real independence and lack of 
accountability, turn that agency loose in the mazes of 
bureaucracy as a tiny segment of a super-agency. In the hide-and-
seek of the intricacies and technicalities and divided 
responsibilities within a giant agency, no governor and no 
legislator can track it down. In the corridors of bureaucracy the 
full-time professional administrator is king, and the layman, 
whether governor, legislator, or average citizen just seeking 
service, is subject.

	Establish a separate, independent agency for the blind with 
a lay board appointed by the governor and you have checks and 
balances and the maximum incentive for that agency to do a good 
job. Submerge services for the blind in a large department, and 
you give that program a blank check of independence and 
authority--independence and authority which it should neither 
want nor have.

	Further, when you place services for the blind in a larger 
department of government, this will necessarily divert the 
energies and talents of administrators whose training, 
experience, and main professional concerns should be strictly 
with the blind. Can anyone really doubt what the main 
professional concerns of the high-level administrators of a 
giant, umbrella agency are? I can assure you that those concerns 
have nothing to do with blindness.

	We who are blind do not wish to divert the energies or 
talents of anybody, nor do we wish the agency for the blind's 
energies and talents to be diverted, watered down, or shifted 
from the course of giving the best possible service to the blind 
of the state. This is probably one of the principal reasons why 
many states have separated their services for the blind from 
large departments.

	"But," as a last-ditch effort, it is argued by the 
uninformed, "can't we save a lot of state and federal money if we 
just lump together these seemingly related programs? We can avoid 
duplication and save a bundle." While this sounds logical and 
responsible, the fact is that, where this re-organizing takes 
place, the same program administrators and managers are generally 
retained, but in addition a new and costly level of 
administrators is imposed to supervise the original program 
managers. This practice costs more, not less.

	Finally, several years ago an independent study (The Mallas 
Report) was made of service delivery systems to determine which 
type was best suited to provide quality rehabilitation and 
related services for the blind. The study concluded that the 
separate, independent agency with a lay board appointed by the 
governor is best. In an interview the researcher said, "Where 
reorganization of services for the blind has taken place on the 
basis of the economy-of-scale principle, its proponents have sold 
the legislature and the Governor on statements such as, `This 
will be more efficient and economical. It will let us get more 
mileage out of every tax dollar.' As a matter of fact, in every 
state where such a reorganization has taken place, the prestige 
and level of operation of the agencies serving the blind have 
been downgraded." This study also makes another revealing 
finding. "In general programs for the blind which fall under 
rehabilitation departments and umbrella agencies have the least 
effectiveness in developing and utilizing necessary financial 
resources."

	In conclusion, we who are blind want the opportunity to 
receive services aimed at returning us to the mainstream of life. 
We want to be taxpayers, not tax users. The separate, independent 
agency for the blind offers us the best chance for meaningful 
programs. We are willing to work, and work hard, but we will also 
dare to dream in order to develop and protect our separate 
programs.
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