Attachment 2.3

Summary of the Public Comments on the State Plan and its Supplement and the State Unit's Response to the Comments

The Virginia Department for the Visually Handicapped (DVH) conducted public meetings in Richmond, Virginia on March 30, 1998; in Norfolk, Virginia on April 1, 1998; in Bristol, Virginia on April 6, 1998; in Arlington, Virginia on April 8, 1998; in Winchester, Virginia on April 14, 1998; and in Roanoke, Virginia on April 15, 1998, regarding the amendment of the State and Strategic plans. The agency received substantial input from those meetings as well as written comments.

Public Comment 1:
I like what DVH is doing in the area of deafblind services. I think it is good you are providing some services for this population at VRCB. I believe there is even more that can be done.

Agency Response 1:
We are trying to involve more individuals who are deafblind in supported employment and special programs at VRCB, such as the one-week program made available with Strategic plan funds. These are positive steps toward improving employment opportunities for this special population. The agency will continue to strive to further improve services for deafblind individuals.

Public Comment 2:
There are not enough training programs available at VRCB. The vocational training programs that are here are very narrow in focus. I think there should be more general training for jobs.

Agency Response 2:
The primary objective of VRCB is to assist persons who are blind to acquire the necessary adaptive skills to enable them to successfully participate in vocational training and/or employment in the community. The Customer Service Representative (CRS) is the only vocational training program provided directly by VRCB. In order to be successful, it needs to remain narrowly focused. VRCB concentrates on preparing blind and visually impaired persons to access vocational training in the community. VRCB provides customers with work experience with employers in the community and will continue this activity for individual customers in the future. Due to the small size of VRCB, we are unable to offer additional vocational training programs.

Public Comment 3:
The agency is not placing enough emphasis on selling the Randolph-Sheppard program to its customers. Counselors and other programs, like VRCB, are not promoting the program. We talk about unemployment for blind people being more than 70%, but yet we can't fill all of the available stands. In fact, the number of operators in Virginia has decreased over the past few years.

Agency Response 3:
The agency believes the Randolph-Sheppard program offers an excellent employment opportunity for those customers who choose that as their vocational objective. A representative from the Randolph-Sheppard program is given time on the agenda at most VR staff meetings. Due in large part to advances in technology, there are more job opportunities available to blind workers than ever before. We must allow customers to make choices regarding their employment goals. We will emphasize to counselors to continue presenting the Randolph-Sheppard program in a positive manner as a vocational option. Counselors will be encouraged to use Randolph-Sheppard facilities for summer work experience for interested customers. The Randolph-Sheppard manager and the Business Opportunities for the Blind (BOB) will be encouraged to work with VR in marketing the Randolph-Sheppard program.

During the five-day evaluation at VRCB, all new students are familiarized with the Randolph-Sheppard training program. It is up to the individual student to decide if he or she is interested in pursuing that program, either during the evaluation or later. Most students are already aware of this program before coming to VRCB.

Public Comment 4:
There is a need for more special computer training programs in the evenings and weekends for people working and who cannot go to VRCB during weekdays. There had been an increase in the availability of these special programs, but they have been dwindling. The agency has all these technology labs, and it is a shame not to utilize them if there are individuals needing training. The special training programs could be staffed by regular staff or volunteers.

Agency Response 4:
VR provided additional funding a couple of years ago for part-time staff to help make technology more accessible to individuals unable to access training during the day. If the training is not as accessible as it was earlier, we need to identify the reason and address the problem. DVH wants to be a resource for blind individuals who are working and addressing "changing technology" in the workplace, even if VR cannot pay for it.

Three to four times a year, VRCB provides specialized computer trainingto groups of people on Friday nights and Saturday for those who are unable to access training during the week. What is offered is based on the needs and interests of the largest number of people at the time.

There has been limited response from the community to evening training opportunities. A computer/braille technology lab assistant has been available two evenings a week for the last two years. A few individuals with visual impairments from the community have participated for brief

periods. Transportation at night tends to be the barrier most potential participants have identified. Current VRCB students, who come for extra practice in the evenings, are the primary beneficiaries of this service. The extra practice seems to decrease the length of time these individuals need to stay at VRCB.

Saturday seminars have achieved better response. VRCB can teach ten students at a time in Saturday seminars who have similar needs and abilities. Participants have included visually impaired individuals who were VR customers, others who were not currently agency customers, and non-visually impaired individuals who wanted to provide technology instruction to visually impaired students, employees, etc. Our major problem in offering more than three seminars a year is manpower. Identifying teachers with the expertise to teach adaptive technology to group classes and identifying funds to pay those teachers has been a problem.

Public Comment 5:
The new staff training program needs to be made more realistic by requiring more activity under blindfold. Staff participating in the training need to be treated like students. Also, experienced staff should participate in the training when there aren't enough new staff to fill available slots

in a program. The last program had to be canceled because there were not enough participants.

Agency Response 5:
DVH remains committed to requiring new staff to participate in the one-week training program at VRCB. All new staff who are hired are told participation in this training program is a condition for employment. We will discuss, with managers, strategies to ensure that all new staff training programs are utilized by either new or experienced staff.

Public Comment 6:
I think some trainees are forced to waste time at VRCB. I am familiar with one individual who wanted to be a dietitian and was placed in the vending stand evaluation for five weeks. Looks like that was wasted time. Why not place her in a hospital or some place where she could get some practical experience?

Agency Response 6:
Training for students at VRCB is done on an individual basis. Students are encouraged to be an active participant in the decisions being made about their classes. If a student has concerns with their training, these concerns should be brought up with the VRCB instructor involved and the VRCB counselor.

Public Comment 7:
I commend the agency for purchasing computers and adaptive equipment for customers. In most instances, I am sure it is used for the purpose it was intended to be used for; however, those not using them for the reason they were purchased, I think the agency should get them back.

Agency Response 7:
The agency has a policy regarding when computers and adaptive equipment can be purchased and when such equipment can be donated to the customer. DVH will review these policies on purchasing and donating equipment.

Public Comment 8:
I have some concern that counselors are not being consistent in when they will buy an adapted computer for a customer. My counselor would not buy me a computer, but another individual in the same program at VRCB was purchased a computer. I feel like I fell behind in my keyboarding skills because I didn't have the computer to practice on while I was waiting at home between evaluation and my training at VRCB.

Agency Response 8:
VR services are individualized to assist an eligible customer achieve an employment outcome. Therefore, each Individualized Written Rehabilitation Program (IWRP) may be different. However, individuals in similar situations should be treated similarly. This situation will be discussed with the regional offices in question. This will also be a topic during the next VR staff meeting.

Counselors at VRCB do not buy computers. Anyone who needs a computer can be assessed for what specific types of adaptive equipment would be best for that individual. Recommendations for specific equipment are made to the referring field counselor (or rehabilitation teacher), and it is the final decision of the field counselor to purchase the equipment or not.

Any individual feeling he is being treated unfairly or being discriminated against by the agency has the right to and should file a formal complaint; and, he must be reminded about the availability of the Client Assistance Program (CAP).

Public Comment 9:
DVH needs to look into enhancing homebound employment opportunities utilizing technology. It might be good to approach it like the Randolph-Sheppard where blind people could do government contract work in the home.

Response 9:
There is no question the computer can be utilized to expand job opportunities out-of-the-home for individuals who are blind. There are already some activity in this area with banks, etc. VR counselors and technology staff are committed to working with customers who have the skills and want to seek employment in the home.

Public Comment 10:
Some customers are getting high-priced computer equipment and are not working. There are differences as to when equipment is purchased from region to region.

Agency Response 10:
Policy states that adapted computer equipment can only be purchased if it is necessary to enable a customer to participate in a vocational training program or to perform a job. Also, see Agency Response 8.

Public Comment 11:
The Randolph-Sheppard program is showing weaknesses. I hear operators talk about the lack of cleanness in the facilities. There seems to be fewer openings. The program needs support and to be a big part of the agency.

Agency Response 11:
Your concerns will be shared with the agency's Randolph-Sheppard manager and BOB. Also, see Agency Response 3.

Public Comment 12:
There is a need for more computer training classes in the evenings and on Saturdays for those working. Transportation to evening or Saturday classes would be a problem for some individuals. I suggest resolving the transportation problem by allowing the use of one of VRCB's vans and a volunteer driver to transport those who cannot get transportation to the classes.

Response 12:
Since most individuals participating in such training would not be VR customers, we probably need to seek some other resolution to the transportation problem. Regarding the issue of the need for more adaptive technology training opportunities for those working, see Agency Response 4.

Public Comment 13:
There is a need for more staff sensitivity training at VRCB in dealing with new people coming in. Some don't even know they have a post office box.

Agency Response 13:
This comment will be shared with the director of VRCB.

Public Comment 14:
I filled out a paper about a year ago asking me if I would be interested in computer training as a vending stand operator. I have never heard anything else about Saturday classes or partial help from BOB to get a computer. There is a need for more publicity about what is available.

Response 14:
This comment will be shared with the agency's Randolph-Sheppard manager, BOB and VRCB. Also, see Agency Response 4.

Public Comment 15:
There continues to be a problem with accessibility for the blind. Street curbing in many places are hard to see. I am told it would be too expensive to have a contrast in color at curbs so low vision people could see them. Also, there are still public elevators not properly labeled.

Agency Response 15:
DVH is not responsible for enforcement of accessibility laws, even though we understand your concern. There are channels for filing complaints. A DVH worker in the local regional office or someone with the Department of Rights for Virginians with Disabilities (1-800-552-3962) can provide you with information regarding steps you might need to pursue if you have a complaint.

Public Comment 16:
Every time we apply for help for our 14-year-old son, it seems we don't qualify because of our income and assets. We are not wealthy. We are paying for college tuition for our other child, are trying to save for retirement, and take care our handicapped son's needs. It takes a huge toll on us financially and emotionally dealing with the school system, insurance companies, other agencies, etc., to deal with thesedisabilities. We also spend much time doing homework with him, reading to him, and tutoring him. Middle class families are the backbone of the Commonwealth as well as the country, both financially and socially. Therefore, access to specialized services for visually handicapped individuals should not be based on financial need (parent's resources).

Agency Response 16:
DVH's VR program does not consider financial need for all services. The VR counselor can provide you with a list of those services that are not based on financial need. The agency has just completed a study to determine the impact of eliminating financial need. A final decision has not been made as to whether additional services might be excluded from the financial needs test.

Public Comment 17:
We live in an inclusive world. After exiting the school system, the clients of the department should be ready to function in their community as their typical peers do with assistance only when indicated. A person will be more likely to be successful at work if he is better prepared to follow the social rules of arriving to work appropriately dressed, on time, behaving appropriately during meals, etc. This can only be accomplished through social inclusion in school. Transition plans, starting in middle school, should include provisions for as much socialization with the real world of regular education as possible so that formal rehabilitation in those areas does not need to be done and the child learns those things naturally by living it.

Agency Response 17:
DVH agrees that transition services are very important if a student with a visual disability is to compete as a productive employee. During FY 99 DVH will emphasize transition services in special programs at VRCB, summer work, etc. Your comments will also be shared with the education services director at DVH.

Public Comment 18:
I think orientation and mobility training at VRCB should emphasize more the use of public transportation. You have to be able to use public transportation if you get a job.

Agency Response 18:
The focus of the VR program is to assist customers to obtain or maintain employment, and the agency wants to assist in eliminating any barriers to achieving that objective, including the ability to travel independently.

VRCB agrees that being able to travel independently is an important goal. All O&M students at VRCB are informed of the various skill levels of travel which are taught, including public transportation. Goals are mutually discussed and agreed upon between the student and the instructor. When a student acquires the travel skills needed to safely use public transportation, and the student agrees that he/she wants to learn to use public transportation, public transportation is taught. VRCB will continue to strive to encourage students to reach their maximum travel potential.

Presently out of 15 students receiving O&M at VRCB, one is working on public transportation, and 5 almost have the skills to start toward this goal. The others are beginners or intermediate level students. Of the total students at VRCB between July, 1997 through April, 1998, who were not involved in short term special programs, about 24% received public transportation training.

Public Comment 19:
DVH should provide bioptics for driving. Being able to drive would solve the transportation problem for those who could obtain a license.

Agency Response 19:
DVH's current policy is that bioptics can be purchased if they are needed for vocational training and/or employment. While it is an individual's choice if they also want to use them to obtain a driver's license, the bioptics are not purchased solely for the purpose of driving. This policy received support from the VR Advisory Council (VRAC) a couple of years ago. The Council will be informed that the issue was raised during the public meeting.

Public Comment 20:
I do not believe individuals should be denied VR services based on their past records.

Agency Response 20:
The agency concurs that VR eligibility decisions should not be made on past records. Medical conditions change; an individual's circumstances may change; and, federal or state policies may have changed. The only situation, where making an eligibility decision based on past records would be permissible, is if the past records were less than a year ago and there were no changes or reported changes in the available information.

Public Comment 21:
DVH needs a job placement person in Norfolk.

Agency Response 21:
The agency does not have job placement specialists in any regional office. It is very doubtful, with current funding and maximum employee levels, that placement specialists will be hired for regional offices. At this time, if additional resources were available, they would be utilized to add additional rehabilitation technology staff. Counselors will continue to have responsibility for job placement. There are resources counselors used to assist with job development/placement, such as job-coach trainers. Counselors in the Norfolk region also have an excellent resource for job placement assistance for customers provided by the Project With Industries (PWI).

Public Comment 22:
I attended VRCB and was taught how to clean and cook but was never told about the computer program. I am now back home working on a computer and doing good.

Agency Response 22:
If the VR counselor requested a computer evaluation, it would be provided. If it was not requested by the counselor and if you still wanted to be scheduled in a computer class, VRCB would accommodate you. It is up to you to make your needs and interests known.

Presently, every five-day evaluation student is placed in an evaluation schedule which includes an overview of the computer areas and the adaptive computer equipment. During that first week, or later in one's program, a student can express an interest in learning more about computers.

Public Comment 23:
I am in a community college. At first my counselor would not get me a computer. I had to work on a computer in the library. After a lot of complaints, I finally got a computer. Things seem to move too slowly.

Agency Response 23:
The agency's policy is that a computer will be provided if it is needed for vocational training and/or employment. Problems such as you describe need to be brought to the attention of the regional manager if they cannot be resolved between you and the worker. If the issue is not resolved, after speaking to the regional manager, you should contact CAP and or file a formal complaint.

Public Comment 24:
Why are there time limits for technology training if the individual feels he has not completed the training?

Agency Response 24:
If the individual has reached the point he can access training or employment, VR has met its responsibility. It is not VR's responsibility to pay for technology training to learn software, etc., that is not specifically related to enabling the customer to access training or to perform the job. Also, other factors have to be considered when determining if training will continue to be sponsored by DVH, such as whether the customer is practicing his skills between training sessions.

Public Comment 25:
If the job situation changes, can VR assist with adaptive technology training?

Agency Response 25:
Each situation would need to be considered on an individual basis. If the individual was working, it would be reasonable to expect his employer to pay for any accommodation to enable the individual with a disability to perform the essential functions of the job, and this reasonable accommodation would include paying for training by the tutor. If the accommodation is substantial or would create an undue hardship on the employer, DVH may assist. The most important thing is to not sit silently by and allow the individual to lose his job.

Public Comment 26:
Who is responsible for providing a Braille 'N Speak for children?

Agency Response 26:
The VR program will provide adaptive equipment at the end of the junior year if it is determined the equipment will be necessary for the student to participate in training and/or employment after leaving school. The Individualized Written Rehabilitation Program (IWRP) would have to include such equipment. Otherwise, it is the responsibility of the school to provide the equipment necessary to the student to participate in the classroom. Parents need to ensure that all needs of the student with a disability are addressed in the Individualized Education Plan (IEP).

Public Comment 27:
Is VRCB going to upgrade its computer training program? They don't always teach the most current software. They should also have an introduction to PC class.

Agency Response 27:
We are aware of this concern. This spring we did upgrade some software at VRCB. Upgrading is something we will do as often as practical. However, our approach is to concentrate on providing training in the adaptive equipment and to assist customers in applying that adaptive equipment to different types of software. We will never be able to keep up with the most current versions of all software. We will, however, remind counselors to let VRCB staff know what software a customer might need training on before they come to the Center. If it is something we don't have, we will try to get it before the customer arrives.

Public Comment 28:
Who determines if you have to carry a full load in college and how long you can be sponsored?

Agency Response 28:
There is no requirement that a college student take a full load unless DVH is paying for maintenance. If DVH is paying for maintenance, the student must take at least twelve hours per semester. If a student chooses not to take a full load, agency policy requires that an associate

degree be completed in 3.5 years, and part-time students cannot take longer than seven years to complete the bachelor's degree.

Public Comment 29:
VRCB should offer an introduction to computers class after a typing class.

Agency Response 29:
VRCB currently offers a 20-hour introduction to computer skills. Prior to that, students are introduced to keyboarding and basic computer operation. As their skills to access the computer through the keyboard or alternative means increases, they progress to the 20-hour class. This introduction includes one-to-one instruction in the adaptive equipment that is identified as most appropriate for that student, as well as the use of a word processing program of the student's choice (usually MS Word or Corel WordPerfect). At the end of this training, the student is eligible to continue computer instruction for another 20 hours in a group class (usually one instructor to three students).

Public Comment 30:
I went to VRCB to learn sewing but had to also learn cleaning and cooking. I was told though I didn't need to learn braille, but after I left the Center, the Independent Living Center in Norfolk taught me braille.

Agency Response 30:
It would be difficult to schedule an individual in only one class such as sewing. As far as braille, even if the evaluation does not recommend it, we would expect the Center to accommodate a request to take braille if scheduling would permit.

VRCB offers individual choices. If a student wanted to take braille, even though the instructor may not have recommended it, it would be available to him.

Each student has the opportunity, while at VRCB, to express concerns about their program either by speaking directly to instructors or talking with their VRCB counselors. Often when concerns are made known, adjustments can be made to the class schedule.

Any student dissatisfied with decisions regarding services may contact CAP for assistance in resolving the problem and or file a formal complaint.

Public Comment 31:
We need to know more about what kind of jobs can be done by a blind person and what jobs are out there.

Agency Response 31:
It is very difficult to provide you with a list of the jobs that can be done by a blind person, because there are very few jobs you can find that are not being performed somewhere by a person who is blind. An individual's interests and abilities are more determining factors regarding what he can do vocationally than whether he has vision. The DVH counselor, who knows the customer's interests and abilities, should help the individual develop vocational choices. Once the individual has made a vocational choice, the counselor and customer need to identify job development and placement strategies.

Public Comment 32:
DVH is no longer supporting me to attend college because they say I am taking too long. I knew someone who was not doing well in college and DVH went ahead and sponsored him for an $8,000 computer training program. Yet, I am told I can no longer be sponsored.

Agency Response 32:
See Agency Response 28 for guidelines regarding time for college sponsorship. The rehabilitation program is individualized, and it might be appropriate to sponsor training in another area if an individual had not been successful in the original training program. Individual circumstances have to be considered. However, any individual who feels he has been treated unfairly by the agency should contact CAP for assistance and or file a formal complaint.

Public Comment 33:
In the past DVH and customers have almost had an adversarial relationship when customers wanted something. Customers had to fight to get things purchased.

Agency Response 33:
DVH is committed to providing the necessary services to assist an eligible VR customer achieve their vocational goal. In the rehabilitation process, we offer informed choices which is outlined in policy. If a customer feels he is not being provided the necessary services to achieve his vocational goal and discussion has not resolved the issue, he should contact CAP and or file a formal complaint.

Public Comment 34:
VRCB should have someone there to show trainees around the first day.

Agency Response 34:
Presently, new students are assigned to their VRCB counselor for orientation to VRCB. VRCB provides an orientation to the dormitory on Sunday for residents arriving that day. This orientation does not include the AA building, just the dorm, recreation facilities, and cafeteria. On Monday morning counselors do an orientation with all new students at 9:00 a.m. Individual counselors orient students who arrive after 10 a.m. on an individual basis, and many are given tours. O&M instructors show people around the first week.

Public Comment 35:
An individual who was an electronic engineer went to VRCB and wanted to learn computers but could not because he could not type. People who are slow should also be given consideration in computer training.

Agency Response 35:
A person does need to learn basic keyboarding or have some other alternative method for inputting information, such as speech, to be able to use a computer. Whether at home or VRCB, they need to acquire that basic input skill. An individual's typing speed should not be a sole factor in determining whether he will be trained to be a computer user. How much speed a person needed would depend on how he will be using the computer.

Public Comment 36:
Customers are now being told, by the agency, they have a choice of who will be providing the tutor training for using computers. How will they know what is out there? I understand some are told training is available at VRCB and Goodwill but not told it is available in the home. The training would be cheaper provided in the home. For example, I have heard somewhere that it cost about $400 per day to send a customer to VRCB. Compare that with the cost of providing a trainer from the tutoring network in the home.

Agency Response 36:
The Rehabilitation Act, as amended, requires that individuals be allowed to make informed choices in selecting providers of services. With input from VRAC, DVH in 1997 developed a policy statement for VR regarding "informed choice." When there are more than one service provider, counselors are required to inform customers of their availability. While it is true it does cost to send customers to VRCB, the cost at VRCB is fixed (not a per diem charge to VR for each customer). Training in the home remains an option, but to provide such training does not represent a cost savings. Since VRCB cost is fixed, the cost for the training in the home would be an additional expense for the VR program.

Public Comment 37:
It is my understanding that, in some locations, an individual can get equipment and in others they can't. I have bioptics and use them to drive to work; therefore, they help me to be able to work. Also, would a person be eligible for computer training if they were already working?

Agency Response 37:
See Agency Responses 8 and 19. An individual who is employed may be eligible for vocational rehabilitation services. The fact that an individual is working is not reason enough to deny VR services.

Public Comment 38:
There needs to be more information about job fairs and job leads provided by DVH.

Agency Response 38:
Achieving successful employment outcomes remains a priority for DVH's VR Program. Job placement activities are emphasized with counselors. Job fairs, employer seminars, and job development are included in these activities and need to be expanded. None of us can be satisfied as long as the unemployment rate among blind persons is so great. We all need to work together to meet this challenge.

Public Comment 39:
There need to be more vendors in the Randolph-Sheppard program. The agency needs to do more to promote the program. Operators have volunteered to take summer work students to give them exposure to the program. Vendors will work with you to promote the program in a positive manner. I had some fifth grade visually impaired students to visit my facility, and they were interested. It is this sort of thing that will promote the program. Make vision teachers and young students aware of the program.

Agency Response 39:
The comment regarding making vision teachers and younger students aware of the Randolph-Sheppard will be shared with the director of the education services and manager of the Randolph-Sheppard program. Also, see Agency Response 3.

Public Comment 40:
Two years ago I made a comment about the need for medical transcription training for customers, and I was glad to see that happening. I also at that time suggested that the Independent Living Center provide computer training for blind people, and I haven't seen anything happening in that area. I also have been told that in another state blind people are working with relay services for the deaf.

Agency Response 40:
The agency has not established a formal medical transcription training program. We do recognize it as an employment option for the blind and encourage counselors to purchase that training in the community for those customers interested in pursuing it as a vocation. We have also expanded adaptive technology training opportunities in the community. This has been accomplished by expanding the tutor training network; establishing adaptive technology in some facilities, such as adult learning centers, Goodwill, Independent Living Centers, and DVH regional offices. We do recognize, as evident by comments here at other public meetings, there is still a need for adaptive technology training that is not being met. We will try to expand our efforts to meet this need even more during FY 99. Also, in Virginia there is one deaf relay center located in Norton, and there is a blind person working at that center.

Public Comment 41:
I also feel strongly about the need for more computer training. In the Fall of 1991, I mentioned to my counselor I would be leaving the state in one year to pursue a masters degree and was told I was not eligible for VR services. That counselor offered me no options. I wasn't told about any grants or scholarships that might be available. I was also not told about SSI, which I was eligible for but not aware of.

Agency Response 41:
It is unfortunate you had such an experience, and we apologize for the problems it caused you. First of all, there is no residence requirement for VR services. Any person not satisfied with a decision made by a counselor is encouraged to contact CAP and or file a formal complaint, if there is not a satisfactory resolution, after talking to the counselor. Hopefully, we are doing a better job in training counselors regarding eligibility. Also, comparable benefits information including grants, scholarships, and social security should be the kind of resource information counselors would routinely make available to customers. We provide counselors training and resources regarding comparable benefits regionally and on a statewide basis. Since we have several fairly new counselors, we will target comparable benefits during training for VR counselors in FY 99.

Public Comment 42:
I urge DVH to a presence nationally with NCSAB and organizations fighting to make sure developing computer technology is made accessible for the blind. DVH must be involved in this issue and be aggressive in forcing Bill Gates and others to make software accessible. Most jobs will depend on technology and the blind could be left behind.

Agency Response 42:
DVH agrees that accessibility must be addressed up front in hardware and software development. The agency is committed to advocate to help ensure this occurs. This is a battle that we all have a stake in and cannot afford to lose.

Public Comment 43:
I have a problem with what I understand to be DVH's philosophy about computer training. It is my understanding they will not train in Windows 95 until you have a job.

Agency Response 43:
If an individual's vocational goal requires using a computer or if the customer believes Windows 95 would make him more employable, we provide Windows 95 training. We generally do not purchase computers unless one is needed for vocational training and/or employment.

Public Comment 44:
When a member of this group was commissioner of DVH, he lead the effort to get fast food restaurants operated by the blind on military installations. We won that but nothing has ever been done about it. The agency always says it is the Attorney General's fault that nothing has been done. That arbitration should have been forced in court. This issue should be taken up with our new attorney general. Look what Minnesota did with the Veterans Affairs by forcing arbitration in court. Look at the Veteran Centers in Virginia and the potential for blind operators.

Agency Response 44:
Comment 44 involves two issues; the Department of Defense (DOD) fast food arbitration of which the DVH State Licensing Agency (SLA) was a part, and the issue with the Veteran's Affairs (VA) hospitals and the reluctance to observe the priority in the Randolph-Sheppard Law and implementing regulations. Let 's review the DOD arbitration first. Arbitration panel in its opinion did recognize that certain DOD entities, namely the Army/Air Force Exchange Service (AAFES) and the Navy Exchange Service (NEXCOM) did fail to offer the opportunity to SLAs under the Randolph-Sheppard Act the first priority in establishing national name brand fast food operations on DOD property. In the award section of the arbitration opinion, the panel required that any future openings must first be offered to the SLAs prior to a bid issuance; the same would occur for the option in the NEXCOM case where contracts will expire after ten years. The burden that this ruling places upon the SLAs is that the SLAs would have to absorb any and all costs associated with the establishment of such a facility or the taking over of an operation whose contract has expired. In addition, the SLA and any licensed vendor who operates the facility would be obliged to pay all utility costs associated with the facility, the franchising fee to the name brand company (McDonalds, Burger King, Wendy's etc.), and also pay a royalty to AAFES or NEXCOM to operate on the property. The cost of a franchise alone is in the neighborhood of $ 500,000 and the cost to furnish and install equipment is at least that amount as well. It is very questionable if any SLA in Randolph-Sheppard has the assets to establish such a venture nor is it economically feasible to expend that amount of money for the opportunity to provide entrepreneurial situation for one licensee. I am also unsure as to whether a nationally known fast food company would grant an SLA a franchise, even if the money were available, due to the fact that the nationally known companies enter into the competition on their own in DOD property and, in effect, in competition with a prospective franchiser. What must be understood, however, is that the "favorable" ruling did not involve monetary damages to the aggrieved parties nor did it provide an special advantage other that simple priority to operate "nationally known fast-food operations" on DOD property. The SLA has been contacted by NEXCOM to determine whether the SLA in Virginia was interested in operating a facility that had its lease expired; the facility was located in the Naval Operations Base in Norfolk. We evaluated the opportunity and, for the reasons previously enumerated, elected not to submit a proposal.

As far as the Veteran Centers in Virginia, DVH will revisit this issue with our current legal counsel to determine if the SLA for Virginia will again petition the VA for a satisfactory site in Salem. The decision to revisit this issue with our legal counsel is based on the rulings in the Minnesota and Maryland cases. Previously, the VA Center in Salem, Virginia rejected the SLA's inquiry regarding the establishment of a Randolph-Sheppard facility at that VA Center.

Public Comment 45:
I have several comments. I am concerned about the lack of technology for school kids. The State plan indicates that only about $40,000 will be provided for adapted technology. Waiting until the junior year for a student is too late to introduce adaptive equipment. There needs to be more assurance that IDEA and rehab are getting technology to students. We need to make more technology training available for working adults. Technology is changing in the workplace, and we need to keep up. It is an issue of job retention. Also, the State plan talked about an eight hundred number and $16,000 for another technology position. The State plan, in the VR Mission Statement, talks about competitive employment in integrated settings. I don't want the agency to lose sight of the fact that jobs like those in VIB are good jobs, and customers should have a right to chose them. Don't allow the Mission Statement and talk about weighted closure allow counselors to steer customers away from those type placements if the pay is better and they chose those settings. I also want to commend VIB for the outstanding job it is doing in developing service jobs. I hope DVH and VIB will continue to work together, and I commend DVH for putting forward the capital for those new projects. I hope that any effort to establish weighted closures will take into consideration the standards and indicators that will be issued by RSA.

Agency Response 45:
The agency agrees with your concern about students not being introduced to computers much earlier than the junior year. Parents need to force that adaptive technology is addressed on the Individual Education Plan (IEP). DVH will also try to identify other available alternatives to help address the problem. This concern will be shared with the director of education services (also, see Agency Response 26). DVH does recognize an individual's right to make choices regarding employment outcomes. Counselors will not discourage individuals from choosing VIB as an outcome, even if RSA does not recognize it as a competitive closure. We have been allowing VIB service jobs to be coded as competitive in integrated setting. The $40,000 referenced for adaptive equipment was in the Strategic plan and expenditures in that area for all DVH VR customers have far exceeded that amount. DVH will try to expand adaptive technology training for adults during FY 99 (see Agency Response 25).

Public Comment 46:
I recently attended a seminar in Washington, D.C. and the commissioner of the Washington Agency for the Blind said she used rehab money to sponsor clients to go to conventions for consumer organizations. I think the agency should be doing that in Virginia. I also see where the agency last year started requiring new staff to participate in a one-week training program at VRCB requiring the use of sleepshades. I would like to know what has been the response to that training? Has it been evaluated?

Agency Response 46:
DVH would not be in favor of routinely using Title I funds to sponsor eligible VR customers to attend conventions for consumer organizations.

The majority of participants have been very positive about the experiences during the new employee orientation; however, many have recommended the use of simulators in addition to using sleepshades so that employees become acquainted with the difficulties people have with low vision. The program has been evaluated by VRAC.

Public Comment 47:
I have a couple of masters degrees and do not need much assistance, but I do think DVH should do more to help me with job placement, like looking at my resumes. I do the work and DVH gets the credit for a successful closure.

Agency Response 47:
Providing job leads and reviewing resumes to help a job-ready customer with a college degree is a reasonable request.

Public Comment 48:
The Lions in Virginia have a program to provide Braille 'N Speaks and Type 'N Speaks to eligible students. Please share this information with customers.

Agency Response 48:
This information will be shared with counselors and education services staff.

Public Comment 49:
When DVH offers special computer classes for adults, the word does not get out. I know a lot of vending facility operators would take advantage of it if they knew about it.

Agency Response 49:
VRCB will be offering an Excel with JFW speech Saturday seminar for vendors in the Fall of 98 (exact date has not been scheduled). The seminar will be advertised through B.O.B. and the Vendor's Council. Eligible students will be those who have good keyboarding skills and, at least, a basic knowledge of Windows.

Public Comment 50:
Parents need to know more about independent living skills training available for their young children. I recently saw a parent with a small child who was unaware that her child could receive help with those skills. The parent was willing but did not know how to teach them.

Agency Response 50:
This comment will be shared with directors of the Rehabilitation Teaching and Education Services programs.

Public Comment 51:
I hope the recent directive from RSA is reflected in the VR Mission Statement in the State plan. Also, articulated clearly to counselors. There should not be a question that VR needs to consider customer choice in developing goals with the customer. Entry level jobs are not good enough if the customer have other interests and abilities.

Agency Response 51:
The agency understands the intent of RSA 97-04, and it has been communicated to counselors. That directive will be considered when the Mission Statement for VR is reviewed for FY 99.

Public Comment 52:
I want to reinforce what people have said about the Randolph-Sheppard program. It presents an excellent opportunity for customers. I think that times counselors have looked at the vending and VIB as a dumping for people they don't know what to do with. Staff should receive training that focuses on presenting the vending program in a positive light.

Agency Response 52:
See Agency Responses 3 and 39.

Public Comment 53:
I recommend that each individual receiving a low vision aid receive a written description of the aid, including the power, etc. If you don't know the power, it is difficult to have one repaired; and, it is hard to share it with someone else later if you can no longer use it. I would also like to have a low vision exchange and demonstration program in the area. Some place an individual could go and try various aids and devices.

Agency Response 53:
Your recommendation regarding the provision of descriptive information with low vision aids will be shared with the low vision program director. As far as a low vision store/exchange site, it would need to be initiated and operated at the local level by volunteers, consumer organizations, or civic organizations like the Lions Clubs, etc. DVH could provide some technical support.

Public Comment 54:
There is a need for a list of doctors to be provided so it isn't a hit or miss. We go to doctors that are not DVH low vision examiners and have to pay very high prices for low vision examinations and aids. I don't mind paying, but those prices are too high.

Agency Response 54:
If an individual is being served by DVH and needs a low vision examination, he will be provided a list of low vision examiners, by staff, that he can choose from. If this is not being done, we will make sure that all staff understand it is a requirement. Unfortunately, if an individual has not been referred to DVH before scheduling a low vision examination, there is very little that can be done by the agency. We will try to improve our effectiveness in educating doctors and other referral sources about DVH.

Public Comment 55:
Public awareness about DVH is definitely a problem. I have contacted people myself a year or two after they lost their vision, and they know nothing about DVH. Something needs to be done in this area.

Agency Response 55:
We recognize the lack of awareness of DVH services is a problem. We are a small agency and the incidence of blindness in the general population is small, which creates a real challenge as far as making the public aware of agency services. We require staff in the regional offices, as a part of their outreach responsibility, to educate potential referral sources, including doctors. A public poll conducted by VCU a couple of years ago revealed that about 45% of the public were aware of DVH services. We need individuals and consumer organizations to help educate the public about services available to blind or visually impaired individuals and the capabilities of individuals who are blind to work. The VRAC will be asked to help develop strategies to address the public awareness concern.

Public Comment 56:
I work with Access Independence, an Independent Living Center. We already are working with individuals who are deaf. We are able to loan them equipment, etc. We would like to work more with persons who are blind. Maybe we could work with individuals locally and the agency to help address the need identified regarding low vision equipment being available locally for loaned or demonstration, etc.

Public Comment 57:
Is there a possibility that a regional office can be opened in Winchester? It seems like there are a lot of blind people here not receiving services. I volunteer to work with some of them but can just do so much.

Agency Response 57:
It is very unlikely that additional DVH regional offices will be opened in the state. Financial resources are not available to open new offices. We are out stationing staff so they can spend more time working with customers in the area. A good example of this is the most recent VR counselor hired for the Northern Virginia region has been outstationed in Winchester. Unfortunately, we have had positions vacant in your area, and this has accounted for some disruption in the delivery of services. We are working to address this problem.

Public Comment 58:
Can the state provide more psychological counseling? The loss of sight creates a lot of problems. It is very hard to deal with the loss of one's independence, like driving, etc.

Agency Response 58:
The VR program can purchase psychological counseling if it is needed. Adjusting to the loss of vision, however, normally does not require psychological counseling unless there are mental health issues involved not directly related to the loss of vision. Adjustment counseling provided by DVH staff and specialized services to help the individual acquire adaptive skills to enable him to live independently and/or work are the keys to coping with the loss of vision. Other blind individuals and support groups may also play an important role.

Public Comment 59:
There needs to be more advance computer training available in the Roanoke area. I would like to be able to use the Internet and other advanced stuff. There also seems to be some disparity between training available between various parts of the state.

Agency Response 59:
The agency is trying to address computer training needs in several ways. Regional offices are encouraged to develop computer training for customers with local facilities, such as community colleges, Goodwill, adult learning centers, etc. There is special funding available to help them with this effort. Also, the computer training network is continuously being expanded. There are some areas with more approved trainers than others, but we are continuing to address the problem. Each regional office has a technology lab that is available. There are also two technology specialists and a part-time technology resource person available. The agency would like to employ up to three additional technology specialists to help meet the growing need for assistance with adaptive technology and is in the process of determining if resources will allow that to happen. Tutorials are being purchased to be maintained in the technology lab in each office for use by staff and customers. Counselors may purchase tutorials for eligible VR customers. Blind computer users can be very helpful to each other, especially those interested in acquiring more advanced skills as a blind user.

Public Comment 60:
DRS has a computer in a job bank to be used by customers for placement. DRS also has job placement staff. That kind of job placement assistance should be available for DVH customers.

Agency Response 60:
A goal in FY 99 will be to have a computer dedicated in each regional office (probably in the technology lab) for job search on the Internet or bulletin boards by counselors or customers. We will continue to work jointly with DRS in promoting job fairs and other activities that might benefit individuals who are blind in their job search. It is not likely DVH will hire a full-time job placement person (see Agency Response 21).

Public Comment 61:
Computer training tutorials should be made available in regional libraries.

Agency Response 61:
This suggestion will be shared with the director of the Library and Resource Center to see if this can be accomplished.

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