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Summary of the 2004 Public Comments and the State Agency's Responses

The Virginia Department for the Blind and Vision Impaired (DBVI) conducted public meetings across the Commonwealth during the month of October, 2004. Held in McLean on October 2, Roanoke on October 20, Virginia Beach on October 23, and Charlottesville on October 29, DBVI received substantial input from individuals who attended these public meetings. Additionally, public comment was obtained from individuals submitting written remarks. Following is a listing of the questions asked and issues raised during the public meetings along with agency responses.

Public Comment 1:
Students in the K-12 setting have a pretty good support structure and the department coordinates with the schools to get the things they need to be successful in school. What happens at the college level? What is the relationship between the department and, for instance, the offices of disabled students on campus?

Agency Response 1:
DBVI provides services and supports to eligible students transitioning from high school often involving Vocational Rehabilitation Counselors working directly with Offices of Student Services or Disability Services at the post-secondary level. The same services and supports are available to eligible individuals coming to DBVI for vocational rehabilitation when college is required for a specific vocational goal. DBVI staff works collaboratively with customers to either make contact with the office of special services or disability support services on behalf of the customer or to facilitate contact between the customer and the college or university.

Public Comment 2:
What is the current state of the order of selection provision, and are you thinking in terms of changing the order of selection provision in any way as it may actually have to be used in a year or so.

Agency Response 2:
Order of Selection occurs when state Vocational Rehabilitation (VR) programs are unable to serve all eligible customers because of limited resources. On July 1, 2004, DBVI initiated Order of Selection with three categories based on vision loss, functional limitation subsequent to vision loss, and length and duration of services. We have no plans to change the current Order of Selection categories.

Public Comment 3:
Is an order of selection federally mandated?

Agency Response 3:
The designated state unit for VR is mandated to implement an Order of Selection in any year in which it determines that the full range of VR services identified in the Rehabilitation Act cannot be provided to all eligible individuals.

Public Comment 4:
There is a provision of the State plan that deals with the underserved population, and I have a concern that deaf blind individuals are in that category; but in this state, there is a group that I think needs to have special attention made from the department, and that is individuals who are Native American Indians who are blind and vision impaired. I hope there is an emphasis to serve them, and they should be added to a category for the order of selection.

Agency Response 4:
All individuals determined eligible are placed in an order of selection category with no special consideration given to any specific group of individuals, including Native Americans. The order of selection criteria is as follows:

1) Category 1 - Eligible Individual with the Most Significant Disabilities: The individual has no functional vision or is significantly visually impaired and has a secondary disability which profoundly limits functioning in two or more major life activities (such as mobility, communication, self-care, interpersonal skills, self-direction, and work tolerance or work skills) in terms of achieving an employment outcome. The individual's vocational rehabilitation must also be expected to require three or more VR services over an extended period of time (one year or more)

2) Category 2 - Eligible Individual with a Significant Disability: The significant visual impairment does not enable the individual to obtain a driver's license in Virginia (with normal correction) and also severely limits functioning in one or more major life activities (such as mobility, communication, self-care, interpersonal skills, self-direction, work tolerance or work skills) in terms of achieving an employment outcome. The individual's vocational rehabilitation must also require two or more substantial VR services over an extended period of time (minimum of three months)

3) Category 3 – All Eligible Individuals.

Although the DBVI order of selection does not specifically address “underserved populations”, these groups may be targeted through outreach activities.

Public Comment 5:
There is a great need for volunteers to help with blind and visually impaired individuals in the community that are taking classes, and the department seems to have very limited staff who can help with such needs.

Agency Response 5:
The department does not have sufficient staff to devote to volunteer development. The department does receive referrals from Volunteer Match and follows-up in assigning those volunteers to blind individuals who need their assistance. DBVI will re-evaluate our use volunteers.

Public Comment 6:
I would like to suggest that the agency send out a flyer to every single person on their caseload announcing these hearings. I know that the counselors are supposed to tell the people they work with, but in the last two years, I have not heard a word from my counselor.

Agency Response 6:
This is a very good suggestion. DBVI will examine current methods used to advertise public meetings and consider ways to ensure that every vocational rehabilitation customer is made aware of the opportunities available to provide input to the department on development of the state plan.

Public Comment 7:
Are blind people in Virginia who want to work at Virginia Industries for the Blind eligible to gain access to that employment opportunity through vocational rehabilitation services?

Agency Response 7:
This is a two part answer. We have determined that certain jobs at the Virginia Industries for the Blind (VIB) are in an integrated setting meaning that the eligible individual with the disability is working along side people with and without disabilities similar to what is found in the public workforce. Individuals interested in and having the skills and abilities to perform jobs in integrated settings can gain access to those employment opportunities through the Vocational Rehabilitation Program.

There are also a number of positions at VIB that we have determined do not meet the definition of integrated setting in the Rehabilitation Act. People interested in those non-integrated positions are not served through the Vocational Rehabilitation Program since employment in non-integrated jobs is not an allowable VR employment outcome.

Public Comment 8:
Please give an example as to what type of job would quality for services, and one that would not, and what about the information on the referral function for this part.

Agency Response 8:
An example of an integrated job at the VIB are sewing jobs in the Army T-shirt department where about 50% of the workforce are sighted individuals and 50% are blind individuals. An example of a non-integrated setting is the area where pillows and writing instruments are manufactured exclusively by blind workers. When customers are referred to DBVI for vocational rehabilitation services employment options appropriate to the customer’s skills, abilities, and interests, including those at the VIB, are the focus of the discussion.

Public Comment 9:
I am a programmer, and I am concerned that the counselors are not aware of what people are capable of and may not be steering them in the right direction.

Agency Response 9:
DBVI counselors are trained to work with each customer individually providing services designed to meet that customer’s needs, abilities, interests, and preferences. Subsequently, not every customer will necessarily receive the same guidance or direction as another. Customers that experience situations where DBVI staff does not provide appropriate vocational guidance, counseling and support should bring it to our attention.

Public Comment 10:
I have a BA, I am a teacher, and I found that people have told me that I need to go for something that is below my standards. But I know if I am given the right tools, I would be okay. How do I fight for these things I need? The Center needs restructuring.

Agency Response 10:
Self-advocacy is always a good first step. The relationship between the customer and vocational rehabilitation counselor is a partnership requiring open dialogue. DBVI encourages customers to talk openly with counselors about their interests, choices, skills, and abilities.

Although there are no current plans to restructure the Virginia Rehabilitation Center for the Blind and Vision Impaired (VRCBVI) suggestions that would improve services are welcomed.

Public Comment 11:
I am a teacher in the public schools, and this year I have all seniors and my specialty area is transition and adaptive technology. My concerns are that there are no pre-assessments from the Center; and almost two months later, I have not received any evaluation reports stating what my student needs are from either the counselors or the parents. I suggest we have more guidance and make the students’ senior year more valuable.

Agency Response 11:
DBVI has already initiated action to ensure timely completion and submission of reports following a student’s participation in assessments at the Rehabilitation Center for the Blind and Visually Impaired (VRCBVI.) The Vocational Rehabilitation and Education Services programs are working collaboratively to ensure that students receive the guidance and counseling they need to coordinate smooth transition from secondary to post-secondary education, training, or work. Transition is an ongoing priority for DBVI.

Public Comment 12:
Can you explain a way that is consistent with the example that you gave; if it has to be an integrated setting, I think by definition that means at least equal if not more able body people in the category than the handicapped people; it would not meet the direct labor standard.

Agency Response 12:
Compliance with the direct labor standard is calculated on the total direct labor hours worked. There are integrated work units at VIB where the ratio of direct labor performed by blind to sighted workers may be slightly less than the required overall 75% ratio that NIB affiliated agencies must meet in order to qualify for federal contracts. There are other work units at VIB where the ratio of blind to sighted is higher than 75%. We maintain the required overall 75% ratio of blind to sighted direct labor hours on the total direct labor hours worked at VIB.

Public Comment 13:
Six months ago I started preparing for college and attended a college prep session at the Center and returned to college this year preparing to get my master’s. When my counselor received my recommendations from the Center, she did absolutely nothing about them. She sat on them. So when I was ready to go to college, I said, hey what is going on. It was like we had to back shuffle and hurry and get everything done quickly.

Agency Response 13:
We require our counselors to provide prompt service and support. This expectation is supported by individual performance plans for each counselor. The situation you describe appears to be an individual counselor performance issue, not a policy issue.

Public Comment 14:
Your need and request for volunteers was well taken. To supplement that, every federal department has a training and development center; and I would be more than willing to not only provide you with resources that I have collected over the years, but I am pretty confident that I can put you in touch with someone in the field that will do some hands-on training for you.

Agency Response 14:
See Agency Response 5. Please feel free to share resources with staff at the DBVI local field office or Headquarters in Richmond.

Public Comment 15:
What is JWOD?

Agency Response 15:
The Wagner-O’Day Act signed by President Franklin D. Roosevelt in 1937 and amended in 1971 to become the Javits-Wagner-O’Day Act (JWOD) provides a method for qualified non-profit organizations employing blind or severally disabled individuals to be placed on the Federal Procurement List for products or services as long as they meet the required quality and fair market price. The JWOD Program is a coordinated effort by the Committee for Purchase from People Who Are Blind or Severely Disabled, National Industries for the Blind (NIB) and NISH–Creating Employment Opportunities for People with Severe Disabilities. For nearly 70 years, this program has allowed people who are blind to acquire job skills and training, receive wages and benefits, and gain greater independence and quality of life. The JWOD Program is the largest single provider of employment for people who are blind or have other severe disabilities in the United States, providing job opportunities to more than 42,000 individuals.

Public Comment 16:
I am an 18-year-old junior at Woodson High School. I am profoundly deaf, and I have low vision. I will be finishing high school next year. I need help in preparing to go to Galluadet University. I need note takers and adaptive technology to be independent in college. I saw things in college-bound programs that I know can help me at the university. I need more vision support to be independent when I go to college. I cannot always get large print and notes. I need equipment like the flipper port to see the board and mouse port to help read books.

Agency Response 16:
Technical assistance has been provided to this student in accessing VR services in preparation for college.

Public Comment 17:
How is a person going to get the skills to go on to college if they didn't have computer skills to begin with and all they are getting is the 30-hour class and maybe an additional 20 hours at the Center? Is there some way that you could do some coordination with local community colleges, so you go down to Richmond, take their 30-hour class, then take a beginning computer class through the college that the Center does some coordination with so that you can get the advanced computer skills you need.

Agency Response 17:
VRCBVI typically provides training in the areas of basic adaptive equipment use, windows operating system skills, word processing, e-mail use, and basis internet use skills within 30 to 40 hours of computer training. Based on individual ability and aptitude, some students also acquire skills in Excel, Access basics, and PowerPoint during this time. These students would be adequately equipped to participate in community and college computer classes with adaptive equipment. Assistance in determining the appropriate adaptive equipment can provided by the Rehabilitation Engineer at the local level.

Not all students move at the same pace; some students may cover significantly less material during the 30 to 40 hours at VRCBVI. Unfortunately, these students may have difficulty participating in community computer classes. Individual tutoring may be the best resource for students in this situation.

DBVI attempts to obtain training in the community for customers through the utilization of tutors at the local level. Currently, the use of tutors occurs at varying degrees in different locations around the state based on resources in the individual communities.

Public Comment 18:
Does the Center have any of the Iowa training tutorials to loan to individuals?

Agency Response 18:
Iowa Commission for the Blind Tutorial Training Tapes are available at the VRCBVI for customer use.

Public Comment 19:
I have had low vision all my life. About a year ago I lost more vision, but I am still considered low vision. I am concerned about this order of selection and where I fall into its categories. I spoke to my counselor and she said wait until my condition stabilized. Just how long am I suppose to wait for this determination?

Agency Response 19:
For clarification, eligibility determination and order of selection are two different issues. Eligibility determinations for individuals that apply for vocational rehabilitation services are made as soon as possible but no later than 60 days after application for services. Following eligibility determination, and if the designated state unit has implemented an Order of Selection, the Order of Selection criteria are applied and the individual either begins receiving services or moves into in a holding status. Customers disagreeing with eligibility decisions or order of selection categorization may appeal those decisions.

Public Comment 20:
At the Rehab Center how final is the work evaluation department's decision? What is the recourse to disagree with that evaluation? Are we making sure that the staff in that area truly believe that blind people have the ability to do jobs outside of VIB and customer service? This is the impression that clients are getting when they are going through work evaluation at the Center.

Agency Response 20:
Evaluations at VRCBVI are evaluations, not final decisions. Final decisions are made jointly by the Vocational Rehabilitation counselors and customers based on individual skills, abilities, and interests. Any person who disagrees with the services they receive or the way they have been treated has the right to an appeal. DBVI will work on making it our job to open doors rather than close them.

Public Comment 21:
I have been doing my own job search for the past nine months, and now I work for the federal government. I have always done things on my own and have used my web site to find jobs that are available. How much is your organization utilizing web sites as there are a lot of resources out with job search information?

Agency Response 21:
Utilization of websites as a job search tool varies from counselor to counselor and customer to customer. Use of technology is a priority at DBVI and we thank you for your excellent suggestion.

Public Comment 22:
I was told by my counselor that I needed to have a cognitive test? I have attended college, and I have worked in a professional job. Are they insinuating that because I have gone blind that they need to test my cognitive abilities or is it because of my age?

Agency Response 22:
Although the department required cognitive testing for college sponsorships at one time, it has not been a DBVI policy or practice for a number of years. Any eligible consumer who requires college in order to attain their chosen employment outcome consistent with their individual skills, abilities, interests and informed choice may access that training upon acceptance into an accredited college program. Your individual situation is best addressed through constructive conversations with your counselor. You also have the right to appeal or access a fair hearing on any program decision.

Public Comment 23:
As part of the State plan re-evaluation, do you seek accreditation and are you currently accredited? Second, for your individual professionals as I understand the State plan, your professional counselors, rehab teachers, etc. are suppose to be certified. I was wondering, since there are two competing bodies out there who do accrediting work (the Academy for Certification of Vocational Rehabilitation and Education Professionals and the National Blind Professional Certification Board), do you accept both of these accreditations? What will be the new amendment to the State plan?

Agency Response 23:
The agency has not been accredited by National Accreditation Council since the 1980s. DBVI has no plans to seek accreditation by NAC or other accreditation bodies.

Regarding staff certification, Orientation and Mobility is the only discipline that the National Blindness Professional Certification Board certifies at this time. The agency now requires that all new O & M instructors be certified and we recognize and accept both the NBPCB and ACVREP certifications in O&M. V R Counselors are required to meet the criteria established in federal regulation though the RSA's "Comprehensive System of Personnel Development". Application of these standards in Virginia means that V R Counselors must have a Masters degree in rehabilitation counseling or closely related fields, or is a Certified Rehab Counselor (CRC) or Certified Vocational Evaluator (CVE), as designated by CRCC. Although Rehabilitation Teachers are not required to be certified to maintain employment, we encourage them to obtain the certification available through the ACVREP.

Public Comment 24:
Do you prefer or encourage your professionals to seek one body over the other?

Agency Response 24:
We do not prefer or encourage professionals to seek certification from one body over the other. The only certification body at this time that certifies vocational rehabilitation counselors is the Commission on Rehabilitation Counselor Certification (CRCC).

Public Comment 25:
Are the rehabilitation teachers certified?

Agency Response 25:
DBVI does not require certification, but encourages it. The agency supports teachers in professional development.

Public Comment 26:
If you don't require certification, what is the incentive to get it?

Agency Response 26:
Employees who work toward and receive certification do not receive an increase in salary, but the department pays expenses incurred through the certification process. Many of our rehabilitation teachers are motivated by their desire for professional development.

Public Comment 27:
Getting back to the agency's general accreditation issue; the agency was certified when I worked there. Why did the agency's board, which was a policy board, decide not to seek re-accreditation?

Agency Response 27:
The DBVI Board, which was at the time a policy board, decided not to seek re-accreditation. Funding may have been a small consideration in making that decision.

Public Comment 28:
I have been approached by a young lady who serves on the Virginia Beach Special Education Advisory Committee and she wants to know what VAB does for blind students once they start high school. My question to you is what does DBVI do for students once they have started high school?

Agency Response 28:
DBVI provides transition services to eligible students. This collaborative effort includes partnerships between DBVI Education Services and Vocational Rehabilitation Program staff, local school systems, students and their families. Within 30 days of a student's 14th birthday, Education Coordinators and Vocational Rehabilitation Counselors consult to determine whether vocational rehabilitation services are appropriate. Following referral which could also come from the school system, parent, or other referral source, the VR Counselor establishes contact with the student and family to discuss and plan appropriate transition services. Transition services can begin in VR as early as age 14 depending on the individual needs of the student. Other transition services may include assessment or training at the VRCBVI, participation in summer college preparatory programs, or Summer Work where students can actually work and earn a paycheck.

Public Comment 29:
A few days ago my JAWS died on me and I called Westhaven Blind Rehabilitation Center and they wanted me to come to the center for re-evaluation and training. I contacted by counselor in the Roanoke office and was told my case had been closed and it would have to be re-opened. What recourse have I to take care of a situation like this?

Agency Response 29:
To receive vocational rehabilitation services you must apply and be determined eligible for services. In this situation, the first thing to do is reapply for services at DBVI to have your case re-opened. You will need to provide updated information to facilitate eligibility determination. If determined eligible for VR services, goods and services may be appropriate if required for you to achieve a vocational goal.

Also refer to Agency Response #4 relating to Order of Selection.

The Assistive Technology Loan Fund Authority (ATLFA) and the Consumer Services Fund (CSF) are two other funding options for you to consider. You can make application for those two funding services independently. You may access information about the ATLFA and the Consumer Services Fund at www.atlfa.org.

Public Comment 30:
Do all people have to be employed?

Agency Response 30:
No, an individual does not have to be employed to receive VR services but employment is the expected outcome in VR. The individual must have a disability (for DBVI that means blindness or significant vision impairment); the disability must be an impediment to employment; and, the individual must require vocational rehabilitation services to maintain or obtain employment.

Public Comment 31:
You mentioned a loan program, could you explain that further?

Agency Response 31:
A number of years ago, The General Assembly allotted funds to establish the Assistive Technology Loan Fund Authority (ATLFA.) ATLFA makes loans and loan guarantees to people with disabilities for equipment and technology that increases independence, quality of life, and employment opportunities.

Public Comment 32:
Is there a resource listing for the other fund sources of this kind that people can access?

Agency Response 32:
DBVI does not maintain a formal list of resources for funding, however, local DBVI and DRS Field offices may maintain listings of local resources. Centers for Independent Living, Lions Clubs, United Way agencies, church discretionary funds, and other community specific organizations may have resources. Sometimes health insurance providers have resource listings as well. A copy of the Appendix H in the VR Policies and Procedures Manual will be sent to the individual who made this comment along with the other requested information.

Public Comment 33:
What are the categories for the order of selection?

Agency Response 33:
Refer to Agency Response #4.

Public Comment 34:
If you don't qualify, do you have books available to try to find resources?

Agency Response 34:
Refer to agency response #32.

Public Comment 35:
How many counselors do you have in the Roanoke regional office?

Agency Response 35:
We have three VR counselors, one rehabilitation engineer, one education coordinator, five rehabilitation teachers, two O & M specialists, and one deaf blind specialist in the Roanoke regional office.

Public Comment 36:
Could we look into getting a vision impaired person working in the Camp Easter Seal dining room or in the office for summer programs? That would be good experience.

Agency Response 36:
We will look into that opportunity.

Public Comment 37:
Can DBVI provide resources when someone goes into an unserved category?

Agency Response 37:
DBVI counselors can and do provide information regarding other resources to customers, however, no services can be provided when customers are in unserved categories. See Agency Response #4.

Public Comment 38:
If you are outside the criteria for services and you do have a need; say you can't thread your needle on your sewing machine, can you go through the agency and they could tell you where to go and tell you where you could get training?

Agency Response 38:
Order of Selection does not affect other DBVI services, such as our Rehabilitation Teaching/Independent Living program. Individuals requiring assistance in performing activities of daily living may be served through other DBVI programs for which they are eligible. Additionally, customers may access resources through Centers for Independent Living and other community providers at the local level.

Public Comment 39:
Regarding the vending machine program, many of the stands are closing now and you can't get them in places like Walmart, K-Mart, or something like that.

Agency Response 39:
The Randolph-Sheppard Vending Program continues to be a viable employment option for customers who have the skills, abilities, and interested associated with the food management. Randolph-Sheppard opportunities are generally housed in state or federal facilities. Depending on the circumstances of each location or business, some locations close while others have opened.

Public Comment 40:
How much time does it take to get into the program?

Agency Response 40:
Entry into the program varies based on several critical things. Customers are only able to access the Randolph-Sheppard Food Management training program through participation in a vocational rehabilitation program. Subsequently, customers must be eligible for services through the vocational rehabilitation program. After eligibility has been determined individuals participate in a Randolph-Sheppard evaluation at the VRCBVI. Participation in the program includes a 20 week training program. Program participants must also be willing to relocate, if necessary, when a stand opportunity arises.

Public Comment 41:
Can there be more information in physicians' offices regarding the resources?

Agency Response 41:
DBVI field offices and agency low vision staff generally provide resources to physicians locally. This is an ongoing process with DBVI encouraging physicians to provide patients with information and other resources about DBVI services.

Public Comment 42:
There is a problem in the doctors' offices, because when I have asked for information about blindness they have flatly said no.

Agency Response 42:
Physicians are required to refer individuals who are legally blind to DBVI (see §51.5-68, Code of Virginia). DBVI field office and low vision staff periodically go to MCV, UVA, and medical centers in localities and do outreach activities on a regular basis. Thank you for bringing this issue to our attention.

Public Comment 43:
Lots of doctors struggle with having to tell the patient that they cannot do any more for you. We as individuals need to approach our own doctors, both eye and medical, and they make more of an effort to get you the information you are requesting. It is very helpful to have a list of catalogues for blind individuals to order and educate themselves on what is available for the blind community.

Agency Response 43:
DBVI does share catalogue information with consumers. The agency switchboard operator has toll-free numbers for those resources.

Public Comment 44:
I have been blind for four years and I have diabetes. They wanted me to check my blood sugar but I couldn't see to read the meter. I felt like I was wasting my trip and time and everything. Finally, I got a glucometer and now I can read my blood sugar level. You just have to keep after them. At first they said Medicare wouldn't cover it but now they do.

Agency Response 44:
Thank you for your comment.

Public Comment 45:
I work at a furniture store and over the past several months, I have had seven or eight ladies wondering if their husbands are blind. Is there any literature that I can make available for individuals like that?

Agency Response 45:
Yes, DBVI can provide informational brochures about the various programs and services provided through the agency.

Public Comment 46:
The agency use to have a brochure some time ago called "Now Your Patient is Blind" or something like that. Are they still available?

Agency Response 46:
DBVI is not aware of that particular brochure; however the agency does have brochures. Also, consumer groups such as the National Federation of the Blind (NFB), the American Council of the Blind (ACB) and the Blinded Veterans Association (BVA) can provide helpful information.

Public Comment 47:
Can you tell me exactly where I could order one of those liquid level indicators? Also, there is a summer camp for adults and children, and there is no age limit. I was just wondering if some of the blind adults would be interested in going to some of the adult sessions at Camp Easter Seal.

Agency Response 47:
There are several companies/organizations that sell aids and appliances for the blind such as liquid indicators. You can contact the regional office and they can provide you a list of them. You may also call the agency toll-free number at 1800-622-2155 and request information about companies that sell adaptive aids and appliances.

Some of our customers, ages 8 - 17, already attend Super Summer Camp held at the Camp Easter Seal facility each summer. We will be happy to make information available about heir adult program to individuals who may be interested.

Public Comment 48:
Newsline has come to Virginia, starting July 1, and the department is actually footing the bill through the endowment fund, and there is a lack of promotion at the local office level. One issue that came up at their last board meeting is promotion and letting people know about it, how it works, and how to access.

Agency Response 48:
To clarify, the Board for Blind and Vision Impaired, not DBVI, is paying for Newsline this year. We have sent information about Newsline to DBVI field staff directing them to share this information with customers. Volunteers provided demonstrations to DBVI and VRCBVI staff to educate and inform them about Newsline. We are sending a general mailing about Newsline and other reading services to all recipients of DBVI library services. While we have made a concerted effort to promote this valuable service, perhaps we can do more. We welcome suggestions to facilitate further promotion.

Public Comment 49:
If counselors and teachers could be given a pass code to Newsline, they could demonstrate to customers in their homes.

Agency Response 49:
Good suggestion. Thank you.

Public Comment 50:
There is a lot of wonderful equipment from DBVI, and my issue is that I would like to see more tutoring, tapes, and things. Tutors only are allowed to share certain things. If she could get information on tape, it would be very helpful. I want training tapes, and it would save a lot of money when paying tutors $80 per hour. I could use it at my own pace, and it would be much more successful.

Agency Response 50:
That is a good suggestion. Vocational Rehabilitation counselors are knowledgeable about the availability of taped tutorials and can purchase tutorials if appropriate for the customer to accomplish their established vocational goal. Please let your counselor know you would prefer tutorials rather than a tutor. As a point of clarification, DBVI pays for tutors through the Technology Tutoring Network $35 per hours for all regions of the state except Northern Virginia where the rate is $45 per hour.

Public Comment 51:
There may be few training tapes designed for zoom text users, and they have to learn how to use them as well.

Agency Comment 51:
DBVI can assist in helping customers learn how to use training tapes.

Public Comment 52:
I would like to see piggy-back on Newsline promotion with teachers and counselors having a pass code, I would like to see students receive one as well. Multi-disabled individuals are often shifted around from one agency to another. Students will need services from both agencies. I know it is difficult for two agencies to work together, but it is necessary in certain cases in order for success.

Agency Response 52:
DBVI and DRS have a cooperative agreement that facilitates working collaboratively when a student that requires specialized assistance provided by both agencies. Obviously, it is in the best interest of the student when the two agencies work together to meet the student's needs. One of the most important things the student needs is a strong advocate in their parents.

Anyone who cannot read conventional newsprint could qualify for the free Newsline service. To apply they need to contact Kathy Proffitt (toll-free) at 1800-622-2155.

Public Comment 53:
Doesn't WWRC also have services available to the blind?

Agency Response 53:
The cooperative agreement DBVI and DRS provides for blind, deaf blind or visually impaired customers to be jointly served with WWRC being a service option when services provided at that facility will best meet the needs of the customer.

Public Comment 54:
I am a SSI benefits worker at CIL in Norfolk and I think it is crucial that all transition age students and individuals with visual disabilities know and understand about their SSI benefits. I am available to meet with students, parents, other individuals to help them understand these benefits. I can also help transition students understand what work incentives are available. It is very important that DBVI establish an ongoing relationship with benefits specialists to help students as far as their benefits are concerned. Also, I was wondering if you could tell me briefly about the criteria for services under the order of selection.

Agency Response 54:
To address Order of Selection questions, please see Agency Response #4. As for benefits planning, a number of the recommendations in the Olmstead Report of 2003 speak to benefits planning and coordination of services, guidance and counseling to transition students. Representatives from the Department of Education, DBVI, DRS, and other state agencies, are a part of the Olmstead Implementation Team charged with addressing and costing out recommendations in the Olmstead Report including those related to benefits planning to students. Centers for Independent Living are identified community partners.

Public Comment 55:
I work for Endependence Center, and I work with visually impaired. I have had 4 or 5 DBVI clients come for VR services saying they were not certified or something like that since the order of selection protocol. Has it changed the way of applying for services? I have heard that resources were not going to be used for them for some reason. Another thing I have been hearing is that counselors are not helping individuals try to find the kind of vocational goal they are trying to pursue. These statements are off the wall to me and I need to know if they are valid statements. I have directed them to contact the regional manager instead of relying on the counselors.

Agency Response 55:
Order of Selection and eligibility determination for vocational rehabilitation services are two different things. In fact, Order of Selection has nothing to do with eligibility for vocational rehabilitation. See Agency Response #4 for details about criteria for Order of Selection. DBVI Regional Managers in the local field offices should be contacted if customers are getting the responses you have indicated.

Public Comment 56:
I have a suggestion that I would like to make, is it possible that after eligibility has been established that the client could receive in alternative format the role of responsibilities of the client and the counselor. Does information go out to clients in an accessible format?

Agency Response 56:
Alternative formats are available to DBVI customers upon request.

Public Comment 57:
On local employment training, there is a lot of training for taxes and things not made accessible locally. In order for me to take a tax exam, I would have to go all the way to Little Rock Arkansas. I have a suggestion, is there any way to address this training locally? With the Rehab Center for the Blind, we need more training programs and people need to know how do you do multi-tasks. It needs to be looked into.

Agency Response 57:
The IRS tax training program you reference is an established program that trains blind people from throughout the United States to be IRS tax consultants. Over the years Virginia has sponsored several individuals to participant in that training. We will continue to pay for individuals who are eligible for vocational rehabilitation and are accepted into that program. A state is limited by resources and potential trainees in the number of special vocational training programs it can set up and operate. Currently, we do have one vocational training program at VRCBVI which is customer service training. Most vocational training is not specialized for the blind; our primary objective is to provide services to assist a blind person to acquire the adaptive skills that will enable them to participate in the vocational training programs of their choice. Based on individual need, eligible customers participating in a vocational training program receive necessary support services such as financial assistance, adaptive technology, reader service, maintenance and transportation.

Public Comment 58:
Don't want to keep on about the order of selection, but say you have a low vision exam and you use bi-optics and you are in a category two and then your selection changes and you become a category three. What happens to you then? My other question, are there going to be any cuts in regional office staff in the future?

Agency Response 58:
As a point of clarification, if the only service requested by a customer is purchase of bi-optics, the individual would not be eligible for services through the vocational rehabilitation program.

Situations may occur where an individual might move from one category to another; subsequently, the customer may move from non-served to a served category. This would happen if the individual experiences a significant change in condition, functional limitation and duration of services required.

DBVI is not planning any position reductions in the regional offices at this time.

Public Comment 59:
I have a possibility of employment and I shared that with the counselor and he shared that with his supervisor and they did not want to meet with me. He said would the rehabilitation engineer be able to use their equipment to show me how to use it. He asked if I needed an accommodation. Does that accommodation come from a staff person? My computer was down for 30 days before I could get help. Secondly, I was having difficulty using my computer and asked for rehab engineer and he said I could work on the speech myself; however, the words were not on the screen so it made it impossible for me to address the issue.

Agency Response 59:
In this type of situation, it is a good idea to talk directly with the Regional Field Office Manager.

Public Comment 60:
I don't understand this order of selection.

Agency Response 60:
See Agency Response #4.

Public Comment 61:
I have two questions. It is my understanding that there is a 48-hour limit in which to return a customers call? I was asked if I thought that was reasonable, and I said it was not. I think that counselors should be encouraged to check their voice mail and at least acknowledge it. You can play that 48-hour game forever. It is my understanding that the people who conduct assistive technology assessments are given only a week or two before the referrals are made to them, not allowing enough time. If it is true about the 48 hours before counselor getting in touch with a customer, can that be revoked? The assistive technology is an issue of a breakdown. There is too much time between the evaluation for needed technology and the referral for assistive technology assistance.

Agency Response 61:
It is agency policy that customer calls are to be returned within one work day of receipt of the call. Many of our field staff have only one day scheduled in the office and, as such, may not "receive" the phone message for several days. We are working to establish a method by which the staff will make it clear to all customers as to the day(s) they are in the office and if a message is urgent, there will be a method to insure that the message is conveyed to the staff member in a timely fashion or that another staff member can be available to answer a question. We will share your concerns with the regional managers.

Public Comment 63:
What is the purpose of the Vocational Rehabilitation program and counselor? I am a senior in high school, and I am not seeing my counselor enough.

Agency Response 63:
The State Vocational Rehabilitation Program is federally mandated and is designed to assist people with disabilities in gaining or maintaining employment and living independently in the community. When the customer is a student the VR Counselor works in partnership with the customer in planning for transition. Both the Counselor and the customer are responsible for maintaining contact with each other, so if you want more contact with your counselor, let your counselor know. If you are not satisfied after talking with your counselor, please contact the Regional Office Manager. You always have a right for fair hearing if you are not getting the service you feel you need. DBVI takes pride in working issues out with customers before a fair hearing is necessary. One of our main priorities as an agency is provide quality transition services.

Public Comment 64:
What is order of selection?

Agency Response 64:
See Agency Response #4.

Public Comment 65:
I hope counselors are not playing games; for instance, if someone is totally blind they probably need orientation services and assistive technology training. So if you need the equipment and you need training on the equipment that would be considered two services, right?

Agency Response 66:
In the example you gave, if mobility training, assistive technology services, and a full training program exceeding 90 days is required, the person would meet the requirement for category 2. Also, see Agency Response #4.

Public Comment 67:
I have a two-part question. Are we a privy to the order of selection assessment? Can we appeal the category we have been placed in?

Agency Response 67:
Customers should always be actively involved with all aspects of the vocational rehabilitation process; of course, customers have the right to ask questions about everything including the Order of Selection. Customers always have the right to an appeal if you are dissatisfied with the decisions made.

Public Comment 68:
I have been on the Rehabilitation Council for the agency, and I have worked for DBVI. I have been getting a lot of calls about inaction in the Fairfax office. People don't hear from counselors and the assistive technology services are not being met. It is a management issue or something. I am certainly not pointing blame, but something needs to be done.

Agency Response 68:
Thank you for bringing these concerns to our attention; we will look into this issue. The agency has been aware of some of the problems you cite in the Fairfax Office and has been working to remedy them. The caseloads in the Fairfax office have been among the highest in the state and as a result we transferred a counselor position from another office to Fairfax this past year. We anticipate that this will improve the response time of the VR staff.

DBVI has established an assistive technology tracking system in the Fairfax Office. This system, instituted in late 2004, has significantly improved our ability to provide assistive technology in a timely manner.

Public Comment 69:
In the workshop in Charlottesville, I haven't seen blind people in management in Charlottesville or Richmond. Is there any plan to have blind managers? What kind of steps are you going to take to change that?

Agency Response 69:
As a point of clarification, Virginia Industries for the Blind (VIB) is not a Workshop. Workshops are generally exempt from the FLSA and can pay less than minimum wage. VIB does not pay below minimum wage. VIB has an upward mobility plan which allows any qualified individual to apply, blind or sighted. Promotions or new hires are awarded to the most qualified. Recently a blind candidate was promoted to a group leader position but unfortunately later reversed their decision.

Public Comment 70:
Just speaking in general as an agency, do you tell people they should not go to college? Do you support students making choices for training?

Agency Response 70:
Students are partners in the VR process like every other customer. DBVI does not discourage individuals from attending college. In order to sponsor customers for college training, the training has to be consistent with and required for the vocational goal identified on the student's Individual Plan for Employment. See Agency Response #22 and #63.

Public Comment 71:
Is there something that is done to track how counselors do their work? Is there a way to track whether or not a counselor is not supportive to customers?

Agency Response 71:
Counselors have position descriptions detailing core responsibilities and measurements for the core responsibilities. Regional Office Managers evaluate counselors based on those outcome measures. Additionally, customer satisfaction surveys are another valuable tool in determining individual counselor performance.

Public Comment 72:
There is a perception that customers need to know, and I heard in more than in one instance where there are some customers who believe that counselors should write and submit resumes'. No, that is not the counselor's job, it is your job. Do counselors sit down with new customers and tell them what their responsibilities are? What is it that these customers are being told when they are working with the counselors?

Agency Response 72:
Developing collaborative partnerships with our customers is a priority in the Vocational Rehabilitation Program. The partnership involves active participation by counselor and customers. In December 2004, the Vocational Rehabilitation Program in conjunction with Education Services held a staff meeting where a major focus was the development of the partnership between counselors and customers. The identification of specific responsibilities of the customer and counselor is based on customer specific skills, abilities, and interests. DBVI acknowledges that definition of counselor and customer responsibility from the outset is critical to ensure that customers obtain their vocational goals.

Public Comment 73:
I have a general question in regards to a customer who wishes to obtain college training. Does DBVI have policies to determine financial amount that can be paid? How does DBVI handle awards, such as the Pell Grant and other grants based on needs and how do they distinguish them between that and merit.

Agency Response 73:
All college students seeking assistance for college expenses from DBVI must apply for comparable benefits such as Pell Grants. Generally, DBVI sponsors college training for financially eligible individuals through the Individualized Plan for Employment (IPE) up to the highest rate of Virginia public colleges and universities. Out of state rates can only be funded when the student cannot access the education required to accomplish their vocational goal at a Virginia college or university. If the individual applies for a private college and university, DBVI will only pay an amount equal to the highest rate for tuition, room and board charged by Virginia public institutions of higher education.

The Pell Grant and other grants based on need are considered as comparable benefits in developing the Individualized Plan for Employment. A monetary merit award provided to a vocational rehabilitation student by a civic, professional, social, or consumer organization, such as the National Federation of the Blind, or the American Council of the Blind, in most instances will not be considered a comparable benefit. If the use of the award by the student is unrestricted by the donor, it will not be considered by the Vocational Rehabilitation program as a comparable benefit. When the award is merely earmarked "educational", it is not restricted enough to be considered as a comparable benefit. For example, the student may elect to use the merit award for travel abroad or some other educational enriching experience.

Public Comment 74:
How many rehabilitation center staff are actually blind?

Agency Response 74:
VRCBVI has 24 full time positions with two current vacancies; four out of the 24 positions are filled with blind or visually impaired people. Additionally, there are 20 part-time positions with two current vacancies; five of the 20 part-time positions are filled with blind or visually impaired people. In total, there are 44 positions of which 9 are filled by individuals who are blind or visually impaired.

Public Comment 75:
There is a lack of role models in that environment to show that things can be done. How effective the environment can be to empowering a student applying, if you have no role models in that spot?

Agency Response 75:
DBVI agrees that roles models play a very important role in the lives of individuals who are blind, deaf blind, and vision impaired. Fortunately, VRCBVI currently has nine blind or visually impaired staff working as teachers, dormitory staff, technicians, and janitors. On a daily basis these staff are role models to students demonstrating that blind people can and do live and work independently and successfully. Additionally, staff with other disabilities carry a similar message regarding capabilities of people with disabilities. VRCBVI is also fortunate to have a number of volunteers with visual impairments who are role models for VRCBVI students. Of course, we agree that more role models are needed at VRCBVI.

Public Comment 76:
I am working towards a master's in VR, specializing in deaf blindness and I am blind, will I be able to find employment when I get out of school.

Agency Response 76:
There is a state and national shortage of qualified Vocational Rehabilitation Counselors; individuals with a Master's Degree in Vocational Rehabilitation who are eligible to site for the Certified Rehabilitation Counselor exam should have no problems finding employment. Agencies across the nation, including DBVI, are interesting in hiring qualified individuals with disabilities for jobs at all levels. Additionally, DBVI is engaged in Workforce Planning efforts that have identified the need for hiring more individuals with blindness as important.

Public Comment 78:
Staff at DBVI are required to ask customers if they want to register for the National Voters Registration. I checked with the staff at our local registrar's office, and they said they have never gotten even one from DBVI.

Agency Response 78:
All state agencies providing direct services to citizens assist with initial voter registration. At DBVI, customers are provided voter registration materials and given the choice of submitting their registration application themselves to the registrar in their locality or having DBVI staff submit voter registration application on their behalf. Completion of voter registration materials and awareness of voter rights are documented in customer case files.

Voter registration applications submitted on behalf of the customer by DBVI staff are routed through agency Headquarters to the Henrico County Registrar who forwards the applications to the appropriate registrar in the customer's home community.

Public Comment 79:
After listening to a lot of comments, I am getting the sense that there is a feeling of being discouraged in discussing a vocational goal. Back in New York, we took students ages 14 and up and we provided summer jobs for them, hooked them up with confident role models on job sites so that they can get familiar with blind people working on their jobs and the agency pays for that. It is a very successful program. Are there any plans to address that; these students should be worked with at that age and not when they become college age and time for transitioning? What might be some specific plans for transition students?

Agency Response 79:
Our Vocational Rehabilitation and Education Services Programs work collaboratively to identify transition aged children to ensure involvement from as early as age 14. DBVI sponsors a Summer Work program that generally has 30 to 35 participants annually. Additionally, VRCBVI also has summer transition programs geared toward evaluation, college preparation, and assistive technology evaluations. Transition is a priority for DBVI and we are making a concerted effort to improve both delivery of services and identification of students requiring vocational rehabilitation to achieve their vocational goals.

Public Comment 80:
In a follow-up question to that, customers have identified vocational goals that they would like to achieve; what do the counselors do, if anything, to try to help that customer connect to another blind person who is performing that job?

Agency Response 80:
DBVI supports mentoring of blind students by blind adults in all areas of a child life. It is especially important for students in transition to have mentors. The December 2004 combination Vocational Rehabilitation and Education Services Program staff meeting and Workforce Training activities conducted by the agency identified the need for DBVI to be more active in assisting customers to connect with other blind individuals who can provide mentorship opportunities. We will request the Rehabilitation Council to work with us in developing a stronger and more effective mentoring program.

Public Comment 81:
Rather than wait until your staff meeting in December, why not address these issues now?

Agency Response 81:
Absolutely.

Public Comment 82:
If you have customers who want to try job shadowing or summer jobs, we will find you some place to go and try it.

Agency Response 82:
Information regarding the Summer Work Program will be sent to the DBVI field offices in the spring. If you know of potential job opportunities for students, please let us know.

Public Comment 83:
I have a couple of questions. You made reference to a summer work program for teenagers. Can you tell me when that started taking place and what that involves? I have never heard of the program. How many successful closures are closed each year?

Agency Response 83:
The Summer Work program began about 15 years ago and provides an opportunity for students to gain valuable work experience through a summer job. Information regarding employment opportunities comes from the community and from DBVI. Students contact employers, with assistance if needed, and DBVI pays the student; in some cases employers pay students wages.

In federal year 2004, DBVI had 231 successful case closures; we expect this number to decline in FFY 2005 because of Order of Selection.

Public Comment 84:
My daughter has found a job mentor but there is the issue of transportation getting the student to and from job site. She gets out of school at 2:00 p.m. and she needs transportation to the job site by 3:00 p.m. There is some transportation available; however, it is not a dependable service.

Agency Response 84:
We can discuss your student's needs personally after this meeting and make contact with the appropriate DBVI field office as necessary. Reliable public and para-transportation is an ongoing issue in many parts of Virginia.

Public Comment 85:
You speak a lot about partnerships and I agree with you. Do you not think that this partnership has a breech when there is not support and no ongoing communication? Do you agree or disagree? I would love to brainstorm with you about ways to improve the partnership theory.

Agency Response 85:
DBVI would welcome the opportunity to brainstorm about ways to improve communication and support between customers and counselors. Your ideas would be quite welcome.

Public Comment 86:
I am speaking as a sighted math teacher new to this field. I was working with a blind student taking geometry and trig, and this student did not have a calculator. We can't expect students to do the math in their heads. Who is responsible for paying for the calculator? Who is responsible for determining the need? The school is saying they are not responsible and the counselor had no knowledge of her needing a calculator for my class.

Agency Response 86:
Parents are responsible for making this type of purchase when the equipment is to be used at home. Equipment to be used on the school site is the school's responsibility. DBVI technology staff can help provide information about what is available for individuals who are blind, deaf blind, or visually impaired.

Public Comment 87:
We were both looking up calculators at the same time. One of the things that happens for myself, and I was amazed and shocked at the lack of good talking calculators. I was looking on all the blind resource. We must make more efforts to make strides to improved technology for the blind students.

Agency Response 87:
DBVI agrees that efforts need to continue to improve technology to meet the needs of blind students.