Be a Change Agent in the Vocational Rehabilitation (VR) System: Legally Mandated Ways to Let Your Voice Be Heard

by Doug Powell

(Editor's Note: Doug Powell is the chairman of the rehabilitation issues task force.)
As this article is being written, the Workforce Investment Act (WIA) and the Rehabilitation Act are currently under discussion in Congress for reauthorization.  In periodic e-mails, we have been supplying you with our concerns that you can use to advocate on the federal level to maintain and improve services to blind and visually impaired consumers.  Under WIA, state agencies apply every year through their state plan to be licensed to provide rehab services to us.  There are various ways for us to have meaningful input into the policies and program services administered by the state agencies - from the individual counselor or teacher all the way up to the Rehabilitation Services Administration (RSA).  Next month, we'll give members information on the grievance procedures when a specific rehab case is not going the way the client wishes. This month, we'll outline some of the more formal ways, mandated in the Rehab Act, you can give feedback to the agency on what is working and what is not.

Consumer Satisfaction Surveys

The state rehabilitation councils (SRCs) are a body of citizens appointed by the governor to oversee the policies and programs of the VR agency.  They are responsible for administering and reviewing the results of consumer satisfaction surveys.  Different states survey with various frequencies - some survey consumers yearly, while others solicit input only when a case is closed.  The SRCs use information gathered in these surveys to make necessary changes to service provision.

Public Comment at SRC Meetings

The SRCs meet at least quarterly.  On each regular meeting agenda, there is time set aside for public comment.  If you can get to the meeting site, or if you are allowed to call in to the meeting, you can make your comment directly to the SRC and key people on the VR staff who attend these meetings.

Public Meetings

Each year, the SRC and VR staff are responsible for holding a series of public meetings to get input from consumers and advocates around the state.  Often these meetings are held on a regional basis, or by phone.  Membership organization conventions such as your affiliate or chapter conventions or meetings may provide good opportunities for direct contact with VR staff and SRC representatives to receive input of concern from your affiliate.  The comments from these public meetings are published by the SRC and VR staff, and are considered when formulating changes to policies and programs in the next year's state plan.  (The state plan is the request for licensing that outlines pretty specifically what the agency is going to do to provide services to their consumers for the coming year.)

State Plan SRC Attachment

The attachments to the yearly state plan is where the details of what has been done, what the results were, what will be done, and what the expected results will be are outlined.  One of the attachments, "4 2(c) Summary of Input and Recommendations Made by the SRC," is an opportunity for the SRC to express concerns with current programs, policies, and services, and these concerns are supposed to be specifically answered by the VR staff.  It is a way to potentially draw Rehabilitation Services Administration (RSA) attention to a problem that the staff doesn't feel they can address or solve.

Comprehensive Statewide Needs Assessment (CSNA)

Every three years, the agency must undertake an assessment of their effectiveness at reaching and providing services to all citizens who would qualify for those services.  The major focus of this exercise is to determine as well as possible who is eligible for services, where they live, and whether they are getting the services they need.  It attempts to identify unserved and underserved populations so that better attempts can be made in the next several state plans to contact and provide adequate services to those populations.  Surveying stakeholders is one aspect of the CSNA process, so ACB affiliates can provide input into future outreach by the VR agency.

RSA Monitoring

Every three to five years, each state agency is assessed by a team of RSA staffers.  They look at all of the documents above as part of their assessment of the performance of the agency.  The RSA report can point out persistent issues of non-performance, and either suggest improvements or mandate compliance if the agency is out of compliance with the provisions of the Rehab Act.  Input is sought from the SRC and, in some cases, affiliate presidents on top of auditing documents.
As always, change will happen sooner and more smoothly if we have good relationships with our VR management and staff.  Most VR professionals are trying to do the best job they can (they aren't in it for the money).  But when informal discussions don't work, you can resort to the options above to be heard and, if plausible, you will be able to enlist the support of RSA to exert pressure on your behalf to bring the state agency into compliance with the law.
We hope you find this useful.  Next month, we will focus on the individual consumer and their options for changing the course of a case that is not meeting their needs.  And in December, we'll discuss the SRC in more detail, and why it is important to have ACB representation on yours.
Questions or suggestions for future rehab information in the ACB Forums?  Contact Doug Powell via e-mail,