4733 Bethesda Avenue, Suite 330, Bethesda, MD 20814
Phone - 301.654.4885 FAX - 301.654.5542
Dr. Timothy Muzzio
U.S. Department of Education
400 Maryland Avenue, SW.
Potomac Center Plaza, room 5157
Washington, DC 20202-2800.
Re: Comments on the RSA Rehabilitation Training Program
Dear Dr. Muzzio:
The National Council of State Agencies for the Blind (NCSAB) represents state vocational rehabilitation programs serving people who are blind and visually impaired. Member agencies promote, through advocacy, coordination, and education, the delivery of specialized services that enable individuals who are blind and visually impaired to achieve personal and vocational independence. One of our primary functions is to establish and maintain a liaison and serve as an advisory body with the U.S. Department of Education, Rehabilitation Services Administration, and all other federal agencies, as they develop policies and administer programs affecting services for individuals who are blind or visually impaired.
We are writing in response to the recently published Notice of Request for Comments and Recommendations regarding the Rehabilitation Services Administration (RSA) Rehabilitation Training Program. In particular we are concerned about possible changes to the Regional Rehabilitation Continuing Education Programs (RRCEPs). We strongly recommend that the current RRCEP structure be maintained under any restructuring plan.
The RRCEPs provide support to training centers that serve either a Federal region or another geographic area and provide for a broad integrated sequence of training activities that focus on meeting recurrent and common training needs of employed rehabilitation personnel throughout a multi-State geographical area. The RRCEP structure has been in existence since 1974 and has established successful working relationships with existing personnel at every level within state vocational rehabilitation agencies, as well as the network of community partners.
The RRCEP structure is well-established and provides successful
mechanisms and processes for the dissemination of training, instruction and
technical assistance to its constituents. Rehabilitation Continuing
Education Programs train newly employed State Agency staff at the
administrative, supervisory, professional, sub-professional, or clerical
levels in order to develop needed skills
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Dr. Timothy Muzzio
Comments on RSA Rehabilitation Training Center
for effective agency performance. They provide training opportunities for experienced State Agency personnel at all levels to upgrade their skills and to develop mastery of new program developments dealing with significant issues, priorities and legislative thrusts of the State/Federal Vocational Rehabilitation program. The existing structure allows each state to decide if they would like to compete for funds that exceed the basic allotment priorities and offers those states the greatest flexibility in competing for the limited resources that are available beyond the basic allotment. In addition, for those states that receive only the basic allotment, consideration should be given to the elimination and/or streamlining of the current grant application process and enhancing the efficiency of the application process for specific programs that are identified by those states.
Another consideration that might impact negatively on those states that are facing fiscal and budgetary issues is the possibility of rolling the training grant into the Title I program. Title I has a much higher matching requirement than the in-service training grants (23 percent versus 10 percent) and rolling training funds into Title I would effectively reduce the availability of training dollars, not only from a matching perspective, but also from the perspective of flexibility to use these funds.
The RRCEPs also develop and conduct training programs for the staff of: private rehabilitation agencies and facilities which cooperate with State Vocational Rehabilitation units in providing vocational rehabilitation and other rehabilitation services; Centers for Independent Living; Client assistance programs, and Section 121 (American Indian Vocational Rehabilitation) Programs.
The RRCEPs support the infrastructure of the Federal- State VR Program.
They are knowledgeable regarding the latest technologies, latest laws and
operating procedures of the VR Program. They provide invaluable Technical
Assistance to State VR agencies, Centers for Independent Living, Projects
with Industry, Migrant and Seasonal Farm worker programs, and long and
Short-term training grantees. This symbiotic relationship with these
organizations has been an ongoing development over the last 32 years. It is
through this trusted relationship that RRCEPs have developed an
understanding of each respective regional culture, inter/intra agency
cultures and the unique flavor of each agency. Through the efficiencies and
economies of scale that have been established since the inception of the
RCCEPs, the cost savings to the taxpayers is extremely significant. By
immediately being able to intervene when problems arise, the RRCEPs are at
the forefront of improving the quality of life for individuals with
disabilities.
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Dr. Timothy Muzzio
Comments on RSA Rehabilitation Training Center
Our concern is that to change a system that has a regulatory base, has maximized resources and eliminated duplication, would be a major mistake. There have been no studies conducted, and therefore no clear data that indicate this model is ineffective or inefficient. If we were to change this configuration it would undermine the linkages between agencies, educational institutions and community rehabilitation providers at a time when states are in a human resource crisis. Many of the NCSAB’s member agencies have served on RRCEP Advisory Boards and consistently report that their experience is that the RRCEPs are cost effective, efficient and customer driven.
We appreciate the opportunity to express the viewpoint of the members of
the National Council of State Agencies for the Blind on this issue.
Sincerely,
Greg Trapp, J.D.
President
National Council of State
Agencies for the Blind