What Will Become of Continuing Education Programs?
Issue: The Rehabilitation Services Administration recently published a
notice outlining its plan to restructure RSA's network of Regional
Continuing Education Programs. What will this mean for continuing education
support for state VR agencies and Community Rehabilitation Programs?
Response: On January 29, 2008, the Rehabilitation Services Administration (RSA)
published a Notice of Proposed Priority (NPP) in the Federal Register. The
NPP announces RSA's intent to replace its Regional Rehabilitation Continuing
Education Programs (RRCEPs) with ten Technical Assistance and Continuing
Education (TACE) centers.
The background section of the Proposed Priority states in part:
To address the need for technical assistance and continuing education, RSA
seeks to revise the structure of the RRCEP. Rather than supporting two types
of Regional Centers as has been done under the current RRCEP model--those
serving State VR agencies, CILS, and CAPs and those serving CRPs--RSA seeks
to fund 10 regional Technical Assistance and Continuing Education (TACE)
centers to provide technical assistance and continuing education for both
employees of State VR agencies and all agency partners (e.g., CILs, CAPs and
CRPs).
On its face this looks like a move to streamline the system, consolidating
functions and increasing coordination. The model itself is not a bad one, a
centralized technical assistance and continuing education center in each
region serving the full range of partners in the vocational rehabilitation
(VR) system. The problem lies not in what is said but in what is left
unsaid.
Why replace the name Regional Rehabilitation Continuing Education Programs
with the name Technical Assistance and Continuing Education Centers? In my
reading of the NPP the reason seems clear: the change is intended to
compensate for RSA's lack of ability to meet its responsibility to provide
technical assistance, particularly to state VR agencies. In 2005, when the
RSA regional offices were closed and nearly half of RSA's staff were
eliminated, Department of Education leadership claimed that under its new
centralized structure, RSA would be able to provide better and more
responsive technical assistance than it had in the past. In response to an
overwhelming number of complaints objecting to the closure of the regional
offices, the Department developed a list of talking points for staff to use
in answering constituent letters.
The talking points contained vague assurances to the effect that technical
assistance would be strengthened under the new system. For example, if an
individual wrote expressing the concern that migrant programs would be left
out, unable to obtain needed technical assistance , the talking points
document instructed RSA staff to respond that Migrant Programs would not
only maintain the level of assistance they previously received but would
receive better, more responsive assistance than in the past. The document
contained the same assurance for all its programs. Tribal VR programs,
services for blind and deaf individuals, all were told that the new system
would increase RSA's ability to provide technical assistance, not lessen it.
The new RSA would be all things to all people, better, faster, more
responsive. Of course, there was no way to prove otherwise, so the
dismantling of the regional offices proceeded; and as was predicted, the
reality bears little resemblance to the promise.
The loss of the regional offices has been devastating. It now appears that
RSA is on track to compound one folly with yet another. Today, RSA has
virtually no capacity to provide meaningful technical assistance to state VR
agencies. The NPP appears to be an attempt to fill this void by diverting
funds from the continuing education program to replace the technical
assistance function RSA is no longer able to provide.
The language of the NPP makes clear RSA's intent. For example, paragraph 1
reads in part that the new TACE center will: "Establish, in consultation
with RSA, an annual work plan ..." The TACE center does not consult with the
state VR agency, the Client Assistance Program, independent living centers,
tribal VR programs or any other community
partners, only RSA. And what will the TACE center's workplan describe?
According to the NPP, "...activities that the center will conduct to assist
State VR agencies to accomplish the goals identified in their VR State plans
and to achieve other performance and compliance goals identified by RSA's
monitoring reports.."
Paragraph 2 of the NPP goes on to discuss the process for conducting a needs
assessment. It reads in part : "Conduct an annual needs assessment to
identify technical assistance and continuing education needs of State VR
agencies and agency partners ..." While the language mentions "agency
partners," the NPP continues by saying: "... Each center must base its
annual needs assessment on a thorough review of VR State plans, on-site
monitoring reports and annual review reports issued by RSA ..."
If it is not already clear that the RSA envisions the new TACE centers to be
its technical assistance arm, focusing exclusively, or nearly so, on the TA
needs of state VR agencies as determined by RSA, paragraph four of the NPP
goes on to require that the TACE center must "Participate as an observer in
RSA's triennial monitoring of State VR agencies in its region by attending,
at a minimum, each State VR agency's monitoring exit conference in order to
gain a thorough understanding of each State VR agency's technical assistance
and continuing education needs."
Of course RSA will claim that it does not intend to dismantle the RRCEPs.
Yet, the NPP makes clear that RSA sees the new TACE centers as merely an
extension of RSA and its monitoring function. Technical assistance and, for
that matter, continuing education are determined by deficiencies in state
agency performance identified by RSA through its monitoring.
There is more in the NPP that raises concern. Paragraph 3 states that the
Department of Education intends to publish a notice of proposed rulemaking (NPRM)
to amend 34 CFR 385.40 that would change the requirements concerning the
composition of training project advisory committees.
"The NPRM would add a requirement that an applicant include individuals who
are knowledgeable about the special needs of individuals with disabilities
from diverse groups, including minority groups. The purpose of this change
would be to more clearly reflect the intent of the Department that project
advisory committees include individuals who are familiar with the needs of
individuals with disabilities from diverse groups, rather than individuals
who are just members of such groups."
What a condescending statement. The NPP suggests that minority individuals
are today merely token members of advisory committees, offering nothing of
substance. This gratuitous statement is made without a reference to any data
supporting such a claim. Instead of minority people representing the
perspective of minority individuals, RSA proposes to replace them with "...
individuals who are familiar with the needs of individuals with disabilities
from diverse groups ..."
In summary, the NPP proposes replacing the present system of Regional
Rehabilitation Continuing Education Programs with a network of Technical
Assistance and Continuing Education Centers. This is more than a name
change. From my reading of the NPP, it appears clear that the plan is to
find a way to compensate for the loss of RSA's ten regional offices and the
commensurate loss of 65 of its most knowledgeable and experienced staff. It
also appears clear that the plan is to focus technical assistance on
addressing the needs of state VR agencies, ignoring the fact that VR
functions as an integrated system of partner programs in the states.
Finally, it seems clear that technical assistance needs will no longer be
jointly determined but will be exclusively driven by RSA monitoring
findings. Certainly RSA will call foul, saying that I have misread the NPP
and its intent. Perhaps so. I hope I am wrong; however, advocates did not
misread the consequences of closing the regional offices more than two years
ago and I am afraid that we have not misjudged the consequences of RSA's
reorganization of its continuing education program.
Fredric K. Schroeder, Ph.D.