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POSITION PAPERS & action items

Why You Should Support Licensure of O&M Specialists
By
Grace Ambrose-Zaken, Ed.D.
August 13, 2008

Orientation and Mobility (O&M) is a profession that teaches age-appropriate travel to children and adults who are blind and visually impaired. Detractors of New York State licensure for O&M Specialists suggest that there is no proof that specialized degree and certificate programs offered at universities across the U.S. are necessary for the preparation of professionals who teach children who are born blind and visually impaired to travel and therefore, they argue, O&M Specialists should not be licensed. The purpose of this article is to briefly summarize a research study on access to O&M instruction and to argue that licensure for O&M Specialists is vital to the future of this profession in its ability to increase the numbers of practitioners in the field.

Between the years 1998-2000, 100 subjects who were blind and visually impaired were interviewed. Of those, 43 men aged 19-84 (mean=48.51, SD = 15.47) and 57 women aged 19-83 (mean = 46.86, SD 14.13), were either full-time university students, current wage earners, or retirees from gainful employment. Fifty-eight of the subjects were congenitally blind or visually impaired or became blind before the age of 2 (n=4). Thirty-eight acquired a visual impairment between the ages of 3-68 (X=21.13, SD=17.14).
The two groups (congenital and adventitiously blind/visually impaired) were analyzed to determine whether decade the subjects were born was correlated with when the subjects began O&M instruction. Crosstabs of decade born and age O&M instruction began indicated that for subjects who were congenitally blind or visually impaired there was a significant correlation (r=77.32, DF=35, p=<.05). Subjects born after 1970 were more likely to begin O&M instruction in Preschool through 2nd grade, subjects born between 1917 and 1969 were more likely to begin O&M instruction after the age of 15, later in adulthood or never.

There was no correlation found in the decade subjects who acquired a visual impairment were born to when they began receiving O&M instruction (r = 41.65 with 30 DF, p=.077). On average, these subjects received O&M within 1 -2 years after becoming blind/visually impaired.

The results suggest that it was not until the 1970s, when there were 12 university preparation programs in O&M, that subjects born blind and visually impaired were more likely to begin O&M instruction in preschool to 2nd grade. Subjects born in the 1940s and 1950s on average waited until High School to begin O&M instruction. Subjects born between 1917 and 1939 were more likely to learn O&M as adults and 5 subjects stated they never had formal O&M instruction.

Inside these group statistics can be found the 100 unique stories of growing up blind or visually impaired; for example Paul, Sam, Theresa and Sabrina. Paul, Sam and Sabrina were born totally blind. Theresa was born severely visually impaired. Paul and Sabrina received weekly O&M instruction from Pre-Kindergarten to Twelfth Grade and started using a cane at that time. Sam received O&M as an adult and Theresa never had O&M instruction.

Sabrina, born in 1980 is now a Public School Teacher and Paul born in 1974, said working as a sales representative he has accumulated over 62,000 frequent flyer miles. Paul said, “I know that most people I meet have a notion about blind people to begin with. You don’t want to give them something else to grumble about. I make a really determined effort to be where I say I’m going to be and when I’m going to be there. This is just part of the job. I mean, that’s the way it is, I have real confidence in my ability as a person, to plan and do what needs to be done with whatever situation may arise.”

Paul continued, “Now we also have a network of distributors around the country and when I am in their area, I’ll allow them to assist me by either driving me someplace or finding me a driver that I can hire to go places in their area. And, if that’s the case, we cut back considerably on costs. And that’s nice. So, whenever that opportunity presents itself, I grab it.”

Sabrina recalled a difficult transition from High School to adulthood that revealed some of the complexity that can occur around this transition. Sabrina was asked:

“Q. What do you attribute to your present level of mobility?
My dog. I learned all the skills when I was in Elementary School, High School, but I never; outside of that hour a week that I had direct instruction, I really didn’t get a chance to practice them a whole lot. When I got my dog, I got a lot of confidence. Knowing that I had to go out for walks and get out and work her or we weren’t going to bond--just learning that I could do it. I’d been told so much that I couldn’t and proving to myself that I could and proving to others that I could do it has really made a big difference.”

Sam born in 1934, retired from working in a warehouse for a film company, did not receive O&M instruction during grade school, but he did obtain a cane as an adult. Sam said: “I was about 18 years old. I didn’t carry a cane. Well, without the cane I had some experiences. I fell off the platform a few times…a couple of times.

Q. Oh, my. What happened?
A. Walking without a cane I just took a step and there wasn’t any ground [laugh] to walk on.
Q. Oh, my. So, there was no train coming in, that’s good.
A. Oh, thank God. That was good, yeah.
Q. Did you get hurt?
A. No, no, I jumped up, you know.
Q. Wow. That’s very high.
A. Yeah, it’s about chest high.
Q. Yeah.
A. Yeah. I hit them all…I hit the BMT and the IRT, the Independent line.
Q. Oh, so, you fell onto all of those tracks?
A. Yeah, enough of them, about three times. Then I figured I’d better need a cane. And then my wife got after me to use a cane.

Theresa born in 1933 never had O&M instruction, in grade school she was considered severely low vision and gifted – she attended college at age 16. As a young mother, she became totally blind due to an accident while vacuuming her home. After her children moved out, she went back to work at the newsstand in a commuter train station. During that interview she talked about her “soft life”, and responded to questions about getting O&M instruction in this way,
“Q. So, you’ve never, to this day, had rehabilitation teaching or orientation and mobility instruction?
A. No.
Q. And, being totally blind since ’72, what steps did you take on your own to get you back up and taking care of your family again?
A. I never found cooking hard. You know every time, though, I used to go to bake a cake or something, both the kids would come… “Mom! We'll do it”, you know. I think they were afraid I was going to burn the house down, or something. Of course, it was very hard for my mother, she was elderly and she had gone all these years with me [with severe low vision] and everything else and now to see me lose [all my vision] really just broke her heart, you know. …the main thing is my old boss, Jerry He said, “come on, we need you back working the concession stand at the station”.

I went back and it really wasn’t all that much different from before I became totally blind, because before then, I was still putting the 20s in one spot, the10s in another spot, the 5s one spot, and stuff like that. Uh, but as far as traveling around, I had two kids that were kind of soft for me, you know, and as I said, I live a very soft life. Right now, there’s a young lady that works for me and, once a week she does my shopping.”
Theresa continued: “I don’t like too long of a cane and I never knew how to use it, but in that station, you see yourself, there's nothing square about that place. You know, I have to square myself when I go out, because otherwise, if you go off just a little bit, I could go God knows where.” A few years after taping this interview, at age 75, while on a smoke break from her work at the station, Theresa stepped into the path of an on-coming Amtrak Express train and died.

Not every city has a subway or train track and some towns may not have much traffic, but every child who is born blind or visually impaired should receive O&M instruction from a qualified O&M Specialist as well as the expectation he will travel age-appropriately from family and other teachers and friends. The difference from the early 1900s to now can be seen in the overall improvement in the lives of persons with disabilities due to better laws, greater accessibility, and greater access to formalized instruction.

Recent employment figures are showing positive upward trends among working aged adults who are blind and visually impaired, Shaw, Gold, & Wolffe (2007) wrote “the percentage of youths with visual impairment who had worked for pay since they left high school had increased 36.6% for Cohort 1 (1987), and 62.4% for Cohort 2 (2003). This 25.8% increase is a strong, positive change that indicates that these young adults are working following school.
These positive trends must continue and the next step is licensure. The brief history of O&M as a profession can be understood as a march towards better and more formalized standards and practices in the field. The story of vision education and rehabilitation begins with individuals who were blind being given charitable assistance from churches and synagogues in lieu of employment. Vision rehabilitation agencies staffed with many blind and visually impaired instructors came next. O&M techniques were developed by the Veteran’s Administration in the 1940s. Since 1960, these O&M techniques and the supporting curriculum have been disseminated by universities with a great deal of support from United States Office of Education and Rehabilitation Services Administration. There are now 52 universities preparing vision rehabilitation and education professionals, still while several states have multiple programs, other states do not have a university preparation program in the area of blindness and visual impairment (Ambrose-Zaken, Bozeman, & Lusk, study in process).
The professional organization, the Association for the Education and Rehabilitation for the Blind and Visually Impaired (AER) was first to certify these university graduates and later formed the separate, independent organization the Academy for Certification of Vision Rehabilitation and Education Professionals (ACVREP). Now, the next logical step is state licensure.

New York State licensure is a stronger more recognizable system for upholding the standards of professionals and protecting New Yorkers who are blind and visually impaired from those who are unwilling or unable to achieve these standards. Unfortunately, there continues to be a shortage of the O&M Specialists across the U.S., including New York which has an O&M Preparation Program at Hunter College of The City University of New York.
In 1998, the bill to license O&M and VRT professionals was introduced into the New York legislature and has been reintroduced every 2 years since then. At a recent meeting held by State Assembly Sponsor of the Bill, Jonathon Bing (D, Manhattan), Nancy Miller, President of New York Vision Rehabilitation Association (NYVRA) stated that when a profession becomes licensed the number of people entering the profession escalates sharply and licensure is what the general public wants in their professionals (Kleiner, 2006). Upon hearing this, Carl Jacobson, Affiliate President of the National Federation of the Blind responded that “given the choice between a licensed and unlicensed professional, he would choose a licensed professional every time”.

Supporters of licensure understand that this bill (Assembly Bill A08471 and Senate Bill S5308) to provide for the licensing of licensed orientation and mobility (O&M) specialists and vision rehabilitation therapists (VRTs) is about the future of two professions that make positive differences in the lives of individuals who are blind and visually impaired. Vision rehabilitation includes a range of interventions that can have significant direct and indirect effects on an individual’s physical and mental health, the well-being of families, and the demand for other healthcare services (Horowitz, 2004); including alleviating the symptoms of depression in individuals with age-related vision loss (Horowitz, Reinhardt, & Boerner 2005).

Licensure for O&M would bring more people into the doors of universities to be trained and provide these vital services, it would provide an avenue for consumers to lodge complaint when inadequate or dangerous services are being provided, and it would ensure that these vital professions live on into the future as long as they are needed by individuals who are blind and visually impaired.

The task of getting a bill enacted into law takes a great deal of advocacy on the part of its supporters, money, and a little bit of luck. The easy question to answer; “Why do I think we can get it to pass in New York?” is that on July 16, 2008 at 6:01PM, the New York Senate, led by State Senate Sponsor Senator Carl Marcellino R-Syosset (5th District), passed the Senate version of the bill by a vote of 62:0.

With your help, I believe in 2008-2009 legislative session we will see Vision Rehabilitation Professional Licensure in New York.

United we stand, Divided we Fall.

Please Join NYVRA today and help New Yorkers achieve licensure in 2009! www.nyvra.org

References
Ambrose-Zaken, G. (unpublished manuscript). Access to O&M Instruction Impact on Adult Travel.
Ambrose-Zaken, G., Bozeman, L., & Lusk, K. (Study in process). Profile of Personnel Preparation Programs and their Faculty in Blindness and Visual Impairment: Status Report V.
Horowitz, A., Reinhardt, J. P., & Boerner, K. (2005). The effect of rehabilitation on depression among disabled elders. Aging and Mental Health, 9(6), 563-570.
Horowitz, A. (2004). Prevalence and consequences of age-related vision impairment. Topics in Geriatric Rehabilitation, 20(3), 185-195.
Kleiner, M. (2006). Licensing Occupations: Ensuring quality or restricting competition. W. E. Upjohn Institute for Employment Research:
Kalamazoo, Michigan.
Shaw, A., Gold, D., Wolffe, K. (2007). Employment-related Experiences of Youths Who Are Visually Impaired: How Are These Youths Faring? 101(1).

To Promote the Medicare Low
Vision Demonstration Project:

Things that individuals can do

1. If you are not ACVREP certified, then become certified. Medicare is counting. Currently there are 100,000+ occupational therapists, and only 2,700 ACVREP certified professionals.
   
   
2. If you are ACVREP certified, then stay certified!
   
   
3. Learn how to write a Plan of Care with individualized and measurable goals, objectives and outcomes, and use the process. You can learn how at www.lowvisionproject.org .
   
   
4. Take personal responsibility to reach out and educate the medical community in your community about what vision rehabilitation is and what our professionals do. An easy way to accomplish this is to volunteer as a speaker at local meetings of AAO and AOA, grand rounds at Universities, and meetings of other medical professionals.
   
5. If you live and work near or in the five boroughs of New York City or in the 8 counties in New York that now qualify under the "Demo Project," - Dutchess, Nassau, Orange, Putnam, Suffolk, Sullivan, Ulster, or Westchester - visit local Optometrists and Ophthalmologists and propose partnering with them to provide vision rehabilitation services. The doctors will approve your plan of care, review it every 30 days, and bill Medicare; and you will provide the vision rehabilitation services. You can negotiate the split of $14.97 per 15 minutes of services if you are a COMS or CLVT, or $12.81 if you are a CVRT.
   

Please contact me at the e-mail or phone number below if you need assistance or have questions. Thanks everyone - Licensing and Medicare reimbursement go hand-in-hand -

Together we will make a difference!

Grace Ambrose Zaken, Ed.D., COMS
Project Coordinator RT/O&M Programs
Department of Special Education
Hunter College CUNY
695 Park Ave.
New York, NY 10065
(212) 772-4741

Testimony for the Public Hearing on the
New York State Budget 2008-2009
Brooklyn, New York
November 29, 2007

Presented by Nancy D, Miller, President
New York Vision Rehabilitation Association
500 Greenwich Street, Suite 302
New York, New York 10013

Phone 917-859-9184
Email NMiller@visionsvcb.org

Thank you for this opportunity to testify on spending needs and priorities. I represent the New York Vision Rehabilitation Association, a nonprofit statewide coalition of blind individuals, advocacy groups, providers, educators and professionals addressing issues that impact services for people of all ages who are blind or visually impaired.

NYVRA’s recommendations are:

Fund Senior Vision Services (A897/S522), new legislation passed by the legislature and signed by the Governor at the level of $5 million.

Increase state funding to the NYS Commission for the Blind and Visually Handicapped for non-vocational services for legally blind children and legally blind elders from just over $1 million to $3 million.

Increase SSI (Supplemental Security Income) to raise recipients above the poverty level. Pass through all future federal increases to SSI without reducing the state share.

Pass New York State licensure of vision rehabilitation professionals.

Why are we making these recommendations? There are over a million New Yorkers of all ages living with vision loss that interferes with their daily functioning, education or employment.

The number of elders in New York is increasing dramatically. The New York Citizens Committee on Aging, confirmed by the NYC Department for the Aging,  has documented that the number of seniors living in poverty and living with disabilities (including vision loss) is DOUBLE the national average.

Without appropriate training and vision rehabilitation services, elders with vision loss are more likely to experience falls and fractures, more likely to experience unnecessary disability, more likely to experience untreated depression. This impacts New York State in unnecessary health care costs and impacts the senior with a decreased quality of life.

Senior Vision Services, to be administered by the NYS Office for the Aging, will locate seniors with vision loss and provide services to help them maintain their independence.

Funding for non-vocational services administered by the NYS Office of Children and Families Services/NYS Commission for the Blind has remained the same for decades while the population of legally blind children and legally blind seniors has grown.

Licensure of vision rehabilitation professionals ensures that only qualified professionals will offer the training that restores independent functioning for people with vision loss; licensed professionals to earn a license would need to meet standards, demonstrate competencies, pass an exam, adhere to a code of ethics and take continuing education to keep their skills fresh.

We are pleased that the NYS Commission for the Blind and Visually Handicapped has increased the number of blind persons in employment in both federal Fiscal Year 2006 and 2007 using primarily federal dollars. It is time for the state to step up to the plate and invest in the needs of blind children and blind and visually impaired seniors.

A.7952 (Benedetto)/S.4236 (Winner)

Relates to unlawful discriminatory practices against persons with a disability on the basis of the use of a guide dog, hearing dog or service dog

The New York Vision Rehabilitation Association (“NYVRA”) supports the above-mentioned proposed legislation that would add definitions to Section 292 of New York State’s Human Rights Law for the terms “guide dog,” “hearing dog” and “service dog.” Discrimination against any person who uses a guide, hearing or service dog is never acceptable in our society. An individual who uses such a dog as an aide should be treated with the same respect as anyone else. It is important that the definitions of these different types of dogs are enunciated in our Human Rights Laws so that there is a clear understanding as to their purpose, qualification and use by a disabled person. Passage of this legislation would succeed in clarifying these terms.

NYVRA strongly supports this legislation.

A.7976 (Sweeney)/S.929 (Johnson, O.)

Directs New York state energy research and development authority to study the best technologies to enable blind and visually impaired persons to read utility meters

The New York Vision Rehabilitation Association (“NYVRA”) strongly supports this proposed legislation which would direct the New York state energy research and development authority to study technologies that would enable blind and visually impaired persons to read utility meters. It is important that blind and visually impaired individuals be as capable as possible of obtaining accurate readings of their own utility meters in an independent manner. NYVRA endorses this effort by both Houses of the legislature to require a study that will hopefully produce feasible, usable methods for achieving this goal.

For the foregoing reasons, NYVRA strongly supports this legislation.

A.897/S.522

AN ACT to amend the elder law, in relation to establishing a senior vision services program

The New York Vision Rehabilitation Association (“NYVRA”) strongly supports the above-referenced legislation that would authorize the State Office for the Aging (“SOFA”) to establish a Senior Vision Services Program to provide the specified services across NYS for elderly residents experiencing vision loss. This is a long overdue, important step towards recognizing the ever-growing issue of vision impairment amongst the elderly population in New York State.

NYVRA is a not-for-profit organization comprised of organizational entities and individuals across the state, that address issues and services for people who are blind and visually impaired. NYVRA’s mission is to insure that New York residents with vision loss receive the best possible services across our state. It is well-documented that as persons continue to live longer through advances in science, medicine and better living conditions, they are more and more likely to experience some form of age related vision impairment. This is a serious problem in Ne York due to the extremely large population of senior citizens. In fact, it is estimated that nearly 20% of seniors 65 years and older have age-related eye diseases that impair vision and effect daily functioning.

Vision loss in senior citizens is both a precursor to or accompanies many other significant problems and ailments. The gradual or sudden inability to navigate through daily life leads to depression, isolation and, often, serious injury. The Framingham study documented that, nationally, as many as 18% of all hip fractures are a direct result of vision loss. More outreach and a commitment by New York State is needed to help seniors that lose vision access vision rehabilitation services. They can then learn how to function in their environment with dramatically improve lives and avoid the pitfalls associated with isolation and unnecessary diminished functioning generated by vision loss.

A real commitment to the development of these programs in New York will undoubtedly save our state Medicaid funding by preventing serious conditions and injuries through proactive interventions.

Consequently, we applaud the efforts of the Legislature and strongly support its passage and delivery to the Governor for his signature.

MEMORANDUM IN SUPPORT

A.8471 (Bing)/S.5308 (Marcellino)

Provides for the licensing of licensed orientation and mobility specialists and vision rehabilitation therapists

The New York Vision Rehabilitation Association (“NYVRA”) supports the above-mentioned proposed legislation that establishes licensing and certification requirements for two categories of vision rehabilitation professionals: licensed orientation and mobility specialists and licensed vision rehabilitation therapists; creates a state committee for vision rehabilitation services; describes persons exempt from licensing requirements; and provides for licensure without examination for persons engaged in the occupation for three years that have completed the appropriate education or that are certified by another state or national credentialing body acceptable to the department of education.

For the foregoing reasons, NYVRA strongly supports this legislation.

Testimony to the Human Services Public Hearing on the New York State Budget on behalf of the New York Vision Rehabilitation Association (NYVRA)
March 1, 2007
Presented by Ms. Nancy D. Miller, LMSW, President, NYVRA

I am Nancy D. Miller, President of the New York Vision Rehabilitation Association (NYVRA), a nonprofit coalition comprised of blind and sighted individual members, groups and agencies located across New York State addressing issues that impact services for people of all ages who are blind or visually impaired. NYVRA members include consumers, professionals and advocates and the organizations in which they work or volunteer with a common interest in improving, enhancing and expanding services for a diverse and growing population of people with vision loss. I have worked with people who are blind and people experiencing vision loss for 35 years. This testimony is in opposition to Governor Spitzer’s proposed budget, as currently structured, to create a new Office for the Blind and to eliminate the Commission for the Blind and Visually Handicapped.

The cover page of this testimony is in Braille and large print. Did you know that people who are legally blind, the population to be served by the proposed Office for the Blind, range in vision from a tiny percent with no sight at all to people who read large print and even people who can read regular size print with optical aids and special technology?

The model that the Office for the Blind is based on and that operates services in other states, advocates that people in training wear shades that obscure all their vision. If you had poor vision wouldn’t you want to use whatever you have remaining to manage as independently as possible? Imagine if you were deaf as well as blind and could not use your remaining vision? People who are deaf and blind, like Helen Keller, are not even mentioned in the legislation establishing the new office and yet represent hundreds of residents of New York State.

Did you know that the Iowa model state agency that the Office for the Blind is based on was sued for preventing a blind person from bringing their dog guide into the state training center in violation of the American with Disabilities Act (Stephanie Dohmen vs. Iowa Division of Blind Services)?

Did you know that the model that the Office for the Blind is based on does not support state licensure, professional standards and accreditation of services for people who are blind or visually impaired? If you lost your sight, wouldn’t you want the protection of services provided by licensed professionals with specialized education and expertise? How will New York’s new Office for the Blind ensure that professionally trained and licensed individuals provide quality services? We don’t know because the enabling legislation is silent on qualifications of the new Advisory Executive Board, it is silent on the qualifications of the new Executive Director and it is silent on the qualifications of staff of the new office or staff from the contract providers. We do know that the model that the Office for the Blind is based on advocates that the essential qualification to administer and provide services is blindness. This model supports blind teachers and trainers without professionally recognized national certification from the Academy for Certification of Vision Rehabilitation and Education Professionals (ACVREP) and without state licensure. Groups supporting this Iowa model have even come up with their own credential that is not recognized by any national credentialing organization.

Blindness and severe vision impairment are more prevalent in communities of color. Certain diseases and eye conditions such as diabetes-related vision loss and glaucoma are two to three times more common among African-American and Latino/Latina populations. Shouldn’t New York’s Office for the Blind ensure that outreach and services are provided to people most in need and traditionally under-served? The legislation enabling the Office for the Blind is silent on the diversity of the blind population and the prevalence of vision loss in communities of color.

Hundreds of blind people work in “preferred source” programs that give preference on contracts to entities that employ people who are blind. We don’t know how the new Office for the Blind will interact with these programs since the enabling legislation is silent on these existing programs that provide wages and benefits to blind New Yorkers. It is silent on the relationship that exists between Industries for the Blind of New York State and the current Commission for the Blind and Visually Handicapped.

There are an estimated 120,000 legally blind people living in New York State and less than 2% are totally blind and have no perception of light. This does not include people who do not yet qualify as legally blind but will likely qualify due to progressive eye diseases. Nearly two thirds of the legally blind population are seniors who lost vision as a result of age-related eye diseases but have remaining vision that can be enhanced with optical aids prescribed by an optometrist or ophthalmologist specializing in low vision. Many children with vision loss have additional disabilities and although they comprise a small number within the overall blind population, and they are a growing number as medical breakthroughs save low birth weight babies, children born with congenital conditions causing blindness and children who survive cancers of the eye. Yet the proposed Office for the Blind enabling legislation mentions seniors and children only once in the thirteen pages without any standards for quality, comprehensiveness and type of services.

While NYVRA supports Governor Spitzer’s aggressive stance favoring reform, transparency and accountability, the proposed legislation to eliminate the current New York State Commission for the Blind and Visually Handicapped deserves objective and critical review. Eliminating it will result in significant and potentially unneeded changes in the administration and delivery of services for New York State residents who are blind or visually impaired. Such changes should require extensive public input from all stakeholders including blind consumers of all ages, providers, professionals, educators, and parents of children who are blind or visually impaired. While NYVRA welcomes the opportunity to explore current practices, recommendations for changes and strengthening the current system, we cannot endorse the Governor’s proposal in its current form and, certainly, not without further consideration of the issues outlined below.

From the perspective of many interested parties including many former and current clients of the NYS Commission for the Blind and Visually Handicapped, the current system is not “broken.” Many states look to New York State as a model of service delivery for blind people of all ages. New York State has a network of 17 private nonprofit agencies that provide hundreds of thousands of hours of service under contracts with the Commission for the Blind and Visually Handicapped, a department within the Office of Children and Family Services, serving people of all ages who are legally blind. The private, nonprofit agencies serve thousands of unfunded visually impaired seniors who are not yet legally blind and therefore not covered for vision rehabilitation services by any state agency.

All consumer groups, providers and associations agree that we need more funding to serve the growing population of people who are legally blind due to the aging of the Baby Boomers. The private nonprofit agencies that contract with the Commission are funded at 50 % of the true cost and subsidize the state system with millions of private dollars. Despite this significant shortfall, it is a model public private partnership. The services provided by the network of private nonprofit agencies save New York State money. Will the new Office for the Blind save New York State money? We don’t know because the legislation is silent on the array of services, the outcomes sought and the service delivery methods to be used. The current system meets Federal Rehabilitation Services Administration standards and indicators and maintains an active and diverse State Rehabilitation Council reflecting the balanced viewpoints of many stakeholders. Why do we need a duplicative and costly new Advisory Executive Board when we have the federally mandated State Rehabilitation Council?

There is no objective evidence that a separate state agency such as the Iowa model of an Office for the Blind improves outcomes. In fact, objective research conducted by the Mississippi State University Rehabilitation Research and Training Center indicates that the best outcomes for blind people come from a system that employs specialized, educated and credentialed rehabilitation staff and counselors for people who are blind. New York State currently has a system of specialized, educated and credentialed rehabilitation staff and counselors. Benefits of a new Office for the Blind can only be realized if the new agency functions with a full understanding of the needs of its individual consumers and respects each individual’s right to choose the services and rehabilitation modalities best suited to his or her needs. New York State’s current system protects this choice. The model on which the proposed Office for the Blind is based does not.

Without endorsing or acknowledging the need to establish a new Office for the Blind, and if legislation is needed, the New York Vision Rehabilitation Association strongly recommends:

A Call for Public Participation Prior to the Establishment of a New Office for the Blind

Establishment of an Office for the Blind represents a major alteration in the administration and structure for developing policies and delivering services for New York State residents who are blind or visually impaired. Such a change should be made only after a significant opportunity for public review and comment. Therefore, the legislature should conduct public hearings prior to enactment of this proposal. The proposed timeframe as part of the Governor’s budget does not provide an adequate opportunity for public input.

Issues that must be thoroughly explored, addressed and resolved through a public process before any reorganization is made include the following:

• How can the current system and services provided under the administration of the Commission for the Blind and Visually Handicapped be improved

• Rationale for why a new Office for the Blind is needed, what problems is it attempting to resolve and what outcomes it is attempting to achieve

• Clarification of the scope of the new agency’s authority to exercise oversight and coordination and a commitment to provide comprehensive services and programs for people who are blind or visually impaired, regardless of the source of funding

• Procedures for managing the transition of programs and services from the Commission for the Blind and Visually Handicapped to the proposed new Office for the Blind without interruption of services

• Delineation of the specific services to be directly provided by the proposed new Office for the Blind and services that will be contracted out (i.e. Blind Enterprise Programs, Equipment Loan Fund, Residential Rehabilitation Centers/Services, Services for Children, Services for Elders, Services for People who are Deaf-Blind, Services for People of all Ages with Multiple Disabilities, Employment Services, preferred source Facility Based Employment, Housing/Homes for People who are Blind, Outreach to unserved and underserved populations including communities of color, etc.)

• Composition, qualifications and role of the advisory executive board with assurances of representation from all stakeholders and diverse populations including communities of color, women and elders who together comprise the vast majority of people with vision loss in New York State

• Procedures governing appointment, meetings and term limits of the advisory executive board

• Qualifications and job description for the executive director including minimum education, credentials and experience

• Establishment of educational and professional standards for contractors, consultants, and government employees who provide direct services for New York State residents who are blind or visually impaired.

On a personal note, as the parent of a daughter with vision problems and other disabilities who was educated in both mainstream New York public schools and specialized schools, I know first hand what a difference it made for her future to be taught and served by educated, credentialed and licensed specialists. Wouldn’t you want the same for your children, your parents, and your family? Let us not rush into these drastic changes that will affect the lives of so many people in need.

Remove the Office for the Blind from the budget and spend the time needed to acknowledge the strengths of the current system, recommend ways to improve our results and involve all interested parties in the plans going forward. New Yorkers who are blind or visually impaired, their families and the taxpayers deserve nothing less. Thank you.

New York Vision Rehabilitation Association
Memorandum in Opposition

Position Statement On the Creation of The
New York State Office for the Blind

February 2007

The New York Vision Rehabilitation Association (NYVRA) is a nonprofit coalition comprised of individual members, groups and agencies located across New York State addressing issues that impact services for people of all ages who are blind or visually impaired. NYVRA members include consumers, professionals and advocates and the organizations in which they work or volunteer with a common interest in improving, enhancing and expanding services for a diverse and growing population of people with vision loss.

NYVRA has grave concerns regarding Governor Spitzer’s S. 02107 and A. 04307 (Part J) proposed Office for the Blind legislation. While NYVRA supports Governor Spitzer’s aggressive stance favoring reform, transparency and accountability, the proposed legislation will result in significant and potentially unneeded changes in the administration and delivery of services for New York State residents who are blind or visually impaired. Such changes should require extensive public input from all stakeholders including consumers of all ages, providers, professionals, educators, and parents of children who are blind or visually impaired. While NYVRA welcomes the opportunity to explore this proposal in greater detail, we cannot endorse it in its current form and, certainly, not without further consideration of the issues outlined below.

From the perspective of many interested parties, the current system is not “broken.” Many states look to New York State as a model of service delivery for blind people of all ages. The current system meets all Federal standards and indicators and maintains a State Rehabilitation Council reflecting the balanced viewpoints of many stakeholders. There is no evidence that a separate state agency improves outcomes. In fact, the only objective evidence of better outcomes is a system that employs specialized, educated and credentialed rehabilitation staff for people who are blind. New York State currently has a system of specialized, educated and credentialed staff. Benefits of a new Office for the Blind can only be realized if the consolidated agency functions with a full understanding of the needs of its individual consumers and respects each individual’s right to choose the services and rehabilitation modalities best suited to his or her needs. New York State’s current system protects this choice.

Without endorsing or acknowledging the need to establish a new Office for the Blind, the New York Vision Rehabilitation Association strongly recommends the following:

Call for Public Participation Prior to the Establishment of a New Office for the Blind

Establishment of an Office for the Blind represents a major alteration in the administration and structure for developing policies and delivering services for New York State residents who are blind or visually impaired. Such a change should be made only after a significant opportunity for public review and comment. Therefore, the legislature should conduct public hearings prior to enactment of this proposal. The proposed timeframe does not provide an adequate opportunity for public input.

Issues to be addressed and resolved through a public process include:

• Why a new Office for the Blind is needed, what problems it is attempting to resolve and what outcomes it is attempting to achieve

• Clarification of the scope of the new agency’s authority to exercise oversight and coordination of all services and programs provided for people who are blind or visually impaired, regardless of the source of funding

• Procedures for managing the transition of programs and services from the Commission for the Blind and Visually Handicapped to the proposed new Office for the Blind without interruption of services

• Delineation of the specific services to be directly provided by the proposed new Office for the Blind and services that will be contracted out (i.e. Blind Enterprise Programs, Equipment Loan Fund, Residential Rehabilitation Services, Services for Children, Services for Elders, Services for People who are Deaf-Blind, Employment Services, preferred source Facility Based Employment, State School for the Blind, Housing/Homes, Outreach to unserved and underserved populations, etc.)

• Composition, qualifications and role of the advisory executive board with assurances of representation from all stakeholders and diverse populations including communities of color, women and elders who together comprise the vast majority of people with vision loss in New York State

• Procedures governing appointment, meetings and term limits of the advisory executive board

• Qualifications and job description for the executive director including minimum education and experience

• Establishment of educational and professional standards for contractors, consultants, and government employees who provide direct services for New York State residents who are blind or visually impaired.

Approved by the Board of Directors of the New York Vision Rehabilitation Association

For More Information, contact Nancy D. Miller, President, NYVRA, 917-859-9184.

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