Braille Monitor                                             February 2016

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A Report to National Federation of the Blind Members on COMSTAC and NAC

by Kenneth Jernigan, President
National Federation of the Blind

From the Editor: In the early 1960s the National Accreditation Council for Agencies Serving the Blind and Visually Handicapped was formed, its major purpose being to thwart the legitimate concerns of consumers by waving the banner of accreditation in defense of agencies providing poor service to the blind. The battles between NAC and the Federation are legendary, but to many new Federationists, the reason for NAC’s creation and why we fought its attempts to thwart the will of the organized blind are the stuff of myth and history, lacking any reality or the need for action today. The assumption has been that NAC is dead, and the threat is gone. Would that it were so, but it is not. The state agency for the blind in Florida requires that any agency for the blind there be accredited by NAC in order to use state money to provide services to blind Floridians. The consortium that binds together small service providers for the blind in the state of Pennsylvania also strongly encourages NAC accreditation. NAC is actively encouraging guide dog training schools to affiliate with it, and one prominent school has unfortunately lent its name and quality services to an accrediting body which is widely frowned upon by involved and informed blind people.

It seems time that we reeducate ourselves about NAC and prepare once again to demand that any accreditation be meaningful and that it involve the voice of the organized blind. Following is a speech delivered by Dr. Kenneth Jernigan in 1971 when he was the president of the National Federation of the Blind and a member of the NAC board. This speech has appeared in the pages of the Braille Monitor at least one other time, that being in 1991, and here is the way Dr. Jernigan introduced it when he was serving as the editor of this publication.

Kenneth Jernigan’s Headnote: I delivered this address at the 1971 convention of the National Federation of the Blind in Houston. NAC's president and executive director had come to discuss what NAC was doing and why. My remarks were meant to set the tone for the debate. In the context of NAC's current maneuvering I think this 1971 analysis is still pertinent. Here it is:

When the Commission on Standards and Accreditation on Services for the Blind (COMSTAC) and its successor organization, the National Accreditation Council for Agencies Serving the Blind and Visually Impaired (NAC), came into being during the 1960s, the leaders of the organized blind movement sounded the alarm. It was pointed out that the American Association of Workers for the Blind had unsuccessfully tried, during the 1950s, to gain control of the field of work for the blind by instituting what it called a "seal of good practices." Of the several hundred agencies and organizations in this country doing work with the blind only twenty or thirty ever applied for and received this "seal." Several of those which did were not regarded by the blind as either very effective or very progressive. As the decade of the '60s approached, the proponents of rigid agency control apparently decided to change tactics. The American Foundation for the Blind and certain other leading agency officials adopted the idea of establishing a so-called "independent" accrediting system for all groups doing work with the blind. Although individual blind persons who were agency officials were involved in the establishment and development of COMSTAC, the blind as a group were not consulted—that is, the representative organizations of the blind were not given a voice, except occasionally as a matter of tokenism. Thus, the consumers of the services were not heard in any meaningful way, and they had no part in developing or promulgating the standards to govern the agencies established to give them assistance.

Profiting by the earlier failure of the AAWB [American Association of Workers for the Blind] "seal of good practices" experiment, the authors of COMSTAC built more carefully. The American Foundation for the Blind appointed an "independent" commission—the Commission on Standards and Accreditation for Services for the Blind (COMSTAC). The full-time staff consultant for COMSTAC was a staff member of the AFB, on loan to the group, purely as a means of demonstrating the Foundation's concern with the improvement of services for the blind. To add respectability, people of prestige outside of the field of work with the blind were placed on the commission—public officials, business executives, the dean of the Temple Law School, etc. These were people of good will and integrity, but they were not knowledgeable concerning the problems of blindness. Obviously they took their tone and orientation from the Foundation appointees on COMSTAC. All of these appointees, it must be borne in mind, were high-ranking officials doing work with the blind. Not one of them represented the blind themselves. Not one of them came from a membership organization of blind persons.

As its work developed, COMSTAC divided into subcommittees, involving hundreds of people throughout the country, since the subcommittees further subdivided into smaller groups. Again, the pattern was followed. The subcommittees, or the subcommittees of the subcommittees, had, in every instance, at least one of the COMSTAC agency officials as a member, plus people of prestige and ordinary rank and file agency workers or board members. In fact, at the sub-subcommittee level a few members of the organized blind movement were even added.

The American Foundation for the Blind and COMSTAC were later to proclaim with pride that they had sought and achieved a broad consensus throughout the field of work with the blind. However, the method of arriving at that consensus was, to say the least, novel. At Denver in the summer of 1965, for instance, the AAWB convention was largely taken up with a discussion of the COMSTAC standards—to gather opinions and achieve consensus, it was said. Only the discussion leaders had copies of the standards (there had been a delay in mimeographing), and any touchy point which was raised was answered either by the statement that it was covered somewhere else in the COMSTAC standards or that another group was discussing that matter and it was not properly the concern of the group in which it had been raised.

Home teachers from throughout the country were present and were considering the standards affecting their specialty. The overwhelming majority apparently disagreed with a particular item in the COMSTAC document and suggested that a vote be taken to determine the sentiments of the group. They were informed by the discussion leader that a vote certainly would not be taken but that their views would be reported to COMSTAC, which had the sole responsibility for deciding such matters.

Throughout the summer and fall of 1965 promises were repeatedly made that copies of the proposed COMSTAC standards would be made available. They were forthcoming, hundreds of pages of them—three days prior to the final conference in New York City, which brought together hundreds of agency representatives for the announced purpose of arriving at a final consensus. Dr. Jacobus tenBroek and I attended that conference. Again, the democracy and fair play with which it was conducted were novel. One had to indicate in writing ahead of time which particular group discussion he would like to attend. There was no assurance that his choice would be honored. He might be assigned to another group. He could not move from group to group at all. If he had not received a special invitation, he could not attend the meetings. COMSTAC appointees were stationed at the door to check credentials, and I personally witnessed the turning away of one agency director who had been critical of COMSTAC.

It is no wonder that the blind people of the country felt apprehensive. What type of standards were likely to emerge from a commission so appointed and so conducted? Not only the blind but also many of the agencies expressed concern. Many felt that the AFB and federal rehabilitation officials (unwittingly aided by people of prestige in the broader community) would impose a system of rigid controls—which would stifle initiative, foster domination, and take the emphasis off of real service and place it on bureaucracy, red tape, and professional jargon. It was further felt that what purported to begin as a voluntary system would (once firmly established) become mandatory. The AFB and other proponents of COMSTAC and its successor organization, NAC, vigorously denied these assertions. COMSTAC and NAC were to be truly independent. Their very watchword was to be objectivity. They were to be the means of improving services to blind people throughout the country and the vehicle for progressive thought and constructive change.

Readers of the Braille Monitor will remember that from 1965 through 1968 a detailed analysis was made of the COMSTAC and NAC reports and activities. The fact that the Federation has not called attention in recent months to COMSTAC and NAC should not lead the blind to believe that the threat has passed or the situation improved. Quite the contrary is the case.

The question of NAC's independence, for example, is no longer a matter for serious debate. The Scriptures tell us that "where a man's treasure is, there will his heart be also." In an official NAC document entitled "Budget Comparison—1968 and 1969," dated April 15, 1968, the following items appear.

"Total approved budget calendar year 1968, $154,034; total projected calendar year 1969, $154,000. Estimated income 1968: grant from American Foundation for the Blind $70,000; grant from Department of Health, Education, and Welfare $75,000. Estimated income 1969: grant from American Foundation for the Blind $70,000; grant from Department of Health, Education, and Welfare $70,000."

Today (in 1971) the overwhelming majority of NAC's funds still come from HEW and the American Foundation for the Blind. Many of the NAC meetings are held at the AFB building in New York, and the executive director of NAC is a former Foundation staff member, the same one who was on "loan" to COMSTAC. When the first annual NAC awards were given, in 1970, it may be of significance that two recipients were named: Mr. Jansen Noyes, President of the Board of Directors of the American Foundation for the Blind; and Miss Mary Switzer, the long-time head of rehabilitation in the federal Department of Health, Education, and Welfare. Even more to the point may be Miss Switzer's comments upon that occasion as reported in the NAC minutes of April 24, 1970: "She predicted that difficult times might lie ahead if agencies accept the idea of standards but do nothing about them. The expending or withholding of public money can provide the incentive that is needed."

Thus spoke Miss Switzer, confirming what Federation leaders had predicted and COMSTAC spokesmen had denied a decade ago. The full meaning of Miss Switzer's statement was spelled out by Alexander Handel, Executive Director of NAC, as reported in the NAC minutes of April 25, 1970: "Mr. Handel reported a new and important step in encouraging accreditation. The Council of State Administrators has passed a resolution that by July 1, 1974, state rehabilitation agencies will require that agencies from which they purchase services be accredited." The use of the word "encouraging" in this context is almost reminiscent of George Orwell's double-think and new-speak of 1984—only thirteen years away, at that. Perhaps sooner. The "encouraging" of agencies to seek accreditation from NAC will probably be called by some by the ugly name of blackmail. The pressure for conformity and the concentration of power could well be the most serious threat to good programs for the blind in the decade ahead.

Federationists who attended the 1966 Louisville convention will remember that a report on COMSTAC and NAC was given at that time. I had been officially asked to serve on the NAC board. The offer was, of course, tokenism of the most blatant sort; and the question was whether to accept, leaving the Federation open to the charge of approving NAC actions, or to reject, exposing us to the charge of non-cooperation and leaving us with no means of observing and getting information. Federationists will remember that it was decided that I should accept the invitation. Thus, I have been a member of the NAC board since its inception. In the spring of 1970 I was elected to another three-year term. There are more than thirty NAC board members, of whom I am one.

While expressing my minority views, I have tried to be personally congenial and friendly with the NAC board members. Nevertheless, tokenism remains tokenism. The other members of the board not only seemed unconcerned with but unaware of the non-representative character of NAC. It is as if General Motors, Chrysler, Ford, and American Motors should set up a council and put six or seven officials from each of their companies on its board and then ask the UAW to contribute a single representative. What would the unions do in such a situation? What would racial minorities do if their representative organizations were offered such tokenism in the establishment and promulgation of standards affecting their lives? I think we know what they would do. They would take both political and court action, and they would instigate mass demonstrations. Perhaps the blind should take a leaf from the same book. We cannot and should not exhibit endless patience. We cannot and should not forever tolerate the intolerable. I continue to sit on the NAC board, but I often wonder why. It does not discuss the real problems which face the blind today or the methods of solving those problems. In fact, NAC itself may well be more a part of the problem than the solution. I repeat that tokenism by any other name is still tokenism. In May of 1969, for instance, I received a document from NAC entitled "Statement of Understanding Among National Accreditation Council, National Industries for the Blind and the General Council of Workshops for the Blind." This document was sent to all NAC board members with the request that they vote to approve or disapprove it. It contained six points, of which one and five are particularly pertinent. They are as follows: "1. By June 30, 1970, all NIB affiliated shops shall have either: a. applied to NAC for accreditation and submitted a self-study guide (or) b. applied to the General Council for a Certificate of Affiliation with NIB and submitted a self-study guide. 5. Certificates of Affiliation with NIB entitle shops to membership in the General Council and to access through NIB to: a. Government business allocated by NIB, b. Commercial business allocated by NIB, c. Consulting services of NIB, d. Any and all other benefits of NIB affiliation." In other words if a workshop for the blind wishes any contracts from the federal government, it had better get into line and "volunteer" for accreditation by NAC. No pressure, of course, merely a system of "voluntary accreditation!" As you might expect, I voted no on the NIB agreement. Along with my ballot, I sent the following comments:

"I do not approve this statement because I do not believe government contracts and other benefits to workshops should be conditioned upon their accreditation by NAC. Rather, receipt of government contracts and other benefits should depend upon the quality of performance of the workshop in question. Does the shop pay at least a minimum wage? Do its workers have the rights associated with collective bargaining? What sort of image of blindness does it present to the public?

"Prior to NAC (in the days of COMSTAC) many of us said that NAC would become a vehicle for blackmail—dressed out nicely, of course, in professional jargon. It would appear that the prophecy is beginning to come true, earlier assurances to the contrary notwithstanding."

As I say, I voted no. What do you suppose the final tally of the ballots indicated? Twenty-seven yes votes and one no vote. How different the results might have been if there had been equal representation of the blind themselves and the agencies! Yes, tokenism is still tokenism.

In order that my position cannot be twisted or misinterpreted I would like to say that the quarrel is not with the concept of accreditation itself. Rather, we object to what is being done in the name of accreditation. Proper accreditation by a properly accredited group is a constructive thing. What NAC is doing is something else altogether.

There is, of course, not time here to go into the details of all of the standards originally developed by COMSTAC and now being fostered by NAC, but a brief sample is sufficient to make the point. Federationists will remember that the Braille Monitor for February, 1966, carried an analysis of the COMSTAC standards on physical facilities. That analysis said in part:

“The standards [on physical facilities] are perhaps notable chiefly in that they are so vague and minimal as to be equally applicable to office buildings, nursing homes, or universities by the simple substitution of the names of these other facilities....”

Perhaps a brief run-down of the standards themselves would serve as the best and most complete illustration (headings theirs).

  1. Overall Suitability—The total facility is constructed to best serve the needs of the particular agency. It will adequately serve everyone concerned. It will meet the requirements of its governing body, the Department of Health, Education, and Welfare, and the city building code. The physical facilities will be helpful to the program.
  2. Location—The facility is located where it can easily be reached by staff, clients, and others who need to use it. The facility should be close to shopping and other community interests. The location is reasonably safe, with hazards minimized.
  3. Grounds—The grounds will be large enough to allow for future expansion. They will be pleasant ("free of undue nuisances and hazards,"), with parking areas and roadways. Signs will be posted to help people locate the proper areas.
  4. Activity Area—The layout of the facility will be efficient. The facility will be designed for the planned activities, will be large enough and well organized (reception rooms next to entries, work areas together, etc.). Sufficient maintenance will be provided for.
  5. Privacy—People will have as much privacy as individual cases call for. Confidentiality will be maintained.
  6. Health and Safety—The health and safety codes of the community will be met. Sufficient heat and light will be provided. Sanitary conditions will be as good as possible. Suitable entries will be provided for wheelchairs, etc. Safety features will be related to the level of competence of the occupants, the activities undertaken, and the equipment used. Adequate first aid facilities are provided.
  7. Fire and Disaster Protection—All buildings will be so designed and equipped as to minimize the danger of fire. The buildings will be inspected by local authorities and/or independent authorities and records of inspection kept. Smoking areas are clearly specified. Proper protection shall be provided the occupants of the facility to minimize danger should fire or disaster occur. Suitable fire extinguishers will be provided. Fire alarms will be installed as to be heard throughout the facility. Fire drills will be held irregularly. Special provisions will be made for fire warnings to deaf-blind.
  8. Maintenance—"The condition of the physical facility gives evidence of planful and effective maintenance and housekeeping."
  9. Remodeling—When remodeling is undertaken, it should be to best suit the needs of the program.

The preceding is an inclusive summary! One can imagine the breadth of interpretation that can result from application of these standards. One can also imagine the range of individual whim and axe-grinding, not to say blackmail and favoritism, that can enter into the proposed accreditation of agencies for the blind based on such vague and capricious requirements. The danger to be anticipated is the possibility of varying application of standards to friends and foes when "accrediting" agencies....

One is tempted to dismiss this entire report of "Standards for Physical Facilities" with the single word, "Blah!" But more intensive study indicates otherwise. Tucked away among the platitudes and the generalities are the age-old misconceptions and stereotypes.

What, for instance, is meant by the requirement that a facility for the blind be located near to shopping and other community interests, and that it be in a location reasonably safe, with hazards minimized? The exact words of the committee are, "Where undue hazards cannot be avoided, proper measures are instituted to assure the safety of all persons coming to the agency. (For example, where an agency is on a street with heavy traffic, a light or crosswalk or other means is available for safe crossing by blind persons.)"

If this standard is simply meant to express the general pious platitude that everybody ought to be as safe as possible, then what a farcical and pathetic waste of time and money to assemble a committee to spell out what everybody already knows. On the other hand, if the standard means to imply that the blind are not able to live and compete among the ordinary hazards of the regular workaday world and that they need more shelter and care than others, the implications are not only false but they are insidiously vicious.

Of a similar character is the committee's statement that the grounds must "provide pleasant and appropriate surroundings, and be free of undue nuisances and hazards." Surely we do not need a special commission on standards and accreditation to tell us that people should live in pleasant surroundings that are free of undue hazards, if this is all that is meant. If, however, the committee is saying that the blind require surroundings that are more "pleasant and free from hazards" than the surroundings required by other people, one cannot help but be unhappily reminded of the 19th century concept that the blind should be entertained and provided with recreation, that they should be helped in every way possible to "live with their misfortune."

If this type of analysis seems blunt, one can only reply that this is no time for nice words and mousy phrases. The people who were formerly the Commission on Standards, and are now the National Accreditation, hold themselves out to the public at large as the qualified experts, the people who have the right to make standards and grant or refuse accreditation to all and sundry. These are not children indulging in the innocent games of childhood. They are adults, playing with the lives of hundreds of people.

Federationists should review the Braille Monitor from 1965 through 1968 to study the COMSTAC reports in light of present developments. I have not tried here to analyze the content of those reports. Mostly it is bad, and the standards and rules established by COMSTAC and NAC harmful. Let anyone who doubts this assertion read the COMSTAC reports and the Monitor analyses. They speak for themselves.

One final matter requires comment. At a recent meeting of the National Accreditation Council I was telling a new member of the board (a prominent businessman totally uninformed about the problems faced by the blind) that I thought most of the actions of NAC were irrelevant. He seemed surprised and said something to this effect:

"If you think what we are doing here is not relevant, what is relevant?"

To which I said, "Last fall a blind man in Minneapolis (a person who had worked for several years as a computer programmer at Honeywell and was laid off because of the recession) applied to take a civil service examination for computer programmer with the city of Minneapolis. His application was rejected, on the grounds of blindness. The National Federation of the Blind helped him with advice and legal counsel. As a result, he took the examination, and he now has a job with the city of Minneapolis as a computer programmer.

"How many of the people who are on the NAC board," I asked, "are even aware that such an incident occurred? How many of them think it is important?"

"Or," I went on, "consider another incident. A few weeks ago in Ohio a blind high school senior (duly elected by her class) was denied the right to attend the American Legion Girls' State. The story was carried nationwide by United Press, and the matter is still pending. Do you see any of these people here today concerned or excited about this case? Do you see them trying to do anything about it?"

"Well," my companion replied, "your organization seems to be working on matters like this. Maybe NAC is doing good in other areas."

"The difficulty," I told him, "is that the actions of NAC are helping to create the kind of problem situations I have been describing to you."

"How?" he asked me.

"NAC," I said, "accredits workshops, for instance. What kind of standards does it use in determining whether a shop should be approved and presented to the public as a worthy and progressive institution? NAC is concerned about whether the workshop has a good accounting system. It is concerned about good pay and good working conditions for the professional staff (almost all of them sighted). It is concerned with the physical facilities and (perhaps) whether there is a psychologist or psychiatrist available to minister to the blind workers. But what about minimum wages for those same blind workers, or the right of collective bargaining, or grievance committees? On such items NAC is silent. It will accredit a sheltered shop which pays less than fifty cents an hour to its blind workers. By so doing, it puts its stamp of approval on such practices. It helps perpetuate the system that has kept the blind in bondage and made them second-class citizens through the centuries. It helps to slam the door on the computer programmer in Minneapolis and the high school student in Ohio. Worst of all, perhaps, it reinforces and helps to continue the myth that blindness means inferiority, that the blind are unable to compete on terms of equality in regular industry or the professions, that the blind should be grateful for what they have and stay in their places. The workshop example is only that, an example. The same theme is everywhere present in NAC's action and standards—and, for that matter, in its very makeup."

As we talked, my businessman companion seemed shocked that there were sheltered shops paying less than the minimum wage to blind workers. Yet, he is on the NAC board, lending his name to the accreditation. I pointed out to him a variety of other ways in which the work of NAC is helping to promote misconceptions about blindness and add to our problems. I can only hope that the seeds I planted will bear fruit.

To round out the picture we are considering today, one further item might be mentioned. The April 25, 1968 minutes of NAC report as follows:

"Over thirty agencies and schools have indicated, in writing, an interest in applying for accreditation. Official applications have been received from six agencies. Some of these have already paid the application fee. The American Council of the Blind is the first membership association to apply for membership in the National Accreditation Council."

In a letter dated July 11, 1968, from Alexander Handel, Executive Director of the National Accreditation Council for Agencies Serving the Blind and Visually Handicapped, to members of the NAC Board of Directors an article is discussed which appears in the July, 1968, issue of the Braille Forum (the official publication of the American Council of the Blind). The article says in part:

"It should be emphasized, however, that from the first, ACB officers and members actively consulted with the various committees developing the standards, and ACB was the only national organization of the blind which both participated in and financially supported the National Conference on Standards which led to the formation of the National Accreditation Council."

I give you this quotation without comment. It speaks for itself. So do the actions of NAC. I presume all of you have read the exchange of correspondence concerning the appearance of NAC representatives at this meeting today. The contempt and condescension inherent in NAC's bland assumption that it was proper to reject our invitation to appear at this convention because a debate might occur are clear for all to see. Likewise, the agreement just concluded between NAC and the American Foundation for the Blind whereby the Foundation will work with agencies and help prepare them for accreditation is equally revealing.

In any case the one central point which must be repeatedly hammered home is the total irrelevance of NAC as it is now constituted and as it is now performing. What we need today and in the years ahead is not more detailed standards but a real belief in the competence and innate normality of blind people, a willingness on the part of agency officials to help blind people secure meaningful training and competitive employment, a recognition that the blind are able to participate fully in the mainstream of American life. We need acceptance and equality, not shelter and care.

When seen in this light, NAC must be viewed as one of our most serious problems in the decade ahead. The blind of the nation should thoroughly inform themselves about its activities and should insist upon a voice in determining the character of programs affecting their lives. We should insist that state and federal governments not delegate their powers of setting standards for state agencies to a private group, which is not responsive to the needs or views of the consumers of the services. It is true that many of the agencies doing work with the blind need to be reformed and improved, but NAC is not the entity to do it. We the organized blind intend (in the best tradition of American democracy) to have something to say about the scope and direction of the reform and the improvement. We are not children, nor are we psychological cripples. We are free citizens, fully capable of participating in the determination of our own destiny, and we have every right and intention of having something to say about what is done with our lives.
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