Why Accreditation Failed Agencies

Why Accreditation Failed Agencies

C. Edwin Vaughan

Why Accreditation Failed

Agencies Serving the

Blind and Visually Impaired

by C. Edwin Vaughan

From the Editor: The following article first

appeared in the January/February/March, 1997, issue of the Journal of Rehabilitation. Ed

Vaughan is a long-time member of the National Federation of the Blind of Missouri and a

published authority on the history and sociology of blindness and the blindness field.

Many of us in the Federation have lived the history Ed summarizes in this piece, but it is

interesting and instructive to review the whole sorry mess that has been made of

accreditation in the blindness field. We would all be wise to remember what has happened

during the last forty years in order to see that the same mistakes are not made in the

future. Here is Ed Vaughan's paper:

Four major organizations provide national

accrediting services for rehabilitation agencies. National accreditation becomes

increasingly important when both consumers of services and those who provide economic

support for these agencies expect increased accountability. The most specialized of these

national agencies is the National Accreditation Council for Agencies Serving the Blind and

Visually Handicapped (NAC). NAC grew out of a two-year planning process which culminated

in the establishment of the new accrediting organization in 1967. Its founders envisioned

accrediting more than five hundred agencies that provided education and rehabilitation

services to people who are blind.

Throughout its history NAC has been opposed by

well-organized consumers of services and has not attracted the support of most agencies.

It has never reached its envisioned goals and is now declining. This article reviews the

history of this accrediting organization and discusses the reasons for continuous and

intense consumer and professional resistance. It analyzes why different occupational

groups within this field failed to unite in support of NAC and provides data documenting

its rapid decline during the past decade. The article concludes by exploring available

alternatives for agencies in the blindness field when accreditation fails.

Currently there are at least four organizations

providing nationwide accreditation services: the Accreditation Council on Services for

People with Disabilities (ACD), the Commission on Accreditation of Rehabilitation

Facilities (CARF), the Joint Commission on the Accreditation of Health Care Organizations,

and the National Accreditation Council for Agencies Serving the Blind and Visually

Handicapped (NAC). These accreditation programs frequently focus on a particular aspect of

rehabilitation, such as blindness, developmental disabilities, or medical aspects of

rehabilitation not necessarily related to vocational rehabilitation.

Rehabilitation usually involves a continuum of

services, and comprehensive agencies try to provide a continuum of care or services.

Accreditation becomes a general concern when the accrediting organizations themselves

become specialized and may only be able to accredit certain aspects of an agency's

complete program (Grove, 1995).

Some states require any agencies receiving state

appropriations to be certified. Such certification is sometimes done in house, using state

employees for the certification process. Other states, such as Missouri, require that

agencies receiving state funding have some form of national accreditation. This brings a

national perspective to the state-funded programs and does not require the direct use of

state funds, which can then be used for client services (Solum, 1995).

The cost of national accreditation is becoming an

issue with some agencies. The cost usually varies with the size and complexity of a

rehabilitation program. For example, the Accreditation Council for Services for People

with Disabilities may charge as little as $3,000 and as much as $18,000. The larger figure

would be for a complex agency with several locations. A typical figure would be $8,000 for

a two-year accreditation (Nudler, 1995).

Accrediting agencies are created to assure the

public that economic resources are properly utilized, that facilities are both safe and

adequate, and that they have a properly educated staff. Duplication of programs can be

minimized and, as the process of professionalization continues, task differentiation can

be certified (Rothman, 1987). As a profession develops, it tends to seek increasing

control over the organizational settings where services are provided (Abbott, 1988;

Larson, 1977). This frequently produces internal conflicts as agencies resist external

domination. Conflicts within a profession and consumer criticism and opposition may become

insurmountable barriers for an accrediting organization. This paper analyzes the sources

of the decline of the National Accreditation Council for Agencies Serving the Blind and

Visually Handicapped and suggests alternatives for a more effective accreditation program.

Following World War II there was a rapid growth

in the number of agencies serving the blind and visually impaired. With this growth came

concerns about the quality of programs and the qualifications of professional workers.

This concern led to the development of the National Accreditation Council for Agencies

Serving the Blind and Visually Handicapped in 1967. NAC began with great expectations

among professionals who work with the blind and visually impaired.

However, it never met the expectation that it

would become financially self-supporting and at its height accredited only a small portion

of the agencies and organizations in the field of blindness. It has been in decline for

the past decade and has been consistently opposed by the largest consumer organization of

blind people, the National Federation of the Blind (NFB). It recently lost the financial

support of the American Foundation for the Blind (AFB). The AFB had been crucial in

providing the financial and staff resources for the process that led to the creation of

NAC and had been its largest single source of financial support for over fifteen years. In

1994 the United States Secretary of Education informed the National Accreditation Council

that it had been dropped from the Secretary of Education's list of recognized national

accrediting agencies (Pierce, 1995).

As this paper will show, the number of agencies

accredited by NAC has been dropping steadily for the past nine years, moving from a high

of one hundred and four to its present sixty-four. NAC's decline comes at a time of

increasing national concern about accountability and an increasing emphasis upon the

outcome of education and rehabilitation programs (Szymanski & Linkowski, 1995).

Origins of NAC

Two years of a carefully planned organizational

effort leading to the formal establishment of NAC attracted both consumer and professional

criticism. Disregarded criticism led to a lukewarm support from agency professionals and

intense consumer opposition; more articles have appeared in the Braille Monitor about the

failures of accreditation than on any other single topic. For more than fifteen years

large numbers of blind people, usually between two hundred to three hundred fifty, have

come from all over the United States to demonstrate publicly against the failures of NAC

(Rabby, 1984).

To understand the roots of this conflict, it is

necessary to examine some of the developments in the field of work with the blind over the

three decades preceding the establishment of the National Accreditation Council. It is

then possible to analyze the process by which the new agency was established, along with

its goals and early successes. It is also important to consider the reasons it was

continually opposed by consumers and why it has been ignored or boycotted by many agencies

and professionals working with people who are blind.

Before World War II most teaching of the blind

occurred either in special institutions, in schools for the blind, or in a home setting by

itinerant home teachers. Beginning shortly after World War II, rehabilitation centers were

established in several parts of the United States. The number of blinded war veterans and

the financial support from the Veterans Administration were one source of this growth.

These centers, sometimes developed in tandem with sheltered workshops, aimed at helping

blind people adjust to their blindness, learn skills, and be evaluated for vocational

training or educational purposes.

As early as 1932 there was concern about the

degree or adequacy of the training of home teachers of the blind. These teachers were

mainly women, and the majority were blind. They found themselves interacting with the

rapidly expanding profession of social work, which was developing its own standards for

educational requirements. In 1932 a regional organization of home teachers appointed its

own committee to develop minimum standards of practice (Koestler, 1976).

Further impetus toward standards came from the

federal government in the 1939 amendments to the Social Security Act. All persons employed

in the federally funded welfare programs would have to participate in a merit system.

"In many states the commission for the blind would have to meet the same civil

service standards as those of the sighted civil service workers employed in other facets

of welfare assistance" (Koestler, 1976, p. 291). As Koestler noted, the question

arose whether or not blind people employed as home teachers would lose their jobs or be

replaced by more educationally qualified sighted teachers. The possible displacement of

blind workers was the earliest source of resistance.

In 1938 the American Foundation for the Blind

convened a special conference to work out the philosophy and principles of home teaching.

Following this, the American Association of Workers for the Blind (AAWB) appointed a board

for certification of home teachers. The new standards were adopted by the 1941 convention

of the AAWB and included two levels. Class 1 required two years of college training

including courses in social work and education. In addition, Braille, typing, and

proficiency in six handicraft skills were required. Four years of experience could be

substituted for the college training. Class 2 required completion of the college course

work of Class 1 and at least one year of postgraduate training in social work. In 1947 the

annual convention of AAWB was informed that sixty Class 1 and three Class 2 certificates

had been granted (Koestler, 1976).

Reporting as chairman of a 1952 committee to

explore standards, Roberta Townsend stated to the 1953 AAWB convention that a lack of

unanimity of thought and standards had resulted in "many sporadic programs" and

frequent duplication of services. Following her report, the AAWB adopted a resolution

"asking that `a manual be devised of useful criteria and standards for the guidance

of agencies' and that it be developed by the American Foundation for the Blind"

(Koestler, 1976, p. 340). In the same year the organization issued another blunt report

criticizing empty or shallow agencies which provided almost no services but sought funds

from the public, ostensibly to provide help to the blind. It noted that more than six

hundred agencies for the blind were making conflicting approaches to the public for

support with sometimes counterproductive results. Both reports led to a growing concern

for standards which would result in a seal of approval for agencies in compliance with the

agreed-upon criteria.

In 1956 the Federal Office of Vocational

Rehabilitation, with the American Foundation for the Blind, sponsored a conference

intended to develop principles and standards to guide proliferation of work for the blind.

Development had been rapid because of the increasing support from the federal government

in areas such as the Veterans Administration, the Office of Vocational Rehabilitation, and

the Hill-Burton Act, which made funds available for constructing rehabilitation facilities

independent of hospitals themselves. Private agencies serving the blind were growing in

both number and size in almost every large American city.

The 1956 conference invited carefully selected

workers in the field of blindness. As Koestler notes, many of these were the same

individuals who had met at previous AFB-sponsored conferences to deal with standards and

accreditation. "Out of the work of the seventeen people who spent five days in

sub-committees and general sessions came a set of precepts that largely foreshadowed the

standards later adopted by COMSTAC" (1976, p. 297). The Commission on Standards and

Accreditation of Services for the Blind (COMSTAC) would lead to the establishment of the

National Accreditation Council.

Robert Barnett, then President of the American

Foundation for the Blind, recognized that a structured process which would involve

standards and a method of implementing them would be necessary to achieve the maximum

benefits for blind people, given the proliferation of agencies and funds available for

rehabilitative services. Following this lead, the President of the AFB Board in 1961 said,

"It is not our intention that the American Foundation for the Blind will itself

conduct a policing program, but rather that it will arrange to expedite a service program

of evaluation and accreditation which would find its authority in a democratic

representation of all legitimate interests in this field" (Koestler, 1976, p. 342).

As this article will subsequently show, the

conflict that swirled around this accreditation effort resulted, in part, from confusion

about the meaning of "democratic representation of all legitimate interests in this

field." It later became a central contention of the leadership of the only national

organization of blind people existing at that time that, not only were blind people not

adequately represented, but the entire process leading to the National Accreditation

Council was tightly managed by a small group of professionals and orchestrated by the

American Foundation for the Blind (Vaughan, 1993).

In 1962 an ad hoc committee appointed by the

American Foundation for the Blind recommended that an autonomous commission be appointed

to develop standards and regulations and to create a permanent accrediting body. The

American Foundation for the Blind agreed to finance the commission's work partially while

allowing it autonomy. Over the four years of the commission's work, the AFB provided

$300,000 plus the labor of many of its staff members, while an additional $138,000 was

obtained from three private foundations and the Vocational Rehabilitation Administration.

The resulting committee reports were reviewed at

a conference attended by more than four hundred people in 1965, and the revised standards

appeared in "The COMSTAC Report: Standards for Strength in Services." This

report recommended that an organization be established to carry out the accreditation

process. Thus the National Accreditation Council for Agencies Serving the Blind and

Visually Handicapped was established in 1967 with Arthur Brandon, the former chair of the

COMSTAC, as its first president. A. F. Handel, the new executive director, had also been

executive director of COMSTAC.

The founders of NAC projected a ten-year plan,

which would conclude with levels of economic support sufficient to eliminate external

subsidy. The organization would be supported by fees paid by the agencies seeking

accreditation. To underwrite the program during the developmental phase, the American

Foundation for the Blind and the Vocational Rehabilitation Administration assumed the

greatest burdens. By 1972 NAC had accredited forty-seven agencies with approximately fifty

more involved in some stage of the accreditation process (Koestler, 1976). By 1972 it was

apparent that self-sufficiency was not possible, and it would require an additional period

of subsidizing.

The enthusiasm for NAC was not unanimous. Support

was concentrated in larger private agencies. Koestler's interpretation of reasons for

resistance or lack of enthusiasm on the part of some groups included the following: 1)

Professional standards might threaten the positions held by some blind people who might

not measure up to new requirements in public and private agencies; and 2) the interests of

blind people working in sheltered workshops were threatened by an accreditation process

that might ignore their concerns about minimum wage, collective bargaining, and other

labor-practice issues (Koestler, 1976).

Consumer literature reflected a concern that a

small group of self-designated professional staff people had their own agenda for managing

and controlling the field of blindness. Consumer groups particularly argued that they had

been under-represented and even ignored in the COMSTAC process. However, before turning to

the consumers' point of view, we will review some of the early reported enthusiasm by the

officers of NAC as well as some agencies who experienced accreditation.

The first accreditations were granted in 1968 and

were lauded in the first annual report of NAC. Its president commented, "The ferment

continues. Out of it will come rising numbers of accredited agencies giving even better

service to the blind and visually handicapped. And even as the numbers grow, the ferment

spreads" (NAC Annual Report, 1968). The first three accredited agencies were proud of

their accomplishments and began immediately using the seal of approval on their stationery

and in their publicity.

In NAC's first years a three hundred forty-two

page study guide was published. The check list and rating scales, intended to guide

self-study, covered eleven aspects of agency activity: function and structure, financial

accounting and service reporting, personnel administration and volunteer service, physical

facilities, public relations and fund raising, library services, orientation and mobility

services, rehabilitation centers, sheltered workshops (in multi-service agencies), social

services, and vocational services.

The professional literature, as reflected in the

two major journals of that time, presented no critique of COMSTAC or the resulting

accreditation agency, NAC. Articles extolled the virtues of being accredited. The

strongest agencies would be further challenged, and the weakest improved. Through the

self-study process staff members would be exposed to national perspectives, and agencies

would no longer be isolated. Facility improvements could become the basis of fund-raising

appeals based on the need to be nationally accredited. NAC had been created as the only

source of the seal of approval.

Consumer Perspective

During the period discussed in this article, the

National Federation of the Blind, founded in 1940, was the only broad-based organization

of blind people. Its regular publication, the Braille Monitor, focused on the harm caused

by "custodialism," any practice which diminished the independent living

capabilities of blind people. While a fairly small group of carefully selected leaders in

the profession were developing the process and agenda for COMSTAC, the Braille Monitor was

publishing articles about agencies and practices which, it alleged, provided either

exploitative or unequal treatment to clients receiving rehabilitation services. For

example, in May, 1963, the journal described the firing of forty blind people from the

Berkeley workshop of California Industries for the Blind. They were laid off because of

their demands for better pay and their efforts to organize a labor union. In September,

1964, an article entitled "Struggle Against Odds" in the Braille Monitor

described the efforts of its members in New Mexico to obtain an orientation center for

their state (Matson, 1963).

During the years immediately preceding the

creation of COMSTAC, members of the National Federation of the Blind and of other

organizations such as the Blinded Veterans Association were working to improve the

economic and social conditions faced by blind people. There were requests for new

rehabilitation centers and union recognition of employees of sheltered workshops, demands

for better pay for blind workers in these workshops, and the initiation of many types of

legislation to benefit blind people. Prominent national political leaders such as Senators

Robert Kennedy, Vance Hartke, and Frank Moss spoke at the NFB National Convention in 1965

praising the Federation's efforts on behalf of blind people. More than one hundred

Congressmen attended the conference's final banquet.

Clearly the National Federation of the Blind was

a strong and growing force in the struggle for equal opportunities for blind people. As

its journal suggested, the Federation frequently worked with private and state agencies in

mutual efforts to secure improved legislation and new programs. However, there appears to

have been almost no relationship between the rapidly growing organized movement of blind

people and the relatively small leadership group which had been shepherding the effort to

professionalize the field of work for the blind (Vaughan, 1993).

Opposition to NAC had been voiced even before NAC

was created. In 1965 tenBroek stated, "Organizations of the blind themselves, such as

the National Federation of the Blind, have been conspicuously absent from the roster of

groups and individuals asked to formulate supposedly objective `standards' to be applied

to all organizations in the field" (1965, p. 25).

Many articles would soon appear claiming that the

American Foundation for the Blind and a related social network of professionals were

attempting to dominate and control all agencies. The National Federation of the Blind was

founded in 1940. Its purpose was to empower blind people—so that they would not be

taken care of but would instead take care of themselves. However, because the COMSTAC

Commission and the establishment of the National Accreditation Council occurred in the

1960's, the decade of the equality revolution in the United States, the reaction of the

National Federation of the Blind was probably more intense than it would have been at an

earlier time (Gans, 1974). Almost every minority and gender group in the United States was

demanding equal treatment. The convergence of the interests of these different movements

brought political responses leading to the civil rights legislation of that decade.

Self-determination and full participation were in the air.

Professionals in the blindness field who were

providing leadership during the COMSTAC period could not have picked a less propitious

time to launch a new program and organization which did not include the full participation

of the consumers in a rapidly growing social movement of blind people dedicated to

self-determination. Dr. Jacobus tenBroek, President of the National Federation of the

Blind during this period, was a nationally recognized scholar in the field of welfare

rights, showing interest in and participating in other social movements of that day

(Vaughan, 1993). He also served as chairman of the California Board of Social Welfare.

Through 1966 articles appeared in the Braille

Monitor condemning a lack of consumer participation in the planning process and the

regressive nature of many recommendations being proposed for the future NAC. The

Commission was criticized for institutionalizing practices resulting in dependency. To

many blind people as well as to several agency directors, a small group of professionals

with similar and overlapping institutional affiliations were trying to dominate the field

of rehabilitation through a new inclusive organization, which was saddled with negative

and regressive assumptions about blindness (Vaughan, 1993).

The gulf between the organized blind movement and

the professionals in charge of COMSTAC is perhaps illustrated most clearly in a February

14, 1966, letter from the President of the National Federation of the Blind to Arthur L.

Brandon:

Our right to participate in the preparation of

plans for our own lives and our own future—or if you will, in the formulation of

standards for our institutions and services— cannot any longer be casually spurned as

if it were an argument about the formulation of a standard or the punctuation of a

sentence. That right is not in any sense complied with by a form request to any of us to

submit our views, which the professionals then may not pay attention to in their work on

our lives (tenBroek, 1966, p. 26).

Koestler observed that opposition to COMSTAC and

NAC also came from blind workers whose positions were threatened by professional

standards. She noted that some groups objected to work conditions, labor practices, and

low wages being paid in sheltered workshops, many of which were or would be accredited and

given the seal of approval by NAC.

In a 1971 convention address Dr. Kenneth Jernigan

made clear that the NFB's quarrel with the National Accreditation Council was neither over

the concept of accreditation nor because of efforts to improve services to blind people.

In this same speech Jernigan explained his perception of NAC and the way it operated.

Consumer participation was minimal—tokenism. To Jernigan, key issues not included in

NAC's purview were as follows: "...does the shop pay at least minimum wage? Do its

workers have the rights associated with collective bargaining? What sort of image of

blindness does it present to the public?" (pp. 21-22). Jernigan felt that board

members were not aware of these issues and not aware of the significance of consumers'

almost complete exclusion from the board (Jernigan, pp. 21-22).

Over the next twenty years an average of seven

articles per year appeared critiquing and exposing alleged and documented shortcomings of

NAC-accredited agencies. Up until 1990 the annual NAC board meetings were picketed by two

to three hundred blind people who traveled from all over the United States to meeting

sites (Rabby, 1984). In almost every state Federation members continually tried, often

with success, to persuade agencies to disassociate from NAC. The conflict has become a

struggle with no middle ground.

However, the criticism of NAC has been ignored

within the professional literature of blindness rehabilitation. The issue was too divisive

for a nascent organization of professionals. Some small agencies did not want to incur the

cost of accreditation. The various professions comprising the field—work for the

blind—had long histories of being independent. Although they were now merged in one

professional organization, principals and teachers in schools for the blind had different

traditions and social networks than the private agencies, which often represent social

work activities. Each state also now had its own rehabilitation programs funded with

public money and had become yet another stake holder in this field. Many professionals

from these three areas saw no reason to incur costs and give up autonomy to a new national

accrediting organization.

The Present Situation

However, in the past two years there have been a

declining base of economic support and failure to accredit even a small portion of

agencies and programs serving the blind and visually impaired. The National Accreditation

Council is in crisis and by only a slight margin failed to vote for its own dissolution.

The high point for NAC accreditation, according

to its annual reports, was 1986 when one hundred four agencies were listed as accredited.

"On February 21, 1991, the National Industries for the Blind officially announced

that its funding of NAC would cease in June, 1991, and the American Foundation for the

Blind made the same decision shortly thereafter" (Vaughan, 1993, p. 159). On April 7,

1991, the NAC board met to consider its financial crisis. The board then voted by a twelve

to two vote to disband NAC. Subsequently, the board learned that a vote by the entire

membership was required for dissolution. On May 5, 1991, with ten members present and

ninety-one proxy votes, the National Accreditation Council voted fifty-three to

forty-eight to continue its accreditation efforts (Megivern, 1991). The president and vice

president of the board resigned after this vote.

The Association for the Education and

Rehabilitation for the Blind and Visually Impaired (AER) is the most influential and

comprehensive professional organization in the field of blindness rehabilitation. In her

coverage of NAC's problems, Megivern (1991) in her AER Reports mentions NAC's financial

problems and its failure to accredit new agencies. She provides no background information

concerning these failures but does report that business goes on as usual.

The following table (Pierce, 1995) illustrates

the decline in the number of agencies accredited and displays the ratio of accredited

agencies to potentially accreditable agencies:

Decline in NAC-Accredited Agencies

1990 1992 1994

Schools for the Blind: 26/71* 20/71 18/71

State Vocational

Rehabilitation Agencies: 10/52 5/52 4/52

Sheltered Workshops: 33/82 21/82 18/82

Regional or City-Based

Private Agencies:** 28 32 29

Total 97 78 69

**********

*X/Y: X equals number of NAC accredited agencies

Y equals total number possible

**The number of private agencies fluctuates from

year to year

The consumer criticism, particularly from within

the National Federation of the Blind, continues to include an unrelenting effort of

investigative journalism concerning agencies that have come to the attention of the

general public for either financial mismanagement practices, endangering the safety of

children and students, or sexual harassment and abuse. For example, beginning in November,

1994, the Braille Monitor staff reported newspaper articles from the Arkansas

Democrat-Gazette reporting on a series of financial irregularities and culminating in

charges of sexual harassment of present employees and former blind female students. The

superintendent, Mr. Leonard Ogburn, was suspended June 24, 1994, and resigned on September

23 of the same year. Formal charges were filed, and when his case came to trial,

"Ogburn, former superintendent at the school, pleaded no contest Wednesday to

harassing a female employee by saying he wanted to spank her. Little Rock Municipal Judge

Lee Munson placed Ogburn on probation for one year and fined him $250 court cost"

(Pierce, 1994a, p. 128).

The National Accreditation Council's publication,

The Standard-Bearer, in its annual report, 1994, lists the Arkansas School for the Blind

as one of four schools continuously accredited for twenty-five years. Mr. Ogburn became

superintendent of the Arkansas School in 1985 and was a member of the NAC Commission on

Accreditation. Following his resignation from the Arkansas School, he was no longer

eligible to be a member of the NAC National Commission on Accreditation (Westman, 1995).

The Braille Monitor has reviewed a long history

of similar publicly documented abuse or mismanagement cases, all associated with

NAC-accredited agencies. To its consumer critics NAC has frequently placed its stamp of

approval on some of the more regressive and badly managed agencies in this area of

education and rehabilitation. "Three quarters of the residential schools for the

blind in this country have chosen to have nothing to do with NAC. Of the eighteen that do

find it handy to wave the NAC flag, five (Alabama, Arkansas, Florida, Illinois, and

Maryland), which is almost a third, have found their way into the front pages of the

newspapers because of some sort of scandal during the last five years" (Pierce,

1995b, p. 294).

Why NAC Failed

Why has the National Accreditation Council for

Agencies Serving the Blind and Visually Handicapped not been successful in accrediting

agencies? It began with more than two years of preparation. At that time it envisioned

accrediting more than five hundred agencies. The initial effort was supported by the

prestigious American Foundation for the Blind, originally created to advance the interests

of professionals working in the field of blindness. The project also had financial support

from the U.S. government and the leadership of many prominent individuals in this field.

First and possibly most important, the

originating process, COMSTAC, and the later NAC organization did not significantly involve

the organized blind. By 1965 the National Federation of the Blind was a strong and

influential organization. Its membership and leaders were committed to full participation

in decisions that affected them. They also opposed NAC because, from their analysis and

investigations, they concluded that it accredits some of the most regressive agencies.

Second, the profession is comprised of diverse

occupations providing educational and rehabilitation services. It represents groups with

different historic origins and consequently different social networks and interests,

including principals of schools for the blind, staff workers in private agencies,

directors in state agencies, and directors of sheltered workshops. Differences between

these groups are sometimes greater than concerns that unite them. It may not have been in

their interest to have the field controlled or regulated by a relatively small group who

created and have continued to support NAC. Many agencies wish to avoid the negative

publicity, for fund-raising if nothing else, of the continuing consumer opposition to NAC.

Third, the large, state-funded rehabilitation

programs never became significantly involved with NAC accreditation. Such agencies are

more vulnerable to consumer opposition. Consumer groups have lobbied their state and

national political representatives to "stop wasting money on NAC." Also some

requirements associated with licensing are sometimes seen as discriminatory in publicly

supported agencies. For example, one state director of rehabilitation services for the

blind told me, "We consider applicants for positions on the basis of ability,

training, and education, not on their visual acuity" (Vogel, 1992). This is contrary

to the requirements of AER, the primary supporter of NAC, that orientation and mobility

instructors be sighted.

More recently vision tests have been replaced by

functional requirements, which still exclude blind workers. The applicant would need to

demonstrate his or her ability to perceive what a sighted instructor would consider a

potentially dangerous situation. However, this functional approach is now being debated

within the profession. The policy is currently under review by the Certification and

Review Committee of AER (Weessies, 1995). The Americans with Disabilities Act requires

reasonable accommodations; for example, a blind mobility instructor might well argue that

he or she could use an assistant when providing mobility training in a potentially

dangerous area.

Consumers have less ability to influence smaller

private agencies such as the Lighthouses. Consumers have less leverage in these agencies

because the boards of directors are primarily comprised of wealthy or prominent citizens

who frequently know little about the issues involved. Management can usually rely on board

support to disregard consumer complaints.

Future Prospects

If the development of a broadly supported and

effective accreditation program for agencies serving the blind and visually impaired

depends on NAC, the prospects appear bleak. Richard L. Welsh, President of NAC, in the

1994 Annual Report of NAC makes the following comments, "This heart is still beating

strong even though there is less blood flowing through the arteries and veins." He

goes on to comment that this national accrediting organization belongs to its volunteers.

"As long as enough volunteers and agencies see a value in the process, it will

continue to exist and to be of service to schools, agencies, and programs that serve the

people with visual impairments." Based on the evidence of decline we have presented,

it is unlikely that this relatively small, beleaguered group will be the vanguard of a new

accreditation program that could attract broad support in this specialized area of

rehabilitation and education.

Agencies which require accreditation or find it

otherwise useful may seek accreditation outside the blindness field. For example, the

Cleveland Society for the Blind, after dropping its relationship with NAC, sought and

obtained accreditation from the Commission on Accreditation of Rehabilitation Facilities

(CARF). Many agencies which serve multiple client groups including blind people are

already accredited by CARF. Most professionals working in the field of blindness strongly

support the need for specialized services for their clients and would probably prefer an

accreditation process focusing on their specialized agencies.

Throughout education, for diverse reasons,

politicians and educators are demanding accountability. This concern is increasingly

focused on the outcome or results of education programs (Loganecker, 1994). Applying these

concerns to the rehabilitation of blind individuals, the primary focus will not be on

credentials, physical facilities, or rehabilitation procedures. It will focus on the

outcome of rehabilitation processes. Are graduates able to live more independently and

find competitive employment? Can agencies be compared using these criteria? Measurement

and comparison of outcomes in this area are not easy, but it is the direction that CARF

and other accrediting organizations are moving. Client participation and client

satisfaction will be necessary ingredients.

It is possible that the long-term supporters of

NAC may conclude that their organization is not adequately serving their agencies and

their profession. New leadership may emerge and begin the process with full consumer

participation from the beginning. That might result in a broadly supported accreditation

organization that would focus on the results of rehabilitation efforts.

Although this has been an historical analysis of

the decline of NAC, the issues raised appear in most areas of rehabilitation services.

With one exception almost all of the national accrediting organizations have not been

successful in attracting voluntary cooperation from large numbers of agencies.

"Rehabilitation agencies face many challenges as they seek to improve their services

in the coming decades. Increased demand for accountability and effectiveness, combined

with dedication to empower clients, present major program goals" (Mason, 1990;

Emener, 1991). In this context rehabilitation

counselors are asking for more autonomy in decision-making to serve clients better

(Jackson, 1995). Most states continue to prefer national accreditation, ensuring broader

perspective and a basis for making comparisons with programs from similar cultural regions

and economic conditions. The most comprehensive and most successful in accrediting

programs is CARF. In 1995 the number of CARF-accredited programs surpassed 11,000 for the

first time (Galvin, 1995).

The Commission on Accreditation of Rehabilitation

Facilities recently expanded its acronym to reflect philosophic changes in the

organization's approach to accreditation. It is now CARF...Rehabilitation Accreditation

Commission. It has avoided many of the problems NAC encountered by incorporating

organizational and programmatic changes as the organization evolved. Its large governing

board, forty-two members, has significant representation from consumer and advocacy

groups. Evaluation includes effectiveness, efficiency, and client satisfaction. An agency

is not told what its goals should be, but the agency is expected to attempt to measure or

assess the outcomes of its program efforts. The agencies are asked to document the extent

to which they have incorporated suggestions from previous evaluations or have developed on

going arrangements for self-evaluation.

Accreditation does not disregard structure and

organization, but the focus is on the outcome or results of the rehabilitation process.

Programs, not agencies, are accredited. The organization provides a comprehensive approach

with an ability to accredit all aspects of the rehabilitation process. Its success in

accrediting agencies permits a budget sufficient to provide educational materials,

conferences and backup support for agencies. Comprehensiveness, consumer involvement, a

focus on programs, and a national perspective are important elements in the success of

this particular model.

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