Separate Agency Best

Separate Agency Best

Jim Omvig

Separate Agency for the Blind: Best Practice for Success

by James H. Omvig

From the Editor: Ever since Dr. Jernigan went to Iowa in 1958 to transform

the worst agency serving blind people in the country into the best program anywhere,

we have known how important it is for effective rehabilitation of the blind

to be conducted by a separate agency. "Because separate agencies do a better

job" is not a sufficient reason to give legislators being lured by the

siren song of consolidation. Jim Omvig is one of the people whom Dr. Jernigan

first rehabilitated and then trained to assist him to do his work in Iowa. Jim

is a blind attorney who has now been involved in rehabilitation for more than

thirty years. He wrote the following paper for several Arizona legislators some

years ago. It is as relevant and helpful today as it was then.

Background

Every state has some form of vocational rehabilitation and

training program for its blind adults, for which the federal

government pays approximately eighty percent of the cost. The

blind receive these services in one of two ways: either from a

large general rehabilitation agency, which tries to serve people

with all types of disabilities, or from a separate agency for the

blind, which presumably has the requisite expertise and serves

only blind consumers. Then in turn, if a separate program for the

blind is established, it may be either a section or division

within a much larger umbrella agency, or it may be a completely

separate and independent agency, directly accountable to the

governor, the legislature, the blind, and the general citizenry.

It is up to each state to determine which governmental structure

is best suited to meet the particular needs of its blind

citizens.

Congress has recognized that the problems of the blind are

unique and therefore that meaningful services for the blind are

distinctly different from rehabilitation and related services for

people with other disabilities. Accordingly, federal law permits

the states to establish a completely separate, independent agency

for the blind if they wish in order to address these unique needs

in a comprehensive, specialized program. The relevant federal law

is Title 29 USC, Section 701 (a) (1) (A) of the Rehabilitation

Act of 1973, as amended.

Experience has shown that the blind always have the best

possible chance of receiving quality services when such services

are delivered through an independent, separate agency for the

blind. There are numerous reasons for the tremendous success of

these programs. They are outlined in the section below.

Why a Separate, Independent Agency for the Blind?

Rehabilitation of the blind has more in common with

independent living services for the blind, services for the older

blind, orientation and adjustment training for the blind, sight

conservation, and sheltered employment for the blind than it does

with rehabilitation of other disability groups or the socially or

economically disadvantaged. Likewise small business enterprise

programs for the blind have more in common with rehabilitation

services for the blind than they do with other types of small

business programs.

Even so, some argue that the blind should be lumped together

with other disability groups or served through some giant

umbrella agency to achieve integration and coordination of

services. Until you think about it carefully and have certain

facts presented to you, this might sound like pretty good,

logical thinking.

There is, indeed, a need for coordination and integration of

state services for the blind, but terminology should not be

confused with reality. If, for instance, a state has a supervisor

of highway construction, a supervisor of elementary education, a

supervisor of pest control, and a supervisor of health and

welfare, it does not follow that integration and coordination are

achieved by creating a Department of Supervisors and lumping all

of these people and functions together. Nor is any real

integration or coordination achieved by establishing a Department

of Health and Highways. Health is one function, highways another,

and they cannot meaningfully be integrated.

If such a department is established, all that can be

accomplished is to superimpose a costly administrative hierarchy

upon the two departments. They will still remain separate

functions whether they be called departments, divisions,

sections, bureaus, or whatever. In fact the administrative

hierarchy will be detrimental and will only cause inefficiency

and waste in such a situation.

Relating all of this to the blind, fragmentation is

increased rather than helped by putting all of the services for

the blind into a division of a super-department. What is needed

is common sense rather than textbook theory and neatness of

somebody's organizational chart. Sound reasoning tells us that

the various services for the blind complement and supplement one

another and form one unique entity. They are only very slightly

and incidentally related to services for people with other

disabilities or other disadvantaged groups despite the similarity

of terminology.

The people who administer rehabilitation and other services for the blind

should be able to administer the entire package, and they should not be distracted

by other duties. Furthermore, they should not be responsible to people who have

other program interests and who may, therefore, subordinate the needs of programs

for the blind to other interests or pet projects. At the same time the professional

agency for the blind administrator must be responsible to some authority as

a check and balance and a testing ground for his or her judgment. This authority

should be a lay board, preferably one containing a number of blind people themselves—people

who know firsthand what the services are and what they should be to achieve

best results.

In those states where separate, independent agencies exist,

the governor (often with the advice and consent of the Senate)

appoints the members of the lay board. The board hires the

director, and the director then hires other staff and provides

the leadership and day-to-day management of the program.

On the other hand, if the administrator of programs for the

blind is responsible to the head of some super-agency or even

directly to the governor, he or she is really not responsible to

anyone, for these people are not knowledgeable about what is

needed and are likely to be extremely busy with other matters.

Thus an independent department or commission for the blind

administering all state services for the blind is clearly best

suited to meet the requirements for a good program.

It is, of course, possible to have an inefficient

independent agency just as it is possible to have an inefficient

program under any other type of structure, but the odds are much

better for good programs if you have the independent agency

system. This all depends, of course, upon the caliber and

expertise of the people who do the administering. However, if all

other things are equal, an independent commission affords the

best organizational structure. Let me be more specific about what

I have been saying. Even though the same words are sometimes used

when we talk of various service programs, the mere use of such

words is where the similarity ends. For example, rehabilitation

of people using wheelchairs or of the deaf is in no sense the

same process as rehabilitation of the blind. And this is equally

true when discussing a hundred other types of rehabilitation. In

other words, the problems facing blind people are unique. From

this it naturally follows that those who are hired to provide

rehabilitation services for blind people must possess a unique

reservoir of knowledge specifically related to the problems of

blindness, if effective programs are to be carried on. If we are

to be truly effective, we need experts whose training and

experience relate specifically to the problems of blindness. It

is sheer nonsense to expect any human being to be knowledgeable

about and to possess the necessary expertise to deal effectively

with all of the problems of everyone needing various types of

rehabilitation services.

"But," it is sometimes argued, "it is desirable to have the

uniformity of administration found in a large super-agency." This argument

might be made with considerable validity for producing license plates or for

regulatory agencies—licensing, permits, etc. Its validity is much more

doubtful, however, with respect to human-service programs, which for maximum

efficiency must operate on a person-to-person basis. As I have said, neatness

of somebody's organizational chart and uniformity of administrative pattern

must not be permitted to obscure the human element. In fact, there is considerable

evidence that bigness itself is a negative, not a positive factor.

"But," it is further argued, "programs for the blind and

others which sound similar should be merged into large

departments so that they will not function in a vacuum and be too

independent." An interesting point can be made here. The best way

to hide a tree is in a forest. A separate, independent agency for

the blind with a lay board would always operate in the spotlight

of inescapable scrutiny, accountability, and responsibility. If

its programs are not functioning well, the blind can and will

rise in protest, and there can be no possibility of evasion, no

shifting of responsibility, no passing the buck. There is no

hierarchy of administrators, divisions, or bureaucrats to stand

between unhappy blind consumers and the people employed to give

them service.

On the other hand, if you want real independence and lack of

accountability, turn that agency loose in the mazes of

bureaucracy as a tiny segment of a super-agency. In the hide-and-

seek of the intricacies and technicalities and divided

responsibilities within a giant agency, no governor and no

legislator can track it down. In the corridors of bureaucracy the

full-time professional administrator is king, and the layman,

whether governor, legislator, or average citizen just seeking

service, is subject.

Establish a separate, independent agency for the blind with a lay board appointed

by the governor and you have checks and balances and the maximum incentive for

that agency to do a good job. Submerge services for the blind in a large department,

and you give that program a blank check of independence and authority—independence

and authority which it should neither want nor have.

Further, when you place services for the blind in a larger

department of government, this will necessarily divert the

energies and talents of administrators whose training,

experience, and main professional concerns should be strictly

with the blind. Can anyone really doubt what the main

professional concerns of the high-level administrators of a

giant, umbrella agency are? I can assure you that those concerns

have nothing to do with blindness.

We who are blind do not wish to divert the energies or

talents of anybody, nor do we wish the agency for the blind's

energies and talents to be diverted, watered down, or shifted

from the course of giving the best possible service to the blind

of the state. This is probably one of the principal reasons why

many states have separated their services for the blind from

large departments.

"But," as a last-ditch effort, it is argued by the

uninformed, "can't we save a lot of state and federal money if we

just lump together these seemingly related programs? We can avoid

duplication and save a bundle." While this sounds logical and

responsible, the fact is that, where this re-organizing takes

place, the same program administrators and managers are generally

retained, but in addition a new and costly level of

administrators is imposed to supervise the original program

managers. This practice costs more, not less.

Finally, several years ago an independent study (The Mallas

Report) was made of service delivery systems to determine which

type was best suited to provide quality rehabilitation and

related services for the blind. The study concluded that the

separate, independent agency with a lay board appointed by the

governor is best. In an interview the researcher said, "Where

reorganization of services for the blind has taken place on the

basis of the economy-of-scale principle, its proponents have sold

the legislature and the Governor on statements such as, `This

will be more efficient and economical. It will let us get more

mileage out of every tax dollar.' As a matter of fact, in every

state where such a reorganization has taken place, the prestige

and level of operation of the agencies serving the blind have

been downgraded." This study also makes another revealing

finding. "In general programs for the blind which fall under

rehabilitation departments and umbrella agencies have the least

effectiveness in developing and utilizing necessary financial

resources."

In conclusion, we who are blind want the opportunity to receive services aimed

at returning us to the mainstream of life. We want to be taxpayers, not tax

users. The separate, independent agency for the blind offers us the best chance

for meaningful programs. We are willing to work, and work hard, but we will

also dare to dream in order to develop and protect our separate programs.

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