SRC- DBVI State Plan Comments - 2015
This is been quite a year for the SRC and DBVI. The year started out quietly but as it progressed some major issues within the agency came to light, testing the relationship between the SRC and DBVI. We are ending the year with, what we hope to be, an agency that is moving forward in a healthy manner, with a sustainable plan, and working cooperatively together as the SRC and DBVI.
As RSA knows DBVI ran into a financial shortfall starting in June 2015. The SRC started working on this issue in September 2015.There has been much input from the community as to where the SRC should be devoting it resources in 2016. The major areas are: homemaker closures, transition students (PETS) and "realignment".
Homemaker:
DBVI has historically use the homemaker closure to meet the needs of its older independent living consumers. The Independent Living arm of DBVI is currently in a financial deficit. In the past "homemakers" have fallen into the Title I section of the DBVI budget. It is clear this will not be happening as we move forward. Though the homemaker client represents a large portion of who DBVI Maine serves, most of this document focuses on employment. Employment is an important and worthwhile goal. It appears to the SRC the older blind and visually impaired population make up a large and growing portion of the state’s residents. The state plan appears to treat this portion of the blind community as an afterthought. It is the SRC's opinion that DBVI needs to allocate time and resources to this population of blind Mainers
Transition:
DBVI and the SRC also has to develop a plan with its PETS students.There is much work to be done in this area: retention of students, the 15% fiscal set aside in a state that is aging without dismantling the services being provided to other consumers of DBVI services.
Realignment:
The final focus of the SRC this year is the "realignment" activities of DBVI. Realignment is the term coined to describe the activities of DBVI to or seek efficiency and re-organize DBVI to bring operational expenditures back in line with federal and state funding. DBVI and the SRC are taking a retrospective look at how we ended up in the financial situation we are currently in. Working together, and trying to get a clear picture of what happened and how to prevent this from happening in the future. We are doing this by reviewing budgets, talking to staff and consumers along with reviewing various parts of the agency specifically contracts, technology, staffing, and outreach to the community.
Finally, early in the fall the combining of DVR and DBVI was not “off the table” The SRC would request from BRS/DOL whether activities within BRS are still looking at combining the two agencies as an option or has this issue been taken off "the table" permanently?
Though we have been on a rocky road we appreciate the effort DBVI is currently putting forth to help solve some very big issues in conjunction with the SRC for the community it serves.
Sincerely,
SRC DBVI
Specific Comments:
Page 2 line 28
As an ACB member and PTGDU member I had no knowledge this ever happened. I heard about it from a source outside of these specific groups. I then distributed the information about the hearings to these organization.
Page 5, lines 9-14
This paragraph speaks regarding a strong relationship between DVR and OADS/SAMHS. Does this information pertain to DBVI? If so, what is DBVI doing with these entities in terms of “implementing joint approaches to the workforce development of community rehabilitation providers and business engagement throughout the state”?
Page 6 line 34
We believe 504 students should also be added to this MOU.
Page 7, lines 1-18
The plan states that the DBVI Director sits on DOE advisory committee and is a member of a DOE team preparing for statewide implementation of UEB. The DBVI Director position has been vacant for several months. Who is fulfilling this role to ensure that DBVI is involved in moving these efforts forward?
Page 8, lines 14-26
The plan states that DVR and DBVI are working with DHHS to learn about new service opportunities such as Discovering Personal Genius and Medicaid waiver funding for persons with head injury. Does DPG pertain to DBVI or just to DVR?
Page 8 line 37
The SRC would like to see some data surrounding how the Business Relations Specialist has benefited DBVI in the past. Also, please explain why the Business Relations Specialist positions have not been filled. It does not seem feasible that DBVI Counselors/directors can cover these duties, considering the reductions in staff that have occurred.
Page 11
Plan states that DBVI’s leadership will continue to monitor and deliver training needs although CSPD is no longer a requirement. Should this state that DBVI has continued to monitor and deliver the services instead of will continue?
Page 12
Plan states that Maine DBVI does not currently have a wait list. Considering the budget shortfall and cutting of key DBVI positions, as well as reports from providers and clients that services were not being provided by DBVI, has DBVI formally considered entering into an order of selection? If not, has DBVI conversed with the SRC regarding their decision not to enter into an order of selection?
Page 12
In regards to projected vacancies over the next five years, is the Rehab Services Manager position the Assistant DBVI Director position? If not, where is the Assistant Director position? Why is the position projected to be vacant over the next five years? Why is the Business Enterprise Program staff position expected to be vacant over the next five years? There is no discussion in this section regarding the staffing cuts that have occurred or the impact of these cuts on DBVI. Please address the cuts as well as the impacts.
Page 14 line 26
Could DBVI please elaborate on the statement, "Going forward there are concerns regarding the impact on retention of qualified staff due to limited training resources and other physical challenges".
Page 18
One of the themes in the CSNA was the need for peer support/peer monitoring. We would recommend DBVI subscribe to the Iris networks newsletter (community connections) for a list of peer support groups around the state that staff could refer consumers too.
Page 18
The section talks of service delivery models. The two listed are, home-based and center-based models. In the past, there has been a third model a regional model. In the regional model several consumers from a community get together and receive services. This is cost-effective. It also allows consumers to be with others who are going through similar situations.
Page 19 lines 33 through 35
Where is the data or sources to support this statement? The statement being, "consumers continue to stress the need to have in-state option".
Page 20
Plan needs to address/include community-based model of services. There is great concern from blind consumers that choices have been strictly limited as independent providers have stopped receiving referrals to provide services. How is DBVI going to ensure consumer choice as well as timely access to services?
Page 21 section D
The SILC and others in the disability community are working toward developing a transportation voucher system in Maine which would substantially improve transportation problems for people with disabilities, especially in the rural areas. DBVI should include the intention of participating and supporting the development and implementation of an effective transportation voucher program in Maine.
Page 21 line 2
What were the ages of the people attending out-of-state immersion centers?
Page 22 line 31
The SRC believe "Awareness of DBVI Services" should be the first grouping in the section.
Page 23
In regards to DBVI eligible population doubling, how will DBVI prepare to serve these numbers? What additional resources will be needed and how will the resources be accessed? Additionally, the plan states that “consumers identified the need to explore service delivery models” related to non-English speaking immigrants and refugees. How will DBVI explore service delivery models and plan to better serve this identified population?
Page 24
STATE GOALS – Goal 1) The goal focuses on stabilizing DBVI’s financial situation; however, neither the goal nor the plan identifies DBVI’s financial situation. DBVI experienced significant changes during the past reporting year. Staff positions were eliminated; providers stopped receiving referrals; contracts were reduced. The structure of DBVI was changed in a significant way. Please speak to the changes and the potential impacts. Please include a goal that focuses on DBVI’s plan to restore structure, positions, and services statewide.
It is concerning that re-allotment funds will be used for “one-time initiatives.” Shouldn’t DBVI focus on initiatives that are sustainable and have great impact on individuals served?
Page 25
Order of Selection – Please explain how DBVI concluded that an order of selection is not needed. What discussion did DBVI have with the SRC regarding order of selection?
Page 25 section M
Maine DBVI does not currently have a wait list for individual seeking services but the SRC would suggest doing some research into referrals made by doctors’ offices. There is a thought that these referrals may not be processed in a timely manner.
Page 27 line 11
As an SRC we feel that Reallotment Funds, when used correctly and prudently can be incorporated into an annual budget. It should be noted that historically DBVI has time and time again utilized Reallotment funds in this manner. We do not feel it would be prudent at this time to remove this much needed stabilizing resource.
Page 28 winds 13 through 16
Offering an employment service that only runs every other year is not timely. Clients cannot wait up to 48 months for service. If this is a necessary service for clients it needs to either run more frequently or on an individual as needed basis.
Page 28
Goal 2) This goal includes an objective for implementing new WIOA regulations that affect homemakers. Do we have WIOA regulations? What will we do in terms of homemakers if we do not have regulations or until we have regulations? Please consider a goal that specifically addresses homemakers in a holistic manner. For example, DBVI needs a goal that will identify and provide supports and services to the homemaker population. How will IL funds be available to this group?
Page 29
Goal 4) unserved or underserved – please consider adding objective that addresses services for New Mainers (need identified by consumer).
Page 30 lines 44 and 45 and a page 31 lines
It is not obvious why you would want to form alliances with these two programs. DB VI is short staffed at this time. Establishing partnerships that are not paramount in nature seems to be a waste of resources. The SRC would recommend that you take these out.
Page 31
Supported Employment – The plan states that at least two consumers were closed successfully into integrated employment. What is the exact number? The plan identifies a lack of a variety of natural supports as a barrier for this population. What is/can DBVI do to develop/increase natural supports?
Page 31
Innovation and Expansion – How are these funds used specifically?
Page 33 lines 1 and 2
Could you please explain, to the best of your ability, why there was a drop in competitive closures in fiscal year 2015?
Page 33 lines 33 through 35
In 2011 RSA noted a 40% loss of students just before or after graduation. What is the percentage of students lost in 2014?
Page 37
Quality of Supported Employment Services: Why does the lack of long-term support prevent the development of a plan? What other options, like natural supports or connections wit community providers, has been done to ensure that these individuals who are eligible receive services?
Page 37
The plan states that there is ongoing self-evaluation that will positively impact the quality of service area, including supported employment. Please outline the self-evaluation plan and explain how it has and will positively impact services.
Page 37
The plan states that “trial work settings should be available to assess the consumer’s ability in an integrated, competitive setting.” Are these available? If not, why?
Page 38
What are the new ideas that DBVI is exploring in terms of extended support?
Page 38
How many of the 23 clients were closed successfully? Why is DBVI reporting “at least two individuals”? What is the exact number?
Page 38
The final sentence states that each individual “should” get the support they need. Why aren’t they getting the support they need? How can/will DBVI work to ensure the support is secured?
General Comments on the Plan:
- There is no indication in the plan that DBVI suffered major losses and setbacks during the previous fiscal year, including but not limited to: reduced staffing positions, limitation of services, decreased referrals for independent providers, reduction of contracts, staff uncertainly and fear, consumer uncertainty and fear. The current state of DBVI is the direct result of the substantial restructuring instituted by BRS.
- The relationship between DBVI and the SRC suffered major setbacks during the previous fiscal year. There is no indication in this plan that DBVI and the SRC need/plan to repair the relationship.
- The plan does not strongly differentiate blindness services from general VR services. Much of the language within the plan speaks generically of DBVI and DVR.
- Blind consumers expressed clear concerns with the way that DBVI has been restructured and requested input in terms of “restoring” DBVI to its current level of staffing. This plan does not indicate that blind consumers have expressed these concerns.
- Blind consumers have requested that DBVI be moved out of BRS into its own Commission. DBVI has not responded to the consumers’ desires/request.
- The plan does not address the projected shortfall of funding of IL for the blind community.
- DVR and DBVI have not worked well together for several years. The state plan should include clear commitment to improve the relations between the two departments and encourage a focus of collaboration.
- Consumers are not familiar or very comfortable with the public hearing process. Consequently the consumer voice in the state plan process has historically been less than what it could or should be. The state plan should make clear that DBV I will create plans to proactively and consistently meet consumers where they gather throughout the year to collect needs data, satisfaction data and other comments regarding consumers’ needs and how well the DBVI is meeting them.
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