PCB Public Comment on State WIOA Plan

The Pennsylvania Council of the Blind is a grassroots advocacy organization made up of over 400 members across the Commonwealth who experience blindness or vision impairment. PCB gives a collective voice to these individuals on issues that impact their lives and the lives of all Pennsylvanian’s with a vision loss. In this capacity, PCB would like to provide comment on Pennsylvania’s Workforce Development Plan (FY 2016-FY 2019) as proposed.

Accessible Software
On page 70, in the section entitled “Non-Discrimination and Accessibility,” the narrative describes the various accessibility features of the one-stop operators and one-stop partners. While we applaud these centers for providing screen reader software such as JAWS and magnification software such as Zoomtext, there are two concerns we wish to raise.

1. While JAWS and Zoomtext are two of the more popular screen reader and screen magnification programs, not all patrons who are visually impaired know how to use these specific brands. Our recommendation in this regard is to add a second alternative for screen reading and magnification. One free alternative which is gaining more popularity is Non-Visual Desktop Access (NVDA). NVDA is an open-source screen reading software which can include a free add-on for screen magnification.

2. The narrative does not indicate with what regularity this software is being updated to insure maximum accessibility. Offering software that is woefully outdated limits the functionality of the user experience. If not already part of the ADA compliance recertification guidelines for the one-stop centers, PCB recommends that all accessibility software be up-to-date to pass recertification.

Citizen Advisory Committees
On the section on Citizen Advisory Committees (CACs), as described on page 110, PCB appreciates the response of OVR to the recommendations. PCB strongly supports the actions indicated in these responses because in some districts the CACs are not meeting or if meeting receive very limited support from OVR.

Personnel Development
With regard to “Comprehensive System of Personnel Development; Data System on Personnel and Personnel Development,” which begins on page 122, there are a number of concerns relevant to people with vision loss that we wish to address.

1. Blind and visually impaired individuals rely on the instruction from Orientation and Mobility (O & M) professionals to travel to school, work, medical appointments, and daily living sites such as the grocery store, the bank, the pharmacy, the post office, etc. This training is absolutely vital to the safety and independence of people with vision loss. Based on the numbers provided, there are currently eleven positions held by O & M professionals and seven current vacancies. Of the eleven current employees, six are projected to retire within five years. These numbers are of grave concern. From the percentage perspective, currently 37 percent of the available O & M positions are vacant with 33 percent of the current staff due to retire within the next five years. We commend OVR for recognizing the importance of these professionals by waiving the state residency requirement and developing a paid internship program. But clearly, based on the numbers, OVR needs to develop even more strategies to recruit and hire these professionals and make this area of personnel development a higher priority.

2. Within the Bureau of Blindness and Visual Services, staff hired in the positions of orientation and Mobility Specialists and Vision Rehabilitation Therapists are required to have achieved both a Bachelor’s degree and a practicum in their field. These professionals have met certain standards of knowledge, experience, and conduct in their given fields. Unfortunately though, what has become obvious to BBVS clients is that such standards are not a requirement to be hired as an independent contractor to teach/train clients on assistive technology. In many ways, the assistive technology skills taught to individuals who are vision impaired are as vital to daily living independence and employment success as the skills taught by these other two professionals. The Academy of Certification for Vision Rehabilitation and Education Professionals (ACVREP) is currently developing a certification program to insure that individuals teaching assistive technology meet basic standards. It is our recommendation that OVR review the ACVREP Certified Assistive Technology instructional Specialist (CATIS) proposed standards and establish its own basic standards for BBVS’ AT instructors. Once OVR adopts such standards, all existing BBVS AT contractors should be re-evaluated to confirm they possess the minimum instructional, experiential, and knowledge requirements. All new AT consultants should be required to either meet these same standards or possess CATIS certification.

3. Through PCB member participation on the Citizen Advisory Committees, it has been observed that within OVR the hiring process takes, on average, three to four months to fill vacant positions. Vocational rehabilitation services for people with disabilities are in high demand as shown by the needs for priority of service classifications and the service waiting lists for clients already enrolled. In some cases, district offices are barely treading water to meet client needs. Surely there is a way to decrease these long delays in filling vacancies; especially for the direct service provider positions.

The Pennsylvania Council of the Blind appreciates the opportunity to make comment on the state’s WIOA plan. These comments have been made in furtherance of our mission to promote independence and opportunities for people with vision loss.

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