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Bosma Enterprises - 6/11/2015 5:13:21 PM

Imagine losing your vision over time or maybe overnight. How would you learn to live life over again without your eyesight? For many people, training is critical to learning skills to reclaim life after vision loss. Unfortunately, an important training option is being removed as well as a path to employment. Please take the time to read the following information and to act no later than June 15, 2015.

How would you learn to live life over again without your eyesight?

Friends,

Imagine losing your vision over time or maybe overnight. How would you learn to live life over again without your eyesight? For many people, training is critical to learning skills to reclaim life after vision loss. Unfortunately, an important training option is being removed as well as a path to employment. Please take the time to read the following information and to act no later than June 15, 2015.

Bosma Enterprises is extremely concerned about some provisions specified in the Notices of Proposed Rulemaking (NPRM) to the Workforce Innovation and Opportunities Act (WIOA), which will make significant changes to the Rehabilitation Act. Specifically, the proposal eliminates funding for critical skills training for people who have disabilities and are seeking uncompensated employment.

The elimination of funding and the homemaker outcome for Vocational Rehabilitation (VR) clients will mandate that everyone entering the program must work towards competitive, integrated employment. This is troublesome because not every citizen seeking VR services desires compensated employment outside their home. Many people value caring for their family and their residence. Additionally, for someone who has a new disability, especially vision loss, performing routine tasks safely or caring for their children is impossible without the training VR has funded through the homemaker designation for years.

Meet Kristy
As a young adult, Kristy lost her sight through the degenerative eye disease retinitis pigmentosa. She has two children and a husband and wanted to continue to care for them and their home. Without critical skills training, she was unable to do the things she had always done and it caused her to be depressed. Through the VR homemaker program, she worked with Bosma Enterprises to learn to live with her vision loss. She is no longer depressed and has more confidence. She now has the skills to care for her family and home. "If I didn't have this training, I would have to depend on others and would be depressed because I could not do the things I needed to do to help my family," Kristy said.

In addition to denying VR clients vocational choice, the proposed change removes a stepping stone for working-age people experiencing recent vision loss. For many people seeking training from Bosma Enterprises, their vision loss occurred in adulthood. Often times their only concern at the inception of their training program is living independently, not preparing for employment. Through the successful completion of the homemaker training, these clients gain skills and confidence that lay the groundwork for them to seek competitive, integrated employment. The NPRM also leaves a large training gap for people experiencing vision loss as they approach the end of their working years and into retirement. The number of people falling into this category is growing as funding for services from all sources is declining.

Meet Eric
Eric was climbing the corporate ladder at a financial services company. He had a great job with a limitless future, but then, he lost his sight. He was able to work a few more years, but eventually had to quit. He had no idea what his next step would be until he connected with Bosma Enterprises through VR. At this point, newly blinded, he was scared and didn't know how he was going to live out the rest of his life. His path started with the homemaker program to gain confidence and learn how independent he could really be without his eyesight. After completing this goal, he knew he could work again and started rebuilding his professional skills. He started working at Bosma Enterprises as an outreach coordinator. There, he built a network that allowed him to find a job as a program manager leading various projects for a national healthcare company. "I would not be here today without the training I received starting with the homemaker goal," Eric said.

Act Now
Help us in our efforts to save the homemakers program so that people like Kristy and Eric can get the training they deserve to lead fulfilling lives. The U.S. Department of Education is accepting comments until June 15, 2015. We encourage you to submit a comment here. Once you are at the webpage, click on the "comment now" button. Then copy, paste and complete the template below into the form box. Unfortunately, submissions not properly formatted will not be considered.


TEMPLATE (SUGGESTED) FOR FILING COMMENTS
IN RESPONSE TO WOIA NPRM

June __, 2015

Honorable Janet LaBreck
Commissioner, Rehabilitation Services Administration
U.S. Department of Education
400 Maryland Ave. SW, RM 5086
Washington, DC 20202

RE:
Comments for WIOA NPRM
Docket Number: ED-2015-OSERS-OOO1
RIN: 1820-AB70

(INSERT [INTRODUCTORY PARAGRAPH DESCRIBING YOUR REASON FOR BEING A CONCERNED STAKEHOLDER.) 

Section 361.5(c)(15)
In the Employment Outcome definition, RSA removes "uncompensated outcomes" in its explanation of the revised regulation. This includes "Homemaker" outcomes. The RSA reports that only 0.8% of total outcomes utilize this training pathway for individuals with disabilities. In the case of people who are blind, over 10% of outcomes among individuals served through Designate State Units for the blind will be adversely impacted. If the proposed change is implemented, individuals who are blind would no longer be allowed to choose homemaker as an outcome. This will eliminate funding for critical skill training that often helps people who are blind have the ability to care for their family and homes as well as regain the confidence and skills to work.


COMMENT:
There is a clear disproportionate impact that will occur among individuals who are blind, without necessary assurance that critical and unique services will still be available for this group. It is recommended to strike this revision. If not, then further guidance is necessary to assure these individuals will not be shut in and shut out from vital rehabilitation services. 


[INCLUDE CLOSING REMARKS AND CONTACT INFORMATION.]


Sincerely,

[Insert Name]

If you have any questions, please contact Lise Pace at 317.704.8196 or lisep@bosma.org. Thank you in advance for your assistance.

Sincerely,



Lou Moneymaker
President & CEO