Workforce Innovation and Opportunity Act
Resolution 2015-08
Whereas, the American Council of the Blind wishes to express some overarching concerns about WIOA (the Workforce Innovation and Opportunity Act), passed in 2014, whose regulations will soon be implemented, and we hope our concerns will be considered by RSA (the Rehabilitation Services Administration) and the United State Congress;
Now, therefore, be it resolved that this organization believes:

  1. The potential loss of homemaker and unpaid family worker closures disproportionately impacts people who are blind and, if implemented, will create a high likelihood of more non-positive closures for potentially employable people who are blind;
  1. There is insufficient recognition of the substantial differences between regular rehab and separate agency provision of transition services, which results in making the application of the 15 percent requirement in the law disproportionately disadvantage separate agencies who are already often providing effective transition services and who may be forced to limit services to others by these arbitrary allocations;
  1. The proposed elimination of “extended evaluation” may also increase the number of individuals who are blind and have other disabilities who may not be deemed qualified for vocational rehabilitation services because they cannot be given sufficient time to demonstrate their ability to handle potential employment;
  1. The continuing narrowing of the definition of what will be considered acceptable as integrated, competitive employment excludes many blind people who are employed in jobs that pay well above the minimum wage but do not meet arbitrary and unjustifiable definitions of employment that have the effect of removing client choice and denying people who are blind or have low vision VR services they deserve;
  1. We believe that the creation of joint state plans has the potential of significantly impacting the funding and effectiveness of vocational rehabilitation services by creating new competition for funding and priorities at the state level;
  1. We are convinced that regulations concerning the qualifications of personnel need to be strengthened rather than weakened and that specialized, blindness-specific positions such as access technology specialists, vision rehabilitation therapists (rehab teachers), and orientation and mobility specialists need to be defined and encouraged by RSA through formal recognition and funding for specialized training programs; and

Be it further resolved that the American Council of the Blind remain concerned over the relative lack of consultation with interested parties that preceded the passage of the legislation in 2014 which led to specific requirements which are ill-considered and disproportionately disadvantageous to people who are blind or have low vision who seek vocational rehabilitation services; and
Be it further resolved that ACB join with other organizations working to promote the interests of people who are blind to propose and advocate for amendments to WIOA which will seek to mitigate some of the most egregiously unfair elements of this hastily drafted and ill-considered legislation.
Ray Campbell, Secretary