Tuesday, August 8, 2017

Reaction to a Consolidation Proposal from Administration on Community Living

Here are comments I plan to submit to the Administration on Community Living (ACL) in the U.S. Department of Health and Human Services on Friday, August 11, 2017. ACL is requesting stakeholder input on its idea, through legislation, to create one disability council in every state and eliminate State Developmental Disability Councils and State Independent Living Councils, and in 19 states, Advisory Boards on Traumatic Brain Injury.

Comments on the Partnership for Innovation, Inclusion, and Independence (PIII) Concept


Ø  People in the disability community, in and out of government, understand and endorse the idea that public funds should be spent to promote and realize opportunities for individuals with disabilities to be fully engaged members of their communities.
Ø  It is important to spend public funds in smart ways.
Ø  Collaboration is often the way to secure necessary expertise, stretch funding, test new ideas, and obtain meaningful results.

PIII Concept

Ø  Eliminates two councils (State Developmental Disabilities Councils and State Independent Living Councils in all states and territories) and one advisory board (State Advisory Boards on traumatic brain injury in 19 states) that serve largely distinct populations.
Ø  Requires that the three be replaced by one disability council in each state.
Ø  Offers $45 million (a 43% cut) to continue serving the populations being served (Current funding is about $106 million for the councils and boards.).
Ø  Appears to assume that provisions in the three laws authorizing councils and boards could be drawn upon to draft, for the new disability council, – membership requirements, operating procedures, and programmatic choices related to systems change and capacity building.
Ø  Assumes, with a promise of modest funding which has yet to be projected on a state by state basis, governors will close down existing councils and boards, stop funding activities they sponsor, spend time finding and appointing new council members, and have sufficient funding to impact positively on populations that previously benefited from individual consideration and more funding targeted at their needs.

Challenges to PIII’s successful realization

Ø  All three programs have a long and proud history – the State DD Councils were created over 40 year years ago, State Independent Living Councils over 30 years ago, and the TBI Advisory Councils in the 1990s. Around these three entities there are powerful associations, constituents with expectations and voices, and congressional supporters.
Ø  Substantial public negative feedback to the elimination of these three programs may be anticipated. The argument “just to save $50 million and harm people with disabilities” will be seen a lot on social media.
Ø  Congressional action to bring about PIII, especially in the Senate on the HELP Committee, is highly unlikely, because of its bipartisan commitment to health care reform, which has already started.

An Alternative to PIII

Instead of dismantling three popular programs, test the power of collaboration among them by:

Ø  Funding demonstration projects, asking all three to collaborate on one initiative;
Ø  Asking a project to focus on one of three initiatives:
o   Education on benefits planning,
o   Helping youth in transition from high school to post-secondary education, vocational training, or employment;
o   Helping job seekers obtain and maintain competitive and integrated employment;
Ø  Ensuring that individuals with developmental disabilities, traumatic brain injury, and other significant disabilities participate in each project;
Ø  Securing funding contributions from other federal agencies to fund the projects;
Ø  Documenting and evaluating the projects to determine if it is effective and efficient, worth replicating nationwide.

Benefits of the Alternative to PIII

Ø  Federal lead to bring about new partnerships in states and within the federal government (funding partners could be drawn from Departments of Labor, Education, and Health and Human Services as well as from the Social Security Administration);
Ø  Basis for a creative and constructive dialogue between ACL and the disability community

Ø  Potential opportunity for CILs, as project sites, to broaden their expertise and client pool, and for professionals, family members, and self-advocates help them do it.

If you like this alternative, email: P3I-comments@acl.hhs.gov. Use Alternative to PIII as your reference to my idea

Thank you,
Common Grounder

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