Public Comment — TWC regarding Consolidation of Divisions of Rehabilitative and Blind Services

TCDD Letterhead

Comments to Texas Workforce Commission
Consolidation of Divisions of Rehabilitative and Blind Services
January 27, 2017

Thank you for the opportunity to provide comments regarding the consolidation of the Division for Rehabilitative Services (DRS) and the Division for Blind Services (DBS). The Texas Council for Developmental Disabilities (TCDD) is established by federal law and is governed by 27 board members, appointed by the Governor, 60% of whom are individuals with developmental disabilities or family members of individuals with disabilities. TCDD’s purpose in law is to encourage policy change so that people with disabilities have opportunities to be fully included in their communities and exercise control over their own lives.

The following comments are based on public testimony offered at the Texas Workforce Commission (TWC) public hearing held on January 16, 2017, in Austin, as well as the comments of members and visitors at recent meetings of the Employment First Task Force and the Policy Council for Children and Families. We appreciate the level of activity involved in the complex transfer of programs from Department of Assistive and Rehabilitative Services (DARS) to TWC, including combining policy manuals as well as standards for provider manuals; and the pilot projects on the co-location of vocational rehabilitation staff and Workforce Solutions staff. We are, however, very concerned to learn that children and families are experiencing gaps in the form of cancellation of longstanding programs used by children who are blind or visually impaired because of the transfer, especially because families voiced these specific concerns during the 84th Texas Legislature’s debate over Senate Bill 208.

With respect to the statewide hearings to gather public comments and concerns about the impending consolidation, we understand that some of the issues raised include the following:

  • Maintaining specialized caseloads for individuals who are visually impaired.
  • Combining VR field staff and Workforce Solutions staff.
  • Maintaining privacy as VR counselors work with customers with disabilities.
  • Raising the age of transition for children with visual impairments from 10 to 14 years.

It is with respect to the raising the age of transition for children with visual impairments from 10 to 14 years that we wish to comment. We concur with the testimony of Ron Lucey, Executive Director, Governor’s Committee on People with Disabilities, made at the Austin public hearing that “earlier is better than later” for beginning to plan for a student’s transition from secondary school to higher education and/or meaningful employment.

Transition for 10-year-old students has been the reality in Texas for many years and has been regarded as high quality, and has bridged a gap that has improved the development of necessary skills for a successful school experience, not to mention transition. We further submit that students with disabilities that do not include blindness would benefit from moving the age of transition services earlier than 14.

As one parent noted, a year is a long time to delay assistive technology, services, and training for students. It is even more significant that their teachers could go without the requisite training currently provided. We understand that TWC may be exploring ways for the HHSC Blind Children’s Vocational Discovery and Development Program to assist in bridging the gap, and we encourage that collaboration. Parents and staff have been clear that the DBS transition services are provided in a manner that supports individuation and are less family focused. Unless HHSC has a plan in place to fully meet the needs of this new population, including the provision of similar services in a manner like those currently received by students ages 10-14 who are visually impaired, more will be needed.

In conclusion, TCDD supports transition supports for both students with visual impairments and students with other disabilities as early as possible. These critical supports would enhance the ability to meet the needs of these young students at a particularly important stage in their lives.

Thank you again for the opportunity to submit comments regarding the consolidation of the DRS and DBS.


Linda Logan, MPAff