The Telecommunications Deregulation Act of 1996 calls for the
establishment of a universal service fund to aid low income
Americans in obtaining advanced telecommunications services. The
Chicago Blind Computer User Network supports efforts underway in
the disability community to use proceeds from the fund to pay for
long-distance and other charges between an employer and a person
with a disability working at home. The position statement is
below.
Friday, 28 March 1997
Office of the Secretary
1919 M Street, NW
Washington, D.C. 20554
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C.
In the Matter of Docket No. 96-45 (Universal Service)
Dear Mr. Canton:
We understand that the Federal-State Joint Board on Universal
Service has recommended that voice and data line charges incurred
between the employee and the company be waived, with the service
provider receiving support from universal service support
mechanisms. The Blind computer user Network of Chicago is
writing in response to your request for comments in the Notice
for Proposed Rule making, FCC 96-45, in the above captioned
proceeding.
The Blind Computer User Network is a consortium of blind and
visually impaired people in the Chicago area who want to maintain
up-to-date knowledge about computer technology. Network members
pool knowledge and resources to help themselves and each other
function at their best in this fast-moving electronic age.
They pursue technology-related activities that impact on the
workplace, research, education and the job market. Network
members meet to explore on-line information networks, hear about
developments in the industry, examine new adaptations and test
new software, exchange consultations and training at all levels
of expertise, and repair and refurbish donated computer hardware.
The Chicago Blind computer User Network is affiliated with
Blind Service Association, which is a "people-to people," not-
for-profit agency that supports the independence of blind and
visually impaired Chicago area residents, and has done so for
more than seven decades. Blind Service is supported solely by
contributions from private individuals, foundations and
corporations.
Eliminating telephone charges as an obstacle for telecommuting
employment is an important step in assisting blind persons in
obtaining and keeping jobs.
The Problem:
Nationally, unemployment among the blind exceeds 70 percent. The
computer has opened up opportunities and employment possibilities
that were previously not possible. Now blind persons can access
all written information displayed on a computer screen through a
braille display, text enlargement, or speech synthesis, which
speaks all the material displayed. This access to information
has now permitted blind persons to compete on terms of equality
not available before. Further, this revolution in information
access has open up new professions and fields essentially
unavailable to the blind in the past. However, this access is
moderated by the problem of not being able to drive to these jobs
in suburbia. Employers are leaving the City of Chicago and
moving to the suburbs, where access to public transportation is
often difficult if not impossible to obtain. The biggest example
is that of Sears, which moved from 50 floors in the Sears Tower
to Hoffman estates--more than 40 miles from downtown Chicago.
Two of the world's leading corporations in information technology
are in the Chicago suburbs and difficult to reach by mass
transit. Skokie, Illinois based U. S. Robotics is the largest
producer of modems. Schaumberg, Illinois based Motorola is a
leading producer of pagers, semiconductors, and cellular
telephones.
That is why we believe that the problem of blind persons and
unemployment is based on a combination of factors that include
societal attitudes and an urban environment that is designed for
the automobile rather than the person, locking blind persons out
of opportunities because they cannot travel to them.
Proposed Solution:
If the FCC were to rule that costs incurred for connecting a
blind or homebound disabled individual to an employer via voice
or data lines were covered under the Universal Service Fund, then
employers, the blind, individuals with disabilities, and society
as a whole would reap certain benefits. Such a ruling would
reduce or remove the need for the government to provide public
assistance benefits to those individuals affected, as they would
be able to earn a living. Connecting blind persons to the
workforce would also increase productivity, growth and
competition within our economy.
This is not to imply that an FCC ruling would result in the
immediate employment of thousands of blind individuals. The jobs
must be available for that to take place, and the telecommuting
movement is, at this point in time, still in its infancy. All
indications are, however, that the number and variety of full-
time telecommuting positions will grow. An FCC ruling is a
signal to the private sector that there are no additional costs
involved in seeking out homebound individuals to fill their
telecommuting positions. As a few employers have already
discovered, individuals with disabilities constitute an ideal
workforce for companies looking for home based workers.
These jobs are valued. Turnover is lower, and the underutilized
nature of the homebound disabled population means that it is
often easier to find more motivated, better qualified applicants
within this group than can be found within the general
population.
A Proposal To The FCC:
Low-income Americans are among those for whom the FCC has
pledged assurance that they will receive reasonably priced
telephone service. Blind persons and homebound individuals with
disabilities can easily fit within this low-income category. As
described earlier, the labor department reports that blind
persons have an unemployment or underemployment rate that exceeds
70 percent. Most of these individuals are living off Social
Security or other forms of public assistance.
We propose that the FCC rule in the event that a particular
person identifies himself as both low income and in need of home
based employment, then an employer who hires such an individual
would be able to apply to their long distance provider for a
waiver for all voice and data line charges incurred in order to
connect the homebound worker to the company. The service
providers in turn, would be able to request reimbursement from
the Universal Service Fund for these same costs.
These charges would include: long distance charges between
employer and home-worker; local access charges; local measured
service charges outside of a local calling area between the
worker and employer; and the monthly maintenance expense of one,
or even two, business lines into the home if such lines are
required for the telecommuting connections to take place.
We must depart substantially from the proposal submitted by the
national telecommuting institute and the President's committee
for the Employment of People with Disabilities. We do not believe
that the FCC should mandate a role for sole reliance on
rehabilitation counselors. We propose that blind persons and
those with disabilities can demonstrate a low income status by
providing a statement of benefits from the Social Security
Administration or a copy of the most recent tax return. We also
propose that a blind person or an individual with a disability
can utilize the services of a licensed medical doctor to certify
that the individual's disability presents barriers to travel and
can benefit from home-based work. These methods for identifying
need and benefit are options in addition to the proposal of
certification by a rehabilitation counselor.
It is the experience by the vast majority of our members that
rehabilitation counselors have low expectations of the blind,
lack specific knowledge of our competency, and often prevent
blind persons from attaining meaningful employment outcomes. We
recognize that oversight must occur and mechanisms should be in
place for fraud and abuse to be minimized. However, the
commission should consider the history between people with
disabilities and the rehabilitation profession and issues of
disability culture before permitting that only one entity can
make such employment related decisions. We encourage the
commission to develop mechanisms like those described above that
would allow a person with a disability and his potential employer
to establish and set up this accommodation in the most efficient
and autonomous manner possible.
The commission should also take note of the bias of one of the
filers on this issue. The National Telecommuting Institute works
primarily with rehabilitation counselors and state vocational
rehabilitation agencies, rather than individuals with
disabilities themselves. We believe that this bias inclines NTI
to force rehabilitation counselors into the private employer-
employee relationship even if the person with a disability does
not want the services or assistance of a rehabilitation
professional.
Should training via the telephone be necessary to prepare a blind
person or travel-limited person with a disability for a
telecommuting position, then it is further proposed that the cost
of connecting the homebound trainee to the trainer via the
telephone lines also be covered by the Universal Service Fund.
Only training institutions accredited by regional or national
accreditation organizations and approved by the U. S. department
of Education should be eligible to provide training under this
program. These institutions would apply to their long distance
service provider for a waiver of connection charges between the
instructor and the certified trainee. The long distance provider
would, in turn, submit their request for reimbursement to the
Universal Service Fund.
Our proposal differs dramatically from the proposal submitted by
the National Telecommuting Institute and the President's
Committee on the Employment of People with Disabilities on this
topic. It is the experience of our members, more than 150 blind
computer users in the Chicago area, that training institutions
that are authorized or promoted by state rehabilitation agencies
are segregated, slow to provide service with poorly trained staff
with low expectations about the ability of blind persons and the
technology that is used. Typically, people are steered to
agencies for the blind with staffs that have little understanding
of the competencies or skills needed for mainstream, competitive
employment settings. Consequently, the training is inferior and
inadequate for the person with a disability. Homebound persons
with disabilities should be able to choose between local
community colleges, regional state universities, and private
organizations, some of which may not be on a referral list of a
state rehabilitation agency. Further, some states, such as
Illinois and Wisconsin, require the person with a disability to
prove that a training institution out-of-state is far superior to
that of an instate institution before training can be approved at
the out-of-state institution. Policies and practices such as
these negate the advantages that training through
telecommunications services offer: principally, the ability to
select the best training regardless of geography. When geography
does matter, such as requiring telecommuting students to make
some visits to a campus for testing or in-depth seminars or
instruction, travel limited people with disabilities on border
communities are disadvantaged. We have enclosed the Illinois
regulation. We believe that restrictive policies such as this
decrease the likelihood that a homebound individual with a
disability would receive adequate training for a telecommuting
position.
Further, training programs for the blind and disabled promoted by
state vocational rehabilitation agencies often are able to avoid
the scrutiny and expectation for quality that is realized in many
mainstream programs. This is because that the persons who advise
state rehabilitation agencies on how training funds should be
allocated to benefit people with disabilities are the main
beneficiaries of that spending. For example, Joe Mileczarek, the
director of the Visually Impaired Program at North Central
College in Wausau, Wisconsin is the Chairman of Wisconsin's
Governor's Committee for People with Disabilities. The program
trains blind adults to adjust to their blindness through
vocational skills such as braille and travel.
We accept the need to minimize fraud and abuse and ensure that at
least minimally qualified persons be eligible for this program.
However, we urge the commission to use mechanisms that build upon
already established means in identifying legitimate educational
institutions. for example the commission could allow persons to
use schools that receive federal financial aid in addition to
those utilized by the state rehabilitation agency. This would
meet the needs of simplifying the process, minimizing fraud and
abuse, and allow people with disabilities maximum independence
and choice in choosing training that meets their needs.
Finally, while we support the proposed rule, we remain concerned
about the long-term effects of such a policy. We recognize that
the transportation priorities of the nation are heightening the
emphasis on road construction and the automobile and funding
shared transportation services less and less. We have witnessed
the trend here in Chicago where the Northeast Illinois Planning
Commission reported in 1992 that the developed area in the region
expanded by 55 percent between 1970 and 1990 while the population
grew by only four percent. The newly developed area is where the
new jobs are--nearly unreachable for those who don't drive. At
the same time, we remain concerned that blind persons and those
with disabilities will be encouraged and steered to work at home
rather then in the office setting with other employees. We fear
that the subsidy might be an incentive for employers with
stereotypical attitudes about disability to engage in this kind
of behavior. further, the highly sought after "soft skills"
sought by today's employers are developed and refined by working
in close physical proximity with other workers. However, we
believe that such behavior will not serve the productivity needs
of employers in the long run. further, we forecast that
transportation options to the new jobs being created in today's
economy will continue to constrict. that is why we make this
proposal to the commission and urge it to consider blind persons
as homebound individuals with disabilities.
Kelly Pierce
Chicago Blind Computer User Network
89 ILLINOIS ADMINISTRATIVE CODE CH. IV,
590.250
SUBCHAPTER b
SUBPART C: TRAINING AND RELATED SERVICES
Section 590.250 Choice of Training Facility/Institution
a) To the maximum extent possible, the customer shall have
the choice of the training facility/institution he/she
will attend in completion of his/her IWRP (89 Ill. Adm.
Code 572). However, facilities within the State of
Illinois shall be given preference and State operated
institutions of higher education shall be given
preference over private and out-of-state institutions.
b) Although in-state, State operated facilities and local
community college must be given preference, a customer's
choice to attend a private or out-of-state
facility/institution may be approved if:
1) there is no comparable training at a State
operated facility, in-state facility, or the
customer's local community college as verified by
the
counselor based on information regarding
curriculum, recommendation of colleagues, and past
experience with facilities/institutions offering
training in the area of the customer's employment
objective;
2) the cost of the training at the private or out-of-
state facility/institution is less than that of the
same or similar training at a State operated
facility/institution, in-state facility/institution
or local community college;
3) because of the customer's particular impediments
to employment, no State operated facility/
institution, in-state facility/institution or the
local community college is accessible for the
customer. Whether an in-state facility's/
institution's training is accessible to the
customer shall be determined by the counselor
based on information regarding curriculum,
recommendations of colleagues and past experience
with facilities/institutions offering training in
the area of the customer's employment objective. 89 ILLINOIS ADMINISTRATIVE CODE CH. IV,
590.250
SUBCHAPTER b
c) If none of the circumstances listed in Section 590.250
(b) above is met, DORS shall only authorize the total
cost of tuition, fees and maintenance up to the cost of
attending the most expensive state operated facility (89
Ill. Adm. Code 590, Subpart J), less scholarships, other
comparable benefits (89 Ill. Adm. Code 567) and required
customer financial participation (89 Ill. Adm. Code 562).
If one or more of the criteria is met, DORS may authorize
up to the total cost of the training, less scholarship,
comparable benefits and customer financial participation.
(Source: Amended at 19 Ill. Reg. 10153, effective June 29, 1995)
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