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Randolph-Sheppard
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A Call for Action

 

Yesterday:

"The Congress finds that the potential exists for doubling the number of blind vendors on federal and other property under the Randolph-Sheppard program within the next five years. " Randolph-Sheppard Amendments of 1974: section 201.

Today:

The following call for action is issued as a result of a day long conference on the issues facing the Randolph-Sheppard Vending Program held on February 19, 1999 at the offices of the U.S. Department of Education. The participants shared their expertise after having studied a concept paper from the American Council of the Blind on revitalizing the program.

Participating in the conference were the Randolph-Sheppard Vendors of America, the Blinded Veterans Association, The American Foundation for the Blind, The United States Department of Education Rehabilitation Services Administration Office for the Blind for information purposes, and The American Council of the Blind. Others invited included The National Council of State Agencies for the Blind, The National Federation of the Blind and their Blind Merchants Division, who declined to attend. The interested groups met to discuss ways to improve and expand employment opportunities through the Randolph-Sheppard Program (Program). There is a general view that the Program, if properly funded and administered, could provide many more employment opportunities for blind people than it has to date. The interested groups discussed a variety of issues affecting the Program and generated recommendations for achieving the employment success the Program was intended to realize. The undersigned organizations call on all interested stakeholders in the Randolph-Sheppard Program to join together to create a Randolph-Sheppard Program that will be prepared to take full advantage of the opportunities of the 21st century and to ensure employment opportunities for all blind people who choose to pursue a career in the Program.

States have been vested with the responsibility for administering the Randolph-Sheppard Program and for facilitating achievement of the maximum potential of blind vendors with regulatory and policy oversight from the Rehabilitation Services Administration. If the program is to succeed then there must be a strong and ongoing leadership role taken by the states to advance the program. This kind of commitment from the states requires resources, solid business management expertise, and vigorous advocacy on the part of state agencies.

It is understood that a revitalization of the Randolph-Sheppard Program by the states will take some time to plan and implement. However the development of state plans to address the issues of Randolph-Sheppard are necessary to move the agenda forward in a productive fashion.

The planning process must begin immediately. State plans must address resource requirements, modernization schedules, personnel development, vendor recruitment, training, and placement, consistent with the individual choice provisions of the Rehab Act amendments of 1998. The state planning process may take as much as a year to be ready for implementation. This process should be the product of a state agency/blind vendor partnership, supplemented by RSA technical assistance as needed.

Each state plan for revitalization of the Program should be reviewed annually by RSA to ensure the uniform application of, and compliance with, all provisions of the Randolph-Sheppard Act.

Action required:

In consideration of the above, the following call for action is made:

All states must, in conjunction with the blind vendors in the state, undertake to develop a meaningful and comprehensive plan of action to grow the Randolph-Sheppard program within their jurisdictions. The federal Rehabilitation Services Administration should review and approve the plans to be submitted no more than one year after initiation with such approval conditioned upon the appropriate addressing of the following plan elements as monitored at least yearly. States undertake to apply for all appropriate permits and either through their own effort or in partnership with the cognizant federal enforcement agency; take the necessary steps to insure that existing vendor rights arising out of statutory or case law are observed.

  • Appropriate human and fiscal resources are in place to identify violations of the Act and proceed to enforce its provisions.
  • Sufficient dollars are allocated by the states for their administration of the program to support the needed improvements.
  • Business Enterprise Program administrators must either have a business background or be thoroughly trained in business thinking to complement the rehabilitation mission of the agency.

    Evidence of this can be demonstrated by criteria such as five years of business experience, demonstrated capacity to write business plans, understanding of marketing, customer relations and inventory control, having thorough knowledge of tax forms necessary to manage a business, and possession of the ability to exercise good financial responsibility. This should be seen similarly to the federal requirements of the comprehensive system of personnel development.
  • Facility franchising, small facility consolidation or routing plans, vending machine marketing and implementation along with other business models such as food courts must be explored, addressed, and utilized where appropriate.
  • Location identification, development and maintenance plans should be in place. This should include previously untapped or missed opportunities on federal sites and the renovation and modernization of existing facilities.
  • There must be a guaranteed floor of earning opportunity for new vendors. These opportunities must be advertised throughout the counselor corps and blindness community. This income level must be attractive enough to overcome any disincentives to counselors due to standards and indicators for rehabilitation outcomes.
  • All members of the blindness community should be invited to participate in the state vending program. Opportunities for advancement in the program should not rely upon or be impacted upon by degree of vision or possession of a dog guide or other circumstance attendant to blindness.
  • New funding resources that could be used to enhance the Program should be identified where appropriate. These could be SBA or Department of Labor or state program resources.
  • Assistive technologies should be investigated for what productivity they could bring to the Program within the states and nationally.
  • Customer and site grantor relations must be addressed and improved on an ongoing basis. This includes promotional campaigns. Vending facilities and product mix must be constantly upgraded and made attractive.

Finally and separate and apart from the individual state programs and plans, there must be a national identity to the Randolph-Sheppard program as developed and advanced by a partnership of consumer and governmental interests. Irrespective of whether it is a function of a formal Randolph-Sheppard Council or consumer driven task force; the national identity of the program must be advanced within the federal executive and legislative branches as well as within the states. The need for a national identity is intended to support the federal effort; it is not intended to supplant the Rehabilitation Services Administration in its ongoing responsibilities to protect and enforce the rights of blind vendors and the Program on both the state and federal levels.

To further reinforce the national identity of the program, there should be a national conference on the vending program yearly with representation of the vendor community from all the states. Vendors should also be afforded the opportunity to qualify for a federal competency standard that would certify them to work within any state upon moving, with only a small training cycle to learn that state's health and other requirements.

In conclusion, the above call for action is truly more a call for real and ongoing action then being a revolutionary redefinition of the program that would require federalization or opening of the Randolph-Sheppard Act. These more drastic actions as well as the decline of the program can be realistically avoided by implementing the above strategy. More importantly, the Randolph-Sheppard Vending Program has every reason to grow and flourish if a real and ongoing commitment is made by all its stakeholders, including consumers, the states, and the federal government.

Tomorrow:

The fruits of the above can be a Randolph-Sheppard Vending Facilities Program in which blind persons with the abilities to take on the challenge of small to large business enterprises will have many opportunities to earn a real income limited only by how far their work and dreams will take them.

 

 



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