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A Small Light at the End of a Deep Dark Tunnel

By: Charles Glaser, RSVA President
(Vendorscope Spring 2008)

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Government agencies such as the Department of Defense (DOD) represent the military. USPS represents the Postal Service and, to my way of thinking, the Department of Education's Rehabilitation Administration should be representing the Randolph-Sheppard program. I have been told that the Rehabilitation Services Administration's (RSA) function is to monitor the program, assure proper handling of grievances, and promulgate rules among other administrative duties. What I have also been told is that it is not RSA's responsibility to advocate for Randolph-Sheppard which concerns me. If the Department of Education, the administrator of our program, does not consider itself to be our advocate, than whose governmental responsibility is it?

Many of you know the Randolph-Sheppard program has faced many challenges over the years. Since its original legislation, Congress has periodically attempted to improve opportunities for Blind entrepreneurs by amending the Act. Over the last couple of years an unprecedented amount of attention has fallen on Randolph-Sheppard, most recently a report from the Department of Defense Inspector-General's Office. This report, along with most of the other Randolph-Sheppard related reports presented over the last couple of years, contains many unsubstantiated facts and opinions that are not favorable to our program.

The Department of Education was mandated by Congress, along with the Committee for Purchase and the Department of Defense, to produce a joint policy statement regarding the future of food service for Military troop dining halls. Many people close to the Randolph-Sheppard Program were not impressed; in fact quite disappointed in the final document and believe the Department of Education did a poor job in representing the blind managers.

Internally, for the purpose of revising and simplifying the RSA-15 report, RSA assembled a work group of leaders from the Randolph-Sheppard community, including State agency directors, vendor organization representatives, and key

Randolph-Sheppard RSA staff. The panel worked diligently for over two years to generate a form that gives a true annual snap-shot of program performance. Upon completion, the form was sent up the ladder to the Department of Education, who before publishing the revised form in the Federal Register, added a line item that was objectionable to the panel and I believe most if not all blind managers.

There was a public comment period after the document was published in the Federal Register. Many state directors, blind vendors, and other stakeholders submitted comments. Below are the comments I sent to RSA on behalf of RSVA pertaining to changes in the RSA-15 reporting form.

{This document is to comment on the proposed revisions to the "RSA-15" form identified in the Federal Register as "Report of Vending Facility Program". This form submitted by State Licensing Agencies annually is used for the collection of Randolph-Sheppard vending facility program data by the Rehabilitation Services Administration (RSA) to assist them in fulfilling the statutory obligation placed on the Department of Education to administer the Randolph-Sheppard Act.

The RSA-15 form has been used for many years to evaluate the success of the Randolph-Sheppard program. The form and the mechanism for evaluating the data have changed many times over the years. When RSA decided to form a work group to improve the form, I, as President of the Randolph-Sheppard Vendors of America (RSVA) along with other stakeholders, was asked to join. RSVA is the largest and oldest organization of blind entrepreneurs operating Randolph-Sheppard facilities. We, as an organization, were impressed that RSA had chosen to include the true beneficiaries of the Randolph-Sheppard Act in the structuring of the way our program is evaluated and administered.

I had concerns on many levels with the published proposed document. Although I was enthusiastic about participating in the process and dedicated many hours along with the other members of the work group, I was not prepared for the outcome. Throughout the process of developing the new form, all members of the group came to a consensus on each point and as far as I know were satisfied that we had created an instrument that would give RSA the data they needed to conduct their work while protecting vendor/ manager rights and privacy. Unfortunately, after we completed our work and produced what we considered to be a finished product, it was changed before publication. This action in my opinion was not consistent with the work group's charge and severely undermined the Department of Education's credibility in working with stakeholders.

The Department added a line item in Section II-C that was adamantly opposed in our work group. This item directed State Licensing Agencies to report personal earnings of some vendors. The work group discussed vendor earnings in our deliberations and agreed that individual vendor earnings are personal and confidential and did not add useful information to RSA for administering and monitoring the Randolph-Sheppard Act. Oddly, the small percentage of vendor earnings that the form identified as subject to reporting was the most vulnerable. Most Randolph-Sheppard facilities are governed by permit, whose stipulations are specifically identified in the Randolph-Sheppard Act and Regulations. The incomes that would be required to be reported are derived from competitively bid contracts.

RSA-15 data has been publicly available and widely distributed for many years and there was no reason to expect that this policy would change or that any portion of the collected information would or could be held confidential. Specifically identifying net profits of any Randolph-Sheppard contract that was won through a competitive bid would have a dramatic effect on the ability of
the SLA and the blind vendor being awarded that same contract the next time the opportunity is advertised. The plain and simple truth is that privately held corporations are under no legal obligation to disclose the profits generated from a contract of this nature. If the Randolph-Sheppard vendor's profits are made available, private corporations will have an unfair competitive advantage in the bid process.

My concerns go deeper. In the work group's discussions about
vendor earnings, there was never any mention of segmenting reporting guidelines based on earnings. The action taken begs the question, "Why would the Department of Education and RSA include a line item that does not include the vast majority of Randolph-Sheppard managers, and only pertains to the
earnings of a very small minority of the blind vendors, those being the ones who have to win their jobs by competitive bid, when the work group including RSA staff agreed that the reporting of any vendor earnings was not necessary for RSA to fulfill its legislated mandate."

In conclusion, The Randolph-Sheppard Vendors of America sincerely appreciates any opportunity to actively participate with The Department of Education, RSA, other stakeholders, and any governmental agency in an effort to improve the Randolph-Sheppard Program and the quality of life for blind vendors. RSVA respectfully requests that RSA remove the objectionable line item and move forward with the original revised RSA-15 form developed by the work group. The RSVA leadership feels very strongly about its membership's privacy. In the unlikely event that RSA does not remove the offensive line item, RSVA will recommend that its members seek injunctive relief to protect their privacy and their ability to fairly compete for competitively bid contracts.

Comments respectfully submitted by,
Charles Glaser
Randolph-Sheppard Vendors of America
Phone: (770) 925-1822
Fax with advance notice: (770) 925-1822}

As a result of the many comments submitted, the Department of Education has decided to remove the objectionable line item. I view this as a positive sign. It is unclear what is in store for the Randolph-Sheppard Program in the years to come. With business and politics playing a more active role in our future, we need a Cabinet level advocate. Through its actions, Congress has
identified the Department of Education as the governmental body that represents our tried and true resource for the employment of blind people.

A small light glimmered when after all these many years, the DOE decided to include the stakeholders in the development of the new RSA-15 form. The light shown even brighter when the DOE respected the wishes of the true beneficiaries of the Randolph-Sheppard Act by complying with their recommendation to remove an unnecessary item from the final document. Hopefully, the next step will be for the Department of Education to embrace the most successful rehabilitation program ever created, and become a true advocate using all of its resources to make sure that we will continue to
be the government's largest food service provider for generations to come.


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