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Honorable Jennings Randolph, U.S.S.
Room 5121 New Senate Office Building
Washington, D.C.

Dear Senator Randolph:

June 26, 1974

N.Y.U.

Inst. of Rehab. Med. 400 East 34th Str. New York, N.Y. 10017

I am writing to express the support of the American Congress of Rehabilitation Medicine and the American Academy of Physical Medicine and Rehabilitation for legislation extending the Rehabilitation Act for one year and transferring the Rehabilitation Services Administration ("RSA") to the Office of the Secretary. This letter is intended to be part of the hearing record regarding the extension of the program.

We believe it is important that the program be continued for one year and that action be as soon as possible on this continuation. Otherwise, the uncertainty which the state administrators and providers of rehabilitation services will experience will be damaging to the program. The regulations with regard to the 1973 amendments have not yet been published. Clearly, the 1973 amendments which made substantial changes in the program must be implemented soon since a year has now passed after enactment. ΤΟ make major changes in the program at this point would probably undermine the effective implementation of the 1973 amendments. A simple continuation would enable those working in the program to focus attention on implementing the 1973 amendments.

We also believe that the authorization levels set in H.R. 14225 are reasonable. We are particularly interested in the research and training programs and we feel that $30 million is a reasonable minimum level to set for funding.

We are also supportive of Section 2 of H.R. 14225, and of Senator Stafford's bill, which would transfer the RSA to the Office of the Secretary. It is our belief that the goals of the program the provision of comprehensive vocational rehabilitation services to all of those with disabilities regardless of their income are more consistent with the goals of programs in the Secretary's office, under the Assistant Secretary for Human Development, than with the programs of the Social and Rehabilitation Service ("SRS"). In fact, there have been many negative aspects to the placement of RSA within the SRS.

The major program in the SRS in terms of the budget and, as a result, in terms of high level attention, are the welfare assistance, Medicaid and social services to welfare recipients programs. All of these programs are programs which are incometested, and deal basically with the welfare population and the welfare problem. The basic mission of SRS is related primarily, therefore, to dealing with the welfare problem, and its programs

Senator Jennings Randolph
Page 2

June 26, 1974

are basically payments assistance programs, not services programs. SRS is basically not an agency whose mission is leadership in the development and delivery of services. It is an agency whose mission is bringing effective management to "uncontrollable" payments programs.

The

One of the negative aspects of location in SRS for RSA has been the lack of attention to the program because of preoccupation with the welfare problem and primarily the welfare payments program. Another problem has been the loss of clarity in objectives for the rehabilitation program because of attempts by SRS to require it to serve the welfare population without regard to disability. result has been a focus on services to people who in many cases do not have physical or mental disabilities, but who suffer simply from lack of income. We do not mean to say that poverty is not a substantial problem, but it is not the kind of problem with regard to which the vocational rehabilitation program has focused historically, and has developed expertise.

On the contrary, programs such as the Older Americans Act in the Office of Human Development ("HD") within the Office of the Secretary, are much more consistent with the purposes of the rehabilitation program. For example, the Older Americans Act is a program designed to provide comprehensive goal-oriented services to the elderly without regard to the income level of the elderly. The HD mission is to provide leadership to the states and localities in planning and delivering effective services to the aged, children (Office of Child Development), and delinquents (Juvenile Delinquency Program). Many of the rehabilitation methodologies used for the vocationally-disabled are important to the elderly, delinquents and children.

We wish to express our appreciation for your work on the vocational rehabilitation program.

Sincerely,

I'm Edward Lowman

Dr. Edward Lowman, Chairman,

Legislation Committee,

American Congress of Rehabilitation
Medicine

Legislative Liaison,

American Academy of Physical Medicine & Rehabilitation

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The Department of Rehabilitation wishes to express the position of the State of California with respect to rehabilitation legislation currently pending before the Senate. Most of the provisions, which parallel similar legislation in the House, HR 14225, have the general support of the Federal Administration, the states, including California, and organizations of and for the disabled.

California, however, is concerned about the HEW organi-
zational considerations that have very quickly been interjected
into such legislation. The question exists whether the
Rehabilitation Service Administration (RSA) should be moved out
of Social and Rehabilitation Services (SRS) and, if so, where it
should be placed within HEW. We do not take a position at this
time on the most appropriate organizational location for RSA,
but we strongly question the wisdom of reactive legislation
mandating organizational changes. We believe it is a bad
legislative principle to prescribe such organizational detail,
at least without significant review and study.

As an approach to this issue of RSA location within HEW, we recommend an outside, independent study be conducted by the Secretary with a report and recommendation due within six to eight months. After that time the Administration can make its decision and Congress can then determine any further action necessary on the issue.

Therefore, California respectfully requests you to seek prompt passage of the rehabilitation amendments, deleting provisions for HEW organizational change. Thank you for your consideration and continued assistance to the Vocational Rehabilitation program.

CC: James E. Jenkins, Secretary

Health and Welfare Agency

Sincerely,

Aland. Nelson

ALAN C. NELSON
Director

Senator STAFFORD. The subcommittee is adjourned subject to the call of the Chair.

[Whereupon at 12:25 o'clock, p.m., the subcommittee was adjourned, subject to the call of the Chair.]

APPENDIX

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