Blending and Braiding: A Scam to Bypass WIOA Regulations

The State of Michigan is desperate to find a way to continue funding sheltered workshops despite new federal regulations.

In partnership with Michigan’s association of sheltered workshops (MARO), the Michigan Statewide Independent Living Council (SILC) has submitted a detailed – and shocking – proposal to the Governor’s Office (PDF).

The authors of this document provided a chart demonstrating how the State can maintain the illusion of compliance while continuing the pipeline of Michiganders with disabilities to subminimum wage “jobs”. This graphic demonstrates how the state can move individuals with disabilities from agency to agency for 90 days, collecting every fee they can – with no identified outcome other than a closed case and “ongoing supports provided by Medicaid”. Translation: they intend to continue misusing Medicaid dollars to fund sheltered workshops, and to co-mingle those dollars with vocation rehabilitation funds, which expressly cannot be used to fund sheltered workshops.

Image: Six Boxes. Each box has an arrow leading to the next box: - Box 1: Person-Centered Plan indicates an Employment Goal (Medicaid) - Box 2: Refer to VR Services (MRS/BSBP) for an Eligibility Determination (Vocational Rehabilitation fund/VR funds) - Box 3: If Eligible for VR services develop Plan for Employment & Support Services (VR funds) - Box 4: Refer to a community organization (CRO/CIL) for skill development, job placement, etc. (Medicaid or VR funds) - Box 5: Individual obtains employment-Support such as job coaching may be needed [VR (90-days) or Medicaid funds] - Box 6: After 90-days VR may close the case Ongoing supports provided by Medicaid

The Medicaid funds in question are to be used only to provide skill building assistance in the community according to the Michigan Medicaid Provider Manual. WIOA expressly forbids the use of any vocational rehabilitation funds to Ability One Contractors and non-integrated entities.

The proposal outlines how the state can “blend and braid” funding streams so that it can continue to collect federal dollars while engaging in activities that are not allowable with those funds. The money gets passed from one organization to the next, until no one can understand its original intent or requirements.

  • Blending is a strategy to obscure the source of funding that has specific requirements. Money is transferred from the state to private non-profits so that it can no longer be tracked by the public. Blending will provide the cover Michigan Rehabilitation Services needs to mislead federal regulators.

The Code of Federal Regulations states:

“For Federal awards of similar purpose activity or instances of approved blended funding, a non-Federal entity may submit performance plans that incorporate funds from multiple Federal awards and account for their combined use based on performance-oriented metrics, provided that such plans are approved in advance by all involved Federal awarding agencies. In these instances, the non-Federal entity must submit a request for waiver of the requirements based on documentation that describes the method of charging costs, relates the charging of costs to the specific activity that is applicable to all fund sources, and is based on quantifiable measures of the activity in relation to time charged.”

  • Braiding is a strategy in which separate funding streams are brought together to pay for more than one funding stream can support, then pulled back apart to report to funders on how the money was spent. Braiding requires strict financial and programmatic oversight to ensure that state and federal tax dollars are spent only on allowable activities. Braiding requires a grantee to act in good faith – with transparency and honesty. It is not to be used to bypass or obscure federal regulations.

Two years ago, a formal partnership between Michigan’s Centers for Independent Living and sheltered workshops was developed behind closed doors by Sara Grivetti, Todd Culver (MARO), and Suzanne Howell (State of Michigan). These parties are so closely connected to sheltered workshops that they are completely flummoxed by the new WIOA Regulations because they believe – whole-heartedly – in sheltered work and their role supporting it.

The intent of Section 511 of WIOA is to limit the use of subminimum wage employment.

Graphic: Don’t be fooled! Community Rehabilitation Organization Equals Subminimum Wage EmployerInstead of a good faith effort to follow the law, Michigan Rehabilitation Services, Michigan Centers for Independent Living (Disability Network), the Michigan SILC, sheltered workshops, and the Governor’s Office are doing everything they can to maintain the status quo.

Blending and braiding employment and Medicaid funds does nothing to benefit Michiganders with disabilities. The financial beneficiaries of this absurd proposal are sheltered workshops and their partners.

One major question remains unanswered: why have sheltered workshops and their partners been given control over implementing Employment First? It’s a huge conflict of interest. Employment First is not being carried out with the transparency necessary to blend and braid funds legally and zero consumer input is being solicited or considered.

Notes:

  1. Community Rehabilitation Organization (CRO) is a code word for sheltered workshops.
  2. This proposal references “CRO/CILs”. There is no such thing as a CRO/CIL. Centers for Independent Living are not sheltered workshops. CILs and sheltered workshops are radically different organizations. Centers for Independent Living are taxpayer-funded organizations required by law to be led by local disability communities. Real CILs do not support sheltered work or any other forms of disability discrimination or financial exploitation.
  3. Sara Grivetti should disclose conflicts of interest before requesting funds on behalf of the public that benefit her personally and professionally. It is not appropriate for Ms. Grivetti to use her position on the SILC to direct funds to her organization. This has been an ongoing problem for several years.

See also: How Michigan CILs Became Service Providers Chasing Money and Working for Our Oppressors

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