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RSA-227 for FY-2025: Submission #23

Michigan
09/30/2025
General Information
Designated Agency Identification
Disability Rights Michigan
4095 Legacy Pkwy
Lansing
Michigan
48911
https://www.drmich.org
517-487-1755
517-374-4687
800-288-5923
517-487-0827
Operating Agency (if different from Designated Agency)
Additional Information
Elham Jahshan
Elham Jahshan
517-374-4653
ejahshan@drmich.org
Part I. Non-case Services
A. Information and Referral Services (I&R)
130
9
0
18
2
21
180
B. Training Activities
10
903
The Employment team conducted several training and outreach activities to increase awareness and understanding of Disability Rights Michigan (DRM) services. DRM trained 10 new Michigan Rehabilitation Services (MRS) counselors, 30 Washtenaw Association for Community Advocacy (WACA) staff, 20 Disability Network Northern Michigan staff, 20 Eastern Michigan University (EMU) students, and 10 Work Incentive Planning and Assistance (WIPA) staff. Additionally, an Employment team attorney trained 110 participants at the National Disability Rights Network (NDRN) Conference on representing clients in vocational rehabilitation hearings. The training covered pre-hearing preparation, hearing procedures, post-hearing follow-up, and appeals.

C. Agency Outreach
DRM hosted a booth at the Convention of New Beginnings (RE-CON) Conference, allowing staff to engage with approximately 90 professionals and provide information about DRM services, the Client Assistance Program (CAP), Protection and Advocacy for Beneficiaries of Social Security (PABSS), and vocational rehabilitation services.

DRM also hosted a booth at the Transition Services Association (TSA) Conference, attended by 323 individuals, including students, families, teachers, Pre-Employment Transition Services (Pre-ETS) counselors, life skills counselors, and other professionals.

DRM participated in the Transition Center School open house as part of the community disability resource section, an event attended by approximately 300 students, parents, teachers and other professionals. The school is part of the Saginaw Intermediate School District (ISD) and provides learning opportunities to students with disabilities about the skills and essentials needed to live independently. A case manager/teacher who serves as the contact for each student is responsible for resolving problems. These individuals will also make referrals to a social worker when needed. The Transition Center also employs a vocational consultant, contracted through the ISD, who serves as an advocate between the Transition Program and MRS. This position functions similarly to CAP but operates within the school system.

DRM also developed accessible outreach materials including posters, flyers, and brochures for use during monitoring visits to state facilities such as Child Caring Institutions (CCIs), Juvenile Justice facilities, and the state’s youth psychiatric hospital. These materials, made available on DRM’s website and shared on social media, were designed to inform eligible youth and their parents about Pre-ETS and special education rights.

DRM revised language on marketing materials and online content to clarify Pre-ETS referred to legally mandated services helping students move from high school to adult life. DRM distributed the new materials, created a statewide survey to identify service and awareness gaps, and began active dissemination through digital platforms and direct outreach to existing contacts. Staff integrated the materials into standard communications, offered Pre-ETS information to all eligible callers, and tracked distribution for data collection.

DRM will continue to strengthen public awareness of disability rights, employment supports, and future planning services through ongoing outreach and training.
D. Information Disseminated To The Public By Your Agency
25
0
0
12360
11
0
NA
E. Information Disseminated About Your Agency By External Media Coverage
DRM continued to shape the public's perception of the agency by providing unique perspectives and information on the agency’s social media platforms (Instagram and Facebook). DRM’s social media outreach played a vital role in increasing visibility, engaging with the public, and building trust. Each year, DRM tracks metrics like engagement rates, follower growth, and reach. The agency works to continually optimize its social media efforts for even greater impact. In FY25, DRM had 93,838 impressions. DRM has 5,351 Facebook followers and 1,506 Instagram followers. Total: 6,857.
Part II. Individual Case Services
A. Individuals served
20
53
73
9
19
B. Problem areas
1
9
55
8
0
12
0
0
0
0
C. Intervention Strategies for closed cases
3
0
54
0
5
3
1
66
D. Reasons for closing individuals' case files
54
4
0
1
1
3
3
0
0
0
0
0
NA
E. Results achieved for individuals
8
1
3
4
30
4
3
2
5
6
SR 2426213- The client's Trial Work Experience (TWE) was terminated due to threatening behavior, and MRS case was closed for failure to participate.

SR 2349628- CAP provided the client with information and advice to prepare for a hearing after MRS rejected his chosen small business of non-emergency medical transportation. The administrative law judge (“ALJ”) affirmed MRS’s decision in April 2025.

SR 2386098- By filing for fair hearing, the client received two work-based learning experience (WBLE) during summer 2025, and MRS agreed to review its policies to ensure they are in accordance with law and rules.

SR 2335788- This service request was closed after identifying the funding source could be under Protection and Advocacy Beneficiaries of Social Security (PABSS).

SR 2418954- The client obtained Pre- ETS (Employment transition services) in the area in the requested. MRS has contacted the client’s school to implement Pre-ETS into the client’s school day.

SR 2477781-The client received the requested accommodation of virtual meetings to participate in MRS services.
Part III. Program Data
A. Age
5
9
17
36
6
73
B. Gender
30
42
1
0
73
C. Race/ethnicity of Individuals Served
3
0
3
23
0
42
2
0
D. Primary disabling condition of individuals served
3
2
1
0
0
1
13
0
8
0
1
2
0
1
0
0
0
0
0
5
12
2
1
3
2
8
0
0
0
7
0
0
0
1
73
E. Types of Individuals Served
8
1
70
1
4
1
Part IV. Systemic Activities and Litigation
A. Non-Litigation Systemic Activities
2
1-MRS/BSPB Conformity with Rehabilitation Act and Federal Regulations, FY25
(CAP &PABSS #130945)

Project Narrative:
This project was opened to ensure Michigan Rehabilitation Services (MRS) and Bureau of Services for Blind Persons (BSBP) policies, procedures, and practices align with the Rehabilitation Act and federal regulations with respect to various vocational rehabilitation services including advancing employment, advanced training, Individualized Plan for Employment (IPE) development, and the selection of employment outcomes. Strategies include educating MRS/BSBP about amending administrative rules, developing internal policy manuals, and encouraging MRS/BSBP to adequately train MRS staff. The Employment team will also focus on representing clients in administrative hearings that are likely to result in systemic impact on MRS/BSBP practices.
CAP engaged in three types of activities: helping individuals with cases that have systemic problems, working to educate the MRS policy division, and partnering with Michigan Council for Rehabilitation Services (MCRS) in correcting MRS policies that do not conform with federal law.
Systemic case work examples:
(SR# 2417709) CAP dealt with MRS failing to provide individuals with the information needed to make informed choices, especially around financial participation. DRM took this to a hearing, and the Administrative Law Judge (ALJ) reversed MRS's determination they would not amend the individualized plan for employment. This decision creates a strong precedent for future use. DRM is working to ensure MRS complies with the ALJ's ruling, and ensuring their compliance impacts how MRS responds to future hearing requests.
(SR#2467685) In this case, MRS applied the concept of “comparable benefits and services” too broadly, labeling everything as a comparable benefit. This meant MRS was trying to avoid covering certain services, like rehabilitation technology, which should not fall under that category. DRM successfully advocated for the client and plans to engage MRS’s policy division to address the issue at a systemic level.
These two cases extend beyond solving problems for individuals; they provide evidence for the policy division’s consideration. In some instances, this involves presenting real-life examples, and other times it requires pursuing a hearing or declaratory rulings to prompt their review.

Outside of casework, DRM provided MRS’s policy division direct feedback on their administrative rules. DRM submitted comments on rules related to eligibility determination, extensions, and trial work experiences. However, it is unclear whether MRS is continuing to engage with either CAP or the MCRS about changes to their services manual. DRM will address this issue with the policy division in FY26.
One additional development is noteworthy: MRS indicated it is hiring an in-house attorney with expertise in administrative law. This addition is expected to strengthen MRS’s capacity to address issues raised through CAP advocacy and policy discussions.

2- MRS/BSBP Compliance with APA and Rehabilitation Act rulemaking requirements, FY25 (CAP& PABSS # 130950).

Project Narrative:
This project was opened to correct MRS/BSBP when they fail to comply with Michigan Administrative Procedures Act ("APA") and Rehabilitation Act rulemaking requirements, including ensuring MRS/BSBP promulgate and amend Administrative Rules and follow public participation requirements. Strategies include requesting declaratory rulings from MRS/BSBP under Michigan APA and pursuing litigation in Circuit Court under the Michigan APA.
The main activity in this project was to monitor the Department of Licensing and Regulatory Affairs (LARA) website for MRS rulemaking activity. In doing this, it was determined MRS made a request for rulemaking in May 2025.
DRM allowed MRS time to complete its internal process before notifying MRS the issue had been identified. On June 27, MRS provided DRM with the draft proposed rule amendments and requested feedback.
DRM considers it a success that MRS provided draft rules for review prior to posting them on the LARA website. MRS is expected to consult with DRM regarding proposed rule changes. During its previous rulemaking process in 2023, however, MRS submitted the proposed rules to LARA and announced a public comment period without notifying or consulting DRM. DRM submitted comments regarding MRS’s draft administrative rule amendments, and MRS made changes to the draft rules in response to our comments.
DRM notes the BSBP administrative rules are limited and out of date. BSBP does not seem aware of the rulemaking requirements (although BSBP is currently very active in updating its policy guidance manual). DRM expects to raise this issue with BSBP. However, DRM has not participated in any BSBP hearings over the past three years; therefore, DRM has not had an opportunity to raise the issue with BSBP in the context of an individual case.
This project was closed successfully for FY25 after ensuring MRS complied with the rulemaking requirements.
Systemic casework examples:
SR 2426738: A DRM client with extensive experience working with juveniles, including 10 years as a juvenile justice specialist with the Michigan Department of Health and Human Services (MDHHS), wanted to pursue a career as a school guidance counselor. Under Michigan law, an individual must have a master’s degree to work as a school guidance counselor. MRS declined to support the client’s employment goal and refused to fund the required degree. DRM represented the client in requesting a hearing to challenge MRS’s refusal, asserting the degree was necessary to achieve the chosen employment outcome. After DRM submitted the hearing request, MRS agreed to amend the client’s IPE to include both his chosen employment outcome and the master’s degree.
SR # 2335788: A certified nurse practitioner contacted DRM because MRS was refusing to support the advanced training needed to become certified as a Psychiatric Mental Health Nurse Practitioner (PMHNP). MRS specifically refused to support the client’s employment outcome of PMHNP, saying she was employable with her existing credentials. This is contrary to the federal regulations, which provide that an employment outcome can include advancing in employment. DRM represented the client in an administrative hearing, and the ALJ found MRS acted improperly in denying her employment outcome. Following the ruling, MRS approved an IPE with an employment outcome of PMHNP and provided various services to achieve it.
DRM also noted during the 2024 Rehabilitation Services Administration (RSA) monitoring of MRS, it expressed concerns about the agency’s declining support for higher education or training, with its performance in this area falling below the national average. Both of these successful SRs clearly relate to concerns expressed by RSA.


B. Litigation
7
1
6
SR 2417709. One completed hearing addressed MRS’s failure to ensure a client was able to make an informed choice regarding financial participation in the cost of services. Specifically, the client was seeking a modified vehicle and alleged MRS informed her she was required to pay for the cost of the base vehicle. However, MRS’s administrative rules state financial participation in the cost of services is not required except for certain training services. The client asked MRS to amend her IPE, and MRS refused. The issue proceeded to hearing, where the hearing officer reversed MRS’s decision and ordered the agency to amend the client’s IPE regarding vehicle costs, finding MRS had failed to ensure the client could exercise informed choice concerning her financial participation. This case highlights the systemic issue – MRS routinely pressures clients into financial participation without advising them it is not required, thus denying clients informed choice.
DRM is now representing this same client in an on-going hearing request concerning MRS’s failure to implement the hearing officer’s decision. DRM engaged with MRS counsel to resolve the matter; however, MRS initially declined to implement the hearing officer’s decision. MRS stated it would not implement the decision because it intended to appeal; however, federal regulations require MRS to implement hearing decisions while an appeal is pending. MRS also claimed it does not know how to implement the decision, filing an appeal in Ingham Circuit Court. On October 27, 2025, DRM received an email from the Assistant Attorney General confirming MRS agreed to pay $42,855.00 to the client and had filed a motion to withdraw its claim of appeal. The systemic issues identified in this case were resolved through litigation during the fiscal year.

SR 2426738. Another completed hearing involved MRS’s refusal to amend the employment outcome in a client’s IPE on the grounds he had already signed an IPE with a less specific employment outcome and was already generally employable. MRS also refused to provide the advanced training needed to achieve the employment outcome. Specifically, the client sought to become a middle school guidance counselor, a position that, under Michigan law, requires a master’s degree. DRM presented the issue to the MRS counselor and site manager, however neither altered their position. As a result of the hearing request, MRS agreed to amend the client’s IPE to include the chosen employment outcome and to provide the training necessary to achieve that outcome. The systemic issue involves MRS’s routine denial of advanced training on the basis that individuals are employable in other capacities and its failure to honor clients’ rights to select specific employment outcomes even when those outcomes are consistent with established employment factors. The client withdrew the hearing request based on MRS’s amendment of the IPE.

SR 2426738. Another completed hearing request involved the same client. When MRS amended the IPE, it indicated their tuition assistance for the advanced training was limited by maximum dollar amounts. DRM’s hearing request was grounded in federal regulations prohibiting MRS policies from establishing any arbitrary limits on the nature and scope of vocational rehabilitation services to achieve the employment outcome. DRM advised MRS of this issue after they provided the draft IPE to the client, but MRS did not change their position. Following the hearing request, MRS proposed amending the client’s IPE to fund the first semester as an assessment, which MRS appears to view as exempt from the tuition caps. The client withdrew the hearing request based on MRS’s proposed amendment of the IPE. The systemic issue involves MRS’s practice of applying tuition caps to clients pursuing graduate training, even though the caps bear no relation to the actual cost of graduate tuition, a practice prohibited under regulation.

SR 2467685. Another completed hearing request involved a client who sought an ergonomic chair, along with the necessary assessment. MRS required the client to request the service from her employer as a comparable benefit. However, an ergonomic chair is rehabilitation technology, and the federal regulations provide that rehabilitation technology is exempt from the comparable services and benefits policy. DRM explained this to the MRS counselor and district manager, but they refused to change their positions. After a hearing request was filed, MRS provided the assessment and rehabilitation technology to the client, and the hearing request was withdrawn. The systemic issue is MRS treating assessments and rehabilitation technology as comparable services and benefits.

SR 2469905. DRM is representing a client in a pending hearing request seeking an order requiring MRS to provide rehabilitation technology necessary for the client to achieve her employment outcome. The client, who has Multiple Sclerosis (MS), works from home as an accommodation provided by her employer in her role as an insurance customer service representative. The client’s home does not have central air conditioning, and she experiences heat intolerance issues due to her MS, causing symptoms like fatigue and cognitive impairment. MRS initially provided portable air conditioning units, but they were not meeting her vocational rehabilitation needs. When asked to amend the IPE, MRS responded it had determined it had already provided “reasonable services.”
Part V. Agency Information
A. Designated Agency
External-other public agency
Disability Rights Michigan
No
B. Staff Employed
CAP PPR FY2025

Total FTE's 3.72


Support Staff Full & Part time 11.8% 0.44
Advocate Full & Part time 51.1% 1.9
Attorney 18.8% 0.7
Directors 18.3% 0.68

100.0% 3.72

35 people
total of 6,959
Direct Service
Hours only

Spent $436,227.00
$117,265.32 Per



Part VI. Case Examples
Case Examples
1-SR # 2441111- A client contacted DRM because of difficulties getting support from MRS to complete a graphic design certificate through Interlochen School for the Arts. MRS had previously supported the client’s participation in a voice acting program, however, the client was forced to withdraw when the program shifted to in-person instruction in Detroit, a significant distance from his home. MRS stated, because he voluntarily dropped the program, they would withhold support for future courses until they could see he had done well. The client used the reimbursement from the voice coaching course to pay for the first of three courses in a graphic design certificate program. After doing well, the client contacted MRS to get support for the second course. He experienced a long delay in getting approval for this course and followed up many times. The client and his family eventually decided to pay out-of-pocket for the course to avoid dropping the program. The client did well in the second course and again came back to MRS for support. He again experienced more confusion and delays. At that point, the client contacted DRM for assistance. MRS’s rationale for denying support appeared to shift over time, prompting DRM to contact an MRS manager to discuss the situation. MRS agreed to support the courses contingent upon receipt of Free Application for Federal Student Aid (FAFSA) information, which the client completed and provided with proof of submission. That same day, MRS mailed an authorization for $799 after meeting with the MRS Division Director to discuss the client’s case and the issue of retroactive authorizations. The client confirmed this amount was sufficient to cover both the upcoming class and the course previously paid for out of pocket.

2-SR #2480358- The client’s mother, who serves as her guardian, contacted DRM regarding the client’s enrollment in the Life and Career Studies program (formerly known as Ready for Life) at Calvin University. MRS management indicated uncertainty about whether the agency could support the program and if so, to what extent, noting potential support might range from $2,500 to $5,000 per semester. DRM spoke with the program coordinator at Calvin University, who explained within the past five years the program became a certified Comprehensive Transition and Postsecondary (CTP) program. The coordinator also noted the U.S. Department of Education issued guidance directing VR agencies to treat such programs the same as any other postsecondary or college program. This meant MRS could cover the program as any other college program under their policy. Further review of the MRS policy manual revealed MRS may not require or encourage financial participation in college training services from individuals receiving Social Security benefits, as is the case for this client. This finding resolved the issue related to tuition caps. The client subsequently received an IPE providing support for the full remaining balance of the Calvin University program for the fall semester, after application of scholarship and Pell Grant funds.

3-SR# 2432782- A client contacted DRM after BSBP indicated it could not support two vocational goals simultaneously. The client had a short-term goal of obtaining employment as a customer service representative, for which he was already receiving services such as job placement. He explained this goal was temporary and intended to provide income while he pursued his long-term goal of becoming a web developer through college training. DRM raised the issue with BSBP, after which BSBP agreed the client’s request was reasonable and approved support for both goals. The client ultimately received an IPE that included support for a web development program at Mott Community College, covering the cost of books after Mi Reconnect and Pell Grants paid for tuition. The client received extensive guidance about rules and regulations during the process, per his request.

4-SR# 2416255- A client contacted DRM because of delays during the MRS eligibility process. He consulted with a DRM attorney, who provided guidance on applicable regulations and policies as the client sought clarification in response to questions from his MRS counselor. The client was made eligible on September 17, 2024. The client returned in January 2025 because MRS had not yet developed the IPE for a wheelchair accessible vehicle. DRM contacted MRS to determine the cause of the delay and found an extension had been placed on the client’s case until June 30, 2025, without his knowledge or agreement. DRM attempted an informal resolution with MRS to develop a timely IPE. Ultimately, DRM’s attorney filed a hearing request with regards to the IPE development timeline. Shortly after, MRS made an informal timeline agreement. The IPE was signed, and the wheelchair accessible vehicle was delivered. MRS provided the client with $89,230.60 in support for a base vehicle and modifications. The client paid roughly $6,000 out of pocket to account for the difference in price between a Chrysler Pacifica and Toyota Sienna, and the EZ lock tie down system in the van.

5-SR# 2404946- A client contacted DRM after working with MRS for approximately four years to obtain support for dental implants. The client had advanced tooth decay, resulting in the removal of all teeth, and experienced a gag reflex that made wearing traditional dentures impossible. MRS management referred the client to three different dentists for evaluations. Due to severe dental phobia, the client required full sedation, even for routine cleanings. MRS management ultimately denied support for physical restoration beyond traditional dentures, stating dentures would be significantly less costly than implants and therefore represented the least cost to the agency. DRM successfully argued traditional dentures did not meet the client’s rehabilitation needs due to the gag reflex, and MRS is obligated to provide the least costly services “that meet the customer’s rehabilitation need.” MRS management was persuaded by this reasoning and approved funding for dental implants. The client signed an IPE that included $48,000 toward completion of his dental treatment program.
Certification
Reports are to be submitted to RSA within 90 days after the end of the fiscal year covered by this report. Please be reminded that you can enter data directly into the RSA website via the internet. Information on transmittal of the form is found on pages 19 and 20 of the reporting instructions.
Name and Title of Authorized Certifying Official
I agree to submit this form by electronic means. By signing this form electronically, I certify under penalty of perjury that my answers are correct and complete to the best of my knowledge. I understand that an electronic signature has the same legal meaning and can be enforced in the same way as a written signature.
Elham Jahshan
Employment Tean Director
Yes
2025-12-12
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