Steven Hagemoser, Ph.D., L.P.

2700 Amick Ave

Des Moines, IA 50310

January 14, 2014

Dear Attorney General Miller,

My name is Steve Hagemoser and I had the privilege of serving as one of three commissioners(appointed by governor, approved by senate) overseeing the operations of the Iowa Department for the Blind (IDB) from September 2008 to April 2012. I want to bring your attention to recent developments that I believe pose a potential threat to the consumers the commission for the Blindis obligated to protect. Starting in late 2013, commissioners initiated the practice of being actively involved in the day-to-day operations of the IDB (e.g., being part of an interview panel when selecting new staff members other than for the director position; attending staff meetings; leading classes for orientation center students). I recently phoned one of the commissioners and expressed my concerns about this potentially hazardous blurring of professional boundaries. She told me that state officials had been consulted on this matter and had given their approval. I believe she was telling me the truth and thus I have no quarrel with her or anyof the other current commissioners. What concerns me is that the state officials consulted on this matter apparently lack adequate understanding of how “dual relationships” create a mine-field of potential adverse outcomes. Of course the presence of land mines doesn’t guarantee that they will be triggered and cause injury when one walks through the field,but I believe most would agree that detection and removal is a better strategy than crossing one’s fingers and hoping for the best when it comes to preserving integrity, protecting consumers, and managing foreseeable risk. I fear the approving officials may have looked into the matter and erroneously concluded some variant of “we could find no law/statute/policy that specifically forbids it—therefore it must be okay.”

The primary function of the Iowa Commission for the Blind is to protect the interests of thousands of blind Iowans by providing independent oversight and accountability for those who operate the IDB. Thus, although the interactions between commissioners, the director, and other IDB employees should certainly be pleasant and collegial, there should also be a healthy separation of their professional roles. If commissioners are allowed to function as part-time IDB staff members, then they necessarily become part of the entity they are supposed to be supervising. Thus, the concept of “supervising oneself” comes into play and I believe anyone familiar with government would agree that such an absence of genuine accountability is potentially harmful to the public. If a blind Iowan has a complaint about actions taken by the director or other IDB staff members,historically they have had an opportunity to bring their concerns to the commissioners who would serve as an independent and impartial jury to resolve those grievances. If commissioners are allowed to concurrently function as IDB staff members, then I believe an admittedly rhetorical question is in order—how can a plaintiff expect to get a fair hearing if the defendant and jury are essentially the same entity?

Some might argue that commissioners have knowledge and skills that could be used to improve organizational efficiency and this argument is not without merit. The problem is that there are numerous qualified individuals from government and/or the private sector who could be brought in as organizational consultants without putting blind Iowans at risk. A commissioner should not be an IDB staff member the same way a government meat inspector should not be an employee of the packing plant being inspected. Although I believe there is no willful intent to deceive on the part of any commissioner or IDB staff member, I do believe your office should look into the matter thoroughly and take any corrective actions you believe are warranted.

Thank you for your time and consideration of thisimportant matter.

Steven Hagemoser, Ph.D., L.P.

Licensed Clinical Psychologist

(515) 277-5387