The archetype of bureaucracy is often associated with the Departments of Licensing / Departments of Motor Vehicles in various states. Washington’s contribution for this year manifested in the issuance of handicapped parking placards–the cards that hang from mirrors. It most certainly adds insult to citizens’ injuries who need the placards due to restricted mobility when the Washington Department of Licensing changed rules to supposedly address alleged fraud (which I personally have a difficult time accepting is rampant). But the DOL in doing so created a system that is easily circumvented and worse added another layer of delay for legitimate users by failing to announce changes to forms and procedures; thus requiring untold number of citizens to schedule new appointments with their doctors due to the agency’s bureaucratic rigidity and nonsensical new procedures.
I first became aware of the problem when my sister and I needed to obtain handicapped parking placards for our mother, who is disabled and also unable to drive. Due to her limited mobility, both of us needed a placard to hang on the mirror when we drive her around visiting various businesses. My sister completed the Department of Licensing (DOL) forms that the doctor had in her office, and her physician signed.
My sister then went to the DOL to receive the placard and was told by the employee that the form was invalid because it was the old form. Two or three weeks prior, the DOL changed the form (which differed by only a few sentences in the declaration) and they would no longer accept the old. They were unwilling to implement a transition period where both would be accepted. Of course few knew about the changed form because DOL failed to make sufficient effort to inform the public. The employee stated also they could not take the old form because the legal language had changed and said she would have to get Mom’s doctor to complete the form again with additional paperwork.
So this necessitated another visit to my mother’s doctor, which of course could lead to an office visit paid by Medicare and her Medicare Advantage plan, billed completely unnecessarily, as well as one patient time slot being denied to another patient needing to see the doctor. All this because a DOL bureaucrat and the department had to have the correct piece of paperwork to which in the end accomplished the exact same outcome my mother needed; a complete waste of time for certain.
Though we eventually received the two placards, we certainly were not alone. The problem began to spread to other, handicapped individuals in the state.
Seattle’s KOMO News published an article that brought more light to the red tape surrounding the DOL’s practices.
The article describes how a patient afflicted with cystic fibrosis needed to renew her handicapped parking placard. The process resulted in a month long delay with problems stemming from the DOL’s red tape blunders. The patient brought the DOL form to her doctor but did not notice in the fine print that a change now required a written prescription to receive the placard. The form otherwise looked like the standard form used the last time. The new form lacked any easily discoverable text alerting patients and physicians of the new prescription requirement.
Of course, the DOL rejected her renewal application and this required the patient to make another appointment with her doctor.
Unfortunately for the patient, this would not be the only obstacle. On her second appointment her doctor informed her he was unable to print a paper prescription because their medical records system lacks a prescription code for a Handicapped Parking Placard. Lacking the ability to write a prescription acceptable to the DOL the doctor instead printed a list of her medications and their purpose to indicate the presence of cystic fibrosis. Again, the DOL rejected this information and stated they would need a signed letter bearing the clinic’s letterhead.
Unfortunately, there was an additional delay because her doctor would be out of the office on holiday. She feared if she did not receive a renewal on her handicapped parking placard, she could receive a $250.00 fine for using an expired placard while parking. Though it is in my opinion highly unlikely a law enforcement officer would write such a ticket for one being expired for a few weeks, she would be technically in legal jeopardy if she did so.
KOMO called the DOL’s spokesman David Bennett who claimed he had never heard of any complaints regarding the new prescription system, whether or not he was privy to the information remains to be discovered, but he stated an electronic prescription system was available at the time of the changeover. I believe however it is probable given how poorly DOL notified people of the change that not every health care provider knew of its existence at the time and the fact that the patient’s doctor worked at the University of Washington Medical Center and they were unaware of the changeover.
Since this experience the patient’s clinic updated procedures to provide this prescription.
The DOL’s new procedures are such that can be thwarted with relative ease.
DOL requires that a Tamper Evident paper be used for a written prescription, however if this type of format is not available to the health care provider they may sign a declaration on an official letterhead document from their organization stating that the written prescription is not available. These requirements are so easily thwarted it is almost laughable. A forger could easily claim that their fake doctor does not have such this type of paper prescription and concoct a letterhead document themselves. He must be sure to make it an original forgery complete with a signature as copies of documents are not accepted. Assumingly, DOL can make a phone call to the number listed on the forged document’s letterhead, but I have to wonder how much of a genuine effort DOL employees will make on this given their caseload and waiting lines.
Since the DOL seems to prefer that rules must be followed with absolutely no exception, aligning with the bureaucrat’s automatous mindset, I was dismayed that in my research in compiling this article I discovered that the DOL broke state law in creating the new design of the handicapped placard.
Here is a picture of the former handicapped parking placard, courtesy of KOMO News:
Now, the new placard design:
The most pertinent design change, obviously, is the replacement of the International Symbol of Access with a more kinetic illustration. The new design stems from the Accessible Icon project’s effort to redefine the image of the disabled and handicapped from a sedentary disposition to that fostering accomplishment and the will to go forth despite limitations. The symbol is recognized in the State of New York.
The recognized symbol, two images above, is the defined, internationally recognized symbol codified under ISO-7001. The bottom is the Modified International Symbol of Access. In May of 2015 the United States Federal Highway Administration rejected the “Modified ISA” symbol (used in New York) for display on signs in the United States. The International Standards Organization, which is responsible for maintaining ISO-7001, refused its recognition. The International Symbol of Access is also a codified symbol in Washington under RCW 70.92.120.
Where the DOL gets into trouble is when it approved the state handicapped parking placards having the Modified ISA in its design. State law mandates the DOL to use the recognized International Symbol of Access on the placard under RCW 46.19.030 which reads in pertinent part:
RCW 46.19.030
Display and design of placards, license plates, and year tabs. (Effective July 1, 2015.)(1) The department shall design special license plates for persons with disabilities, parking placards, and year tabs displaying the international symbol of access.
So despite its insistence the public completely adhere to its red tape and bureaucratic lockstep, it failed to simply read and follow the only law codified in the Revised Code of Washington affecting design, and it violated state law by making a new, politically correct but non-compliant image of the disability symbol. This folks is government at its most stereotypical
For those Washingtonians who had to go through all the inconvenience, cost, runs-around, and frustration caused by your trusted Department of Licensing, you can now rest easy now that you have been granted the privilege of having a non-compliant handicapped placard for your parking needs. Your tax dollars were certainly well invested.
By Darren Smith
Sources:
KOMO News
Chapter 46.19 RCW
RCW 70.92.120
Washington Department of Licensing
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