2012-08-07-Randolph Sheppard - Hadley School for the Blind

2012-08-07-Randolph Sheppard
[email protected]
Blind Vendors: Understanding the
Randolph Sheppard Program
Presented by
Kevin Worley
Moderated by
Larry Muffet
August 7, 2012
Larry Muffet
Welcome to seminars at Hadley. My name is Larry
Muffet. I’m a member of Hadley seminar team and I
also work in the Curricular Affairs department.
Today’s seminar topic is, “Understanding the
Randolph Sheppard Program”. Your presenter is
Kevin Worley.
Kevin is the CEO of Worley Enterprises. The
company was founded in 1992 and provides food
services to government installations, which currently
includes Fort Carson, Camp Pendleton, and Shriver
Air Force Base. Kevin also serves as the executive
director of the National Association of Blind
Merchants, a division of the National Federation of the
Blind. He has also built an effective consulting
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business and has recently launched a new company
providing community outreach services to non-profit
Today, Kevin will present us with the basics of the
Randolph Sheppard program. So now, without any
further ado, let me welcome Kevin and turn the
microphone over to him. Okay Kevin, you’re good to
Kevin Worley
I have taken courses from Hadley. I hate to tell you
how long ago that was. Okay, 30 plus years ago I
took a couple of great classes from Hadley. So thank
you for your work over the years. I know we have a lot
to cover in a short time.
But just let me say, on a personal note in passing, my
math and science teacher at the Illinois School for the
Blind, was one of my very, very favorite role model
teachers, again 35 plus years ago. After retiring, he
spent many years teaching Hadley courses in math,
science, and business. So, it’s really nice to be a part
of what you’re doing for the blind in the nation and the
world. Thank you for the opportunity.
Well, I am Kevin Worley and I’m governed by a
couple of things and they will relate to Randolph
Sheppard, hang in with me. George Bernard Shaw
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said, “Those who get on in this world get up every day
and look for the circumstances that they want. And if
they can’t find those circumstances, they make them.”
I like that. It’s about building opportunity and it kind of
leads into the second motto that I have for myself, for
Worley enterprises, and the work I do at the National
Association of Blind Merchants. And the second motto
for me is, “building opportunity through service.”
If you think about it, you can find a place in your life in
business where you can get up every day and look for
circumstances. But if you don’t find the positive
opportunity that you want you’ve built it yourself. And
while you’ve built it, you build it by serving others,
customers collaborators, partners.
I also want to just mention at the top here, I notice the
list of folks who are participating. It looks like the right
numbers of women are on this call. I would say for
purposes of Randolph Sheppard that’s an important
thing because right now. Of more than 2,300 blind
vendors, licensed blind vendors, and business
operators who are engaged and licensed in the
business of Randolph Sheppard, only about 23% of
those folks are women.
So, we really do need to have more women involved
in the program and I think that you’ll see that
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Randolph Sheppard might be an opportunity for
women. I have about three things I want to cover.
Let’s do the first one, the law and the program.
Now I’m not a lawyer, I’ve never played one on TV. I
sometimes have served as an advocate negotiating
individualized education plans for parents of blind kids
or representing folks in rehabilitation who may feel
that they are not getting a fair shake so I’ve been an
advocate, but never a lawyer. So we’re not going to
spend a lot of time on the law of it.
Suffice it to say that the Randolph Sheppard act was
first passed in 1936 Jennings Randolph was a
member of congress. He believed that new deal
programs are to include a place for blind people and
he fought that entrepreneurship would be a place, I
don’t know if they used the word entrepreneurship
much in the 30s, that’s kind of a buzz word in the last
decade, isn’t it when you think about it. Good buzz
word I suppose.
But, Jennings Randolph thought that this would be a
good program to establish so that blind people might
have an opportunity to run little counters, snack
counter at the post office, and sell notions and candy
and cigarettes. He teamed with Senator Morris
Sheppard of Texas. They passed a piece of
legislation called the Randolph Sheppard act but in
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1974 the Randolph Sheppard act was significantly
amended to move this program to a different level of
So that blind individuals, licensed by the state
licensing agency, will get into that in a minute, could
operate not just a few vending machines or not just a
snack counter in the lobby, we could move to full food
services in the federal government sector, on
essentially all federal government property.
Now, I’ll add a caveat to all fed government property
because as the act and the program has evolved in
37 years, we’re finding that there are certain
properties which it is difficult to have this priority. So
the act the Randolph Sheppard act as amended in
1974 gives blind individuals a right of first refusal, or a
priority, to operate food service and concessions on
most fed property.
There are caveats to that but if you want to read the
act you can see those. Where could you read the act
you ask, well Hadley probably has a copy of it, or, you
could go to www.blindmerchants.org. The Randolph
Sheppard act is up there. The rules implementing the
act are up there so that will give you the statutory
basis for the Randolph Sheppard program, also
known, by the way, as the Business Enterprise
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So if you hear someone say well I’m looking into
going into the Business Enterprise Program of the
state of California or Oregon or Illinois, they’re talking
Randolph Sheppard. The Business Enterprise
Program for the blind and the Randolph Sheppard
program is the same thing. What happens is you’ve
got the Randolph Sheppard act.
One of the elements of the Randolph Sheppard act
calls for the United States department of education
through the rehabilitation services administration to
license a state agency to administer the program.
So usually it’s the commission for the blind in your
state or the division of vocational rehabilitation in your
state that says we’re going to have a Business
Enterprise Program under the Randolph Sheppard
act. We’re going to submit our rules and regulations.
The rehabilitation Service Administration says yes
those are good rules, you developed those rules in
collaboration with your elected Committee of Blind
You can have a program. You now can operate a
program. You can get matching funds to help operate
your program. And so the program can come into
being. Now, most states also have what we often
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refer to in the trade business as mini Randolph
Sheppard Acts.
These are laws that have been passed over the past
50-60 years by state legislation. They give blind
people through the designated state licensing agency,
again the commission for the blind or the vocational
rehabilitation agency. They give blind business
owners the opportunity to manage often vending,
snack bars, cafeterias at many state buildings.
Sometimes county and municipal buildings those laws
vary from state to state.
Let’s talk a little about the program and then we’re
going to take a few questions about the first two
elements of this, the act and the program. The
program is for allowing blind people, blind
entrepreneurs, blind vendors, blind merchants, the
opportunity to manage and profit from small
businesses. Usually in the concessions, food service,
cafeteria, vending business.
So you go through training. We’ll get to that in a
minute. You go through training, get a license, and
you can bid on locations around your state and when I
say bit it is typically, well it is never, a financial bid. In
other words, you don’t have to say well I’d like to have
that course house down there or I’d like to have that
bid federal cafeteria, how much is it going to take me.
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What kind of a price offer do I have to make? You
When you bid on a location, it means you present
your business plan and other materials that the state
agency wants to best select the candidate to operate
that location. The state agency, it’s called a program
because the state licensing agency provides the
apparatus, the infrastructure if you will. They help
fund it.
They work in collaboration with the elected Committee
of Blind Vendors. So if you’re a blind vendor you
might say “I want to be a part of governing this
program. I’m going to run to be a member of the
committee so I am part of the program in a
meaningful way. I am helping to construct the
program” so when we talk about the program it
implies governance, operations, management,
How do you get into this program? We’re going to talk
about that in a minute but before we do that, I’m going
to go ahead… I sort of remind myself of my good
friend Senator Michael Bennett of Colorado when he
does town meetings he says “Well, let me take this
question but I don’t want to talk very long because I
want to hear from you. I really want to hear from you.”
Then he answers the question in about 25 minutes.
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So I don’t want to be Senator Bennett. I’m going to let
this key go here and see if there are any quick
questions for me so we can dialog at least a little bit
before we move into the next part of this webinar.
Larry Muffeet
This is your opportunity if you’d like to ask a few
questions of Kevin. We’ve got the chance now so for
those of you that have a question ready, let’s go
ahead and fire away.
Brian Madley
Is there a listing, a clearing house, where we could
see what buildings would qualify as federal or state?
Kevin Worley
Yeah, you know that’s a very good question. There is
no specific listing. You’d think there would be. Maybe
the National Association of Blind Merchants ought to
come up with such a thing. The difficulty really, you
raise a very good point, because the number of both
state and federal buildings which have not been
procured by the state Business Enterprise Programs
and some of the folks on this call by the way I know
have been involved in trying to procure some new
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We certainly have in the National Association of Blind
Merchants. I guess the only way to go about it would
be to reach out to the Business Enterprise Programs
in each state and say “hey I’d like to have a list of the
locations that you are currently running” and they
should be able to do that and if they can’t you call me
and I’ll make sure they do give it to you. But in terms
of a federal government wide list I don’t know of a
repository though we could check with Dan Fry at the
Rehabilitation Services Administration who is the
federal employee who currently is charged with
oversight of this program.
I doubt that he has such a thing because if he did I’d
probably be using it. The thing is we happen to know
that there are thousands and thousands of federal
buildings that we are not doing business in and this is
the kind of thing we need to work more diligently to
create. But I think what you want to do if you plan to
stay in your state is reach out to your state agency
and say “tell me the locations we currently have as I
consider whether or not to get into this program”
which segways very nicely with how do I get into this
Look, the first thing you do is open a rehabilitation
case so if you’re not working and you want to
investigate the program. Well, first thing I would do is
make an appointment with the people in your state
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that run the Business Enterprise Program. You want
to get a sense of who they are, what they are, what
kind of administration you have there.
Are they open to your ideas? Are you open to their
ideas? Stephen cubby says seek to understand
before being understood. I notice a lot of my
colleagues like to tell everybody what they think but
we don’t sometimes (I’m just as guilty) we don’t
sometimes slow down and say “What is the
perspective of the other guy?” And if you’re going to
build business opportunities, getting that
understanding from others before you make your
decisions, your assessments, and your appraisals
makes a lot of sense.
When I deal with hundreds of customers a day, I want
to know what their needs are. I want to understand
their position. I want to understand what their income
level is. I want to understand why their attitude toward
me and my business is what it is before I start telling
them my point of view.
So, you go into the program, I think, by first reaching
out the Business Enterprise Program in your state. If
you don’t know who that is, you can send me an email
and I’ll get it to you.
[email protected] I’ll be happy to get
you that information. So you make an appointment.
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They might say “Well, you have to open a
rehabilitation case first.”
If I were someone in those shoes, I’d say “Well, I
understand that and I don’t know about that process,
but do you have 30 minutes for me to just survey the
land?” Mostly they will. If you like what you hear, you
open a rehabilitation case and you’re going to get a
rehabilitation counselor. And you’re going to talk to
that rehabilitation counselor about your vocational
outcome. And you’re going to say, “I’d like to consider
this Business Enterprise Program.”
Each state, unfortunately, each state will have
different rules of the road. Some of them you’ll have
to go through some sort of vocational assessment.
What are your skills of blindness? Do you travel well
with a long white cane or use a guide dog. Do you
have visual aids like a monocular that make more
effective in terms of the way you deal with business,
your communication with people? What are your math
skills? I mean if you’ve got a third grade math level,
chances are you’re not going to be able to run a
location that you hope will ultimately gross $800,000,
a million, a million five a year.
They need to know that they can teach you
bookkeeping and accounting. You don’t have to be an
accountant to get into this program, but you have to
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have some basic knowledge. So you’ll have to do
some evaluations. I know. Nobody likes rehabilitation
evaluating. But you have to at least do some of that if
you want to get into the trade. States will then offer
you Business Enterprise Program training, Randolph
Sheppard training.
Unfortunately, that varies wildly state to state. Some
states, it’s six months at their rehabilitation center.
Some cases, it’s six weeks at a rehabilitation center.
In some cases, it’s six weeks at a rehabilitation center
and you have to take eight courses at the community
college. So it’s all over the map.
When you have that initial conversation with the BEP
folks or the rehabilitation counselor folks, ask them,
what is the training scenario? And you’ll have to make
a determination. Man, is it two years? Well if it’s two
years, can I really, is that training going to be
beneficial? Is that training going to help me build
opportunity in the program?
Let’s face it if you’re in a state where there are only
eleven Business Enterprise Program locations, there
are already fifteen people licensed, the top earning
level is $50.000 a year, do you want to invest two
years of your time for that kind of opportunity? That’s
a decision, I think, that you’ll have to make.
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So you’re going to go through the training. And then
you’ll ultimately be trained. You will not be licensed
typically. Typically you have to get into a location for a
period of time. 90 days, 120 days, 180 days, and then
you will be provided a license. How do you get into
that first location? Well, hopefully you’re lucky.
You come out of training and there’s a location sitting
there, the court house, a food service that you would
want, or the state hospital or the federal building
downtown. And you say to the agency, “I’ve done my
training. I’d like to get into this” They say, “Let’s take a
look at your training record.” And they say “Well,
gosh, there’s no other blind vendor there. Do you
want to go look at it?” Yeah, I want to go look at it.
You say, “Wow, looking at this data it looks like this
thing could maybe gross $200,000 a year. If I can run
the thing at say 20% or even 15% or 18%, I’m going
to make $30,000 or $40,000 right out of the box. I
think that’s something I ought to do.”
So you submit your business plan and it is likely that
you would get chosen to operate for that location. The
state agency gives you support. They are supposed
to give you your equipment, your initial inventory, and
typically a start-up loan which you’ll have to pay back
over a year. So when you think about considering
Randolph Sheppard, think about it this way. You’re
not going to need opening money. They’re going to
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loan it to you. They’re going to give you the
equipment. They’re going to give you initial inventory.
You’re going to be accountable for those things. In
most states, they’re going to pay; the program is
going to pay for most of your machine and equipment
repairs. In most instances you do not pay for, this is
key stuff now guys as you consider whether this
business opportunities are for you, you don’t pay rent
you don’t pay utilities.
So let’s say mom and pop start up guy went to the
federal building downtown. They would likely have to
get a loan to start his business. They would likely
have to buy their own equipment. They would have to
pay a lease, and pay utilities. In most states, you pay
very little or nothing for all of these services. Many
states have what’s called a set-aside, or an
administrative fee.
That is a percent of your net profit that goes back to
help manage the program. That helps to buy the
equipment, pay repair costs, and buy that initial
inventory. If you were a franchise owner and you
wanted to run a Subway, Quizno’s, or an Einstein
Bagel at that same location, you’d be paying 5, 6, 8,
10 percent of your gross, not on your net. That makes
a big difference.
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So, that’s a little about how you get into the program,
and sort of the initial acclamation to the program. I’m
going to see if there’s any other questions or I notice
there are a couple of my colleagues on here they may
have some corrections. So let me see if there’re any
comments from my colleagues on this webinar
Larry Muffet
Kevin, this is Larry. I’m obviously not one of your
colleagues but a question that comes to mind, we do
a lot of work under our veteran’s initiative. Are there
veteran’s preference points or any sort of veteran’s
preference? I know in a lot of government programs
there is. Is there one for Randolph Sheppard?
Kevin Worley
You know there is not. And it’s something that we, the
advocates for the program, have considered. Also
some states in the bid process for the location, you
remember earlier I talked about how you would
submit a bid plan to the agency and also the
Committee of Blind Vendors they would talk about
your credentials, your qualifications, your past
performance, what kind of percentages you’ve been
I see no reason, I should probably check this, but
frankly I see no reason why there couldn’t be if the
state agency, with the elected Committee, wanted to
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put some sort of preference in there for blind veterans
that we couldn’t do that. Currently I know of no
preference points. There certainly are a number of
veterans programs in business development that
have disabled connected small business
administration has a number of programs for service
disabled connected.
Just like the Aid 8 program, women owned, hub
zone, so there’s a number of programs that some
folks on this call, this webinar, might qualify for other
than Randolph Sheppard. And if you’re looking at
business opportunities, I urge to look at all of the
programs out there. There are other preference
programs out there and depending on your status in
Now, let me say, the good thing about Randolph
Sheppard is, although it is a narrow band of sort of
discrete entrepreneurial services, it is a priority
program which is the strongest right of first refusal.
The other programs through the SBA (small business
administration) are preference programs. So if you
want to be a blind person in food service, vending,
concessions, the priority is a very strong selling point.
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Larry Muffet
While Kevin’s taking a break here, please be thinking
of some questions for him. I’m going to relay
Melissa’s question to him as soon as he gets back.
Kevin Worley
Ok, actually that’s what I was doing is looking at
Melissa Hanson’s question. I don’t know currently if
there are any Randolph Sheppard BEP locations in
any schools for the blind. However, I do know that
over the years sometimes the schools have been
used as training location and I will tell you I’m older
than I used to be but I seem to recall way back in my
distant past, reading of or hearing of some small trial
locations at schools for the blind.
Typically, if you’ve only got 50, 100, 150 students,
and employees, you’re going to be drawing from 200300 potential customers, and a lot of those customers
come during different times, I’m not sure it’s a viable
business unless it’s somehow subsidized. I’m not
opposed to subsidization as long as you can make a
good living.
Anyhow, long answer to your question is I am not
aware of any of those types of paradigms at this
particular time. Okay let me see if there’s one other
then I have to move to the next parts of my
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Larry Muffet
Kevin, Brian would like to know is the program
restricted to sole business ownership.
Kevin Worley
So let me answer two. I notice there’s one on here
that says the Illinois school does actually have an
active Business Enterprise Program location on its
premises. Thank you, Kathy. I told you, these guys on
this call are going to know a lot more about this than I
do. What I don’t know, I just make up and then I get
corrected. So, at least Illinois does and I thought
that’s the one that I recalled and there may be one
So, the question about sole proprietorship I think is
what it is. The program is established to license one
blind vendor. Now, that doesn’t mean that you can’t
become incorporated. I have a corporation. It used to
be said in this program that blind vendors were often
told no you have to be a sole proprietor to be in the
Let’s put it this way, the individual holds the license to
operate the location. If you decide you want to
become a corporate entity, you certainly can do that. I
have. I think there are some folks who are LLCs, I am
not I’m a corporation. But again, the key thing to know
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is that the license is for an individual, not for a
company or corporation. Is there anything else and
then we’ll move to the next part of this. Have you got
anything else for me Larry?
Larry Muffet
No, not unless anyone has a question they’d like to
use their microphone for. We don’t have any in the
check box. So we can free the microphone up here
for a second if anyone has a question, go ahead and
jump in. otherwise, Kevin can go ahead and continue
Kevin Worley
Okay, so now here’s what everybody really wants to
know. Can you make money in Randolph Sheppard? I
mean that’s the bottom line. Folks are on here
because they’re interested in business. You’re
probably more interested in making money than you
are in food service, vending, concessions. The
Randolph Sheppard program is a means to an end I
There may be someone in here that has a passion for
cooking or filling a vending machine and if that’s the
case, Randolph Sheppard Business Enterprise
Program is probably the place for you. Currently, the
medium income of a blind vendor, in the last statistics
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I saw, compiled by the rehabilitation services
administration was about $47,000 a year.
You know, there’s all these statistics that the state
and feds put together and it depends on how you look
at it. There’s the average, there’s the median. I look at
it this way. There are 2,300 blind people making a
living in this program. We know that some of them
frankly are what we call dumping ground locations. I
am going to be real honest with you because I’m
talking from my experience and the collective
experiences of a number of my colleagues that have
been around this program for about 20 years.
We know that there are folks sort of slaving away in
locations that are, as I say, under the stairs in the
basement of the federal building across from the
men’s room, down the hall from the linen closet under
the leaky pipe in the ceiling and they’re making
$15,000 a year. Well, that’s where I started.
I started there and within about ten years I’m making
six figures. So the question really becomes where do
you want to start? Where are you willing to start? How
much ambition do you have? How much imagination
do you have? How much are you willing to collaborate
with others? And I mean that very, very seriously.
How willing are you to not get your back up and your
nose out of join because it’s going to call for
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diplomacy if you really want to make money in this
There are going to be state agency counselors that
are going to come into your store and say “I don’t like
the cut of your jib. I don’t like the way you face your
potato chips. I don’t like the way you did this or that”
so are you willing as a business owner to take their
constructive criticism, not respond in a mean spirited
way, learn how to use the good stuff that they counsel
you and sort of nicely ignore the bad stuff.
And that really is important in business, whether it’s
Randolph Sheppard or anything else. How do you
relate to people? How do you, as we say at Worley
enterprises, how do you build opportunity through
service to others? Is there money to be made? If you
have a heart of service, and I truly mean a heart of
service. You want to bend over backwards to make
customers, colleagues, family members like what you
You want to give them something of yourself. So if
you have a heart of service, then there’s money to be
made in Randolph Sheppard. However, if you think
you can just sort of show up and wipe down some
counters and fill a cash register and maybe go to
Sam’s every once in a while, and you don’t really
have any passion for serving others, and if you bring
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no commitment to it, no imagination to it, then no
there’s probably not much money to be made for you
in Randolph Sheppard. And for that matter, there’s
probably not much for you to be made in any kind of
business realm.
One of the things that I do now is I have rooster’s men
grooming centers. It’s a franchise.
(Facebook/roosters/mgc), and one of the things we
learn there is how important service is. And in the
private sector you’re held to a count. If you don’t hit
certain bench marks, if you don’t pass certain
inspections, you’re going to lose your franchise. So
one of the ways I think to look at Business Enterprise
Programs, the Randolph Sheppard program is very
analogous to a franchise.
Now, it’s not the same. You don’t have a franchise
agreement, but you do have a license from the state.
You don’t pay the franchise fee based on gross, but in
most states, as I said earlier a set-aside, an admin fee
it’s also called, based on your net profit. But what
does that mean?
Well, you take in money in your cash register and
your vending machines. You pay your labor. You pay
cost of goods. You know, you have to pay for your
burger, your lettuce, your Snickers bars, your paper
goods. You have other expenses, envelopes, stamps,
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phone bill, and gas to go to Sam’s. You write all that
stuff off.
Whatever’s left, that is your net profit. That’s your
bottom line. Well, then you have to take your setaside percent off of that bottom line. Some states it’s
three or four percent. In Colorado it’s thirteen percent.
Some states it’s even higher.
We’re not going to get into that battle, but that’s the
fact. Think about what I just said. We’re not going to
get into that battle. If you’re a blind vendor licensed
under this program, you’re going to want to actively
participate with your state agency to help develop the
parameters of your program. You’re licensed, it
becomes your program. So to the extent you work
with them, as a team, should the set-aside fee be
20%, can you run a program on 20% or 13%? And we
can get in.
At some point we can have a discussion on those
types of issues. But for the purposes of this call, does
the Randolph Sheppard provide opportunity? I can
guarantee you there are hundreds of men and women
across this country for 70 years who have found great
opportunity, great possibility in Randolph Sheppard.
The Business Enterprise Program is mostly
concessions, cafeterias, food service, and vending.
But you’re the manager.
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You’re the owner operator with a consultant from the
state agency working with the governance of the state
agency, federal legislation, and your elected
Committee of Blind Vendors. Let me take some
questions about because I don’t know what you all
don’t know and what you want to know about the
opportunities that might exist. So let me pause a
second rather than me just rattle on like my good
friend Senator Bennett and actually take some
Larry Muffet
Kevin, I’ve got a question for you. This is Larry. What
sort of characteristics or attributes, personal
characteristics or attributes, tend to go along with
somebody who’s very successful in the program? Is it
people who are risk takers? Is it people with a higher
level of initiative? Is it people with sort of innate math
skills? What kinds of people are successful in this
Kevin Worley
Well, obviously you’ve pretty much answered the
question, but thank you for it. I think it’s pretty much
all of those things. I don’t think you have to be an
extraordinary risk taker, and let me tell you why. The
program provides you so much in terms of support.
Think about it, they’re going to give you training,
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you’re going to be able to network with peers, other
blind vendors that are doing well.
You get your initial inventor, which in most states you
have to pay back over a period of a year or so. You
get your equipment. One way or another you get
support to get your equipment repaired. You pay no
utilities in most cases. You pay no rent and no lease
in most cases. So to the extent that you’re a risk
taker, that’s a good thing because you’re putting your
sweat, blood, heart, soul, and imagination into this
thing. You’re putting a period of time of your life into
this thing.
And you do have to say “If I lose money, ultimately it’s
on my head” on the other hand, you don’t have to be
the same kind of risk taker that you have to be out in
private sector business. I’ll tell you, I talked a little
about, and I don’t really want to make this about me,
it’s about everyone else, but I’ve had a few other
businesses along the way Randolph Sheppard.
I ran a telemarketing center once for a couple of years
and I like not to talk about that much because I am a
risk taker and I lost a lot of money in that venture. I
made money in the first couple years. I didn’t
anticipate that they were going to offshore all of those
telemarketing centers, send them to India. There are
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a lot of things I didn’t anticipate. I didn’t anticipate that
I would lose a large help desk federal contract.
So I’ll tell you right now I lost well over $300, 000 on
that venture. Well that makes a guy a little gun shy to
go start another private sector business. Fortunately, I
had my Randolph Sheppard business that was doing
fairly well at the time. So I think you have to be much
more of a risk taker to open a business in the private
sector. Is there an element of risk?
Well, sure. You’re giving up your time, you’re asking
your family’s indulgence and forbearance, many of us
have family members that support us and might be
working with us. So risk I don’t think is important. I’ll
tell you what it’s important, more than anything else. I
think there are three things.
One: willingness to work your head off. I mean, you
really do. If you think you’re going to show up in this
program and sort of touch some boxes and pain by
numbers and everything’s going to be groovy…
you’ve got to be willing to, particularly early in the
game, early in your career in this program, you’ve got
to be willing to work. You really do.
You’ve got to be willing to lift that barge and tote that
bail. You have to be willing to fill some vending
machines and you’ve got to be willing to go to Sam’s
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in the morning. You have to be willing to get up at
5:30 in the morning and go in and make the muffins.
Okay and I’m telling you that’s a fact.
Any blind vendor will tell you unless you’re a lot
brighter than I am, and likely you are, I never found a
way to do it any better than just, any different than just
hard work. That doesn’t mean if you’re a blind person
you can’t construct things that work better for you.
Did I flip some burgers in my time or make biscuits
and gravy in my time? Yes I did, but only when I really
had to. Mostly I ran the register. I’m a totally blind guy,
I didn’t feel comfortable doing those things so I
constructed my business, there’s another advantage
of Randolph Sheppard, you can construct a business
that works better for you, working with your peers,
blind vendors, family members, perhaps the state
agency advisors.
And you can construct it so that you can concentrate
on your strengths I think that’s one beauty of
Randolph Sheppard. I’ll tell you a story, in 1997 I had
a little snack bar, I actually helped the air force do the
blue prints. We developed it together with the
Business Enterprise Program and we involved our
Committee of Blind Vendors and we developed this
nice snack bar.
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I was managing this snack bar probably making about
$1,200 dollars a day in sales. Not great, but not bad.
I’m not sure, I’m not going to do the math in my head,
but I think we were making about $60,000 a year on
this venture. I think somewhere in there. I don’t know.
I’d have to look it up. At any rate, I had two
Somehow I made these employees mad. I don’t
know, maybe I didn’t give them a raise, I was
disrespectful, maybe they were just a bunch of
knuckleheads, I don’t know. Anyway, they thought
they were going to show the blind key and they
walked out on me in the middle of a breakfast rush. I
had lines out the door; we had built a pretty good
breakfast business.
So I’m sort of freaking out trying to run from the
register back to dip up biscuits and gravy, get the
toast down, pan up bacon, just deal with the things
that you have to do to run a business. You know, I
hadn’t been cooking much in a while. Yet, I kept the
doors open, right? And good people knew, my
customers knew, that I was doing everything I could
possibly do to earn their trust and to provide them
When there got to be a lull in the service, I called up
my new girlfriend, Bridget, the lovely and talented
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Bridget, I said “have you ever done any cooking?” and
she said “well, just at home. I’ve never really cooked
professionally.” I said, “What are you doing today?”
and she said “I have to go to work in a few hours.”
And I said “Well, you know honey, I know we’ve only
been dating a few times, but how would you like to
come over and bail me out of a jam?”
She came in in 30 minutes, she bailed me out of a
jam, we’ve been working together ever since, and
we’ve been married for twelve years. So, you know.
There are side benefits to the Randolph Sheppard
program. So, one is being willing to work your head
off. Two, is imagination. I cannot stress imagination.
You know, what did I do when I got in that jam? I had
to think creatively. Well, gosh, I’m just dating this girl,
what could it hurt to call her and see if she’ll come in
to work? Imagination is so important. Don’t get into a
box. Don’t say “well, the agency told me to do it this
way.” Or I read an industry manual that says you have
to fill the machines this way.
Be creative in business. That’s not just Randolph
Sheppard. You have to imagine new cool groovy
ways to market what you do so I think imagination is
very important. The third thing is social, some sort of
social awareness. I mention this because I’ve run into
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a number of blind vendors who don’t get that they
share the planet with other people.
I know a fellow, he goes down the hallway swinging
his can from side to side, side to side, with, (I guess
nobody ever taught him a pencil grip on his cane), but
you know, I mean it’s from door to door. Of course he
intimidates people. Why do they want to come and
see that guy who’s carrying a big stick, right?
I know a guy that shows up every day in a Budweiser
t-shirt and wonders why he doesn’t make much
money. So having some notion of social norms, what
other business owners do, what other folks at cash
registers look like. Learn what the expectations of the
sighted public are, and being willing to, to some
extent, to conform to those expectations.
You may be familiar with the leadership principle
that’s BLM that’s essentially “Be Like Me”. People like
to do business with people that are very much like
them. To the extent that you are approachable, that
you make yourself amenable to their needs, their
wishes, you learn what those are. I’m not saying you
Look, after work, I don’t care. Go to a biker bar, it
doesn’t matter to me and it won’t matter to the
performance of your business. But, unless you have a
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biker bar location, don’t act like that if you’re at a nice
upscale office building. To the extent that you can
understand how your customers act and act
accordingly. That’s very important as well. Okay,
other questions?
Larry Muffet
Brian would like to know, he says he gets the
impression that other items besides consumables are
legitimate to offer for sale if the situation made it seem
feasible would a business be cleared to sell apparel
or gift items for example. He says he knows it would
probably vary state to state but are you aware of such
Kevin Worley
Yes, good point. You are absolutely correct. The short
answer is yes. It has to do with what is in called the
permit between the state agency and the property
management agency. So, for example, Don Morris in
Maryland, he has a location at the United States Fire
Academy where it’s under Randolph Sheppard. He’s
had this location for I don’t know 15, 18, 20; time
really flies, probably at least 20 years.
He doesn’t sell any consumables. And if so, it’s just a
little gum or chips at the counter. He sells; it’s a gift
shop, that’s exactly what it is. He sells hats, and tshirts, keychains, and gift cards and all kinds of
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things. That’s where imagination comes. For example,
he has these firefighters that come from all over the
country. They come in and they buy stuff from him.
He captures their name, address, and phone number.
From time to time, he sends them an email and says,
“Hey! Wouldn’t you like to send your girl or boy
fireman, put out the fire flowers, or whatever.” I don’t
know, but he really follows up with these customers.
Not only do you want to think what you have, could
you add apparel, could you add gifts, could you do a
florist, yes… you can do those things, under the
appropriate circumstances. You work with your state
Look, I ran a location in the early 90s that was really,
what I talked about earlier, was this little snack
counter in the basement, across from the men’s room,
etc. I noticed there was a lot of space in the back
there and I worked a deal with the folks off the air
force base with a dry cleaner.
There were a lot of officers in that building and they
had to keep their uniforms up to snuff. They would
drop their dry cleaning in my shop. The dry cleaner
would come pick it up every day and bring it back to
me and I tack 40% onto it and give the dry cleaning
back to the guys.
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Yes, lottery tickets, most states have lottery. In most
programs, given the type of location, you can do
lottery. So you absolutely can think, I absolutely hate
this expression but I’ll use it, you absolutely can think
outside the box, outside the lines and be imaginative.
That’s that characteristic I was talking about earlier,
imagination really needs to guide what you do.
One of the things that the National Association of
Blind Merchants has at our blindmerhcants.org
website is a thing called a customer service
advantage. It’s about a 60 minute audio and it has a
booklet with it that we produced eight or nine years
ago and in that little audio tape that we put together
with some leadership and customer service experts, it
talks about flexibility, service, and some imaginative
I have gone into locations where there are signs
scotch taped to the window and I say to folks, “Why
would you do that? It looks like a third grader’s
business, not like an adult professional entrepreneur.”
And so this audio program with a little booklet and a
test is available at blindmerchant.org and I think we
have it.
I would also commend as a resource a two hour
course taught by James [Gashel]. It’s a video and I
believe it’s segmented so you can learn. You can
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read part of it and listen to part of it and stop it and
keep going. There’s a Randolph Sheppard quiz that
comes with that.
I know Hadley had a lot of material that you can use
as well. The Randolph Sheppard act is at
blindmerchants.org and there are folks like John
Gordon of Illinois, Nikki [Gaecose] of New Jersey, and
many others across the country, that have been at
this game for a long time. We would be open to
mentoring or providing ideas, and getting your ideas
about how we can create entrepreneurship.
Not only in Business Enterprise Program, but
opportunities for blind people in business outside this
program. Not only do we have ideas, but as I said
earlier, we need to seek to understand where you’re
coming from and what your goals and ambitions are
as well. Other comments or questions for me?
Larry Muffet
Kevin, Craig wants to know how much a person can
earn in the Business Enterprise Program before
losing disability benefits.
Kevin Worley
Okay, so we’re going to go two extra hours. The, as
you know, the social security income rules establish
substantial gainful activity, SGA, which is an amount
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of money that you cannot earn more than before
losing your SSDI. Our questioner obviously is very
informed because there are different rules for people
under the Business Enterprise Program for Randolph
I’m not going to get into the weeds of those rules
except to say these things as a guide. The National
Federation of the Blind with Social Security
Administration developed a memorandum of guidance
several years ago. If you’d like that guidance, I’d be
happy to get it to you. Send me an email and we’ll
send it to you. It’s about four or five pages in brail so
it’s only a couple pages in prin.
I don’t think it’s online. We probably should put it up
there. If somebody on my team here would remind
me, we’ll put it up there. What it essentially says is
that these expenses that I was talking to you about
early, such as the equipment, the equipment repair,
management services that you get from the state
licensing agency that I talked about earlier,
counseling and those kinds of things.
The value of the space, for example I said you don’t
pay lease space and you don’t pay utilities. Many of
these costs can be deducted because you don’t pay
them. They are in a sense a subsidy to you as a blind
person. So many of those expenses can be deducted
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in order to determine your substantial gainful activity.
So think about it this way, you earned $80,000 a year.
That’s your net profit after set-aside.
You have expenses that you don’t pay that you would
have to pay if you weren’t a blind person. Let’s say
you made $80.000 and you had expenses, unincurred business expenses they’re called.
Remember that term it’s important, un-incurred
business expenses. Let’s say you have about
$65,000 that you would have to pay.
Add it all up, rent, all that space can be expensive.
Management services, equipment that was given to
you, well then you income, for purposes of calculating
Social Security about $15,000 a year. That’s going to
be under SGA right? There’s a thumbnail sketch. I
may have left out something and my colleagues will,
I’m sure, inform me. There’s the two minute version.
The short answer is yes, some blind vendors can
qualify to get SSDI benefits even if they’re over
substantial Gainful Activity.
Larry Muffet
Well, who else has a question for Kevin? You’ve got a
real opportunity here to talk to the master so let’s feed
those questions to him while we have a chance.
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Yes, my name is Armando. I’m calling from Puerto
Rico. I’m a retired vendor from the state of Illinois. I
was in the program for about 20 years. I supported a
family off of this program and would just like to say
that I feel that this program, if worked correctly by the
licensed vendor could substantially support a family
and is probably one of the best programs available to
us as blind people currently in all the states. Thank
Kevin Worley
Yeah, so I totally and wholeheartedly agree with that.
Look, it’s not for everyone. Not everyone should be in
business. Some folks should be lawyers. Some folks
should teach kids. Some folks should be working
assembly at the Chicago Lighthouse or for IBM.
But there are a lot of folks who have created
substantial opportunity as our gentleman has just
articulated. Let me tell you this. I know at least three
blind vendors in this country who have hit the million
dollar earnings level in this program, take home
dollars. Well, taxable money.
I know probably five of the vendors in Colorado who
are $150,000 a year or more. Now I also know five
blind vendors in Colorado who are at about $25,000.
If they have initiative, and the cookie crumbles just
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right, and they work hard, and they treat people with
respect, and they have a commitment to work hard,
they might get to do that $150,000 - $200,000 level.
There are a lot of opportunities that are out there in
the military dining sector, in expanded vending.
Someone asked earlier do you have a list of all the
businesses that are subject to the Randolph
Sheppard act?
I don’t have such a list, but if you were a business
operator in this program, you could help us grow your
business because even if the post office in Durango is
not on the list now, you would work with all of us, the
Committee of Blind Vendors the state agency and
you’d say “Hey, that looks like that post office in
Durango might be a good opportunity.”
Let’s pursue it together. If you have an
entrepreneurial spirit then I think the sky’s the limit in
this program. Are there glass ceilings to
breakthrough? Sure. Are there encumbrances? Sure.
Is it a bureaucracy? Absolutely it’s a bureaucracy.
Someone said on the phone to me the other day,
“Explain the Randolph Sheppard program in about
three minutes.” I said, “Are you nuts?”
You know, you’ve got the designated state licensing
agency, the Committee of Blind Vendors, and the
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National Association of Blind Merchants, the
Rehabilitation Services Administration. We operate
our business in GSA buildings, in USPS buildings,
and in DOD buildings. If those kind of acronyms and
initials aren’t’ enough to intimidate, I don’t know what
But the facts are if you eat this elephant one bite at a
time; don’t expect to understand it all day after
tomorrow. We just put on foot in front of the other. It
absolutely can be a mountain worth climbing and a
set of challenges worth confronting. I really believe
that. I’ve built a great business over 20 years which
has allowed me to expand beyond Randolph
Sheppard. It’s also allowed me to give back to others.
I have great pride and great satisfaction in working
collaboratively with my fellow blind merchants across
the country and to have national leadership
opportunities in Rotary, the National Federation of the
Blind, and the Catamount Environmental Institute. I
wouldn’t have had those locations in any other way if I
hadn’t found a way to partner my work with Randolph
Sheppard with commitment and work in the national
federation for the blind. To me, those are avenues
that have served me well.
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Larry Muffet
Kevin, we have a question about owning or having
multiple locations. I think probably from reading your
resume that that’s indeed the case. But is there an
upper limit? You know, can you only have so many?
How does that work.
Kevin Worley
So, I talked in the previous segment about the
complexity of this program, vagaries of this program,
and don’t expect to understand it overnight. The
essential principle is one location for one blind
vendor. However, what is the configuration of that
For example, we have a federal center in Denver.
There are 30 buildings. There are thousands of
people. So, the Committee and the state agency at
one point split that federal installation up into five or
six business opportunities. Over the years, we’ve
negotiated with that location, which is grossing a
couple million dollars a year, is one location.
One blind vendor has 80 vending machines, and
Einstein Bagel, a large cafeteria, and three snack
bars. Well, the governance of this program is
controlled by the state agency, which has the final
authority, but in the better states it is in collaboration
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with your Committee of Blind Vendors. Technically,
it’s one location. I think this is fair to say.
My colleagues might correct me, but technically it’s
one location and one business per blind vendor.
However, there are times when a state may not have
enough blind vendors to fill all those locations and you
Joe Opportunity Builder will say “Hey, I’ll run that
snack bar. I can do that. And by the way, those
vending machines over there, I’d be happy to put
those under my business as well.”
So in terms of Randolph Sheppard, rule of thumb, one
business, one concessions per operator. But there’s
some opportunity depending on circumstance and
your entrepreneurial spirit. Now, outside of the
Randolph Sheppard program, you can build and
business you want. Just because you have a blind
vendor license, you can run your snack bar at that
federal center and open a Rooster’s Men’s Grooming
Center (Facebook/rooster/msc), you can open a
telemarketing business, (worleyenterprises.com), you
can do all those things outside the confines of the
program once you get that business experience.
My son just graduated from college. He’s a blind. His
name is [Nija] Worley and he came to live with us
when he was twelve. Anyway, he just graduated from
college. He used to tell me when he was growing up
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and learning English and Brail, he’s from Eastern
Europe and he used to say “I’ll never do Randolph
Well as he finished his college career, he said, “So tell
me more about this Randolph Sheppard.” So he
thought that what he would do is get a Randolph
Sheppard license and then just hire somebody to
manage it and then he would just go off and do
whatever he wanted to do.
I had to explain to him, look, you don’t start at the top
of this game. You have to start getting up at 5:30 and
making the muffins, and running the cash register,
and filling vending machines and maybe going to
Sam’s on weekends and you don’t start at the top. But
if you start at the bottom and you have imagination
and understanding of social morays, and a
commitment to work hard, you can make a living at
this thing.
Hey Kevin, just as an aside, I teach college classes
on the side, business classes, and the majority of
students pretty much have that opinion that they’re
going to walk right out and become vice presidents of
some firm. So, your son’s not the only one.
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Kevin Worley
Well, fortunate for me, he just graduated and he does
have a job. He found a job. He’s going to do fairly
well. So, we’re happy about that because I don’t want
him to come back home and I also don’t care if he’s a
Randolph Sheppard guy or not.
But, I used to tell him, I said, “You know, you don’t
want to be Randolph Sheppard and yet, who paid for
the adoption attorneys and put the clothes on your
back and food on the table and vacations that we
went on?” anyway, he’s a good kid and I’m very proud
of him. Other comments about Randolph Sheppard or
whatever you’d like to talk about as we wrap up here?
Larry Muffet
We’ve got time for a couple more questions here, so
let’s take the opportunity.
I think isn’t the question more, do you believe in
yourself? Whenever you go into business, that’s the
first thing you have to ask yourself. Would you hire
you to do this job? Isn’t that more where you have to
make the first decision?
Kevin Worley
So, I absolutely agree. That really succinctly said it
better than what I did in terms of understanding social
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norms and the behaviors of other people. I like the
way you put it, would you hire yourself? Look critically
at your skill set, your attitude. I can remember coming
into my location and I’d be all grumbly and upset that
it wasn’t making very much money and the state
agency sent me a letter that I didn’t think they should
have sent me and the four cases of lettuce came in
on the back dock when I only ordered one.
I’d be all grumbly and grouchy and I finally learned
that you can teach yourself to smile through anything.
If you make yourself smile through it, things will get
better. I know it sounds very trite. I know it sounds like
something out of a leadership, or an attitude
development book, but it is true.
I always tell people, “Smile like you’re eating a
banana sideways.” And you know what? Things will
tend to get better. I know guys that approach their
business with such a grumbly attitude; they’re usually
not the guys or gals that are making the big bucks.
They usually aren’t.
Larry Muffet
Kevin, Brian would like to know in your experience,
has the charge of unfair competition by other
business owners been an impediment to operating
this particular program?
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Kevin Worley
Not so much a charge of unfair competition, but
encroachment, particularly by other vending food
service and concessions. I answered the question
earlier that we did not have a complete
comprehensive list of all the locations that we would
be entitled to. We’re always struggling. For example,
the Social Security Administration, or the IRS, or the
Department of Defense puts out a request for
proposal and the state agency doesn’t see or doesn’t
know about it. They don’t react in time.
Then you’ve got McDonald’s that has a location that
should be Randolph Sheppard. So we’re constantly
working to ensure our whole program, our whole
system, is vigilant. I’ll tell you one place you get into,
state buildings. Let’s say you have a cafeteria on the
first floor. Then you’ve got a bunch of hot dog
vendors, taco vendors, and steak sandwich wagons
out in front of the building. That kind of competition
can be troublesome.
I think also fighting off the efforts of the larger
corporation who do everything they can to say, “Wow,
the Randolph Sheppard program doesn’t know about
this opportunity so we’re going to snap it up for
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Oftentimes what we find in this program, we end up
with pretty good bunch of little locations, but
sometimes the corporate entities have outsmarted us
to grab some of the larger earning locations. We just
have to be vigilant and creative, and keep pushing
Larry Muffet
We’ve got time for one more question.
Hello. It’s Brendan here from England, Kevin. I’m a
practitioner working in the field of Employment and
Disability. I’m also a registered blind person myself.
I’m interested to know how many of the BEP
businesses are actually run by the individual licensee
only. And, how many employ people. I wonder if
you’ve got any sort of picture of that. Thanks.
Kevin Worley
That’s a tremendous question, thank you, and
greetings across the pond. Most of the 2,300 vendors
operate their locations directly. Some will partner with
private sector owned companies. Let’s say it’s a large,
and I’m going to get to your real answer, but I want to
cover this first.
Let’s say it’s a very large cafeteria that grosses $3
million, $7 million, $15 million, $20 million dollars, and
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we have a few of those in the program. The state
agency doesn’t have the financial resources and the
blind vendor doesn’t have the credit line, then you can
seek a private sector collaborator, a partner, to do a
joint venture with to bring you the skillset that you
might not have as a blind vendor or the line of credit.
You can then take on some of those larger locations,
as long as you own at least 51% of the operation.
There are some locations that we handle that way.
There is no rule that says blind operators much hire
other people with disabilities. There may be in certain
states, we don’t in Colorado and I don’t know about
other states, but I think some others do. They may
say we prefer or we provide guidance that you hire
other blind people or other people with disabilities.
In general, if you look at the statistics that I talked
about earlier, compiled by the Rehabilitation Services
Administration, blind individuals in this program hire
other individuals with disabilities at a rate two and a
half times that of private industry. So, I’d be happy to
stack Worley Enterprises hiring people with
disabilities record against General Motors,
McDonald’s, or [Svetco] any day of the week.
Blind people tend to hire people with disabilities to
work for them as cooks, filling vending machines, as
accountants, as their cashiers, janitorial, or whatever.
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We tend to hire more people with disabilities than the
private sector. Does that help answer the question?
Yes. That’s very useful indeed Kevin, thank you for
Larry Muffet
Kevin, I’m going to feed you one more question then
I’m afraid we’re going to have to start the wrap up
procedure. How would Randolph Sheppard apply to
an International airport? Bob would like to know that.
Kevin Worley
The rule of thumb is that Randolph Sheppard does
not apply to most airports because most airports are
owned either by a private outfit, or they’re owned by
municipalities, or some other configuration. That
doesn’t mean you shouldn’t pursue Randolph
Sheppard opportunities. Years ago, Randolph
Sheppard programs used to have a lot of private
sector companies, factories and that kind of thing.
If I was trying to build opportunity under Randolph
Sheppard in a state, I would have no compunction
against going to the airport and waiving the Randolph
Sheppard Act in the manager’s face and say, “You
know I’m not sure that this applies over here. But, I
notice that you have three food courts here and we
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should operate a magazine store or with hot dogs.” In
other words, I go back to the imagination, the
creativity and the commitment to work. Just because
something hasn’t been done, or isn’t being done,
doesn’t mean that we couldn’t try to make it happen.
In general, Randolph Sheppard doesn’t apply to
airports. Having said that, our good friend David
Patterson, former governor of New York, and a
consultant to the National Federation for the Blind,
while he was completing his term as Governor, just
signed a piece of legislation which would create some
opportunities at the airports in the state of New York.
Those regulations have not yet been regulated, but
we’re working to ensure that there will at least be
some opportunities to operate businesses owned by
the blind, or under Randolph Sheppard, in the state of
New York airports. I don’t know what my colleagues
have found in terms of developing opportunities at
airports, I just know that there aren’t many of them.
Larry Muffet
Kevin, I think unfortunately, sadly, we’re going to have
to start wrapping this up. This has just been a
wonderful seminar. I’ve learned so much and I’m
really excited about what I’ve heard here today. I want
to let everyone know that this seminar, like every
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seminar at Hadley, will be archived on our website for
your use any time around the clock.
Also, each seminar at Hadley is now available as a
podcast which you can download to your computer or
mobile device and listen to it at your convenience.
One of the things I want to take a moment to talk
about is if today’s seminar has got you interested in
business or entrepreneurship, please check out the
Forsythe Center for Entrepreneurship here at Hadley.
We’ve talked about the Randolph Sheppard program
as far as putting a business plan together, customer
service, and federal benefits, a bunch of topics have
come up today. We have courses and modules in
place for those. We also have some in the
development stage on accounting and business
taxes, a whole wealth of information that I think would
really get somebody revved up and ready to go take
full advantage of this program.
Kevin, I thank you for your participation today. Your
questions were just outstanding. I really like the
enthusiasm that all of had in taking part in this
seminar. Hadley values your feedback. Please let us
know what you thought about today’s seminar and
give us some suggestions for future topics.
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One way you can do that is by dropping us an email
at [email protected] Another way to share is by
completing a short on-screen survey that I’m going to
post as we conclude today. I’m going to hand the
microphone back over to Kevin for some final
comments. Kevin?
Kevin Worley
Well, thank you very much. First of all, thank you to
Hadley. The work you’re doing is just really, really
important work and you are the only outfit of its type
that does it. So, folks who are advantaging from
Hadley, keep doing that. They have developed a
whole set of new business, a lot of introductory,
business offerings so check those out.
Also I want to remind folks about BLAST, Business
Leadership and Superior Training sponsored by the
National Association of Blind Merchants and the
National Federation of the Blind. Hadley’s been a
great supporter of that three day training leadership
The next one will be May 20-24 in Indianapolis.
Registration is only about 160 bucks. We get low
room rates and if you’re interested in business, not
just Randolph Sheppard now, we’re working through
the National Federation of the Blind and
Entrepreneur’s Initiative to build business
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opportunities outside of Randolph Sheppard and
Hadley’s been a great partner in that area.
I’m happy to take your calls, your comments, and your
emails. If we can help in any way, we’re happy to do
it. Hadley and gang, thank you so much for the
opportunity. I appreciate it.
Larry Muffet
Thanks Kevin. I want to personally thank you for just
an outstanding seminar today. I want to thank
everyone that took part in it. Goodbye for now.
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