Thread Subject: Re: Subpart A- Draft -Definitions-Assistivetechnology service.

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From: Jim Tobias
Date: Thu, Mar 15 2007 4:05 PM

I don't think we need "assistive technology service", because that's usually
about client
evaluations, prescription of AT, etc. -- all accommodations (504) rather
than the mass
market products we're talking about in 508. Agreed?

On the other hand, I've always had a problem with the AT definition as it
is. It would seem
to swallow up all accessibility, since a mainstream product with
accessibility features fits
that definition. In the spirit of 255, which has a cascading view of
accessibility -- first try to
make the mainstream product accessible, then use AT if the mainstream
approach won't
work -- I think we should make a distinction between AT and "AMT", as Larry
Goldberg
named it: "accessible mainstream technology". Why keep the distinction?
Because the
two industry segments are so different; their markets are different; their
products are usually
different; their funding sources are different; where expertise about them
resides is different....
It's not for the reason some AT enthusiasts think, that somehow AT is a
lesser category. It's
that the distinction is an important one from so many perspectives.


******
Jim Tobias
Inclusive Technologies
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+1 732.441.0831 voice/tty
skype jimtobias
+1 908.907.2387 mobile




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From: Hoffman, Allen [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Thursday, March 15, 2007 11:32 AM
To: TEITAC Subpart A Subcommittee
Subject: Re: [teitac-subparta] Subpart A- Draft -
Definitions-Assistivetechnology service.


I concur, we should just include all the definitions and let the
access-board folks sort it out.




Allen hoffman -- 202-447-0303



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From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Deborah Buck
Sent: Thursday, March 15, 2007 10:51 AM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] Subpart A- Draft - Definitions
-Assistivetechnology service.



Here is my suggestion- maybe the way to approach this is to include all of
the definitions. See my rationale below

Assistive Technology- The term 'assistive technology' means technology
designed to be utilized in an assistive technology device or assistive
technology service.



Assistive Technology Device - Any item, piece of equipment, or system,
whether acquired commercially, modified, or customized, that is commonly
used to increase, maintain, or improve functional capabilities of
individuals with disabilities.



Assistive Technology Service:

A service consisting of expanding the availability of access to technology,
including electronic and information technology, to individuals with
disabilities. (This is a pared down version of the current definition, but
it includes the applicable part (G) of the statutory definition of AT
Service see below)





I'm not sure why you think using the term and definition for AT Device might
cause problems for screen readers that are software. Revisit the definition
of AT Device- the emphasis is mine

Any item, piece of equipment, or system, whether acquired commercially,
modified, or customized, that is commonly used to increase, maintain, or
improve functional capabilities of individuals with disabilities.

The definition of AT Device is so broad that pretty much anything can be
considered an AT Device- you could drive a jumbo jet through that definition
and under certain circumstances it could be considered AT. Under this
definition- software is considered a device.



The Definition of AT Services as included in the draft is a significantly
modified version of the definition in the AT Act (see below). The definition
of AT Services include- evaluation, purchasing, selecting, customizing,
coordination supporting therapies, training or technical assistance for the
individual, training or technical assistance for professional and maybe the
most pertinent to our discussion '(G) a service consisting of expanding the
availability of access to technology, including electronic and information
technology, to individuals with disabilities. (G was language that was added
to the definition of AT Service as a result of the 2004 amendments to the AT
Act). While referencing parts (A) - (F) might result in an expansion of the
scope of Section 508 the new addition (G) is pertinent to 508.

'"(5) ASSISTIVE TECHNOLOGY SERVICE.-The term 'assistive technology service'
means any service that directly assists an individual with a disability in
the selection, acquisition, or

use of an assistive technology device. Such term includes-

'(A) the evaluation of the assistive technology needs of an individual with
a disability, including a functional evaluation of the impact of the
provision of appropriate assistive technology and appropriate services to
the individual in the customary environment of the individual;

'(B) a service consisting of purchasing, leasing, or otherwise providing
for the acquisition of assistive technology devices by individuals with
disabilities;

'(C) a service consisting of selecting, designing, fitting, customizing,
adapting, applying, maintaining, repairing, replacing, or donating assistive
technology devices;

'(D) coordination and use of necessary therapies, interventions, or
services with assistive technology devices, such as therapies,
interventions, or services associated with education and rehabilitation
plans and programs;

'(E) training or technical assistance for an individual with a disability
or, where appropriate, the family members, guardians, advocates, or
authorized representatives

of such an individual;

'(F) training or technical assistance for professionals (including
individuals providing education and rehabilitation services and entities
that manufacture or sell assistive technology devices), employers, providers
of employment and training services, or other individuals who
provide-services to, employ, or are otherwise substantially involved in the
major life functions of individuals with disabilities; and

'(G) a service consisting of expanding the availability of access to
technology, including electronic and information technology, to individuals
with disabilities.





-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Wednesday, March 14, 2007 11:28 PM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] Subpart A- Draft - Definitions
-Assistivetechnology service.



I would concur about keeping AT and deleting AT Service.



As to AT DEVICE. That is fine but if we DO change the definition to AT
Device, then we can't use the term AT anywhere in the standard. We would
have to use the term AT DEVICE (since that is what we defined). I can see
that that might cause problems with AT like screen readers etc that are
software. So I'm not sure AT DEVICE will work.



You might say Assistive Technology (as used in this standard).



There will always be different definitions of this for different
applications.





Anyone got a better word for DEVICE that works everywhere we want to use
Assistive Technology?




Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.






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From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Deborah Buck
Sent: Wednesday, March 14, 2007 8:25 PM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] Subpart A- Draft - Definitions -Assistive
technology service.

Thanks Greg-



It would be helpful for respondents to keep comments in separate threads. If
you can remember try to label them Application, Exceptions or Definitions-
this will help immensely to keep track of the responses and set up some
rules for pre-sorting so nothing gets overlooked or lost.



We currently are not using the term AT Service in the regs (that I know of).
However the term "Assistive Technology" is currently used in the regs; if
there is consensus to keep the term as Assistive Technology the statutory
definition of AT is not consistent with what is currently in the 508 regs,
but includes devices and services- this would necessitate a definition of AT
Service. If however, there is consensus to change the term to AT Device I
see no reason to include the definition for AT Service. I actually think
adding the definition of service opens the door to services and supports
that are not a part of the scope and function of 508.



-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Wednesday, March 14, 2007 8:10 PM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] Subpart A- Draft - Assistive technology
service.



I will put comments in separate emails to facilitate discussion threads.





1) Assistive technology service.

a. There is no need to define a term that is not used in the standard.
Are we using the term somewhere?




Gregg

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