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

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From: Katie Haritos-Shea
Date: Fri, Mar 16 2007 9:35 AM

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<DIV>I agree with adding service to the definition.</DIV>
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<DIV>Katie </DIV>
<BLOCKQUOTE style="PADDING-LEFT: 5px; MARGIN-LEFT: 0px; BORDER-LEFT: #0000ff 2px solid">-----Original Message----- From: Diane Golden < = EMAIL ADDRESS REMOVED = > Sent: Mar 16, 2007 11:42 AM To: 'TEITAC Subpart A Subcommittee' < = EMAIL ADDRESS REMOVED = > Subject: Re: [teitac-subparta] Subpart A- Draft -Definitions-Assistivetechnology service. <ZZZHTML><ZZZHEAD><ZZZMETA CONTENT="text/html; charset=us-ascii" HTTP-EQUIV="Content-Type"><ZZZMETA name="GENERATOR" content="MSHTML 6.00.2900.3059">
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<DIV>I believe the suggestion for adding something about AT "service" or at least indicating that services and products were part of the AT defintion stemmed from the telecom area where access is delivered in a sort of bundled product/service system.  (I think this came up early on in telecom discussions as David Baquis  was identifying issues from the Access Board's perspective.)  So to the extent that the technical standards for telecom cover both products/services in a system, the idea was the definition should cover that.  If indeed that was the impetus, perhaps a much simpler solution is to just add the word "service" in the current definition and leave the term "assistive technology" with not differenciation between device and service.  </DIV>
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<DIV>Assistive technology.  Any itme, piece of equiment, SERVICE, or system, whether acquired commerically, modified, or customized . . . </DIV>
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<DIV>Diane Golden</DIV>
<DIV>NASCIO</DIV>
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 -----Original Message----- From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Deborah Buck Sent: Thursday, March 15, 2007 8:14 PM To: 'TEITAC Subpart A Subcommittee' Subject: Re: [teitac-subparta] Subpart A- Draft -Definitions-Assistivetechnology service. 
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Pretty much anything can fall under the definition of AT. AT can include everything from a tilt in space wheelchair to an electric can opener to toys and beyond â�� well beyond. A plain old telephone that is hearing aid compatible could be considered AT and could be considered Accessible Mainstream Technology.  The intent of the definition of AT is to ensure that it is very broad- where the limits come in (which is not an issue for 508) is at the funding end.  3rd party payors (Medicaid, Private insurance, Medicare) in most cases will not pay for accessible mainstream technology â�� for example Medicaid is unlikely to pay for a product purchased off the shelf at Radio Shack or Wal- Mart, but they will (in most cases) pay for AT. I understand Jimâ��s comments and the distinction and awareness youâ��re trying to promote- but if we are focusing on including definitions of terms in Subpart A that appear in the standards - AT is a term that is clearly used. I donâ��t want to presume that AMT wonâ��t be a term used and assume we donâ��t need a definition- have any of the workgroups used this term in drafting standards- in which case we would need to provide a definition in Subpart A.  
 
-----Original Message----- From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jagbell Sent: Thursday, March 15, 2007 7:37 PM To: TEITAC Subpart A Subcommittee Subject: Re: [teitac-subparta] Subpart A- Draft -Definitions-Assistivetechnology service.
 
I disagree.  I think it is ensuring that products are hearing aid compatible.  That could fall under assistive technology.
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On Mar 15, 2007, at 7:01 PM, Jim Tobias wrote:</DIV>
 
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.
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****** Jim Tobias Inclusive Technologies <A href="mailto: = EMAIL ADDRESS REMOVED = "> = EMAIL ADDRESS REMOVED = </A> +1 732.441.0831 voice/tty skype jimtobias +1 908.907.2387 mobile 
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From: Hoffman, Allen [<A href="mailto: = EMAIL ADDRESS REMOVED = ">mailto: = EMAIL ADDRESS REMOVED = </A>] 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.
 
 
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Allen hoffman -- 202-447-0303 
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From: = EMAIL ADDRESS REMOVED = [<A href="mailto: = EMAIL ADDRESS REMOVED = ">mailto: = EMAIL ADDRESS REMOVED = </A>] 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.
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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 â��assistive technologyâ�� means technology designed to be utilized in an assistive technology device or assistive technology service.
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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.
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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)
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Iâ��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.  
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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 â��â��(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) â�� (F) might result in an expansion of the scope of Section 508 the new addition (G) is pertinent to 508.
â��â��(5) ASSISTIVE TECHNOLOGY SERVICE.â��The term â��assistive technology serviceâ�� means any service that directly assists an individual with a disability in the selection, acquisition, or
use of an assistive technology device. Such term includesâ��
â��â��(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;
â��â��(B) a service consisting of purchasing, leasing, or otherwise providing for the acquisition of assistive technology devices by individuals with disabilities;
â��â��(C) a service consisting of selecting, designing, fitting, customizing, adapting, applying, maintaining, repairing, replacing, or donating assistive technology devices;
â��â��(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;
â��â��(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;
â��â��(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
â��â��(G) a service consisting of expanding the availability of access to technology, including electronic and information technology, to individuals with disabilities.
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-----Original Message----- From: = EMAIL ADDRESS REMOVED = [<A href="mailto: = EMAIL ADDRESS REMOVED = ">mailto: = EMAIL ADDRESS REMOVED = </A>] 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.
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I would concur about keeping AT and deleting AT Service. 
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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.
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You might say    Assistive Technology (as used in this standard).    
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There will always be different definitions of this for different applications. 
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Anyone got a better word for DEVICE that works everywhere we want to use  Assistive Technology? </DIV>
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 Gregg  -- ------------------------------ Gregg C Vanderheiden Ph.D. 
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From: = EMAIL ADDRESS REMOVED = [<A href="mailto: = EMAIL ADDRESS REMOVED = ">mailto: = EMAIL ADDRESS REMOVED = </A>] 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-
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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.
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We currently are not using the term AT Service in the regs (that I know of). However the term â��Assistive Technologyâ�� 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.
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-----Original Message----- From: = EMAIL ADDRESS REMOVED = [<A href="mailto: = EMAIL ADDRESS REMOVED = ">mailto: = EMAIL ADDRESS REMOVED = </A>] 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.
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I will put comments in separate emails to facilitate discussion threads. 
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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?   </DIV>
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 Gregg  
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