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

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From: David Poehlman
Date: Fri, Mar 16 2007 11:20 AM

I cannot read this message as sent. I can read it as below.

On Mar 16, 2007, at 12:31 PM, Katie Haritos-Shea wrote:

I agree with adding service to the definition.

Katie


-----Original Message-----
From: Diane Golden
Sent: Mar 16, 2007 11:42 AM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] Subpart A- Draft -Definitions-
Assistivetechnology service.

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.

Assistive technology. Any itme, piece of equiment, SERVICE, or
system, whether acquired commerically, modified, or customized . . .

Diane Golden
NASCIO

-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto:teitac-subparta-
= 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.


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 – 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 – 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 Jim’s comments and the distinction and awareness you’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 don’t want to presume that AMT won’t be a term
used and assume we don’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:teitac-subparta-
= 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.



On Mar 15, 2007, at 7:01 PM, Jim Tobias wrote:




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
= EMAIL ADDRESS REMOVED =
+1 732.441.0831 voice/tty
skype jimtobias
+1 908.907.2387 mobile



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



From: = EMAIL ADDRESS REMOVED = [mailto:teitac-subparta-
= 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:teitac-subparta-
= 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.



From: = EMAIL ADDRESS REMOVED = [mailto:teitac-subparta-
= 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:teitac-subparta-
= 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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