Thread Subject: Re: teitac-subparta Digest, Vol 6, Issue 53

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From: Baker, Robert C.
Date: Tue, Mar 20 2007 6:55 AM

At SSA, personal use items, such as calculators, cell phones, headsets,
usb drives, are likely to be purchased off a blank purchase agreement.
However - the purchasing vehicle should not be the driver for 508 - as
many agencies approach these types of purchases differently. If a
disabled employee needs an accessible calculator, headset, usb driver,
cell phone - this would likely be pursued under a separate contracting
vehicle - so I don't see that that purchasing controls should be a
determining factor.

Robert Baker
SSA Section 508 Coordinator

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Subject: teitac-subparta Digest, Vol 6, Issue 53

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Today's Topics:

1. Re: Subpart A- Draft -(g)Productswithnarrowdelineated use,
Add Personal Use to front. and (Debbie Cook)
2. Re: Subpart A- Draft -Definitions-Assistivetechnology
service. (Jessica M. Brodey)


----------------------------------------------------------------------

Message: 1
Date: Mon, 19 Mar 2007 12:22:17 -0700
From: "Debbie Cook" < = EMAIL ADDRESS REMOVED = >
Subject: Re: [teitac-subparta] Subpart A- Draft
-(g)Productswithnarrowdelineated use, Add Personal Use to
front. and
To: "TEITAC Subpart A Subcommittee" < = EMAIL ADDRESS REMOVED = >
Message-ID: <00b701c76a5b$e8d85b90$ = EMAIL ADDRESS REMOVED = >
Content-Type: text/plain; charset="iso-8859-1"

Thismay come down to someting like electronic office supplies.
Calculators may abe about all that come into it frankly. Most agencies
have contracts for cell phones, even small printersetc. The key would be
user selectable if it exists. In my office we don't even get to select
the calculators except from a particular group. Common practice is that
employees routinely select these and in this case they would not all
have to be accessible or could have different accessibility. But if
procurement is tightly controlled, thn no prodeucts including the
calculator would fly on this. So maybe the key is not the type of
product as much as how procurement decisions are made.
----- Original Message -----
From: "Gregg Vanderheiden" < = EMAIL ADDRESS REMOVED = >
To: "'TEITAC Subpart A Subcommittee'" < = EMAIL ADDRESS REMOVED = >
Sent: Sunday, March 18, 2007 12:02 PM
Subject: Re: [teitac-subparta] Subpart A- Draft
-(g)Productswithnarrowdelineated use,Add Personal Use to front. and


A desk phone is not what I would think of as "Personal use item that can
be bought out of office funds". They are expensive and have to be part
of the overall system. Also, people use more that just the phones on
their own desks. The use them in common areas, meeting rooms, and even
other offices.



I thought this was meant to apply to things like 'calculators' and other
small personal use items.

Maybe we should first make a list of things that people think are and
are not in this new category that we are thinking of creating an
exception for.
Then figure out how to describe it. And whether it is a good idea. I
think it is a good idea - if we can write it so that it can't be
misapplied easily.

I would think of things in this category as including/excluding


THINGS THAT ARE IN THE EXCEPTION
- calculators
- personal printer (under $300) (if everyone has a different one on
their desk).
- cell phones if people are allowed to pick their own (but not if they
have to use one from a pool or all get the same one)
- PDA if people are allowed to pick their own (but not if they have to
use one from a pool or all get the same one)

THINGS THAT ARE NOT
- personal workstations
- shared devices like
-- fax
-- copier
-- printers
-- Cell phones - if everyone has the same type


Huh, interesting exercise. I'm not coming up with too many things for
examples for the exception and it seems to depend on whether it is
common practice for people to get their own type - or whether the
management and perhaps IT system and support requires / wants everyone
to use the same type.


Other people, take a crack. What would your lists of examples look
like.



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



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Debbie
> Cook
> Sent: Saturday, March 17, 2007 4:12 PM
> To: TEITAC Subpart A Subcommittee
> Subject: Re: [teitac-subparta] Subpart A- Draft -
> (g)Productswithnarrowdelineated use, Add Personal Use to front. and
>
> I'm having some difficulty with all of this. My concern is that we
> cannot deligate budgetary items although in technical guidance we
> could certainly use it as an example. Is a desk phone a personal use
> item or not? Some would certainly argue not though it remains on one
> desk. Likewise, if the calculators are purchased in bulk and employees

> aren't individually selecting them are they really personal use?
> Could anything in the procurement process from the FAR be used to help

> distinquish this?
> ----- Original Message -----
> From: "Gregg Vanderheiden" < = EMAIL ADDRESS REMOVED = >
> To: "'TEITAC Subpart A Subcommittee'"
> < = EMAIL ADDRESS REMOVED = >
> Sent: Thursday, March 15, 2007 9:09 PM
> Subject: Re: [teitac-subparta] Subpart A- Draft - (g)
> Productswithnarrowdelineated use, Add Personal Use to front. and
>
>
> I'm not sure how this provision shifted to hearing aids.
>
>
>
> This discussion started out talking about providing an exception where

> non-conformant E&IT could be purchased under the supposition that a
> person with a disability could be provided with a different accessible

> version in the future if the need came up (e.g. they were hired into a

> department or promoted into a job that required the inaccessible
> equipment.) the example given was a 'personal use calculator'.
>
>
>
> 1) That is a great example but the way the provision was written it
> could be used to purchase anything. The provision did not mention
> personal use products so presumably the provision could apply to small

> copiers, fax
> machines and many other things. This problem could be fixed
> by adding
> "personal use" to the front of the exception - and that is the
> suggested
> fix. That would keep shared E&IT from being purchased under
> this exception
> that was designed for personal use devices (like calculators, cell
> phones,
> etc.) Note that this provision has nothing to do with
> adaptive equipment
> or AT. It is an exception from the rules for mainstream E&IT that
> needs to be constrained to only those products it is meant to provide
> an exception for.
>
>
>
> 2) The second part, "from standard office supplies budget"
> stems from the biggest concern I have heard from consumers.
> That exceptions like this are made, and then when they go to ask for
> an accessible version they are told that there is no money from the
> purchase left to pay for it and there is no money in the budget.
> Their supervisor is perfectly willing but there is no
> money for it. For small items that would fit into the
> standard office
> budget this is not a problem. For larger items it can be.
> One could
> decide that office computer workstations fit under this provision
> (even with
> the 'personal use' clause. But that might be larger than an
> office manager
> could pay for. Some means for limiting this to small,
> personal things is
> needed. The suggestion would be to add "from standard
> office supplies
> budget". But it doesn't have to be that.
>
>
>
> Does someone have other suggestion(s) to keep this limited to small,
> and personal use items?
>
>
>
> Thanks
>
>
>
> Sorry to not be clear.
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
>
>
>
> _____
>
>
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Deborah
> Buck
> Sent: Thursday, March 15, 2007 5:26 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] Subpart A- Draft - (g) Products
> withnarrowdelineated use, Add Personal Use to front.
>
> In some circumstances they are personal items- particularly for
> individuals who have cognitive disabilities, auditory processing
> disorders, etc. In other circumstances they are available for general
> use -conference rooms, auditoriums, etc.
>
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jagbell
> Sent: Thursday, March 15, 2007 2:49 PM
> To: TEITAC Subpart A Subcommittee
> Subject: Re: [teitac-subparta] Subpart A- Draft - (g) Products
> withnarrowdelineated use, Add Personal Use to front.
>
>
>
> We need to be very careful. While I agree that hearing aids are
> personal items, Assisitive Listening Devices or FMs are not.
>
>
>
>
>
>
>
> On Mar 15, 2007, at 11:37 AM, Deborah Buck wrote:
>
>
>
> I shared my concerns with the TEITAC Co-chairs on the discussion on
> use of the term "personal use" and wanted to share it with this
> workgroup.
>
>
>
> (g) was proposed because 2 workgroups identified this issue as
> problematic- indicating to me that the current language does not
> suffice and does not provide enough guidance to be implemented
> consistently and with confidence.
>
>
>
> I'm not sure that classifying devices as "personal devices"
> or "standard
> devices" is the best approach. Unless very clearly defined I could
> see broad and inconsistent interpretations of these terms and as
> result legitimate complaints from employees. From a procurement
> perspective I would think this would be quite challenging to determine

> what constitutes a personal device versus a standard device.
>
>
>
> Hearing aids, wheelchairs, etc. are considered "Personal devices" and

> we should be careful not to mix the two- devices used in the office by

> an individual to complete their job responsibilities and devices that
> are used by the individual in all environments- not exclusive to the
> work environment. In addition, once you tie the purchase to the
> individual and their individual needs doesn't it become an
> accommodation, not a 508 procurement. Agencies have the requirement
> to provide alternate means of access when conforming to 508
> constitutes an undue burden. I would very much like to hear from 508
> coordinators on whether labeling an item "personal use" will address
> the issue.
>
>
>
> The suggestion to add "from standard office supplies budget"
> so it reads
>
> which can and will be purchased from the standard office supplies
> budget to meet individual needs
>
> I think that level of specificity goes beyond the scope of the TEITAC
> and the Access Board. Its not an appropriate for standards to dictate
> what budget or cost accounting code agencies use for purchases.
>
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
> Vanderheiden
> Sent: Wednesday, March 14, 2007 8:56 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] Subpart A- Draft - (g) Products with
> narrowdelineated use, Add Personal Use to front.
>
>
>
> First - thanks for pulling all this together. Lots of work.
>
>
>
>
>
> RE:
>
>
>
> (g) Products with narrow delineated use, no operating system or
> software, no capacity for assistive technology to be attached to the
> product, such as personal use calculators, for which an agency can
> readily document the availability of specialized products, just as a
> talking calculator or calculator with large visual display, which can
> and will be purchased to meet individual needs, are not required to
> comply with this part.
>
>
>
>
>
> In general I think this is good. I wondering if it is
> really needed. I
> think it is covered by the old language. But it is suble and this can

> help people get past the "small personal items" issue.
>
>
>
>
> Two EDITS
>
>
>
>
> 1) I think it needs to have "personal use" added to the front so it
> reads "Personal use product with narrow..etc" .
>
> Shared or public products should not get pushed into this category.
>
> "Narrow use" by itself is not clear enough and is undefined.
> I thought it
> meant 'not multipurpose" but could also be construed to mean only used

> by people in a group or office or floor or..
>
>
>
> 2) The biggest concern I've heard raised about this (other than no
> inadvertantly creating a loophole that can be expanded to cover Mack
> trucks) was that agencies say they are willing but it isn't in their
> budget - so
> nothing happens. To make sure this isn't misapplied to
> things beyond
> the ability of departments to buy easily lets add "from standard
> office supplies budget" so it reads
>
> which can and will be purchased from the standard office supplies
> budget to meet individual needs
>
>
>
>
>
>
> Gregg
>
> ------------------------
>
> Gregg Vanderheiden
>
>
>
>

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