Thread Subject: Re: Comparable Access

Note

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From: Tom Brett
Date: Tue, Jun 05 2007 9:30 AM

It really is not a 508 issue but is a Section 504 issue. Providing
equipment is not part of Section 508. That would fall under Section 504 and
ADA. The government and courts would ask if the individual has been
reasonably accommodated. If one type of AT provides better access than the
other that you could argue that using the lesser of the 2 AT types would not
provide a reasonable solution.

The definition of comparable access is being clarified to insure that when
members of the public with disabilities or Federal employees with
disabilities access government information and data they can perform this
access and use the information and data in a manner that is timely,
accurate, complete and efficient when compared to that access available to
individuals without disabilities.

Section 508 covers Electronic and Information Technology. The comparable
access definition basically says that you need to design your systems in a
manner that allows a person with disabilities to use the information in is
timely, accurate, complete and efficient way.

The use of the AT is covered in a different part of Rehab Act and I would
think that is beyond the scope of this committee.

Tom Brett


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of David Poehlman
Sent: Tuesday, June 05, 2007 11:10 AM
To: TEITAC Subpart A Subcommittee; = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-subparta] Comparable Access

Oh, I think obtrusion is an issue but I am not certain it bears on
accessability unless one provides better access than another? I do agree
this is a consideration but am not certain for this.

----- Original Message -----
From: "Tom Brett" < = EMAIL ADDRESS REMOVED = >
To: < = EMAIL ADDRESS REMOVED = >; "'TEITAC Subpart A Subcommittee'"
< = EMAIL ADDRESS REMOVED = >
Sent: Tuesday, June 05, 2007 10:57 AM
Subject: Re: [teitac-subparta] Comparable Access


The Government would be required to purchase 2 types of AT. Inasmuch as I
support the less intrusive wording I don't see how the government can be
forced to pay for 2 different types of reasonable accommodation. The person
with a disability has been provided with a way to participate in the
conference.

Tom Brett


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
= EMAIL ADDRESS REMOVED =
Sent: Tuesday, June 05, 2007 10:48 AM
To: TEITAC Subpart A Subcommittee
Subject: Re: [teitac-subparta] Comparable Access

If two options are available and one is least obtrusive to the user and thus
less stigma, that option should be used. For example, in a conference room,
there is the option of using an induction loop or an FM system. An FM system
requires the person with hearing loss to wear a receiver and a neckloop. An
iduction loop requires the person to just switch their hearing aid to "T".
Why should a person wear a device when they don't have to? This happens all
the time because people don't understand induction loops. :)

Best,

Janice
Sent from my BlackBerry wireless handheld.

-----Original Message-----
From: David Poehlman < = EMAIL ADDRESS REMOVED = >

Date: Tue, 05 Jun 2007 10:24:43
To:TEITAC Subpart A Subcommittee < = EMAIL ADDRESS REMOVED = >
Subject: Re: [teitac-subparta] Comparable Access


I'm not diagreeing necessarily, but what does "least intrusive" do?
----- Original Message -----
From: "jagbell" < = EMAIL ADDRESS REMOVED = >
To: "TEITAC Subpart A Subcommittee" < = EMAIL ADDRESS REMOVED = >
Sent: Tuesday, June 05, 2007 6:45 AM
Subject: Re: [teitac-subparta] Comparable Access


I would just add "in the least intrusive manner.

Janice
On Jun 4, 2007, at 2:52 PM, Jim Tobias wrote:

> i think you nailed this. i agree completely with this draft.
>
> ***
> Jim Tobias
> Inclusive Technologies
> +1.732.441.0831 v/tty
> +1.908.907.2387 mobile
> skype jimtobias
>
>
>> -----Original Message-----
>> From: Diane Golden [mailto: = EMAIL ADDRESS REMOVED = ]
>> Sent: Monday, June 04, 2007 1:45 PM
>> To: 'TEITAC Subpart A Subcommittee'
>> Subject: Re: [teitac-subparta] Comparable Access
>>
>> So here's yet another draft -- revising the language back
>> into a definition and separating timely and efficient.
>>
>> Proposed New Definition of Comparable Access Comparable
>> access means that individuals with disabilities have access
>> to and use of information and data that is timely, accurate,
>> complete and efficient when compared to that available to
>> individuals without disabilities. Timely access ensures that
>> individuals with disabilities have information and data
>> available to them at the same time as individuals without
>> disabilities. Accurate and complete access ensures that the
>> information and data reflects the intended meaning especially
>> when converted into another form or media. Efficiency of
>> access includes consideration of the speed with which a
>> person with a disability can use electronic and information
>> technology to access information or perform a task as
>> compared to an individual without disabilities.
>>
>> Does changing this to a definition help address the concerns
>> about how this would be used or not used in solicitations?
>>
>> Diane
>>
>> -----Original Message-----
>> From: = EMAIL ADDRESS REMOVED =
>> [mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of
>> Gregg Vanderheiden
>> Sent: Monday, June 04, 2007 12:32 PM
>> To: 'TEITAC Subpart A Subcommittee'
>> Subject: Re: [teitac-subparta] Comparable Access
>>
>>
>> Indeed.
>>
>> I think the term "timely" takes on different meanings for
>> 'content' and for 'devices'
>>
>> We should keep that in mind and perhaps reflect it in out language
>>
>>
>>
>> Gregg
>> -- ------------------------------
>> Gregg C Vanderheiden Ph.D.
>>
>>
>>
>>> -----Original Message-----
>>> From: = EMAIL ADDRESS REMOVED =
>>> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of David
>>> Poehlman
>>> Sent: Monday, June 04, 2007 12:14 PM
>>> To: TEITAC Subpart A Subcommittee
>>> Subject: Re: [teitac-subparta] Comparable Access
>>>
>>> I agree with everything said about this but the note below does not
>>> express this clearly ehough and comparable access is a term
>> oft used
>>> when descriing side by side modalities not alternate formats?
>>> "Timely access includes consideration of the speed with
>> which a person
>>> with a disability can use electronic and information technology to
>>> access information or perform a task as compared to an individual
>>> without disabilities
>>>
>>> To me, this more closely addresses an issue such as being
>> able to use
>>> the equipment in a comparable way.
>>>
>>> ----- Original Message -----
>>> From: "Hoffman, Allen" < = EMAIL ADDRESS REMOVED = >
>>> To: "TEITAC Subpart A Subcommittee"
>> < = EMAIL ADDRESS REMOVED = >
>>> Sent: Monday, June 04, 2007 12:44 PM
>>> Subject: Re: [teitac-subparta] Comparable Access
>>>
>>>
>>> I concur with Karen. Timely is not the same as efficiency
>> and is the
>>> term we should be using. it was timely, accurate, and
>> complete from
>>> my recollection.
>>>
>>>
>>>
>>> Allen Hoffman -- = EMAIL ADDRESS REMOVED = ; v: 202-447-0303
>>>
>>> -----Original Message-----
>>> From: = EMAIL ADDRESS REMOVED =
>>> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Karen
>>> Peltz Strauss
>>> Sent: Sunday, June 03, 2007 11:02 AM
>>> To: TEITAC Subpart A Subcommittee; = EMAIL ADDRESS REMOVED =
>>> Subject: Re: [teitac-subparta] Comparable Access
>>>
>>> Gregg is right. This is a really important point - all too
>> often, the
>>> information is given at a later time, when it is not as
>> relevant, such
>>> as a transcript of a meeting instead of interpreters or captioning
>>> while the meeting is going on. Or a Brailled or electronic
>> version of
>>> something, weeks after sighted people get the printed version. I
>>> watched this happen time and again when I worked in the government.
>>>
>>> Karen
>>>
>>> ----- Original Message -----
>>> From: "Gregg Vanderheiden" < = EMAIL ADDRESS REMOVED = >
>>> To: "'TEITAC Subpart A Subcommittee'"
>>> < = EMAIL ADDRESS REMOVED = >;
>>> < = EMAIL ADDRESS REMOVED = >
>>> Sent: Sunday, June 03, 2007 12:22 AM
>>> Subject: Re: [teitac-subparta] Comparable Access
>>>
>>>
>>>> Timely is included to make sure that information and access is
>>>> provided on a timely basis. That is, if others have access to
>>>> information or devices now
>>>> - then people with disabilities should have access now.
>>>>
>>>> I think that would be timely - not efficiency.
>>>>
>>>> However having efficient access is also important.
>>>>
>>>>
>>>> Gregg
>>>> -- ------------------------------
>>>> Gregg C Vanderheiden Ph.D.
>>>>
>>>>
>>>>
>>>>> -----Original Message-----
>>>>> From: = EMAIL ADDRESS REMOVED =
>>>>> [mailto: = EMAIL ADDRESS REMOVED = ] On
>> Behalf Of David
>>>>> Poehlman
>>>>> Sent: Saturday, June 02, 2007 6:47 AM
>>>>> To: = EMAIL ADDRESS REMOVED = ; TEITAC Subpart A Subcommittee
>>>>> Subject: Re: [teitac-subparta] Comparable Access
>>>>>
>>>>> Hi All,
>>>>>
>>>>> The word timely here is not appropriate to its stated
>> function. We
>>>>> need to find a better word. This has more to do with
>>> efficiency than
>>>
>>>>> timeleness.
>>>>> Lastly, there's a bit of stuff at the top of this
>> message I quote
>>>>> below that I don't understand.
>>>>>
>>>>> "<?xml:namespace prefix = o ns =
>>>>> "urn:schemas-microsoft-com:office:office"
>>>>> />"
>>>>>
>>>>> ----- Original Message -----
>>>>> From: "Diane Golden" < = EMAIL ADDRESS REMOVED = >
>>>>> To: "'TEITAC Subpart A Subcommittee'"
>>>>> < = EMAIL ADDRESS REMOVED = >
>>>>> Sent: Friday, June 01, 2007 11:52 AM
>>>>> Subject: Re: [teitac-subparta] Comparable Access
>>>>>
>>>>>
>>>>> Thanks Robert. Already made that change based on the
>> discussion at
>>>>> the plenary meeting. The following is the current
>> version of that
>>>>> section.
>>>>>
>>>>> <?xml:namespace prefix = o ns =
>>>>> "urn:schemas-microsoft-com:office:office"
>>>>> />
>>>>>
>>>>> "When determining if individuals with disabilities have
>>> access to and
>>>
>>>>> use of information and data that is comparable to that
>> available to
>>>>> individuals without disabilities, each agency shall ensure that
>>>>> individuals with disabilities have access that is
>> timely, accurate
>>>>> and complete. Timely access includes consideration of the
>>> speed with
>>>
>>>>> which a person with a disability can use electronic and
>> information
>>>>> technology to access information or perform a task as
>>> compared to an
>>>>> individual without disabilities. Accurate and complete access
>>>>> ensures that the information and data reflects the
>> intended meaning
>>>>> especially when converted into another form or media. "
>>>>>
>>>>>
>>>>>
>>>>> The rest of the discussion at the plenary meeting was concern
>>>>> expressed at how this would (or would not) be used in
>>> solicitations.
>>>
>>>>> I think the perception of the agency procurement people is
>>> that this
>>>>> would NOT be used in a solicitation, but used internally
>> by agency
>>>>> staff to evaluate if they are meeting the statute
>> requirements in
>>>>> delivery of access to employees and
>>>>> the public. One option that might help address this would
>>>>> be to include
>>>>> this language in the Purpose section (rather than
>>>>> application) as that is
>>>>> where the reference to having "access to and use of
>> information and
>>>>> data that is comparable" is found. Other thoughts/suggestions?
>>>>>
>>>>>
>>>>>
>>>>> Diane Golden
>>>>>
>>>>>
>>>>>
>>>>> -----Original Message-----
>>>>> From: = EMAIL ADDRESS REMOVED =
>>>>> [mailto: = EMAIL ADDRESS REMOVED = ]On
>> Behalf Of Baker,
>>>>> Robert C.
>>>>> Sent: Friday, June 01, 2007 8:07 AM
>>>>> To: = EMAIL ADDRESS REMOVED =
>>>>> Subject: [teitac-subparta] Comparable Access
>>>>>
>>>>>
>>>>>
>>>>> I recommend changing the verbiage to the proposed
>> comparable access
>>>>> provision to delete the phrase "and in a manner and medium
>>>>> appropriate to
>>>>> the significance of the message". The intended meaning of
>>>>> this phrase is
>>>>> very unclear.
>>>>>
>>>>>
>>>>> Thanks,
>>>>> Robert
>>>>>

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