Thread Subject: Re: AT and IT interoperability - the regime we areoperating under today

From: Diane Golden
Date: Wed, Oct 24 2007 10:30 AM

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A number of folks from different states are meeting tomorrow to go through
the standards and develop comments. I will pose this question and get a
feel for what is happening at the state level in interpretation and
implementation.

For Missouri, I can say this interpretation/application problem is one of
the reasons we did not adopt the FPC in our state standards. Instead we use
applicable technical standards in the RFP (ask for conformance information
in a VPAT type structure) and pose a set of additional questions (narrative
in nature) that ask about interoperability. For COTS products we ask the
vendors to describe any compatibility testing that has been done with
commonly used assistive technology and then identify a short list of AT
products we know are used in Missouri since we provide most of them. If it
is app development we ask about plans for interoperability testing to be
done during development and benchmark testing along with identification of
an accessibility coordinator responsible for ensuring conformance to access
standards during product development and in the final version deployment and
a description of the accessibility coordinator?s experience and expertise in
developing accessible products. So this info is requested and reviewed as
part of the bid, but is not done as conformance to a set standards.

Diane Golden - NASCIO


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Peter Korn
Sent: Tuesday, October 23, 2007 8:28 PM
To: TEITAC Committee
Subject: [teitac-committee] AT and IT interoperability - the regime we
areoperating under today


Hi Gregg,

In the plenary con-call earlier today, and also in e-mail discussions
elsewhere, you said that a number of folks believe(d) that the current
language in the current Functional Performance Criteria - specifically
the phrase in §1194.31(a), (b), (c), and (e) "... or support for
assistive technology used by people with disabilities shall be provided"
- means that E&IT is actually demonstrated to work with some specific
(though undefined) AT.

Meanwhile, I and others have always read this language to mean other
than that - to mean that EI&T has provided all it could to enable AT to
work with it.

However, I think my reading (and yours) is perhaps the least interesting
question. Rather, what I think is interesting is how this passage has
been read by folks implementing 508.

Gregg - are you aware of any Federal Agency that reads the current
passage as meaning that the 508 requires E&IT be either self accessible
or accessible via specific AT? Are you aware of any vendor of E&IT who
reads the current passage that way? Has there been any Federal
government employee who has made a complaint based on that reading and
if so, was the complaint sustained? If the answer is "yes" to any of
these, could you cite them please?

Separately, if anyone from the Access Board is following this
discussion, I'd be very curious whether they have a formal
interpretation/reading of that phrase in the Functional Performance
Criteria.

Because if in practice the regime we are all using is that "...support
for assistive technology use by people with disabilities shall be
provided" means E&IT must provide the information needed (and not
guarantee a specific level of interoperability with specific AT), then
what we have today in our draft is a clear and unambiguous improvement
(whether or not we all agree on the sufficiency of said improvement).
On the other hand, if the regime we are operating under today is that it
means E&IT must in fact have some demonstrated interoperability, then
Gregg's claim that language that doesn't specify interoperability would
in fact be less than what we have now would be sustained.


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.

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