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

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From: Hoffman, Allen
Date: Mon, Oct 29 2007 6:40 AM

Just as an FYI:

When Federal agencies need to require compatibility with specific AT, for example when an AT is "the" solution in place for a large group of employees, or as a delivery mechanism for public facing EIT, it should be included as a business requirement in the solicitation. When generalized nonspecific compatibility is required, good practice would be to enumerate any items the agency would like to get specific information on to better select from responders. So, to make this work for all, purchasers need information on compatibility, and information of that type backed up with specifics is best. For the vendors of IT, providing such information is key to success, or it should be. So, basically the standards should indicate that access is provided for people with disabilities. through integrated AT or 3rd party AT is only the technique portion of how it is accomplished, unless specific agency business requirements come in to play. I think this is generally how most Federal agencies apply and interpret Section 508 currently. FPC(s) for the form, "access must be provided for people with X disabilities; via integrated AT functionality, or 3rd party AT, encapsulate this approach well. Maybe we need to develop "quickly" the language recommending that better At compatibility representation methods should be developed as part of the next Access-Board and FAR phase in order to improve the visibility for purchasers of this often confusing portion of vendor representations of compliance.








Allen Hoffman -- = EMAIL ADDRESS REMOVED = ; v: 202-447-0303

-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg Vanderheiden
Sent: Saturday, October 27, 2007 6:06 PM
To: 'TEITAC Committee'
Subject: Re: [teitac-committee] AT and IT interoperability - the regime we areoperating under today

Hi Peter,

You asked :
> 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?


The answer is no. But no one has implied that 508 does or should require access to specific AT - so I'm not sure where the question comes from.


Please look at
<http://teitac.org/wiki/Monday_10-15-2007_General_telecon#Minutes_for_Monday
_10-15-2007_General_telecon>

Particularly the compromise position (Position #2) and the proposed solution. This specifies that the 508 regs would NOT specify any specific AT. Agencies might - as they do now. But the 508 standard would be moot on this.
This is what the group came up with to discuss.


To better understand what you're asking for:

In your opinion, should a product that is not directly usable by people with disabilities, meet the 508 requirements if there is no AT for it (but it does provide an API)?


Thanks



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



> -----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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