James G. Natoli Director of
State Operations

Governor's Task Force on
Information Resource Management
Technology Policy 96-13
     
Subject: Accessibility to Technology Date: November 7, 1996


Purpose
It is the policy of the State that persons, including those with disabilities, have equivalent access to electronic equipment and information technology. Such access applies to current and prospective employees with disabilities, as well as to citizens with disabilities who need to access State offices and public information services. The purpose of this Technology Policy is to review the underlying statutory requirements and to provide guidelines to be followed by State agencies regarding accessibility to technology for persons with disabilities.

Overview
The goals of this policy are:

  • to retain, maintain and/or improve productivity levels of workplace users of technology; and,
  • to improve the ease with which all citizens, including those with disabilities, can access and benefit from government services and information.

The keystone to making technology accessible to persons with disabilities is the concept of "Universal Design." Universal Design is the process of creating products (devices, environments, systems and processes) which can be used by people with the widest possible range of abilities in the widest range of possible situations (environments, conditions, and circumstances). It requires designing products that are flexible enough that they can be used directly (without requiring any assistive technology or modifications), and yet compatible with assistive technologies for those persons who cannot use the product directly.

Universal design is the responsibility of the manufacturers of hardware and software products. State agencies should seek to incorporate the concept of Universal Design, as a framework, into all current systems where feasible, and into all new development initiatives. This policy, and associated attachments, provides an overview of ways to ensure equal access for persons with disabilities and some examples of devices and products on the market that can comprise an agency's Universal Design.

Statutory Requirements
Attachment A provides a description of the Federal and State legislation and regulations governing an agency's responsibility to provide access to technology for persons with disabilities. To summarize, these provisions require that employees and citizens with disabilities have reasonable access to electronic and information technology. State agencies must make reasonable accommodations to such persons to ensure they can adequately perform their jobs and/or access government services.

Guidelines
As a general guideline, State agencies should strive to ensure that present and potential employees, and citizens with disabilities, have access to information and data comparable to that accorded individuals who do not have disabilities.

For the purpose of this Technology Policy, "electronic and information technology" means any equipment, software, interface systems, operating systems, or interconnected system or subsystem of equipment used in the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. "Comparable access" means that individuals with disabilities must be able to produce and have access to the same or equivalent information processing resources, with or without special peripherals, as individuals without disabilities.

What follows is a general overview of the planning and procurement considerations an agency should address, and the types of accessibility accommodations and solutions that are available. In addition, Attachment B describes some products that an agency may utilize to secure equivalent access. Attachment B focuses on five principle areas: Technology Accommodations for Data Entry (Input) and Production (Output), Telephone Access, the Construction of Web Sites, the Use of Kiosks, and Related Tools for Agency Use.

Planning and Procurement. State agencies are required to plan for and be ready to provide equal access to electronic office technology for persons with disabilities. Agencies should first, conduct a needs assessment of the types of accommodations/ modifications which may be necessary, and a requirement analysis to determine the type of modifications and equipment that may need to be acquired. Agencies should also identify the primary access points to buildings or services used by the public to obtain, or provide, information from or to the agency. Agency personnel familiar with accommodations and procurement should be involved in this assessment. Whenever possible, employees with disabilities, supervisors, business/fiscal staff, information resource management staff, community members with disabilities, rehabilitation engineers, or other qualified rehabilitation professionals may also be involved.

As a result of evaluating employee needs and public access, agencies may find that existing equipment can be adapted to provide an accommodation should the need arise, and/or a need for new equipment acquisitions. It should be noted that equipment procured for public access, must have features to provide equivalent access for persons with disabilities. The New York State Office of Advocate for Persons with Disabilities (OAPwD), TRAID Project is available to assist State agencies in planning for accessibility and helping to identify technology resources to meet employee and public access needs. In addition, the Department of Civil Service has issued the following procedures to assist agencies in this regard: "Reasonable Accommodation in State Agencies, 1991;" and "A Supervisor's Guide: Working with People with Disabilities." All agencies are expected to follow these procedures.

Accommodations/Modifications. "Reasonable accommodations" or "reasonable modifications" can include a logical adjustment made to a job and/or work environment which enables a qualified person with a disability to perform the duties of that position. For example, an employee with a visual disability may be provided with a computer with a voice output or a refreshable Braille device. It may also mean acquiring, modifying or enhancing equipment, and/or restructuring jobs.

When a State agency provides services and/or information to the public, it must also ensure that citizens with disabilities can produce, use and access information necessary to provide the service to, and interact with, the consumer. Equipment such as computers, information kiosks, telephones and other office equipment can be modified or enhanced to permit access.

Access to information such as agency brochures, training films, public service announcements, documentation for computer technology, etc., should be provided in a usable format for State agency employees with disabilities and upon request by citizens with disabilities. Braille, large print, or disks in ASCII format, audio tape, and captioned videos are options that can be considered.

Accessibility Alternatives. There are numerous accessibility solutions available to address the needs of persons with disabilities. Accessibility solutions range from hardware and software add-ons, or so-called "layered" or "compatible" solutions, to hardware "built-ins" and operating system enhancements.

"Built in" accessibility solutions (e.g., ability to enlarge characters on the computer screen) are preferable to "layered" solutions. Layering solutions involve adding software and/or hardware between the end-user and the operating system or application software. While this solution may have advantages, it can also increase costs, increase difficulty for maintaining software updates and add costs to train employees to utilize dissimilar equipment at sites across the State. For these reasons, layering should be selected only after careful analysis of its merits (functional operation, purchase cost and costs related to technical assistance and support) relative to those of "built-in" solutions.

Training and Support. Agencies should make arrangements to ensure that technical training and follow-up support is provided in a timely manner to ensure that assistive equipment purchased by the agency, is used for its intended use and to its fullest potential.

Resources/Support. Agencies interested in obtaining additional information or assistance for accommodating employees and/or public access, may contact:

New York State Office of Advocate for Persons with Disabilities
One Empire State Plaza, Suite 1001
Albany, NY 12223-1150
(800) 522-4369 (voice/TTY/Spanish)
(518) 474-2825 (voice only) (518) 473-4231 (TTY only)
(518) 473-6005 (fax)

The New York State Office of Advocate for Persons with Disabilities (OAPwD) operates a computerized Bulletin Board Service (BBS) where users can access database programs with a wealth of information such as SATIRN II: an information and referral database that contains information on programs, services and technology suppliers; TRAID-IN: an equipment exchange service for individuals looking to buy, sell, or donate used equipment; and ABLEDATA: a national database of assistive technology devices for persons with disabilities. The OAPwD, TRAID Project is also available. OAPwD and TRAID staff can assist in identifying professionals and organizations qualified to conduct evaluations of an individual's technology needs and/or technology suppliers. TRAID supports Regional TRAID Centers (RTC) located throughout New York. Many of the Regional TRAID Centers maintain product demonstration centers to enable agency staff to independently research and test devices. Centers should be contacted in advance to determine what is available on site or to discuss arrangements for possible try-outs or demonstrations.

New York State Department of Civil Service
Reasonable Accommodation Unit
Division of Diversity Planning and Management
Harriman State Office Building Campus, Building #1
Albany, NY 12239
(518) 457-8023 (voice)
 
Managing Information Resources for Accessibility is a handbook, published by the U.S. General Services Administration, which addresses Section 508 responsibility. The handbook is available from:
 
GSA Clearinghouse on Computer Accommodation (COCA)
Room 2022 KGDO
18th & F Streets, N.W.
Washington, D.C. 20405
(202) 501-4906 (voice)
(202) 501-2010 (TTY)
Internet Access to COCA via the World Wide Web:
Center on Information Technology Accommodation, IT for persons with disabilities
http://www.gsa.gov/coca

All technology policies are available in alternative formats (large print, disk and braille). Requests should be made to:

The Governor's Task Force on Information Resource Management
Executive Chamber
State Capitol
Albany, NY 12224 or
(518) 473-5622, (518) 473-3389 fax
e-mail nyoft@oft.state.ny.us

 


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